PY-CEI-NRR-0643, Application for Amend to License NPF-58,requesting one-time Exception to Tech Spec 4.6.1.2.f Be Granted to Extend Testing Interval of MSIVs in Steam Line a Until 870712. Application Fee Will Be Submitted Under Separate Cover

Application for Amend to License NPF-58,requesting one-time Exception to Tech Spec 4.6.1.2.f Be Granted to Extend Testing Interval of MSIVs in Steam Line a Until 870712. Application Fee Will Be Submitted Under Separate Cover

ML20215J624
Person / Time
Site:	Perry
Issue date:	05/04/1987
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20215J627	List: ML20215J630 PY-CEI-NRR-0643, Application for Amend to License NPF-58,requesting one-time Exception to Tech Spec 4.6.1.2.f Be Granted to Extend Testing Interval of MSIVs in Steam Line a Until 870712. Application Fee Will Be Submitted Under Separate Cover
References
PY-CEI-NRR-0643, PY-CEI-NRR-643, NUDOCS 8705080170
Download: ML20215J624 (3)

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t THE CLEVELAND ELECTR P.O. BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLOG. - $5 PUBLICSOUARE Serving The Best location in the Nation MURRAY R. EDELMAN May 4,1987 SR VICE PRESIDENT PY-CEI/NRR-0643 L NUCLE A R Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Exigent Technical Specification Change Request Centlemen:

Pursuant to 10 CFR 50.59, the Cleveland Electric Illuminating Company (CEI) hereby requests amendment of Appendix A to the Perry Nucicar Power Plant operating license ( NPF-58) . This change is requested under exigent circumstances under the Commission's Regulations, 10 CFR 50 91' T(6).

Summary Technical Specification 4.6.1.2.f requires the Main Steamilne Isolation Valves

( MSIVs) be leak tested at least once per 18 months. Presently, the MSIVs in steamilne "A" are due to be tested by May 31, 1987. The MSIVs in steamilnes "B," "C," and "D" are not due to be tested until September 1987. CEI requests that a one tlme exception to the Technical Specifications be granted to extend the testing interval of the MSIVs in steamline "A" until July 12, 1987.

Significant Hazards Analysis The standards used to arrive at a determination that a request for amendment regulres no significant hazards consideration are included in the Commlaslon's Regulations, 10 CFR 50.92, which state that the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or dif ferent klnd of accident from any aceldent previously evaluated, or (3) involve a significant reduction in a margin of safety. CEI has revlewed the proposed change with respect to these three factors.

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Document Control Desk May 4, 1987 USNRC PY-CEI/NRR-0643 L CEI is proposing to perform the leak testing of the MSIVs of steamline "A" six weeks later than presently required in the technical specifications. The Commission's Regulations, 10 CFR 50, Appendix J - Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, requires Type C tests to be conducted at intervals no greater than two years. The MSIVs in steamline "A" were leak tested on July 13, 1985. By postponing the leak test until July 12, 1987, CEI will still meet the testing f requency of 10 CFR 50, Appendix J.

Since this test frequency meets the regulations, as well as the ASME code, CEI has concluded that this proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

CEI is proposing to postpone the leak testing of the two MSIVs from May 31, 1987 untti July 12, 1987. At that time, CEI will perform all required testing on the MSIVs. In addition, this change does not result in any modification to plant design or system operation. Since all required testing will ultimately be performed, CEI has concluded that this proposed change does not create the possibility of a new or dif ferent accident from any accident previously evaluated.

The MSIVs in steamline "A" were leak tested on July 13, 1985, and the results were well within the acceptance criteria for each valve. CEI received the low power license for Perry Unit 1 on March 18, 1986, and commenced nuclear heatup in August 1986. Therefore, the MSIVs have only seen approximately 9 months of time in service. CEI is requesting an additional six weeks of time before the leak testing of these MSIVs. Although it will be 24 months since the valves were last tested, these valves will have seen less than 1 year of service time. CEI has concluded that this will not result in a significant reduction in a margin of safety.

CEI has reviewed this proposed amendment in accordance with the standards stated in 10 CFR 50 92, and has concluded that the proposed amendment involves j no significant hazards.

Statement of Exigent Circumstances CEI presently has an exception for the operability of the Reactor Core Isolation Cooling (RCIC) system, which expires on May 31, 1987. The basis for the May 31 date was that modifications to the level instruments which had proved successful during RCIC system testing were to be installed on all 2

reference legs. These modifications were to be installed during the upcoming May/ June outage. During the forced outage to repale the maln steamilne draln header, which was recently completed, CEI modified the remaining reactor vessel water level steam taps. The re fo re , CEI does not need the May/ June outage in order to complete these instrument modlficalions.

Document Control Desk May 4, 1987 USNRC PY-CEI/NRR-0643 L The only item which would force the plant to take an outage on May 31, 1987 is the leak testing of the MSIVs in steamline "A". Since CEI only recently determined that the post modification testing on all the reactor vessel water level instruments was successful, (letter dated May 1,1987, PY-CEI/NRR-0644), I CEI did not have adequate time under the Commission's Regulations to ask for this amendment in a normal manner.

CEI requires this amendment in order to continue operation and startup testing. CEI requests this amendment be processed under exigent circumstances in accordance with 10 CFR 50.91(a)(6) . Without approval of this amendment the ,

Perry Nuclear Power Plant would be required to shutdown after May 31, 1987. '

Thus, insufficient time exists to process the amendment in the normal manner prior to *.his date.

Environmental Impact Cleveland Electric Illuminating has reviewed the proposed Technical Specification change against the criteria of 10 CFR 51.22 for environmental considerations. As shown above, the proposed change does not involve a significant hazards consideration, nor increase the types and amounts of ef fluents that may be released of fsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specification change meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

Administration Pursuant to 10 CFR 170.12, the application fee of $150 00 will follow under separate letter.

A marked up copy of the Technical Specification page is enclosed. We request this amendment be process under exigent circumstances, as described in 10 CFR 50.91(a)(6), and be issued no later than May 22, 1987. Pursuant to 10 CFR 50 91(b) a copy of this application has been sent to the State of Ohio.

Should you have any questions, please feel free to call me.

Very truly yours,

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Murray R. Edelman Senior Vice President Nuclear Group MRE:nje Enclosure cc T. Colburn K. Connaughton USNRC, Region III J. Harris (State of Ohio)