PY-CEI-NRR-2138, Provides Comments on Draft NUREG-1560, Individual Plant Exam Program:Perspectives on Reactor Safety & Plant Performance,Summary Rept

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Provides Comments on Draft NUREG-1560, Individual Plant Exam Program:Perspectives on Reactor Safety & Plant Performance,Summary Rept
ML20137A459
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 02/25/1997
From: Mary Drouin
CENTERIOR ENERGY
To:
NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20137A409 List:
References
RTR-NUREG-1560 PY-CEI-NRR-2138, NUDOCS 9703200335
Download: ML20137A459 (6)
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Text

y& l P6wer Generation Group l

Perry Nudeer Power Plant Med Address. 216-260 4915 LewW.Myers 10 Center Road P.0L Som 97 Perry. ONo 44061 FAX:216-28CNt029 Vce President Perry, OH 44081 I

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Pebruary 25,1997 PY-CEUNRR 2138L Brandi Chief, Rules Review and Directive Branch Office of Mminimation MS: T6-D59 United States Nuclear Regulatory Cbmmission Washington, D.C. 20555-0001 Perry NuclearPowerPlant i

Voluntary Comments on Draft NUREG-1560, "Indivutual Plant Examination Pmgram:

l Perspectives on Reactor Safety and Plant Performance, Summary Report" l

Ladies andGentlemen:

In a letter dated December 13,1996, the Nuclear Regulatory Canmiulon (NRC) indicated that a draft of NUREG-1560," Individual Plant Examination Pmgram: Perspectives on Reactor Safety and Plant Performance, Summary Repont," had been published. 'Ihat letter regW licensee comments to be submitted by February 14,1997; however, no response was required. In a ,

Federal Register notification on January 29,1997 (62 PR 4365), the NRC extended the Mim l

for comments to March 14,1997. The Attachment to this inter prWvides voluntary comments on i Draft NUREG-1560 for the Perry Nuclear Power Plant. '

1 If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory Affairs, at (216) 280-5606.  !

1 Very tmly yours, MQ%

KMN:sc cc: Ms. Mary Drouin i

9703200335 970306 PDR ADOCK 05000395 p PDR l

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Annemanne ,

PYGI/NitR-2138L Page 1 of 5 -

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l o Comments on Draft NUREG-1560 l

" Individual Plant Rumminatinn Program: Perspecthes on Reador Sahey and Plant Pwfbremar="

i Part Chapter Page S*h40 _

Comuneet 1 Fwrmelve xix first NUREG-1560 states, "Many of the analyses relied heavDy on either the use of the

%nmary pangraph MAAP code or the use of a set of industry position papers, reirlwr of whidt have a comprehensive tremenwar of severe accident phenomena." " Ibis armarnment is mielearsng hacanae MAAP was developed for severe accident phennnwns and relied heavily m  !

empiricaldataimm- - :- 2 A more accurale armarment is that MAAP has not undergone a rigorous review by the NRC.

1 2 2-14 third fun In the third fuH paragraph, the reference to " laser" BWRs is missearHng hersnar it  !

paragraph implies that" laser" BWRs have an AC-li4G HPCI sysema. I j1 1 3 3-29 buDet forRCIC In mos(irmranrwm diffbrences in the modeling of RCIC trips and loss of RCIC due to [

q syseem falhue suppressim pool tempenene are based on gnocedores. At Perry, the operators are i

, modes instructed to trip RCIC when the suppression pool tesaperature reaches 185'F. "Ihe a variabihty in the PRAs comes less from analyst practims than fern plant pawi .

and design.

1 3 3-31 buBet for NUREG-1560 ernare, "Some licensees appear to presimimicany not credit the use of l Aleemste the OD system, while others have plant design features (e.g., lanistian signals) that Ooolant affect its use." Even without isolation signals, etc., twename of the low injection rate [

Injection and the fact that there are otherinjection systems that provide more watermore i Sysemn quicidy to the reactor pressere vessel (RPV), it is liloely that those not crediting CRD [

. did not include it berme doing so did not provide any rerthreion in CDF. i i

1 3 3-32 second paragraph NUREG-1560 aranen " Perry is ennairlering a passive ennraimnent vent that the IPE from bottom sutsnittal indicated win redom the plant CDF by 15E" Perry considered such a vent and rejected implementation subsequent to sahenitent ofIPE.

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l PY-CEl#GtR-2138L Page 20f 5 -

Comments on Draft NUREG-1560 i

" Individual Plant Exandmarian Program: Perspectives on Rendor Safhty and Plant Perfbr=manw" Part Chapter Page S<':-I , C Conunent l  !

l 1 3 3-33 second NUREG-1560 suses,"'the highest A'IWS CDF was emirnianad ihr the Peny IPE t paragraph submittal, which did not credit the use of HPCS for coolant injection and also ampunnd i that the operator will always be unable to maintain PCS availability during an ATWS." NUREO-1560 seems to imply that the IPE is driven as much by the analyst biases as by the plant design. Perry did not credit the use of automatic HPCS as a t

successful injection path haran=P the Plant hry inatmaions (PEls) require the i operators to terminate HPCS injection if HPCS initima lhe PEls are based on the Ley Procedure Onidrainen (EPGs). Also,the Peny design incInden a feedwater ,

runbedt to zero flow upon m ATWS signal ' Ibis feedwater runbad is unique among

the BWRM plants. "Ihe operators cannot override the signal and must wait until the valves are fhlly closed to restore feedwater via the motor feed pump.

f, I 3 3-33 third NUREG-1560 ersara. "Two licensees identifled hopewmenen aimed at prhering the f paragraph potential forcore damage daring m ATWS event. 'Ibe most significantis the t irmraltation of an automatic ADS inhibit during an A'IWS, whkh is being evaluated at  ;

