ML20148U355

Responds to to Chairman Jackson Requesting That NRC Act Immediately to Shut Down Plant Until No Increased Danger to Public Health & Safety from Increased Valve Leakage Assumed post-accident from Eccw Sys

ML20148U355
Person / Time
Site:	Perry
Issue date:	07/03/1997
From:	Roe J NRC (Affiliation Not Assigned)
To:	Gannis S AFFILIATION NOT ASSIGNED
Shared Package
ML20148U358	List: ML20148U355
References
NUDOCS 9707100163
Download: ML20148U355 (5)

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1- UNITED STATES Q

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• ] ' NUCLEAR REEULATORY COMMISSION WASHINGTON, D.C. 30006 40M e \***** July 3,1997 j

l i

Mr. Steve Gannis j' ' Coordinator, Ohio Citizens Against A Radioactive Environment

13511 Detroit Avenue, Apt. C-9

Cleveland, Ohio 44107

Dear Mr. Gannis:

I~

l am responding to your letter of April 28,1997, to Chairman Jackson, in which you i requested that the U.S. Nuclear Regulatory Commission (NRC) act immediately to shut down

. the Perry Nuclear Power Plant (PNPP), Unit 1, until it determines that there is no increased

danger to public health and safety from the increased valve leakage assumed post-accident

} from the emergency closed cooling water (ECCW) system.

i

This issue involves a recent NRC inspection team finding (June 10,1997, report enclosed)

concoming a change made by the PNPP licensee to the licensing basis for the surge tanks in j the ECCW system. The change involved the amount of time post-accident that would pass 4

before the surge tanks needed refilling. As a result of a new assumption about ECCW leakage post-accident, the licensee calculated that the surge tanks could need refilling

approximately 50 minutes following the design-basis accident versus the original licensing

- basis of 7 days following the accident. The licensee then proceduralized operator actions to i initiate makeup to the ECCW system within 30 minutes to compensate for this revised l leakage assumption. The assumption change regarding ECCW leakage post-accident was j . due to the licensee's finding that intersystem leakage past isolation valves had not been i considered in the original design.

j Existing system leakage test results showed that the licensee would have had approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> post-accident before action would have been needed. Additionally, those test

results were considered conservatively high by the licensee because the tests were l performed in the opposite direction relative to the system valve design utilized to protect ~

- against post-accident leakage, so it was likely that there was more time available than 2.5 ' i j hours. The ECCW system provides cooling water to safety-related components only during l hot standby, shutdown, and accident conditions. When needed, it provides cooling to room I coolers and the residual heat removal pump seals.

4 The NRC staff performed a preliminary review of the licensee's coupensatory measures, and

. determined that there was reasonable ar,surance that the plant could safely operate before j final resolution of this issue for the following reasons: (1) a loss-of-coolant accident coincident

!  : with a loss of offsite power and an emergency diesel generator failure is a low probability - ,

t event; (2) the staff has accepted in other cases operator action following a design basis .!

accident within the same timeframe (i.e., approximately 30 min.) necessary in this instance;

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] (3) the licensee had procedures in place for the necessary actions to ensure refilling of the S

surge tanks; and (4) the plant areas were accessible and the licensee planned to maintain ,

y any individual doses within allowable limits. During telephone discussions with you on May 9 i

and 15,1997, a member of my staff informed you that the NRC found operation of the Perry {

i plant acceptable while resolution of the issue was pursued.' in the discussion of May 9,1997, l 3 it was also agreed that a letter response was acceptable rather than treating your letter as a l 10 CFR 2.206 petition.

l 3

l When the plant shut down on June 5,1997, it was placed in a condition to perform more l accurate system leakage tests (i.e., in the normal flow direction). The licensee performed the i more accurate tests, which resolved the ECCW system issue to the NRC staffs satisfaction l by showing that the system leakage was sufficiently small such that the surge tanks would

last significantly longer than 7 days post-accident before they would need refilling. Therefore, l the system was shown to meet the original design basis, and the plant started up with no i further action necessary concoming this issue.

l The scenario you raised in which the loss of ECCW could lead to excessive control room i heating and then to the abandonment of the control room and finally to a serious safety event i

! is not considered credible. First, by more accurate testing, the ECCW system has been  ;

shown to meet the original design basis. Additionally, all nuclear power plants (including

PNPP) are equipped with an attemate shutdown panel from which the plant can be safely j~ shut down if, for some reason, the control room has been rendered uninhabitable.

i l Your assertion that PNPP releases massive quantities of radioactive waste to the environment is unsubstantiated. In the 1996 Annual Environmental and Effluent Release j Report for the Perry Nuclear Power Plant, submitted to the NRC by letter dated April 29, i 1997, the licensee reports, "The summation of the hypothetical maximum individual dose l- from effluents in 1996 is equivalent to less than one percent of the dose that an individual l living in the PNPP area receives from all sources of radiation." This statement is consistent j with the staffs conclusion contained in the " Final Environmental Statement Related to the L Operation of Perry Nuclear Power Plant, Units 1 and 2," NUREG-0884, dated August 1982, j p. vi, that "there should be no measurable radiological impact on members of the public from routine operation of the plant."

