PY-CEI-NRR-2165, Application for Amend to License NPF-58,revising Tech Specs Surveillance Requirement for MSIV Leakage Rate Acceptance Criteria

Application for Amend to License NPF-58,revising Tech Specs Surveillance Requirement for MSIV Leakage Rate Acceptance Criteria

ML20148A679
Person / Time
Site:	Perry
Issue date:	05/02/1997
From:	Myers L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20148A684	List: ML20148A687 PY-CEI-NRR-2165, Application for Amend to License NPF-58,revising Tech Specs Surveillance Requirement for MSIV Leakage Rate Acceptance Criteria
References
PY-CEI-NRR-2165, NUDOCS 9705090114
Download: ML20148A679 (7)

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CQNTEREOR ENERGY i

Power Generation Group Perry Nuclear Power Plant Mail Address: 216-280-5915 Lew W. Myers 10 Center Road P.O. Box 97 FAX: 216-280-8029 vce Prescent Perry. Otuo 44081 Perry. OH 44081 May 2,1997 PY-CEl/NRR-2165L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10CFR50.90: Revision ofTechnical Specification Surveillance Requirement for MSIV Leakage Rate Acceptance Criteria Ladies and Gentlemen:

Nuclear Regulatory Commission review and approval cf a license amendment for the Perry Nuclear Power Plant is requested. The proposed amendment would allow the leakage rate of one or more main steam lines to be s 35 standard cubic feet per hour (sefh), as long as the total leakage rate through all four main steam lines is s 100 scfh. This proposed change has been developed for implementation during the sixth refueling outage (RFO6). In order to support the necessary procedure changes, issuance of this amendment is requested by September 1,1997.

Attachment 1 provides the Summary, Description of the Proposed Technical Specification Change, Safety Analysis, and Environmental Consideration. Attachment 2 provides the Significant Hazards Consideration. Attachment 3 provides the annotated Technical Specification page reflecting the proposed change. Attachment 4 provides an annotated Bases page, for information, since the Bases are not a formal part of the Technical Specifications.

If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory Affairs, at (216) 280-5606. j Very truly yours, s

BSF:sc fo\3 ) s Attachments l

cc: NRC Project Manager i NRC Resident Inspector NRC Region 111 State f 0hio

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I, Lew W. Myers, being duly sworn state that (1) I am Vice President, Nuclear of the Centerior Service company, (2) I am duly authorized to execute and file this certification on behalf of The Cleveland Electric Illuminating Company and Toledo l Edison Company, and as the duly authorized agent for Duquesne Light Company, Ohio Edison Company, and Pennsylvania Power Company, and (3) the statements set forth herein are true and correct to the best of my knowledge, information and belief.

I bD SA.) &d%A f Lew W. Myer1!i$

l Sworn to and subscribed before me, the

/997.

A/O day of MI ,

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/D CAROUNE M. BALOG Notary PuMe, State of Ohio 1

My Commiselon expires May 23,2000 (tecordedin Lake County)

CODED /8838/SC l

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Attachment 1 PY-CEl/NRR-2165L Page1of3 l

SUMMARY

The proposed change requests revision of the Perry Nuclear Power Plant (PNPP)

Technical Specification Surveillance Requirement (SR) for verifying the leakage rate of the main steam lines. The proposed change will permit one or more main steam lines to have a leakage rate of 5 35 standard cubic feet per hour (scfh) when tested at 2 post-accident pressure (P,), as long as the total leakage rate through all four main steam lines is s 100 scfh. This change was granted for one main steam line for Operating Cycle 6, by Operating License Amendment 83, issued on March 18,1996. The reason the change was requested for only one operating cycle was the anticipation of having increased main steam line leakage limits approved in concert with the elimination of the Main Steam Isolation Valve (MSIV) Leakage Control System (I CS) prior to Operating Cycle 7. A submittal to request this MSIV-LCS elimination and main steam line increased leakage l limits was submitted to the Nuclear Regulatory Commission (NRC) in a letter dated August 27,1996 (letter number PY-CEI/NRR-2076L). Recent discussions with the NRC Staff have indicated that final approval of this license amendment will not be completed prior to Operating Cycle 7. Therefore, this proposed revision will make the change approved in Amendment 83 a permanent change, and would permit one or more main steam lines to have a leakage rate at s 35 scfh as long as the total of all four of the main steam lines is s 100 scfh.

This proposed change has been developed for implementation during the sixth refueling outage (RFO6), so that unnecessary maintenance on the MSIVs does not have to be performed in RFO6. In order to support the necessary procedure changes, issuance of this amendment is requested by September 1,1997.

DESCRIPTION OF TIIE PROPOSED TECIINICAL SPECIFICATION CIIANGE Technical Specification SR 3.6.1.3.10 will be revised to read " Verify leakage rate through each main steam line is s 35 scfh when tested at 2 P., as long as the total leakage rate through all four main steam lines is s 100 scfh."

[ Note: The Bases are not part of the Technical Specifications, and are not a formal part of this license amendment package. The Bases are revised under the PNPP Bases Control Program (Technical Specification 5.5.11). The annotated Bases page is contained in Attachment 4 "for information only".]

SAFETY ANALYSIS l

j This proposed change modifies the present Technical Specification Surveillance t

Requirement in two ways. First it deletes the one time allowance for main steam line leakage rates during Operating Cycle 6, and makes this allowance permanent. That

___ __ _ .. _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ .._ _ .m Attachment 1 PY-CEI/NRR-2165L Page 2 of 3 allowance was requested only for Operating Cycle 6 because it was planned to have _

another Technical Specification amendment approved by the end of Operating Cycle 6 which would increase the main steam line leakage rate acceptance criteria. The submittal to increase the main steam line leakage rate acceptance criteria was made on August 27, 1996. The main steam line leakage rate limit proposed in that submittal is s 100 scfh per main steam line as long as total leakage through all four main steam lines is s 250 scfh.

