View source for PY-CEI-NRR-0969, Discusses Proposed Changes to Commitments 7,14,16,4,8 & 10 to Resolve Issues Remaining from Plant SER (NUREG-0887),for Approval

{{Adams
| number = ML20235Y485
| issue date = 03/03/1989
| title = Discusses Proposed Changes to Commitments 7,14,16,4,8 & 10 to Resolve Issues Remaining from Plant SER (NUREG-0887),for Approval
| author name = Kaplan A
| author affiliation = CLEVELAND ELECTRIC ILLUMINATING CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000440
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0887, RTR-NUREG-887, RTR-REGGD-01.097, RTR-REGGD-1.097
| document report number = PY-CEI-NRR-0969, PY-CEI-NRR-969, NUDOCS 8903140201
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}

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e THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.O. BOX 97     5  PEARY, OHIO 44081   5 TELEPHONE   (216) 259-3737                       5                         ADDRESS-10 CENTER ROAD FROM CLEVELAND: 241 1650 Serving The Best location in the Nation Al Kaplan                                                                      PERRY NUCLEAR POWER PLANT VICE PRESIDENT NUCLEAR GROUP March 3, 1989 PY-CEI/NRR-0969 L U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.             20555 Perry Nuclear Power Plant Docket No. 50-440 USAR Appendix IB Commitments Gentlemen:
The Perry Nuclear Power Plant USAR Appendix IB compiles license commitments needed to resolve issues remaining from the Safety Evaluation Report for PNPP (NUREG 0887) at the time of operating license issuance. Unless prior approval is obtained from the NRC, no changes may be made to this Appendix by The Cleveland Electric Illuminating Co. (CEI) other than to add information to document closure of the identified items.
In this letter we are proposing changes to several commitments, to clarify their resolution or to allow more time for NRC staff review of a proposed alternative:
Commitment 7, Reg Guide 1.97 Rev. 2 (Neutron Monitoring Post LOCA)
Attachment I describes the Cleveland Electric Illuminating Company's plan regarding the neutron monitoring system. It specifically requests a change to allow time for NRC review of an industry proposed alternative, with more substantial design changes if needed contingent upon ongoing NRC safety evaluations.
Commitment 14, Instrument Setpoint Methodology Attachment 2 proposes to extend the NRC evaluation and PNPP-specific analysis schedule to allow time for the NRC staff to complete their evaluation of the generic Instrument Setpoint Methodology Group effort, plus 6 months for CEI analysis.
Ccmmitment 16, Caseous Effluent Sampling System Representative Sample Attachment 3 proposes clarifications necessary to neet the intent of this condition.
8903140201 890303                %
PDR  ADOCK 05000440 E                      PDC     <
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a U'SN R,C                                                March 3, 1989 PY-CEI/NRR-0969 L Commitments 4 - Turbine System Maintenance Program, and 5 - Containment Purge Criteria, will be separately addressed prior to startup from the first refueling outage, as originally committed.
CEI further proposes to remove Commitments 8 - Detailed Control Room Design Review, and 10 - TDI Diesel Engines, from Appendix 1B of the PNPP USAR, since both subjects are contained in the PNPP Operating License (items 2C(7) and 2C(9) respectively), and are subject to change controls under 10 CFR 50.90, 91 and 92.
If the NRC concurs, these changes will be incorporated in the next USAR update (1990). Please call if you have any questions, and advise us of your concurrence.
Very truly yours, 1
G, Al Kaplan Vice President Nuclear Group AK:nje Attachments I
cc:    T. Colburn                                                              !
NRC Resident Inspector's Office NRC Region III I

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4 Attachmrnt 1 PY-CEI/NRR-0969 L Commitment 7, Reg. Guide 1.97 Rev. 2 (Neutron Monitoring Post LOCA)

==SUMMARY==

Regulatory Guide 1.97, Revision 2 requires Neutron Monitoring System (NHS) instrumentation to meet Category 1, Class IE specifications defined in that Guide. The subject commitment was that CEI would define its plan for NHS                  j upgrades to that standard, and provide the schedule for implementation.
CEI joined the BVR Owners Group in proposing an alternative to the Reg. Guide recommendation for Category 1 neutron monitoring (NED0-31558, Requirements for Post-Accident Neutron Monitoring System) as submitted to the NRC by BVROG-8817, April 1, 1988. This report established that (a) there are no design-basis accidents that require a post-accident neutron monitoring function, and (b) the combination of rod position indication, other plant                 ,
l                                                 status indications (provided in accordance with Regulatory Guide 1.97), and              j emergency procedures assure mitigation of limiting design-basis accidents.
CEI endorses the BVROG position described by NED0-31558 as an effective                   ;
resolution of the subject license commitment, without significant hazards being introduced to the general public or additional radiation exposure to               3 plant personnel for modifications.                                                        !
l Although the CEI position is that the NED0-31558 alternative provides the most            )
l                                                 appropriate resolution of this issue, CEI has also been following developments           1 in NMS technology. At the present time, CEI can not define a system which has             l demonstrated satisfactory performance to Regulatory Guide 1.97 and other applicable U.S. Standards. Among applications known to us, ex-core applications do not have the sensitivity, and in-core systems have neither l
received a favorable NRC safety evaluadon nor demonstrated the required sensitivity and accurney over the presently required range of 8 decades.(10~6 to 100% power). Until such time that an NRC SER approving use of the NED0-31558 alternative for PNPP is received, CEI will contir:ue to follow the development / progress of NMS technology, including experience with the fixed in-core system.             It is not considered prudent for CEI to consider the procurement / installation of an alternative NMS design until the design and regulatory basis are finalized.
i                                                 RECOMMENDATIONS Plant modifications at PNPP should be contingent on the results of NRC evaluation of NED0 report 31558. To allow appropriate time for NRC reviev, and subsequent implementation of further plant modifications contin W - "
conclusions, it is recommended that the subject Appendix 1B commitumn'             l+
revised 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 evaluation of the report, on a schedule to be provided 6 months after receipt of the NRC staff SER.
There are no Technical Specification changes needed for the proposed commitment; it meets the intent of the original commitment.

