Text

License Renewal Application for the Perry Nuclear Power Plant Revision O - Response to Requests for Confirmatory Information (Rcls) - Set 1
	ML24305A134
Person / Time
Site:	Perry
Issue date:	10/31/2024
From:	Penfield R; Vistra Operations Company
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	L-24-226
	Download: ML24305A134 (1)
	v • d • e

L-24-226 October 31, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant Rod L. Penfield Site Vice President 1 O Center Road Perry, Ohio 44081 10 CFR 54 License Renewal Application for the Perry Nuclear Power Plant Revision O - Response to Requests for Confirmatory Information (RCls) - Set 1

REFERENCES:

1.

Letter L-23-146, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 3, 2023, submitting the Perry Nuclear Power Plant License Renewal Application Revision O (ADAMS Accession No. ML23184A081) 2.

Nuclear Regulatory Commission issuance of Conforming License Amendment 203 to Facility Operating License NPF-58 (Enclosure 1) for the license transfer for the Perry Nuclear Power Plant (ADAMS Accession Nos. ML24057A075 and ML24057A077) 3.

Letter L-24-110, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 3, 2024, submitting 10 CFR 54.21(b) Annual Amendment to the Perry Nuclear Power Plant License Renewal Application (ADAMS Accession No. ML24185A092) 4.

Letter from Lauren K. Gibson to Rod L. Penfield, Perry Nuclear Power Plant, Unit No. 1 dated September 25, 2023 - Aging Management Audit Plan Regarding the License Renewal Application Review (ADAMS Accession No. ML23261B019) 5.

Letter L-24-189, from Rod L. Penfield to the Nuclear Regulatory Commission, dated August 7, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 1 (Non-Proprietary) (ADAMS Accession No. ML24220A270) 6555 SIERRA DRIVE IRVING. TEXAS 75039 o 214-812-4600 VISTRACOR P. COM

Perry Nuclear Power Plant L-24-226 Page 2 of 3

6. Letter L-24-020, from Rod L. Penfield to the Nuclear Regulatory Commission, dated June 27, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 2 (ADAMS Accession No. ML24180A010)

7. Letter L-24-108, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 24, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 3 (ADAMS Accession No. ML24206A150)

8. Letter L-24-200, from Rod L. Penfield to the Nuclear Regulatory Commission, dated September 5, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 4 Revision 1 (ADAMS Accession No. ML24249A123)

9. Letter L-24-179, from Rod L. Penfield to the Nuclear Regulatory Commission, dated October 21, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 5 (ADAMS Accession No. ML24295A352)

10. Letter L-24-207, from Rod L. Penfield to the Nuclear Regulatory Commission, dated September 16, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant - Response to Request for Additional Information - Set 1 (ADAMS Accession No. ML24260A266)

11. Letter L-24-208, from Rod L. Penfield to the Nuclear Regulatory Commission, dated October 2, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant -

Response to Request for Additional Information - Set 2 (ADAMS Accession No. ML24276A083)

12. NRC Email from Vaughn Thomas to Rod Penfield - dated October 2, 2024 - Perry LRA -

Requests for Confirmatory Information (ADAMS Accession Nos. ML24276A100 and ML24276A098)

On July 3, 2023, Energy Harbor Nuclear Corp. submitted a license renewal application (LRA) for the Facility Operating License for the Perry Nuclear Power Plant, Unit No. 1 (PNPP) (Reference 1 ).

Subsequent to the submittal of the PNPP LRA, the PNPP Facility Operating License has been transferred to Vistra Operations Company LLC (VistraOps) per conforming license Amendment 203 and the license transfer transaction was closed on March 1, 2024 (Reference 2). The license transfer changes impacting the PNPP LRA are documented in the annual amendment required by 10 CFR 54.21 (b), submitted on July 3, 2024 (Reference 3).

During the Nuclear Regulatory Commission (NRC) staffs aging management audit of the PNPP LRA (Reference 4), the PNPP Staff agreed to supplement the LRA with clarifying information which has led to several LRA supplements (References 5 through 9). In addition, the PNPP Staff has provided responses to the NRC Staffs requests for additional information (RAls) (References 10 and 11 ).

On October 2, 2024, the NRC Staff has submitted Requests for Confirmatory Information (RCls)

(Reference 12). Attachments 1 and 2 of this letter provide the responses to these RCls.