The NRC staff has recently indicated that approval of that submittal will not occur prior to completion of RFO6. Therefore, the one operating cycle restriction must be removed.  :

l The one cycle restriction contained in Amendment 83 was due to an administrative .

l reason and was not made due to a safety concern. Therefore, removing the wording that l states the leakage rates for the main steam line applies to Operating Cycle 6 does not result in a reduction in safety.

l The second part of the proposed change permits more than one main steam line leakage L

rate to be s 35 scfh as long as the total leakage of all four main steam lines is maintained l s 100 scfh. In the February 17,1996 submittal for Amendment 83, the proposal only requested that one main steam line be permitted to have a leakage rate s 35 scfh. At the l time of the February 1996 submittal, PNPP was in the middle of RF05. The main steam

lines had been tested, and the results were known. Since there was only one main steam l line leakage rate in excess of the 25 scfh limit, the proposed change was to permit that one main steam line to have leakage up to 35 scfh as long as all four main steam lines remained s 100 scfh. As discussed above, the February 1996 submittal was intended to address Operating Cycle 6. Therefore only changing the main steam line leakage rate for the one known main steam line was acceptable. However, the technical basis behind the change in Amendment 83 can be applied to the leakage rate for all four of the main steam lines. As stated in the safety evaluation accompanying Amendment 83,"The NRC staff has reviewed the licensee's request and finds that the effective combined limit of 100 scfh for all four main steam lines is maintained by the proposed amendment. Therefore, the staff finds the proposed amendment to be acceptable." Nothing in this proposed change is impacting the total leakage rate of the four main steam lines. The 100 scfh limit will still exist as the total leakage rate limit for the four main steam lines. The proposed change will permit one or more main steam lines to have leakage rates s 35 scfh as long as the 100 scfh leakage rate for all four of the main steam lines is maintained. Therefore, nothing in this part of the proposed change represents a decrease in safety.

ENVIRONMFNTAL CONSIDERATION The proposed Technical Specification change request was evaluated against the criteria of 10CFR51.22 for environmental considerations. The proposed change does not

! significantly increase individual or cumulative occupational radiation exposures, does not significantly increase the amounts of effluents that may be released off-site and, as l

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Attachment 1 PY-CFI/NRR-2165L Page 3 of 3 l

discussed in Attachment 2, does not involve a significant hazards consideration. Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in 10CFR51.22(c)(9) for categorical exclusion from the l requirement for an Environmental Impact Statement.

COMMITMENTS WITHIN THIS LETTER There are no regulatory commitments contained in this letter. Any actions discussed in  :

l this document represent intended or planned actions, are described for the NRC's l information, and are not regulatory commitments. Please notify the Manager -

Regulatory Affairs at the Perry Nuclear Power Plant of any questions regarding this document or any associated regulatory commitments.

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Attachment 2 PY-CEI/NRR-2165L i

SIGNIFICANT HAZARDS CONSIDERATION Page1of2 l

I i The standards used to arrive at a determination that a request for amendment involves no

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significant hazards considerations are included in the Commission's Regulations, l 10CFR50.92, which states 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; or (2) create the possibility of a new or ,

different kind of accident from any accident previously evaluated; or (3) involve a i

significant reduction in a margin of safety.

The proposed amendment has been reviewed with respect to these three factors and it has been determined that the proposed change does not involve a significant hazard because:

1. The proposed change does not involve a significant increase in the probability or i consequences of an accident previously evaluated.

The proposed change involves the deletion of the portion of Technical Specification Surveillance Requirement (SR) 3.6.1.3.10 that states the increased leakage rate of

s 35 scfh for an individual main steam line is only acceptable for Operating l l Cycle 6, and a deletion of the restriction that a main steam line leakage rate of s 35 l scfh is acceptable for only one main steam line. The overall main steam line leakage limit of s 100 scfh for all four main steam lines is not being revised.

The MSIV leakage is not an initiator of an accident, including the steam line rupture accident. Therefore, the probability of an accident previously evaluated has not changed.

The consequences ofinterest are the radiological dose consequences following a large-break Loss of Coolant Accident (LOCA). This is the event which the regulatory guidance requires to be evaluated using the extremely conservative source term assumptions of Regulatory Guide 1.3, " Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors." Since the overall main steam line leakage rate of s 100 scfh for all four main steam lines is not being revised, the radiological consequences of an accident previously evaluated has not changed.

Therefore, the probability or consequences of an accident previously evaluated have not significantly increased.

L l 2. The proposed change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

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. PY-CEI/NRR-2165L l SIGNIFICANT HAZARDS CONSIDERATION Page 2 of 2 This proposed change does not physically alter the plant or systems or equipment in the plant, or the method for operation of the plant. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change will not involve a significant reduction in the margin of safety.

l The proposed change does not revise the overall combined leakage rate of s 100

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scfh for all four main steam lines that is permitted in the present Specification. It is the combined main steam line penetration leakage rate that is assumed in the radiological accident analyses. Thus, although individual steam line leakage rates  ;

may be s 35 scfh, as long as overall leakage of the four main steam lines is j maintained at its current value of s 100 scfh, the proposed change does not reduce i the margin of safety.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

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