l Attechmsnt 2
  *'(                                                                                    PY-CEI/NRR-0969 L Commitment 14, Instrument Setpoint Methodology

==SUMMARY==

k The subject commitment was that prior to startup following the first refueling outage, CEI would provide a detailed technical report documenting the basis and methodology for establishing protection system trip setpoints and                     l allowable values, based on the Instrument Setpoint Methodology Group (ISMG)              {>
effort, as discussed in CEI {{letter dated|date=October 17, 1985|text=letter dated October 17, 1985}} (PY-CEI/NRR-0368L).            l The schedule for the Perry setpoint report submittal was based on the ISMG I
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 from Youngblood to Carolyn dated February 19, 1985, the 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                j Instrument Setpoint Methodology," NEDC-31336, October 1986, forwarded by                 l {{letter dated|date=November 19, 1986|text=November 19, 1986 letter}} from R. Villa to H. M. Berkov. This Report is still              i under consideration by the NRC staff. To the extent setpoints within the                 l
.                            scope of this report have been changed at Perry, the NEDC-31336 methodology has been used in CEI Technical Specification change requests dated February 8, 1988 (PY-CEI/NRR-0765L) and May 20, 1988 (PY-CEI/NRR-0817L), for changes to the RHR/RCIC steam flov Trip Setpoint and Allovable Value, and for changes to the turbine first stage pressure Trip Setpoints and Allovable Values, respectively. These change requests are also still being considered by the NRC staff.
An interim staff evaluation of the GE setpoint methodology (Youngblood to                '
Carolyn, dated February 19, 198S) noted that each plant sponsoring development of setpoint methodology should complete plant-specific assessments within 6 months of being notified of the staff's acceptance of the methodology.
RECOMMENDATIONS Pending a favorable NRC Safety Evaluation Report on NEDC-31336, CEI cannot implement the full scope of RPS and ECCS setpoint evaluations and potential changes covered by that report. In the interim this methodology will be applied as the best available when plant changes are necessary, as in the cases noted above.
It is recommended the subject Appendix 1B commitment be accordingly revised to allow time to complete NRC's evaluation of the methodology:
Six months after receipt of a favorable NRC Safety Evaluation l                                    Report on GE Instrument Setpoint Methodology (NEDC 31336), and I
subject to any stipulations therein, CEI shall provide for NRC staff review and approval, a detailed technical report documenting the basis and methodology for establishing protection system trip setpoints and allovable values, based on the Instrument Setpoint Methodology Group (ISMG) effort, ns discussed in CEI {{letter dated|date=October 17, 1985|text=letter dated October 17, 1985}} (PY-CEI/NRR-0368L).
i CEI has taken every reasonable measure to define and implement this i
methodology at Perry; this change only reschedules completion of initially l                              agreed upon actions.

Attachment 3
         '.*                                                                                                        PY-CEI/NRR-0969 L Commitment 16, Gaseous Effluent Sampling System Representative Sample

==SUMMARY==

The subject commitment addressed representative sampling to determine iodine concentration in stack effluent under design basis accident (LOCA) conditions.
Our interim position (defined in PY-CEI/NRR-327L dated September 6, 1985) is that sampling line losses of iodine are minimized by design to a calculated 6%
in particulate form, and 30% in elemental form. Further action on this commitment depends upon (1) whether the basis for these loss computations remains valid, and whether the liRC will define iodine form to allow factoring for calculated line losses, or (2) whether experimental line loss methods have been developed which can improve on the validity / accuracy of calculated losses.
Either option requires definition of iodine form. Ve most recently addressed iodine form in leakage control system dose assessments (PY-CEI/NRR-0712L, dated September 18, 1987) and were advised in your respor.se (Perkins to Kaplan dated March 11, 1988) that we should have used Regulatory Guide 1.3 assumptions.                Your letter further indicated potential changes to regulatory guides, standard review plan guidelines and regulations which may redefine the chemical form of iodine.
NRC guidance is needed on (1) the chemical form of iodine to use for correcting post-accident measurements of iodine concentration at the plant stack, and (2) techniques to be used to conduct line loss experiments, if such experiments are determined to be necessary.
RECOMMENDATIONS Consistent with the original commitment, we vill not experimentally measure iodine loss until the NRC determines that such measurements are necessary, and defines both line loss methodology and iodine form.
It is recommended the subject Appendix 1B commitment be accordingly revised as follows:
Vork 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 measurements on the radioiodine 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.
NJC/ CODED /V1764
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