Text

Forwards Evaluation of Containment Airborne Contamination Levels & Benefit of Purge Operations,Per 850326 Commitment & Recommends Rev of Tech Spec as Shown on Attached Page 3/4 6-12
	ML20245K646
Person / Time
Site:	Perry
Issue date:	06/30/1989
From:	Kaplan A; CLEVELAND ELECTRIC ILLUMINATING CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	PY-CEI-NRR-1025, NUDOCS 8907050207
	Download: ML20245K646 (26)
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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.J. BOX 97 a PERRY, OHIO 44081 5 TELEPHONE (216) 259 3737 5 ADDRESS 10 CENTER ROAD FROM CLEVELAND: 241 1650 Serving The Best location in the Nation l Al Kaplan PERRY NUCLEAR POWER PLANT VCE PAES1 DENT NUCMAR GHOUP June 30, 1989 PY-CEI/NRR-1025 L U.S. Nuclear Regulatory Commission l Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Submittal of Containment Purge Evaluation (USAR Appendix 1B Commitment 5),

and Technical Specification Change Request Centlemen:

The subject USAR Appendix 1B commitment requires the conduct of data gathering and containment access management programs to maintain personnel exposure as low as. reasonably achievable (ALARA) while limiting operation of the containment purge system. Our letter PY-CEI/NRR-0157L, dated February 19, 1985 described these programs in greater detail. By letter PY-CEI/NRR-0210L dated March 26, 1985 the Cleveland Electric Company (CEI) again committed to submitting a report based on first cycle operating results which would (1) evaluate containment airborne contamination levels and the benefit of purge operations with respect to personnel exposure, and (2) recommend future purge system operating guidelines for the remainder of plant life.

The. attached report (Attachment 1) is provided to fulfill this commitment. CEI recommends that the Perry Technical Specifications be revised as shown on the attached page 3/4 6-12. The 3000 hr/365 day limit on purge system operation should be reduced to 2000 hr/365 days for the second cycle, rather than reducing it to 1000 hr/365 days, for two reasons. First, operating the purge system for greater than 1000 hr/365 days helped keep personnel exposure below comparable industry results for the first cycle. Second, first cycle data is not sufficiently representative to make a judgment for the balance of plant life.

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Until Perry can determine the effectiveness of plant repairs and modifications intended to reduce existing sources of contamination, and until we can determine the effects of potential future fuel and reactor coolant leakage, it is recommended that the second cycle operating limit be 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months , and that second cycle results be re-evaluated similar to this report to allow for determination of operating limits for the balance of plant life.

To operate with a 2000 hr/365 day limit on purge system operation for the second cycle, a determination of no significant hazards /no environmental impact can be made on the same basis as the first cycle Technical Specifications, which showed that there was no significant effect on public hecith and safety as a result of these operations. Attachment 2 provides the necessary evaluations to justify this change to Technical Specification 3.6.1.8 (also attached).

Unless CEI receives the requested Technical Specification change, the present 3000 hr limitation will terminate 3 months after second cycle startup, and a 1000 hr limitation will be imposed at that time (i.e. a new 1000 hr clock will be reset at that time to zero) in accordance with existing Technical Specification 3.6.1.8. To the extent possible while maintaining personnel exposure ALARA, purge system operation will continue to be minimized.

Please call if you have any questions.

Very tru . urs, Ge Al Kaplan Vice President Nuclear Group AK/njc Attachment ec: T. Colburn NRC Resident Office U.S. NRC Region III J. Harris (State of Ohio)

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ATTACHMENT 1 ,

I PY-CEI/NRR-1025 L PAGE 1 0F 6 Perry Nuclear Power Plant Containment Purge Operation and Containment Access - Cycle 1 l

1.0 Introduction The Cleveland Electric Illuminating Company (CEI) is required to administer three programs to assess the need for the operation of containment purge in Operational Modes 1, 2, and 3, and to minimize its use consistent with ALARA guidelines. These programs, as identified by the Perry Nuclear Power Plant (PNPP) Updated Safety Analysis Report, Appendix 1B Commitment 5, are the Containment Purge Operation Data Gathering Program, the Containment Access Management Program, and the Interim Guidelines for Containment Purge Operation as identified below.

1. Containment Purge Operation Data Gathering Program - collect data required.to demonstrate containment purge effectiveness in limiting personnel exposure, and amount of purging required, as well as other necessary functions such as containment pressure control. Correlate !

results to plant conditions and events.

