ML20205E666

Comments on Proposed Amend to License NPF-58.Amend Re Planned Conversion of Inboard Containment Isolation Valve 1E51F063 from Normally Closed W/Dc Motor Operator to Normally Open W/Ac Motor Operator Opposed

ML20205E666
Person / Time
Site:	Perry
Issue date:	03/21/1987
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	NRC
References
FRN-52FR7346 NUDOCS 8703300657
Download: ML20205E666 (1)

Text

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N. 0 h?Airn Norch 21, 1987 DOCKETED USNRC RULES & PROCEDURES BR DRR:ADM COMMENTS OF OHIO CITIZENS FOR RESPONSIBLE ENERGY, INC. (*0CRE*)

ON PROPOSED OPERATING LICENSE AMENDMENT, CLEVELANJ EL EcTPJ C ILLUMINATING CO. (PERRY NUCLEAR POWER PL ANT 87 UNR 26) A9 MET 50-440, LICENSE NPF-58, 52 FED REG 7346 (MARCH 10, 1987). g g g This omendment request concerns a pionned conversion of //vfc/> /p //g7 inboord containment isolation volve 1E51F063 (RCIC) from normally closed, with DC motor operator to normally open with AC /

motor operator. OCRE believes thss amendment is not in the -

public interest in that it will increase the vulnerability of PNPP to core domoge and offsite consequences in the event or o station blockout.

According to draft NUREG-1150, "Reoctor Risk Reference Documenta, for Grand Gulf, o BWR/6-Mark III like Perry, station blockout contributes 99% of the core domoge frequency. (Figure E5-0, p. ES-7) Clearly, no omenoment should be granted which would increose this risk. Yet, the proposed omendment would do just that by making on isolotion volve, closure of which disables RCIC, the only non-electricolly driven core makeup system ovoilable in o station blockout, dependent on AC power.

Should the proposed omendment be granted, and the following scenario occur, core domoge would result unless AC power is restored within a short time. The scenario involves loss of offsite power, followed by closure of 1E51F063 due to operator action or on isolotion signal (real or spurious), and subsequent loss of onsite AC power. Since F063 stoys a os-is> on loss of Power (F5AR Toble 6.0-30), it will remain closed, disabing RCIC, until AC power is restored.

It is not clear that CEI has explored other options for increasing the reliability of F063. Nor is it obvious that CEI hos even ottempted to determine the root cause of the poor performance of the volve. If power source of the volve operotor were the cause, one would expect similor deficient performonce in all similar volves with DC motor operators, which does not appear to have been the cose. OCRE maintoins that a root cause analysis should be performed for the volve problems and indicated corrective action taxen. RCIC must not be mode dependent on AC power.

OCRE concludes that this omendment should be rejected os ininical to the public health and safety.

Respectfully submitted,

.k Susan L. Hiort OCRE Representative 8275 Hunson Road Mentor, OH 44060 (216) 055-3158 G703300657 DR 870321 ADOCK 05000440 PDR