PY-CEI-NRR-1203, Provides Estimate Duration Schedule Re Installation of post-LOCA Neutron Monitoring Sys.Util Will Evaluate Effect of Resolution on Schedule & Confirm or Revise Installation Date as Needed,When Appeal & Criteria Questions Resolved

Provides Estimate Duration Schedule Re Installation of post-LOCA Neutron Monitoring Sys.Util Will Evaluate Effect of Resolution on Schedule & Confirm or Revise Installation Date as Needed,When Appeal & Criteria Questions Resolved

ML20055H872
Person / Time
Site:	Perry
Issue date:	07/27/1990
From:	Lyster M CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1203, TAC-72741, NUDOCS 9007310074
Download: ML20055H872 (4)

Text

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-. OO PERRY NUCt. EAR POWER PLANT Mail Mdress:

.10 CENTER ROAD P.O. BOX 97 Michael D. Lyster PERRY, OH;0 44081 PERRE OHIO 44081 Vice President Nuclear (216)259 3737 July 27, 1990..

PY-CEI/NRR-1203 L-U.S. Nuclear Regulatory Commission Document Control Desk.

Washington, D. C. 20555-Perry Nuclear Power Plant Docket No. 50-440 USAR Appendix 1B Commitment No. 7 Post-Accident Neutron Monitoring (TAC No. 72741)

Gentlemen:

By letter dated' July 14, 1989 (Reference'1) the NRC approved a revision of USAR Appendix 1B Commitment 7, regarding< installation of a post-LOCA neutron monitoring system, as follows:

"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 evalustion 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."

By letter dated January 29, 1990 (Reference 2),-the NRC issued an SER which found the NED0-31558 functional criteria for post accident neutron flux monitoring to be unacceptable. Per our licensing commitment this decision obligated CEI to provide ~a schedule for NMS modifications.

This letter provides a best estimate duration schedule (attached), which is necessarily subject to NRC. resolution of three issues documented below: (1)

NHS design criteria, (2) SER resolution of the incore NMS design report, and (3) BVROC appeal of the January 29 decision. Resolution would lead to installation at'the refueling outage following an estimated 33 month period-for design and ' procurement.

(1) The BVROG-is pursuing resolution of outstanding questions on generic NHS

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design criteria which must be resolved before-CEI-can design any system. In the January 29 letter, the NRC reiterated Regulatory Guide 1.97. criteria ~and specified other design requirements. NHS detection range was to cover the range from 10 -6% power up to 100% power, and the system was to be qualified.

for LOCA conditions associated with "some fuel clad failure" for a time period of about six hours. Further dialogue between the vendor, the BVR Owners Group and the NRC has modified but not-completely defined these requirements.

Reference 3 contributes to that resolution, but the NRC here acknowledges that necessary work remains for " prompt resolution." CEI is participating in this BVROG activity.

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'(2) On a matter related to design' criteria for a new neutron monitoring system, we are considering the incore NMS altert.stive. The design basis for this system is docketed by General Electric letter #054-87, R. Villa to J. L.

Funches dated 7/14/87, which submitted NEDO-31439, "The Nuclear Measurement ,

and Control Wide Range Neutron Monitoring System (NUMAC-WRNMS]". Our schedule  !

for making a procurement decision on an incore system is therefore contingent on an NRC SER being issued which favorably approves NEDO-31439.

.(3) Another f actor af fecting the start date is reso .ution of a BWROC appeal on the 1/29/90 NRC decision. The BWROC and CEI sincerely believe that' substantive technical arguments need to be reconsidered,'and CEI actively supports this dialogue. . Very costly modifications nave been mandated that offer no measurable safety benefit for.the boiling dater reactor. Owners

-Group estimates of capital cost range from $1 milli >n to $7 million. This appeal is scheduled to be flied in the August-September timeframe.

In view of the large cost and significant impact on CEI engineering resources, the implementation schedule must be contingent on resolving the appeal question as well as the design criteria.

With regard to the attached schedule, the NRC earlier reviewed estimates for SRM/IRM replacement on Docket 50-416 (Grand Gulf letter AECM-88/0110, 7/1/88).

At that time critical path design and installation engineering was estimated to take 14 months. More recent PNPP estimates are 18 months. Procurement, initiated about 9 months after engineering start (at some risk to design changes) is estimated by a supplier to take up to 2 years, subject; to delays if multiple utility orders coincide. These durations dictate lapsed time, f rom start to hardware delivery, to be 33' months from the start date. Actual installation would be at the refueling outage next following hardware delivery. If the issues discussed in this letter are resolved'oy January 1991 and it is determined that a system must be installed, then installation would occur in the fourth refuel outage.

When the appeal and criteria questions are resolved, we will evaluate the effect of their resolution on the schedule and confirm or' revise installation date as needed. If you have any questions, please feel free to call.

Sincerel ,

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Michael D. Lyster Vice President, Nuclear - Perry MDL WJEinje Attachments cc: NRR Project Manager Sr. Resident Inspector USNRC Region III

. m USNRC' July 27, 1990 PY-CEI/NRR-1203 L References

1. " Perry Unit l'USAR Appendix IB License Commitments-(TAC No. 72741)"

- Timothy C. Colburn (NRC) to Alvin Kaplan (CEI), 7/14/89. l

2. "BWR Owners' Group Licensing Topical Report Position on NRC Regulatory Guide 1.97, Revision,3 Requirements for Post-Accident Neutron Monitoring Systems'(General. Electric Report NED0-31558)," Frank J. Miraglia (NRC) to Stephen D. Floyd (BWR Owners' Group), 1/29/90.

3. " Position on NRC Regulatory Guide 1.97, Revision 3 Requirements' for e Post-Accident Neutron Monitoring Systems," William T. Russel (NRC) to 1 Stephen D. Floyd (BWR Owners' Group), 5/21/90.

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