ML20128Q259

Submits Comments on Util 850717 Presentation & Tour of Facility.Util Neglected to Mention Effects of Merger W/ Toledo Edison Announced in Late June.Question Raised Re Whether Same Persons Will Manage Davis-Besse & Perry

ML20128Q259
Person / Time
Site:	Perry
Issue date:	07/19/1985
From:	Hiatt S CONCERNED CITIZENS REACTOR EXPORT REVIEW BOARD
To:	Asselstine J NRC COMMISSION (OCM)
Shared Package
ML20128Q246	List: ML20128Q242 ML20128Q259
References
OL, NUDOCS 8507260628
Download: ML20128Q259 (3)

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Ocam sstoner-James X. Asselseine 1717 H StreetiNW U.S. Nuclear Regulatory Commissson Washington, DC 20555 Re Clevelond Electric Illuminating Co. (Perry Nuclear Fower plant, Units 1 and 2), Docket Nos. 50-440 and 50-441 Deor Commsssioner Asselstine:

On behoir or Ohio Ciei: ens for Responsible Energy (=0CRE') I am pleased to submit the rollowing comments on the CEI presentation and tour of PNPP or July 17, 1985.

1. CEI's discussion or management neglected to mention the errects of the merger of CEI and Toledo Edison, announced in late June. News accounts have indscoted that a nuclear management group ws11 be formed to manage the Perry units and Davis-Besse. This raises the question or whether persons responsible for the poor monogement of Davis-Besse will be in charge of Ferry. The errect or the merger on management has'not been evoluoted by the Storrs I feel this must be evoluoted before fuel load, as integrity, capobility, and competonce of management is o material roctor in licensing, and the new

ommany and its nuclear unst (not CEI as was presented to you) will be resconsible for Derry for its 40-year life.

2. CEI mentioned the ' successful' emergency planning exercise held November 29, 1984. I am unable to understand why NRC and FEMA tave this exercise such high marks. According to press a:Ocunts and inrcrmation obtained through FOIA, ene scenorso assumed for the exercise w a s A T'W 5 intesoted by a stuck-omen 3RV, assumed eo stort at 10:17 AM. A site area emergency was dectored, at 12:23 PM the suppression pool was assumed to boil;

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o genero1 emergency was declarad. Seven msnutes later the containment wGs assumed to fail and radiation release to began.

However, the sirens were not hypothetically sounded until 1:45 pH. One hour gad-15 minutes orter the radioactive release began, and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />sfjj ond 28 minutestarter the severe occident was postulated to oegsn. Thishc1early rails the 15-minute criterion or Appendix E to 10 CFR 59~and NUREG-9654 This was not due to o ' mistake = on ene port or the exercise porticipants, but was written into the exercise script. In fact, had the participants not taken the

' correct' oCtiors Within a few minutes, they Would have been prompted to do se by persons having knCwledge of the script.

This hardly Constitutes assurance that prompt protectsve measures Will be token in 3n Occident.

3. CEI stated thor while construction on Perry Unit 2 had eeen esscontinued. the Unit 2 diesel generators were being completed 8507260628 850725 PDR ADOCK 05000440 g PDR'

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'o Foge 2

'ror redundonCy.' Apparently this means that the Unit 2 OOs are to be redundant to Unit l's. However, there is cresently nc way to connece the Unit 2 DGs to Unit i busses, os the Perry F5Ac (Section 9.2.1.1.2.13) cleocly states tnot there zs no shorzng or Class 1E AC power between units. To take credit for the Unie 2 DGs os redundant 15 clearly on unanalyced issue, and te is perhaps ancicacive or on intentson to abandon. roemer than aust postpone, Unit 2.

4 CEI stated the inteneson to resolve all open issues przor to ruel load. This is belied by thezr response to on open item from the NRC's rire Protectzon audit. The Starr stated in the audit report that the item, concerning the sealing or conduit rour inches cr less in diameter, must be resolved =rior to ruel load. In their response CEI proposed a crzterson to meet the intent or the 5 torr's guidelines and stated that it would be implemented prior to exceeding 5% power operation. Although the Storr round CEI's criterion to be unaccepeoble, it stored that the item (ord others identified in the audit) needed to me aesolved before Unit 1 ' licensing.' I am concerned that these items may ce cerecres ceycnc fuel icod, without goo: cause.