Perry. A sensitivity study reporbi in the IPE anhmittal Indiced that this feature can reduce the plant CDP by 23%." When balancing the reduction in CDF against the

{ cost and increased complexity of ADS, Peny decided against kuplemeneurinn in 1 addition, changes to the plant and operating pgw . since eher.ittal of the IPE have reduced the contribution of ATWS to the overall CDF and implementation would l only have a marginalimpact on CDF. I I 5 5-3 ATWS Instead of trying to describe separate human actions during A'IWS and loolting for discussion dorninant actions, the discussion should center around the fact that automatic i functions are larEcly bypsased and operator arrinna globaRy hannme important in j responding to an ATWS event. At Perry, it was decennined that many of the human  !

actions have dependencies upon each other and looking at single funnart actions may [

not be appropriate for A'IWS. i I

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Comments on Draft NUREG-1560

" Individual Plant Rwandameinn Program: N _,._^;ies on Reactor Safkty and Plant Perfbrinunce" Part Chapter Page Section/ Paragraph Comunemt 1 5 5-6 TaNe 5.2 For Perry, cladficadon should be mMed to the maernwnt "ad not take aedit for HPCS." At Perry, the procedures instruct operators to terminsee HPCS injection during an ATWS.

L 2 9 9-24 Secdon 9.3.13 NUREG-1560 states,"Ihe Perry I submittal indirsars a cross-tie capaNiity for the j , batteries has been L.? -- r-L " "Ihe descdption ofimpiennenting a cross-tie capability for batteries needs further clarification. 'Ihe cross-tic capability existed 4

prior to the IPE/PRA. 'Ihe IPE/PRA simply included the capabihty as it existed in the plantdesign and94 at the time the model was a..M  !

2 9 9-25 second NUREG-1560 cEscusses a containment vent systen whida was being evaluated at j paragraph Peny. 'Ihis containment vent system was a passive system. Perry already has a  ;

1 mechanism for vendog the containment via the fuel pool cooling and cleanup system orthe containment spray headers.

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3 2 9 9-25 third NUREG-1560 states,"Ihe licensee for Perry 1 esimnaps a rewerrinen of I paragraph approximmanly IE-5/ry for ATWS changes ifimplemented." "Ihis shoukt read," 10 approximately 1E-5/ry for "

3 11 11-40 Section 11.23.2 - Ihe discus %n of cross-ticing the HPCS diesel generator to earher the Division 1 or 2 emergency buses is misleading. For Grand Oulf, the HPCS bus can be cross-tied to  ;

I either the Division 1 bus or the Division 2 bus, and some pump loads can be =>nnHed For Perry, the HPCS bus can only be cross-tied by design only to the Division 2 bus. i

'Ihere are no pr4-. for operating Division 1 pumps via this cross-tie at Peny. i "Ihe cross-tie was installed to provide power to the inboani mnrainment isolation i valves to asnue containment isolation. 'Ihis is anotherirnranm where plant design and not analyst biases drive the modehng differences in the IPEs. l a  !

h, inneem PY-CEI/NRR-2138L l Page4 cf 5 -  ;

Comunents on Draft NUREG-1560 "Indvidual Plant Examination Program: N Wives on Rear *ir Safety and Plant Peribrmance" i Part Chapter Page Secdon/ Paragraph Conment

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i 3 11 11 42 Section 11.2.33 Peny did not credit HPCS as a sucassful injection system for ATWS because the r plant emergency instructions at the time t'allert for the operators to terminare HPCS 7

., injection if HPCS initiated. Also, the feedwater runbeck at Perry is unique among the 1 other BWRM plants. The Perry design runs back feedwater to zero flow into the j i RPV. 'Ihe operators cannot override the signal and must wait until the valves are fully closed to restore feedwater. "Ihere is less Gy.=Gy on analyst biases than there is  !

. on actual plant design diffestnces to the assumptions used to construct the PRA i i 3 11 11-44 first Perry did not credit HPCS as a unenerful injection system for A*1WS Iwanee the j paragraph plant emergency instructions at the time caBed for the operators to terminate HPCS l injection if HPCS initissed. Also, the feedwater runback at Perry is unique among the other BWRM plants. 'Ihe Perry design runs back feedwater to zero flow into the RPV. The opentors cannot override the signal and must wait untR the valves are fuHy  !

closed to restore feedwater. 'Ihere is less ' "---:j en analyst biases than there is I on ar* int plant design differences to the assumptions used to construct the PRA l models.  !

3 11 l'l-45 secondparagraph It is mielentsnr to simply say that Perry creets the use of fhewater, nnnrieneste f' from boteam transfer, and suppression pool cooling for ahemate injection. Perry only credits a single attemate injection source for any given earpience For most sequences, this is condensate transfer twane ofits case of alignment and quantity of water supplied.

Forloss of offsite power sequences,1m, a, condensate transfer is not available and i the availability of the fire protection system is modeled. This system can be marmally  :

aligned in approximately 20 to 30 minutes and can provide up to 2000 gpm into the i RPV.

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l Comnwets on Draft NUREG-1560 .

'indvidual Plant RumanimmHnn Pmgrant: N Aves on Reador Safety and Plant ParkW. l t i Part Chapter Page Section/ Paragraph W l 3 13 13-15 Table 13.2 For Ptrry, aligning the feed booster punip or suppenninn pool % for ahemate i Wi is listed as being associated with axident sequences (LOOP and loss of IA). l

'Ihese sy*me are lost foHowing a LOOP. 'Ihey are forloss ofinstrument air.

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