[ Your concems with regard to the Below Regulatory Concem Policy document were raised in

your petition for rulemaking dated January 8,1994. The NRC staff fully evaluated those

concems and denied your request as noticed in the Federal Bdater on March 13,1995

i. (60 FR 13385).

! You make several statements that appear to question the actions of the staff with respect to i its handling of the leaking ECCW issue and the continued operation of the facility. We intend i_ to forward your letter to the Office of the inspector General for their information, and any

!- action that they consider appropriate.

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o S. Gannis l l

l In conclusion, after reviewing your concems, the staff finds that operation of PNPP has not j endangered public health and safety or resulted in any significant environmental impact. l 4

I trust this reply responds to your concem.

l Sincerely,

. . : ' := =

hack W. Roe, Director

/ Division of Reactor Projects -lilllV d Office of Nuclear Reactor Regulation Docket No. 50-440 1

Enclosure:

Inspection Report l

\

I

S. Gannis In conclusion, after reviewing your concems, the staff finds that operation of PNPP has not endangered public health and safety or resulted in any significant environmental impact.

I trust this reply responds to your concem.

Sincerely, Original signed by E. Adensam for:

Jack W. Roe, Director Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Inspection Report DISTRIBUTION (w/o encl): M. Boyle (e-mail only MLB4) OGC Docket File (w/ incoming) PD3-3 R/F (w/ incoming) OPA PUBLIC (w/ incoming) C. Paperiello, NMSS OCA EDO #G970315 J. Goldberg, OGC N. Olson L. Callan T. Martin, NRR T. Harris H. Thompson SECY # CRC-97-0406 K. Bohrer E. Jordan NRR Mail Room (EDO #G970315) J. Roe P. Norry R. Zimmerman G. Marcus J. Blaha J. Hopkins (w/ incoming) M. Slosson S. Collins G. Grant, Rlli W. Travers F. Miraglia A. Beach, Rill E. Adensam M. Thadani J. Kennedy, NRR S. Bums, OGC K. Cyr, OGC DOCUMENT NAME: GT970315.LTR *SER PREVIOUS CONCURRENCE OFC Tech Ed PD33:PM ( Phh (; SPLB NAME BCalure* JHopkins [ oyle[h TMarsh*

DATE 6/19/97 7/[/197 h N/b97 U 6/25/97 OFC PERB HHFB OGC PD33:D NAME CMiller* CThomas* GMcGurren* GMarcus*

DATE 6/23/97 6/21/97 6/26/97 6/27/97 OFC , Djtk ADPppQ- NRR:D /

NAMM dRoe RZimnErman SCollins/f } A DATE' / /3 /97 ~~) /} /97 / ,/d7 OFFICIAL RECORD COPY ff%

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l J

. S. Gannis In conclusion, after reviewing your concems, the staff finds that operation of PNPP has not )

endangered public health and safety or resulted in any significant environmental impact. j 1

I trust this reply responds to your concem.

Sincerely, J Original signed by E. Adensam for:

Jack W. Roe, Director  !

Division of Reactor Projects - lil/IV l Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Inspection Report DISTRIBUTION (w/o enct): M. Boyle (e-mail only MLB4) OGC Docket File (w/ incoming) PD3-3 R/F (w/ incoming) OPA i PUBLIC (w/ incoming) C. Paperiello, NMSS OCA EDO #G970315 J. Goldberg, OGC N. Olson L. Callan T. Martin, NRR T. Harris H. Thompson SECY # CRC-97-0406 K. Bohrer E. Jordan NRR Mail Room (EDO #G970315) J. Roe P. Norry R. Zimmerman G. Marcus 4 J. Blaha J. Hopkins (w/ incoming) M. Slosson )

' S. Collins G. Grant, Rill W. Travers F. Miraglia A. Beach, Rlil E. Adensam M. Thadani J. Kennedy, NRR S. Bums, OGC K. Cyr, OGC DOCUMENT NAME: GT970315.LTR *SER PREVIOUS CONCURRENCE OFC Tech Ed PD33:PM ( Phh g SPLB NAME BCalure* JHopkins / oyle[Y TMarsh*

6/19/97 97 6/25/ 7 DAf , .- .

OFC PERB HHFB OGC PD33:D NAME CMiller* CThomas* GMcGurren* GMarcus*

DATE 6/23/97 6/21/97 6/26/97 6/27/97

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OFC , D5t ADP g(ft- NRR:D /

NAMM dRoe RZimbrman SCollins/df)

DATE / /

3 /97 7 /) /97 / [7 OFFICIAL RECORD COPY 18