ML20246Q029
| ML20246Q029 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/14/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246Q025 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8907200411 | |
| Download: ML20246Q029 (5) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO UPDATED SAFETY ANALYSIS REPORT APPENDIX IB LICENSE COMMITNENT REVISIONS PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440 IlfiRODUCTION Appendix IB of the Updated Safety Analysis Report (USAR) for the Perry Nuclear Power Plant, Unit No.1, contains a compilation of the remaining plant-specific license comitments for the Perry Nuclear Power Plant required to resolve license conditions from the Safety Evaluation Report and its Supplements. The appendix provides the licensee's commitments for resolving those issues and ensuring that the NRC requirements for other longer term issues are met during )lant operation.
The licensee may not make changes to the appencix other tlan adding information which satisfies'the commitments or otherwise documents closure of the identified items without NRC approval.
By letter dated March 3,1989, the licensee for the Perry Nuclear Power Plant, Unit No. 1 proposed changes to license commitments 7, 14 and 16 of Appendix IB of the USAR. The staff's evaluation of these proposed license commitment changes is contained below.
DISCUSSION AND EVALUATION Comitment No. 7, Regulatory Guide 1.97, Revision 2 (Neutron Monitoring Post-LOCA)
Regulatory Guide 1.97, Revision 2, requires neutron monitoring system instrumentation to meet Category 1, Class 1E, specifications which are defined in that guide.
By licensee commitment No. 7, the licensee comitted to provide to the NRC prior to startup following the first refueling outage, its plans for upgrading of the neutron monitoring instrumentation to Category I, including a schedule for installing such instrumentation. Additionally, appropriate Technical Specification i
revisions to accident monitoring instrumentation were to be provided at that time. The licensee has proposed changing that commitment to the following:
"CEI shall implement applicable modifications which are consistent with the conclusions of topical report NEDO-31558,
' Requirements for Post-Accident Neutron Monitoring System,' and which are based upon the NRC staff's safety evaluation of the report, on a I
schedule to be provided 6 months after receipt of the NRC staff SER."
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[ In Appendix J to SER Supplement No. 6 dated April 1935 the staff noted that the neutron monitoring instrumentation insta11ec at the Perry J
-Nuclear Power Plant, Unit No.1, is not installed in accordance with scismic Category I requirements but does meet seismic Category II requirements. The staff further determined that the deviation from Cciegory I requirements, mechanical drives that have' not satisfied the environmental qualification requirement of R.G. 1.97, is similar for I
most boiling water reactors (BWR's) and that a Category I system that meets all R.G.1.97 requirements was an industry development item.
The staff concluded that the existing instrumentation is acceptable for interim operation and that the licensee should follow development of this equipment and install Category I instrumentation when it becomes available. The licensee committed to this position.
In section 7.5.2.2 of Supplement No. 6 to the SER, the staff noted the licensee's commitment to provide the staff with information related to upgrading of the neutron flux monitoring instrumentation to Category I requirements prior to plant startup after the second refueling outage (emphasis adoed) which was deemed acceptable by the staff. However, a more restrictive schedule (prior to startup follcwing the first refueling outage) remained unchanged. contrary to a statement in section 7.5.2.2 of Supplement 6 and the more restrictive schedule was incorporated into the licensee's Appendix IB license commitments contained in the USAR.
Nonetheless, the licensee has been following industry development of neutron flux monitoring system technology as directed by the staff.
The licensee has been unable to cefine a system which meets applicable R.G. 1.97 and other U.S. standards. The licensee states that ex-core applications dc not have the required sensitivity and in-core applications
' presently required range of 8 decades (10 gity and accuracy over the have not demonstrated the required sensiti to100% power)norhas their application been approved by the NRC staff.
Further, the licensee states that they have endorsed tcpical report HEDO-31558 submitted to the staff on A.pril 1,1988 by the BWR Owners Group (BWROG)asapplicabletotheirfacility. This topical report establishes that there are no design-basis accidents tht.t require a post-accident neutron monitoring function and the ecmbination of rod position indication, emergency procedures and other plant status indications assure mitigation of limiting design-basis accidents.
This topical report is currently under review by the staff.
If approved, the licensee's current neutron flux monitoring instrumentation would appear sufficient without upgrade.
The staff believes that it is necessary to comment on the licensee's position, as follows. The staff's review of NED0-31558 may not result 3
in staff approval of that document's stated positions with regard to the need for neutron flux monitoring. Further, the review priority for this topical report is not sufficiently high to ensure issuance of an SER in the near future. Therefore, the licensee shculd continue to
l closely follow and encourage industry development of a neutron flux monitoring system that meets the Category I requirements of R.G.1.97 Rev. 2.
However, the staff remains of the position that interim J
operation of the Perry Unit I facility is acceptable with the currently installed Category 2 instrumentation and, based upon the staff's positions as stated $n Supplement No. 6 to the SER, accepts the licensee's revision to the Appendix IB license comitment as modified below:
"CEI shall implement applicable modifications which are consistent with the conclusions of topical report NED0-31558,
' Requirements for Post-Accident Neutron Monitoring System,'
and which are based upon the NRC staff's safety evaluation of the report, on a schedule to be provided 6 months after receipt of the NRR staff SER or prior to startup following the second refueling outage, whichever is sooner."