5. CEI stated that no major des:gn crablems were identirzed zn the Integrated Design Inspection and that no systems hove been round emot die not worv. One or the problems identified my the IDI (Board Notificotton 35-02) was the lack cr considerotron CF cable Voltage creps. This deficiency has been identarted in several other systems subsequent to the IDI. I hoye ottoched a report f: led by CEI pursuont to 10 CFR 50. 55 (e) concerning suen a cer:ciency in tme RCIC system. Note that no commitment te corrective action ss modes rather, there is on explanotzen enot PCIC is not really needed in the control rod crop occident, the event for which it is considered on engineered screty receure, i yhtle this may be true. CEI has neglected the roct that RCIC is on important coolant makeup system in a storson elockout occidenti the 4ericiency renders RCIC inoperable during a storion blockout occident. Chongsng ehe escP and merely accepting o-reduction in plant sorety is nor the a:crceriote

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response to such a dericiency, which con be easily ccc ecree ey connecting other'cobles in parallel with the RCIC conductors,

c. You disclosed the starr's assessment or fuel looc readiness for Perry Unit 1, likely to be the first quarter or 1986. This estimate is in reasonoble agreement with the August 1984 reccet or the Coseload Forecast Panel, which round that a late lo35 fuel load.is attosnoble, assuming problem-Free creoperatsonal restsn9. However, in late 1994 the Licensing acord made inquirses or the porties os to the projecrea ruel load date for scheduling purposes. The starr t~en abanconed zts Coseload Forecast Panel estimate one endorsec CEI's June 15, 1985

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• 4 Page 3 projectee fuel lood date. Heorings were scheduled in occardance with CEI's prosections. The-time constroznts and rrontic case

'preporation imposed by the hearing schedule, thanks to the 5 boff's less-hon-honest behavior. Were cutte cifficult for OCRE, a small organi:otton with limited financial and personnel resources; it is A055161e that on expert Witne55 FC? one 3f our issues Would have been avoilable had there been a more realistic heoring

. Schedule. In any event the behcVior-of the Stoff in this instonce 15 less than what I consider copropriote for a government agency.

Thank you for the CDPortunity to participate in yOur tour of Perry and to crovide comments thereupon.

i sincerely, MA W '

suson L. Hsott CCPE Fecr_esentative c275 Munson c.d.

Mentor. OH e4060 (216) 255-215a

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1 THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.O. 80X $000 - CLEVELAND. CHIO 44101 -

TELEPHONE (216) 622-9800 - ILLUMINATING BLOG. - 55 PUBLICSOUAAE Serving The Best Location in the Nation MURRAY R. EDELMAN vfCE PR(310fNT Nucuca l May 22, 1985 l

PY-CEI/OIE-0046 LQ Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Voltage Drop Affecting RCIC Valves (RDC 127 (85)]

Dear Mr. Keppler:

This letter is the final report pursuant to 10CFR50.55(e) on the potential significant deficiency regarding starting voltage drops in power feeder cables for three valves in the Reactor Core Isolation Cooling (RCIC) System. Mr. J. McCormick-Barger of your .

office was notified on January 30, 1985, by Mr. T. A. Boss of The Cleveland Electric Illuminating Company that this problem was being evaluated per our Deviation Analysis Report Number 222.

Interim reports were submitted on February 28, and April 18, 1985. We have determined that this condition does not constitute a significant deficiency per the requirements of 10CFR50.55(e).

l Descriotion of Potential Deficiency Calculations had indicated that various DC powered valves within the RCIC system might be incapable of operating due to reduced voltage at the valve operators. This condition results upon loss of a battery charger coupled with the voltage drop in the valves ~

motor circuit conductors.

Results of Evaluation Section 5.4.6.1 of our FSAR currently states that the RCIC system f can be utilized to mitigate the consequences of a Control Rod Drop Accident (CRDA). However, in the event that RCIC system  ?

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.J %"qg;y operation becomes impaired due to the loss of a battery charger,.

{ ne' the High Pressure Core Spray system would be available to 3 . . . respond. Additionally, the Automatic Depressurization System pr.: initiates upon Low Low' Reactor Water level, enabling the Low

- Pressure Core Spray and Low Pressure Core Injection to provide core cooling and reactor inventory make-up.

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s Discussions with our Nuclear Steam Supply System supplier, t General Electric (GE), indicate that they are in agreement with

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t-our determination that RCIC is not required to function to mitigate the consequences of a CRDA. Documentation from GE is forthcoming and we will notify you should our position change.

The documentation will be evaluated to determine if any changes to our FSAR are required.

In light of the above, the identified condition would not have had a significant impact on the safe operation of the Perry Nuclear Power Plant.

Please call if there are any questions.

Sincerely, Murray R. Ede n Vice President Nuclear Group .

MRE:sab cc: Mr. J. A. Grobe USNRC, Site Office Mr. D. E. Keating USNRC, Site Office Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C. 20555 Records Center, SEE-IN Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 .

Atlanta, Georgia 30339 e

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