2. Containment Access Management Program - minimize containment access by procedural controls and coordinated work scheduling. Collect access data and evaluate to maintain collective exposure ALARA.

3. Interim Guidelines for Containment Purge Operation - maintain i accessed areas of containment at or below 0.25 MPC using the purge system as necessary, consistent with an operating time limit in Operational Conditions 1, 2, and 3 of 3000 hours0.0347 days 0.833 hours 0.00496 weeks 0.00114 months in any consecutive 365 day period.

Unless the requested Technical Specification change is accepted by the NRC, purge operation vill be limited to 1000 hrs per year, starting 3 months into the second fuel cycle and thereafter. This report concludes that a 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months limit is more beneficial to continuing the record of low personnel exposure at Perry, with no significant effect on public health and safety. The Significant Hazard Evaluation supporting this conclusion is separately attached (Attachment 2).

2.0 Background

Perry Nuclear Power Plant utilizes a Mark III Containment, which differs in design from the previous BVR containments in that a large portion of the i reactor support systems are located inside an isolable primary containment.

This design enhances public safety from a controlled release standpoint, but requires frequent access to the containment with the reactor at power to permit the performance of Technical Specification required surveillance for operability of safety systems, maintenance, and other activities necessary for plant operation. Purging of the containment is required to maintain containment airborne radioactivity levels as lov as reasonably achievable (ALARA). Purging is also required to provide containment {

pressure control, and to support routine plant evolutions (i.e., Reactor '

i Vater Cleanup System backwash, plant inspection rounds etc.) during Operational Conditions 1, 2, and 3.

ATTACHMENT 1 PY-CEI/NRR-1025 L PAGE 2 0F 6 The containment purge system is shown in the Perry USAR Figure 9.4-17.

Operating one of two supply fans with one of two exhaust fans purges the containment vessel with 5000 CFM of fresh air. Air exhausted from the containment is monitored for radiation level, directed through one of two high efficiency particulate and charcoal filter plenums, and then released to atmosphere via the Unit 1 Vent, where it is once again monitored for radiation level. The purge path through the containment boundary is via two 18" butterfly valves in series and a 42" downstream l butterfly valve, which is limited to an opening angle of 50 degrees to !

provide assurance of isolation reliability even under LOCA conditions.

Purge system inboard and outbeard isolation valves are stroke time and leak tested in accordance with Technical Specifications. These valves ;

are also retested after maintenance. Test results to date have demonstrated isolation valve operability.

3.0 Operating Experience During its first operating cycle the Perry plant experienced three primary causes of airborne contamination, which placed demands on the purge system to maintain air in accessed areas below the targeted 0.25 MPC level. These sources of contamination included:

1. Fuel leaks. In March, 1988 coolant activity indicated that fuel rod !

leakage had occurred, which increased toward end of cycle l (Figure 1). These leaking assemblies were replaced during I refueling. Although significantly less than the iodine concentration level assumed in the calculation of purge system operating time reported in PY-CEI/NRR-0157L, this created a significant source of airborne contamination in combination with SRV and equipment leaks.

2. SRV leaks. This factor was also anticipated in the calculation of operating time (at a rate comparable to that experienced during the first cycle) to justify the original 3000 hours0.0347 days 0.833 hours 0.00496 weeks 0.00114 months of first cycle purge operation. All SRV's were replaced during the refueling outage to further reduce this contributor to airborne contamination.

3. Other component leaks. Following the occurrence of fuel leakage, reactor water cleanup (RVCU) operations have caused high airborne activity. Evaluations are continuing to determine and characterize associated airborne releases to investigate potential design changes to reduce this contributor. Other relatively small component leaks also contribute to containment airborne contamination. RUCU heat exchanger and valve leaks were repaired during the refuel outage.

Although immediate improvement is expected entering the second cycle, several of these contamination sources may be experienced again in the future.

ATTACHMENT 1

PY-CEI/NRR-1025 L PAGE 3 0F 6 3.1 Airborne Activity and Purge Operation Vith the iuel leak initiating last March (Figure 1), airborne activity started to increase primarily due to SRV leakage into the suppression pool, with the following three months showing the highest occurrence of airborne contamination levels >0.25 MPC. Figures 2a-2m show month-by-month comparisons of reactor power, containment air sample % MPC and purge operating hours in Operational conditions 1, 2 and 3 for the most recent 12 month period of full power operations (2/23/88 - 2/23/89).