The regulatory commitments identified in Appendix A, Table A.3 of the PNPP LRA are not impacted by the RCI responses provided in the attachments. If there are any questions or if additional information is required, please contact Mr. Mark Bensi, PNPP License Renewal Manager at (440) 280-6179 or via email at Mark.Bensi@vistracorp.com.

6555 SIERRA DRIVE IRVING. TEXAS 75039 o 214-812-4600 VISTRACORP COM

Perry Nuclear Power Plant L-24-226 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on October 31, 2024.

Sincerely,

Staten Barnes for Rod L. Penfield Attachments:

1.

PNPP Response to RCI ESEB RCl-10331-R1 2.

PNPP Response to RCI NCSG RCl-10338-R1 cc:

NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board 6555 SIERRA DRIVE IRVING < TEXAS 75039 o 214-812-4600 VISTRACOR P COM

Perry Nuclear Power Plant Response to RCI ESEB RCI-10331-R1 L-24-226 Attachment 1 Page 1 of 3 ESEB RCI-10331-R1 Regulatory Basis Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants, is designed to elicit application information that will enable the NRC staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects.

Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.

Background

LRA Section B.2.43, as modified by LRA Supplement 3 (ML24206A150), provides new enhancement to the scope of program program element to inspect accessible areas of concrete for the signs of alkali silica reaction (ASR), etc. which belongs to the parameters monitored or inspected program element.

LRA Section B.2.43, as modified by LRA Supplement 3 (ML24206A150), provides an enhancement to the parameters monitored or inspected, program element to require (a) evaluation of the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examination of representative samples of the exposed portions of the below grade concrete, when excavated for any reason. If normally inaccessible areas become accessible due to planned activities, an inspection of these areas shall be conducted. GALL-LR XI.S6 AMP categorizes this as the detection of aging effects, program element.

Question 1 Confirm that the program element for this enhancement related to ASR can be changed to the parameters monitored or inspected, program element.

Question 2 Confirm that the program element in the enhancement, including items (a) and (b), can be changed to the detection of aging effects, program element.

Perry Nuclear Power Plant Response to RCI ESEB RCI-10331-R1 L-24-226 Attachment 1 Page 2 of 3 PNPP Response Question 1 Confirm that the program element for this enhancement related to ASR can be changed to the parameters monitored or inspected, program element.

Response

PNPP concurs with the NRCs recommendation. Therefore, the Structures Monitoring Program enhancement related to ASR will be removed from Scope Program Element 1 and moved to Parameters monitored or inspected, Program Element 3.

PNPP LRA Appendix A, Section A.1.43, as modified by LRA Supplement 3 (Vistra Letter L 108), Enhancement Number 6 and Appendix B, Section B.2.43 will be updated as follows:

Scope (Element 1)

Revise the sixth major bullet in this element as follows.

The program will be enhanced to inspect accessible areas of concrete for the signs of alkali silica reaction (ASR)., such as, map or patterned cracking, alkali-silica gel exudations, surface staining, expansion causing structural deformation, relative movement or displacement, or misalignment/distortion of attached components.

Parameters monitored or inspected (Element 3)

Add the following as major bullet four under this element:

The program implementing documents will be enhanced to inspect accessible areas of concrete for the signs of alkali silica reaction (ASR), such as, map or patterned cracking, alkali-silica gel exudations, surface staining, expansion causing structural deformation, relative movement or displacement, or misalignment/distortion of attached components.

The proposed updates to PNPP LRA, Sections A.1.43 and B.1.43 depicted in this RCI response will be submitted as part of a later supplement to the LRA.

Perry Nuclear Power Plant Response to RCI ESEB RCI-10331-R1 L-24-226 Attachment 1 Page 3 of 3 Question 2 Confirm that the program element in the enhancement, including items (a) and (b),

can be changed to the detection of aging effects, program element.

Response

PNPP concurs with NRCs recommendation. Therefore, for the Structures Monitoring Program, Enhancement 15 will be removed from Parameters monitored or inspected, Program Element 3 and moved to Detection of aging effects, Program Element 4.

The PNPP LRA, Appendix A, Section A.1.43, Enhancement 15 and Appendix B, Section B.2.43 as modified by LRA Supplement 3 (Vistra Letter L-24-108) will be updated as follows:

Parameters Monitored/Inspected (Element 3)

Delete the sixth major bullet item under Element 3.

The program will be enhanced to require (a) evaluation of the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examination of representative samples of the exposed portions of the below grade concrete, when excavated for any reason. If normally inaccessible areas become accessible due to planned activities, an inspection of these areas shall be conducted.

