L-18-174, Response to Request for Additional Information Regarding a Request to Revise the Technical Specifications to Adopt TSTF-542 Reactor Pressure Vessel Water Inventory Control

Response to Request for Additional Information Regarding a Request to Revise the Technical Specifications to Adopt TSTF-542 Reactor Pressure Vessel Water Inventory Control

ML18207A268
Person / Time
Site:	Perry
Issue date:	07/24/2018
From:	Hamilton D FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLA-0405, L-18-174
Download: ML18207A268 (6)

Text

FENOC Perry Nuclear Power Plant P.O. Box 97 10 Center Road Perry, Ohio 44081 FirstEnergy Nuclear Operating Company David B. Hamilton 440-280-5382 Vice President July 24, 2018 L-18-174 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Regarding a Request to Revise the Technical Specifications to Adopt TSTF-542 "Reactor Pressure Vessel Water Inventory Control" (EPID L-2017-LLA-0405)

By correspondence dated December 6, 2017 (Accession No. ML17347A788),

FirstEnergy Nuclear Operating Company (FENOC) submitted a request to adopt Technical Specifications Task Force (TSTF) traveler TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2, for the Perry Nuclear Power Plant.

By electronic mail dated June 28, 2018, the Nuclear Regulatory Commission (NRC) requested additional information to complete its review. FENOC's response to this request is provided in Attachment 1.

A revised Technical Specification (TS) page is provided in Attachment 2. This revised page corrects an editorial error in proposed TS 3.3.5.2. As proposed, ACTIONS CONDITION F states "Required Action and associated Completion Times of Condition C, D, E, or F not met." The revised page removed the reference to CONDITION F and now states "Required Action and associated Completion Times of Condition C, D, or E not met." This page supersedes the page submitted by FENOC on December 6, 2017.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager- Nuclear Licensing & Regulatory Affairs, at (330) 315-6810.

Perry Nuclear Power Plant L-18-174 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on July Jy ,2018.

Sincerely, David B. Hamilton : Response to June 28, 2018 Request for Additional Information : Revised Markup of Technical Specification Page 3.3-43b cc: NRC Region III Administrator NRC Resident Inspector NRC Project Manager Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Attachment 1 L-18-174 Response to June 28, 2018 Request for Additional Information Page 1 of 2 By correspondence dated December 6, 2017, FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request for Nuclear Regulatory Commission (NRC) review and approval. By electronic mail dated June 28, 2018, NRC staff requested additional information to complete its review. The requested information is presented below in bold type, followed by the FENOC response.

RAM:

In Attachment 2 of the amendment request, on pages 3.3-43d and 3.3-43e, proposed PNPP [Perry Nuclear Power Plant] TS [Technical Specifications] Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation," contains values for some functions that are not consistent with the TSTF [Technical Specifications Task Force]-542 Standard TS (STS) values for the Required Channels per Function column. The table below compares PPNP's proposed RPVWIC [Reactor Pressure Vessel Water Inventory Control] required channels per function with the corresponding entry in TSTF-542. The NRC staff reviewed the variations section of the LAR [License Amendment Request]; however, there was not a sufficient description of the variations from the STS format. The staff also reviewed Chapter 6 of the PNPP Updated Safety Analysis Report (ADAMS Accession No. ML17305A201) to determine why the selected Required Channels per Function were retained.

For the proposed PNPP TS Table 3.3.5.2-1 Functions identified in the table below, provide justification for varying from the Required Channels per Function nomenclature specified in TSTF-542, e.g., "1" as opposed to "1 per subsystem."

Function Required Channels Per Function PNPP TS TSTF-542 STS Table 3.3.5.2-1 Table 3.3.5.2-1 1.e Manual Initiation 1 [1 per subsystem]

2.a Reactor Vessel Pressure - 1 per subsystem [3]

Low (LPCI Injection Valve Permissive) 2.c Manual Initiation 1 [1 per subsystem]

Response

For the Functions identified in the request for additional information, TSTF-542 identified each value with brackets, indicating that plant-specific differences may be reflected. In keeping with the construct of TSTF-542, the plant specific values for each of the bracketed items are discussed below.

Function 1 .e, "Manual Initiation," applies to the low pressure coolant injection (LPCI)-A and low pressure core spray (LPCS) subsystems. For PNPP Function 1 .e, there is only one manual initiation switch for both LPCI-A and LPCS subsystems, and it is located in the main control room. The "Required Channels per Function" designation of "1 per L-18-174 Page 2 of 2 subsystem" in TSTF-542 Table 3.3.5.2-1 is not applicable to the PNPP. Therefore, no changes are required for the Function 1.e "Required Channels Per Function" designation, as currently identified in the PNPP LAR.

Currently, PNPP's TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," Function 2.d, "Reactor Vessel Pressure - Low (LPCI Injection Valve Permissive)," which applies to the LPCI-B and LPCI-C subsystems in Modes 1, 2, 3, 4, and 5, specifies one required channel per subsystem. The proposed license amendment relocates the Mode 4 and 5 applicability for Function 2.d to Table 3.3.5.2-1 as Function 2.a and maintains the one required channel per subsystem applicability.

This is appropriate since the designation of "3" required channels per function for Function 2.a in TSTF-542 Table 3.3.5.2-1 is not applicable to the PNPP. Function 2.a applies to only two PNPP subsystems and thus it has only two channels (one per subsystem). Therefore, no changes are required for the Function 2.a "Required Channels Per Function" designation, as currently identified in the PNPP LAR.

Function 2.c, "Manual Initiation," applies to the LPCI-B and LPCI-C subsystems For PNPP Function 2.c, there is only one manual initiation switch for both LPCI-B and LPCI-C subsystems, and it is located in the main control room. The "Required Channels Per Function" designation of "1 per subsystem" in TSTF-542 Table 3.3.5.2-1 is not applicable to the PNPP. Therefore, no changes are required for the Function 2.c "Required Channels Per Function" designation, as currently identified in the PNPP LAR.

Attachment 2 L-18-174 Revised Markup of Technical Specification Page 3.3-43b (1 page follows)

RPV Water Inventorv Control Instrumentation ACTIONS feontinuflri)

CONDITION REQUIRED ACTION COMPLETION TIME D. As reauired bv Required D 1 Declare HPCS svstem 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Action A.1 and inooerable.

referenced in Table 3.3.5.2-1. OR D.2 Alian the HPCS pump 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> suction to the suooression pool.

E. As reauired bv Required E.1 Restore channel to Action A.1 and OPERABLE status.

referenced in Table 3.3.5.2-1.

F. Required Action and F.1 Declare associated ECCS Immediately associated Comoletion iniection/sorav subsystem Time of Condition C. Dr inooerable.

or E not met.

PERRY-UNIT 1 3.3-43b Amendment No.