Areas of high airborne activity (>0.25 MPC) peaked in May 1988. During the balance of the year, high airborne areas vere limited to less than 20% of the May peak. Airborne activity was higher early in this period due to the purge system not being synchronized with high airborne occurrence (April), or contamination exceeding 50% of MPC (May and June),

which is the approximate limit which can be effectively purged when same day entry is required.

Some areas of the containment will persist with airborne activity above MPC regardless of purge operation, due to the plant design. Entry into these areas vill require evaluation for protective apparatus to be used.

Operating results indicate Perry used about 1700 hr of the 3000 hr limit, in the most recent 12 month period of full power operations. Figure 3 shows that purge operation was utilized primarily to maintain radioactive airborne contaminants f 0.25 MPC. Purging was also used to support plant operations and for pressure reduction in containment.

Although planned maintenance is expected to reduce airborne contamination sources in the near term, several sources of contamination could be experienced again in the future, leaving the plant in definite need of purging but unable to accurately predict the future demand for operating hours needed.

3.2 Containment Access i'

The Perry containment is entered for such activities as operation of equipment, maintenance, plant inspection rounds, surveillance for system operability, and plant modifications. Health Physics surveys are also conducted in conjunction with much of this activity to determine / minimize radiation exposure of other personnel. The Radiation Protection Section controls exposure by the Radiation Vork Permit Procedure. The Unit !

Supervisor also approves containment entries to assure their necessity. [

1 ATTACHMEi4T 1 PY-CEI/NRR-1025 L j PAGE 4 OP 6 Non-outage containment entries and durations by function are tabulated below:

Perry Containment Entry, 2/23/88 - 2/23/89 No. Entries Total Manhours % of Manhours Maintenance 7111 5800 53%

(incl. Construction,

.I&C) i Radiation Protection 2212 1119 10%

(Health Physics and Chemistry)

Operations 1922 1064 10%

Administrative:

Security, Planning, Management, NRC Inspectors 3493 2218 20%

Plant Technical 731 398 4%

Engineering 151 170 1.5%

Quality 202 165 1.5%

Totals 15,822 10,934 100%

3.3 Personnel Exposure The important parameter to control is collective unit exposure, rather than manhours spent in containment. Because of the nature of their job, Radiation Protection Section (RPS) personnel have accumulated 31% of the collective exposure tabulated. However, the work performed by RPS personnel substantially limited collective site exposure from a projected 147 man-rem to 94 man-rem. (Projected exposures were derived from BVR industry first cycle experience.)

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i ATTACHMENT 1 PY-CEI/NRR-1025 L PAGE 5 0F 6 The breakdown by organizational element follows for the most recent 12 month period of full power operations. !

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% Collective % Change Organization Man-Rem Exposure Projected from Projected Rad. Protection 31 33% 29 +7%

Constr. Services 20 21% 31 -35%

Maintenance 19 20% 32 -41%

Operations 11 12% 18 -39%

Instr. and Control 5 5% 16 -69%

Other 8 9% 21 -62%

Collective Exposure 94 100% 147 -36%

Construction Services was in containment for plant modifications, which are carefully limited by controls discussed in Section 3.2 and procedures which require a standing ALARA committee to review design changes before installation.

Maintenance personnel exposure was held to 59% of the projected value by I consolidation of tasks with respect to component / system and logical !

sequence. An Operations Quarterly Schedule has been developed to focus project resources and ensure the efficient accomplishment of plant preventive and corrective maintenance, which also minimizes personnel exposure. The result of quarterly scheduling is a 13-veek list of equipment, allowing a vindow of opportunity for working each piece of equipment in the plant once during the quarter. As much vork as possible is done on each system by combining vork orders and repetitive tasks, and by concentrating on different systems in different quarters.

Along with Radiation Protection coverage of work performed in containment, careful scheduling to avoid duplication of effort has effectively limited the most controllable exposures. For example, the, net reduction from projected exposure for all personnel except Radiation Protection and Operations was 48%, or 48 man-rem.

