PY-CEI-NRR-0829, Withdraws Portion of 870918 Tech Spec Change Request Re Deletion of MSIV Leakage Control Sys & Requests Again Portion of Change Request That Allows 100 Scfh Total MSIV Leakage,Per NRC 880311 Rejection Ltr

Withdraws Portion of 870918 Tech Spec Change Request Re Deletion of MSIV Leakage Control Sys & Requests Again Portion of Change Request That Allows 100 Scfh Total MSIV Leakage,Per NRC 880311 Rejection Ltr

ML20151R367
Person / Time
Site:	Perry
Issue date:	04/18/1988
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
REF-GTECI-C-08, REF-GTECI-NI, RTR-NUREG-1169, TASK-C-08, TASK-C-8, TASK-OR GL-86-17, PY-CEI-NRR-0829, PY-CEI-NRR-829, NUDOCS 8804270304
Download: ML20151R367 (2)

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ELECTRIC ILLUMIN ATING COMPANY l f THE CLEVELAND P. O . BOX 97 e PERRY, OHIO 44081 e TE.EPHONE (216) 259-3737 e ADDRESS to CENTER ROAD Serving The Best Location in the Nation PERRY NUCLEAR POWER PLANT Al Kaplan wce passioest April 18, 1938 succan caoup PY-CEI/NRR-0829 L U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Perry Nuclear Power Plant Docke t No. 50-440 Technical Specification Change Request Concerning MSIV Leakage Ce ntleme n:

The NRC, by letter dated March 11, 1988, rejected the subject request for Main Steam Isolation Valve Leakage Control System (LCS) elimination f rom the Perry Technical Specifications. The letter suggested that any resubmittal of the request should be deferred until the Staf f has completed its resolution of Generic Issue C-8. The Cleveland Electric Illuminating Company hereby withdraws the portion of the September 18, 1987 Technical Specification change request that deals with deletion of the MSIV Leakage Control System from the Techncial Specifications.

There remains an additional portion of the change request originally forwarded by our letter dated 9/18/87, to allow total MSIV leakage of 100 scfh through any combination of main steam lines, as opposed to the present limit of 25 scfh per line. This technical specification enange to allow 100 scfh total leakage doe s not change the Perry licensing basis, which includes a LOCA analysis for 100 scf h irrespective of which main steam line(s) are leaking. As justified in the original letter, the criteria of 10 CFR 50.92 for no significant hazards are still satisfied; accident probability or consequences previously evaluated are not adversely af fected, a dif ferent kind of accident is not created, and safety margins are not reduced. This change has the f avorable precedent of other BWR licensees, and was not contested during the public notice periou allowed for this change. The request for this change therefore stands, and NRC action on this technical specification amendment is again requested.

Notwithstanding withdrawal of a portion of the request, we would like to comn2nt on the review process of this Technical Specification change request.

The Cleveland Electric Illuminating Company has expended considerable ef fort to provide the NRC staf f with the inf ormation necessary for their review of this request, through several letters and a meeting on the subject.

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U.S. Nuclear Regulatory Commission April 18, 1988 PY-CEI/NRR-0829 L The NRC forwarded NUREG 1169 by Generic Letter 86-17 (October,1986), to p re se nt technical findings related to MSIV leakage. treatment methods. These p findings clearly demonstrated the post-accident dose reduction potential of processing MSIV leakage through an isolated condenser, versus filtering in an engineered safeguard system. This inf ormation was provided because it "may be useful guidance for some licensees contemplating plant specific change requests related to this issue pending final generic resolution." Perry was contemplating such a change request, and requested a meeting with- the NRC staf f ..

by letter dated July 31, 19 87 (PY-CEI/ NRR-0678L) . Included witn that letter was a Perry-specific dose assessment which showed orders of magnitude reduction in doses f rom the MSIV leakage path, with attendant simplifications in plant -

emergency instructions and improvement in net availability, using NUREG 1169 as . ,

a basis for the calculations.

The Perry-specific calculations adjusted NUREG 1169 results for stated plant and site dif ferences. It was clearly stated in the July 31 letter, and during a September 2,1987 meeting at the NRC Bethesda offices with the staff, that the NUREG 1169 analysis was otherwise used as-is. The dose calculation assumptions, with respect to source term characterization and attendant iodine transport / removal mechanisms, had previously been used by a dif ferent licensee and had been approved by the staf f. CEI answered staf f questions raised at the September 2 meeting; there was no indication at that time of problems with any of the underly'ng assumptions, nor was the detailed. calculation requested.

Based on the results of this meeting, CEI decided to request only the deletion of the MSIV LCS f rom the Technical Specifications, while maintaining the system available f or use as a backup to the isolated condenser operation. This Technical Specification Change Request was forwarded to the NRC by letter dated September 18,1987 (PY-CEI/NRR-0712L) .

The March 11 NRC letter rejecting the change request stated that the Technical Specification Change Request failed to include detailed analyses to support the findings set forth in the submittal. The letter also identified that NUREG 1169 used a different source term than that used as the licensing basis for i PNPP and that used in Regulatory Guide 1.3. There was no prior discussion of l the concerns with source term assumptions used in the NUREG, and no specific I request f or additional information. Nor does the letter identify any technical reason for not proceeding with review of this request in accordance with the normal regulatory process, other than the desirability of first resolving Generic Issue C-8. CEI remains convinced that the concept presented in NUREG 1169 is technically justified. We again of fer our assistance in the technical resolution of these matters specifically for Perry, and generically via the BWR Owners Groups' planned submittal on LCS elimination. We continue to be available f or discussions on the subject with the NRC staff.

If there are any questions, please feel f ree to call.

Very truly yours, d

Al Kap an Vice President Nuclear Group AK: cab cc: J. Silberg T. Colburn K. Connaughton USNRC Region III

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