Should staff review of NED0-31558 extend beyond this timeframe or fail to endorse the positions of the topical report, and industry development of Category I neutron monitoring instrumentation remain inadequate, the staff may entertain alternative schedules or recommendations submitted by the licensee with proper supporting justification.
Commitment No. 14, Instrument Setpoint Methodology The subject commitment was that prior to startup following the first refueling outage, CEI would provide a detailed technical report docu-menting the basis and methodology for establishing protection system trip setpoints and allowable values, based on the Instrument Setpoint Methodology Group (ISMG) effort, as discussed in CEI letter dated October 17, 1985 (PY-CEI/NRR-0368L). The schedule for the Perry setpoint report submittal was based on the ISMG final report schedule as accepted by NRR, with an allowance for CEI technical review and verification of plant specific application. That schedule anticipated submittal of a final report from the Instrument Setpoint Methodology Group to the NRC by early 1986.
In a letter dated February 19, 1985, the NRC staff emphasized that confirmatory review of plant-specific Technical Specifications should be submitted within 6 months of being notified of the staff's acceptance of the methodology.
The ISMG submitted a final report to the NRC, entitled " General Electric Instrum.ent Setpoint Methodology," NEDC-31336, October 1986, forwarded by November 19, 1986 letter from R. Villa to H. M. Berkow.
This report is still under consideration by the NRC staff.
The licensee has proposed the following revision to license comitment No.14:
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-4 "Six months'after receipt of a' favorable NRC Safety'
- Evaluation Report on GE Instrument Setpoint Methodology.
,(NEDC-31336), and subject to any: stipulations therein, CEI shall. provide for NRC staff review and approval, a detailed technica1' report documenting the basis and methodology for establishing. protection system trip setpoints and allowable values, based on the Instrument.
-Setpoint Methodology Group (ISMG) effort, as discussed in CEI letter dated October 17,1985-(PY-CEI/NRR-0368L)".
While the~ staff is unable to determine at this time whether its ' Safety,
Evaluation Report on topical report NEDC-31336 will be." favorable," it finds.it acceptable to allow the licensee 6. months following issuance of the. staff's SER to submit its detailed technical report which must address any concerns or stipulations contained in'the staff's SER.
However, the staff remains of the position as stated in Section 7.2.2.8 of. Supplement No. 7 of thecPerry SER that sufficient conservatism are-inherent.in the safety analyses and the protection system design upon which the Technical Specifications have been developed to allow interim operation unti1~the-ISMG efforts are concluded and that there is reasonable assurance that the results of the ISMG effort will. verify-acceptability of. the setpoints. The staff also remains of the position that-instrument' uncertainties: have been treated properly by the licensee; i.e., independent uncertainties have been combined by the root mean square method, whereas dependent. uncertainties have been combined.
algebraically.
Based on the above discussion, the staff finds that by striking the word
" favorable" the licensee's revised license commitment is acceptable.
Commitment No. 16 Gaseous Effluent Sampling System Representative Sampling The subject commitment states that work is underway at Pacific Northwest Laboratory (PNL) under an NRC technical assistance contract to develop definitive guidance on making sample line loss measurements. The licensee shall perform such measurements on the radioiodine and particulate sampling system prior to startup following the first refueling outage pending (emphasis aoded) availability of staff guidance if the NRC staff concludes that such measurements are necessary for these systems.
The licensee has proposed to revise this commitment as follows:
" Work is underway at the Pacific Northwest Laboratory of DOE, under an NRR technical assistance contract, to develop definitive guidance on making sampling line loss measurements. CEI shall perform such ireasurements on the radiciodine and particulate sampling system, on a schedule to be determined after NRC staff guidance is provided on the chemical form of iodine and'the method for determining line loss, if the NRC staff concludes that such measurements are necessary for these systems."
f,i The staff had anticipated that work on technical assistance contract B-2982 with PNL would be completed sufficiently in aovance of the licensee's first refueling outage to allow staff review and determination of applicability for the licensee, and incorporation by the licensee prior to startup. Such has not been the case. Under the present wording of the license commitrent, no revision is necessary since any commitment is predicted upon staff guidance being available.
However, the staff is appreciative of the licensee's continued resolve to address licensing concerns in this area by inclusion in their license commitment tracking system and, therefore, finds the licensee's proposed revision to their license commitment acceptable with one minor clarification. The contract currently underway at PNL is not expected to result in guidance on the chemical form of iodine as proposed by the licensee but only on line loss. Therefore, the licensee's proposed revision would be acceptable by striking the words
" the chemical form of' iodine and" from the second sentence. The staff will determine an appropriate schedule while reviewing the results of our. contractor's guidance development on sampling line loss measurements if the staff concludes that such measurements are necesshry. This schedule will be provided to the licensee at a later date.
CONCLUSION The staff concludes, based on the discussions above, that the licensee's proposed revisions to the Appendix ID USAR license commitments are acceptable, as indicated, and meet the intent of the staff's SER and Supplements for resolution of these issues. The staff proposes that the licensee make a special upcate of the USAR to docunient these couaitments rather than wait for the regularly scheduled 1990 revision as proposed in their March 3, 1989 letter.
Principal Contributor:
T. Colburn Date:
July 14, 1989 l