Further initiatives to reduce time in containment, implemented or planned, include use of wireless communications systems and high resolution video to speed up jobs and to reduce the need for personnel entry into high radiation areas for supervision and inspection. In addition, the surrogate travel system is being upgraded to provide zoom and panning capabilities so that users can see details needed for work planning and design modifications. This computer controlled video disc system allovs the user to travel through, and view, selected high radiation areas of the plant. {

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ATTACHMENT 1 PY-CEI/NRR-1025 L PAGE 6 0F 6 4.0 Conclusions The Perry plant established a 70% capacity factor during its first calendar year of commercial operation, with particularly good operating-results for the last eight months of its first fuel cycle. The Perry organization similarly climbed a steep learning curve in surveillance testing, maintenance, and other activities requiring containment access.

Combined with measures planned and taken to eliminate / reduce the causes of airborne activity, personnel exposures should continue to be ALARA.

Radiation exposure to Perry personnel is under good control. Collective unit exposure for the 365 day period preceding the start of the first refuel outage was 64% of comparable BVR industry experience. Control of access to containment and work planning have proven most beneficial. But an important complement to our ALARA program has been containment purge operations coincident with the occurrence of airborne activity above 0.25 MPC. Although a small factor in whole body exposure, purging maintains our ALARA discipline and allows more efficient performance of containment tasks without protective clothing. And over plant life, !

reducing airborne contamination from 1.0 to 0.25 MPC or below has a more significant impact on personnel exposure. Using the first cycle ;

experience of 11,000 man hours /yr in containment over a 40 year plant life, the resultant savings in whole body dose is approximately 1100 man-rem.

Due to the design characteristics of the Mark III Containment, frequent personnel access vill be required to support plant evolutions and to perform the required maintenance and surveillance necessary for operation. This required access vill continue to necessitate purge operations to ma'.7tain personnel exposure ALARA.

Until Perry can determine the effectiveness of plant repairs and modifications intended to reduce existing sources of contamination, and until we can determine the (potential) effects of higher fuel and reactor coolant leakage, it is recommended that a limit of 2000 hrs of operation per 365 days be imposed, until second cycle results allow re-evaluation of operating limits for the balance of plant life. The second cycle evaluation vould be similar to this report. With this baseline for sources of airborne contamination and purging hours utilized to control personnel exposure, a second cycle evaluation would provide for a more realistic determination of how much containment purging is !

required with a seasoned operating staff. l NJC/ CODED /2192 f

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ATTACHMENT 2 PY-CEI/NRR-1025 L l PAGE 1 0F 2 Significant Hazards Evaluation for. Perry Containment Purge Operation at 2000 hrs per 365 Day Period Summary The proposed Perry Nuclear Power Plant Technical Specification change reduces the existing limitation on Containment Purge System (M14) operation (3000 hr/365 day period) to 2000 hr/365 day period for the second fuel cycle of plant operation. Without this change, M14 operation vould be limited to 1000 hr/365 days starting 3 months after startup from the.first refueling outage. Since the limitation proposed is more restrictive than that specified for the first fuel cycle, there is no increase in accident probabilities or consequences as compared to evaluations performed for the first cycle, and frum a probabilistic viewpoint, may even result in a reduction in postulated accident consequences due to the reduced number of hours the system is allowed to be in operation.

System description and purpose are provided in Attachment 1 to this letter.

-This change vill result in reduction of radiation exposure to plant personnel by (1)' minimizing direct exposure and (2) minimizing the use of protective clothing, which allows for more efficient performance of duties and less working time in containment without adverse impact on the public.

Safety Analysis A safety evaluation in Perry USAR 6.2.4.2.3, " Consideration of NRC Branch Technical Position CSB 6-4", demonstrates that the radiological consequences of a loss-of-coolant accident are a small fraction of 10 CFR 100 guideline values. Using Branch Technical Position CSB 6-4 assumptions, these offsite dose consequences are 0.9 rem thyroid and 0.162 rem whole body at the site boundary. These doses are 0.3% of the 10 CFR 100 guideline thyroid dose, and 0.6% of the whole body dose.

It is again emphasized that initially licensed safety analysis assumptions, methods and results remain unchanged from original submittals reviewed and found acceptable in Supplements 4 and 7 (Section 6.2.4) of the Perry Safety Evaluation Report, NUREG 0887.

Significant Hazards Analysis The standards used to arrive at a determination that a request for amendment requires no significant hazards consideration are included in the Commission's Regulations, 10 CFR 50.92, which state 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, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. CEI has reviewed the proposed change with respect to these three factors.

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ATTACHMENT 2-PY-CEI/NRR-1025 L PAGE.2 0F 2 The proposed change does not involve an increase in the probability or consequences of any previously evaluated accident. The safety analysis and evaluations performed originally for the 3000 hr/365 day operating limit showed a negligible impact on the results of analyzed accidents as described above in the Safety Analysis discussion. The only relevant safety concern with respect to operation of the containment purge system is the ability to isolate the system after an accident, the probability and consequences of which are unchanged by the proposed amendment from that previously reviewed and accepted.by the NRC. Since the M14 flov path contains three qualified isolation butterfly valves, the probability of the system not being isolated is already extremely small, however the proposed reduction in the number of hours that the system is in operation as compared to the first cycle does result in a slight safety improvement with respect to accident consequences since it further reduces the probability of the system not being isolated post-accident.

The' proposed change does not create the possibility of a new or different kind of accident. The containment purge system design and the method of system operation are unchanged by this amendment. In addition, the operation (or non-operation) of the containment purge system cannot by itself cause challenges to plant systems that would result in an unanalyzed plant transient.

The proposed change does not involve a reduction in the margin of safety. The time limit on purging is reduced as compared to the first cycle, and operating e>perience with the system demonstrated isolation reliability. Technical Specification operability requirements are unchanged. The design of the isolation valves also remains unchanged, therefore their qualification to perform their isolation function under accident conditions is unaffected.

Therefore, CEI has concluded that this proposed amendment involves no significant hazards considerations.

Environmental Impact Cleveland Electric Illuminating has reviewed the proposed Technical Specification change against.the criteria of 10 CFR 51.22 for environmental considerations. As shown above, the proposed change does not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specification change meets the criteria )

given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

NJC/ CODED /2190

4 CONTAINMENT SYSTEMS I DRYWELL AND CONTAINMENT PURGE SYSTEM LIMITING CONDITION FOR OPERATION 3.6.1.8 The drywell and containment purge 42-inch outboard (1M14-F040, F090) supply and exhaust isolation valves and the 18-inch supply and exhaust isolation valves (1M14-F190, F195, F200, F205) shall be OPERABLE and:

a. Each 42-inch inboard purge valve (1M14-F045, F085) shall be sealed closed.

b. Each 42-inch outboard purge valve (1M14-F040, F090) may be open limited to an opening angle of 50 or less for purge system operation

with such operation limited to-900& ourc** 365 days for reducing l airborne activity and pressure control. 2CCO

c. Each 24-inch (1M14-F055A, B and F060A, B) and 36-inch (1M14-F065, F070) drywell purge valve shall be sealed closed.

d. Each 2-inch (1M51-F090 and F110) backup hydrogen purge system iso-lation valves may be open for controlling drywell pressure.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.

ACTION:

a. With a 42-inch inboard drywell and containment purge supply and/or exhaust isolation valve (s) open or not sealed closed, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months close and/or seal the 42-inch valve (s) or otherwise isolate the penetration or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With a 18-inch or 42-inch outboard drywell and containment purge supply and/or exhaust isolation valves inoperable or open for more gg than -390& hours per 365 days for purge system operation *, within four hours close the open 18- or 42-inch valve (s) or otherwise isolate the penetration (s) or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. With a 24- or 36-inch drywell purge supply and/or exhaust isolation valve (s) open or not sealed closed, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months close and/or seal close the 24- or 36-inch valve (s) or otherwise isolate the penetra-tion, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and -

in COLD SHUTDOWN within,the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

d. With a drywell and containment purge supply and/or exhaust isolation valve (s) with resilient material seals having a measured leakage rate exceeding the limit of Surveillance Requirement 4.6.1.8.3 and/or

Purge system operation shall be defined as any time that both 18-inch and the 42-inch outboard purge valves are open concurrently in either the supply or exhaust line.

- Applicable-fr : ir;itial fuel lead-until 3 months following the completion of

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.5ecoricl"efueling outage; otherwise, a 1000-hour per-365-day limit applies. l PERRY - UNIT 1 -

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Figure 1. Perry Fuel Reliability The level of dose equivalent Iodine-131 activity measured in the primary reactor coolant at steady state power.

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PY-CEI-NRR-1025, Forwards Evaluation of Containment Airborne Contamination Levels & Benefit of Purge Operations,Per 850326 Commitment & Recommends Rev of Tech Spec as Shown on Attached Page 3/4 6-12

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