Detection of Aging Effects (Element 4)

Add the following as the fourth major bullet under this element:

The program implementing procedures will be enhanced to require (a) evaluation of the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examination of representative samples of the exposed portions of the below grade concrete, when excavated for any reason. If normally inaccessible areas become accessible due to planned activities, an inspection of these areas shall be conducted.

The proposed updates to PNPP LRA, Sections A.1.43 and B.1.43 depicted in this RCI response will be submitted as part of a later supplement to the LRA.

Perry Nuclear Power Plant Response to RCI NCSG RCI-10338-R1 L-24-226 Attachment 2 Page 1 of 6 NCSG RCI-10338-R1 Regulatory Basis Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants, is designed to elicit application information that will enable the NRC staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects. Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.

Background

As supplemented by letter dated July 24, 2024 (License Renewal Application (LRA) Supplement 3, ML24206A150), LRA Tables 3.5.2-1 and 3.5.2-4 include several component types with intended functions (i.e., support for regulated events Criterion (a)(3) equipment, enclosure, flood barrier, structural pressure boundary, and support for non-safety affecting safety Criterion (a)(2) equipment), in addition to the fire barrier intended function, where only the Fire Protection program is credited to manage the effects of aging. The component types include unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer drywell mechanical penetration (fiberglass fabric), fiberglass/alumina silicate/calcium silicate/mineral fiber drywell mechanical penetration (fiberglass), pyrocrete fire proofing, 3M Interam fire wrap and radiant energy shield, fiberglass/alumina silicate/calcium silicate/mineral fiber fire wrap, fiberglass/alumina silicate/calcium silicate/mineral fiber penetration sealant (fire), unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer penetration sealant (fire), and unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer safety relief valve (SRV) tailpipe penetration boot seals.

Issue During the audit of the Fire Protection AMP, it was discussed whether the Structures Monitoring program should be cited to manage the effects of aging of elastomer fire stops and elastomer penetration sealant (fire) with intended functions, in addition to the fire barrier intended function.

The applicant stated that either the Fire Protection or Structures Monitoring program is sufficient to manage the effects of aging for all intended functions for the elastomer fire stops and elastomer penetration sealant (fire).

Perry Nuclear Power Plant Response to RCI NCSG RCI-10338-R1 L-24-226 Attachment 2 Page 2 of 6 Question 1 To ensure the effects of aging associated with all intended functions are appropriately managed during the period of extended operation, please confirm that the Fire Protection program is sufficient to manage the effects of aging for all the component types noted in this request. That is, the inspections, inspection frequency, acceptance criteria, and corrective actions of the Fire Protection program are sufficient to manage the effects of aging associated with all cited intended functions.

PNPP Response Question 1 To ensure the effects of aging associated with all intended functions are appropriately managed during the period of extended operation, please confirm that the Fire Protection program is sufficient to manage the effects of aging for all the component types noted in this request. That is, the inspections, inspection frequency, acceptance criteria, and corrective actions of the Fire Protection program are sufficient to manage the effects of aging associated with all cited intended functions.

Response

The following component types are addressed: fire stops, penetration sealant, drywell mechanical penetration (fiberglass fabric), Shield building electrical penetration seals and sealant, seismic isolation joints, and Safety Relief Valve (SRV) tailpipe penetration boot seals.

To address this RCI, a sort was performed of the data in LRA Tables 3.5.2-1 and 3.5.2-4 to identify these component types that also credit fire protection as the aging management program.

In the development of this RCI response, a needed clarification to information in LRA Table 3.5.2-1 and 3.5.2-4 rows for these component types was identified. In some cases, the components that are the topic of this RCI are actually sub-components to a larger component.

For example, Drywell mechanical penetration (fiberglass fabric) is a subcomponent to Drywell mechanical penetrations. When the tables for scoping (LRA Sections 2.4.1-1 and 2.4.4-1) were created, the major components were identified with their credited functions, and subcomponents were not separately identified. In the corresponding AMR tables (LRA Tables 3.5.2-1 and 3.5.2-4), the subcomponents inherited the same credited functions from the major component. The needed clarification is to provide the unique functions credited for the subcomponents. Also, functions applicable to the components penetration sealant (flood, radiation) and penetration sealant (flood) were inadvertently applied to the component penetration sealant (fire).

Consequently, in LRA Table 2.4.1-1 and the corresponding LRA Table 3.5.2-1, the following changes regarding functions were identified:

For the component Drywell mechanical penetration (fiberglass fabric), the functions of EN, SPB, SSR apply to the Drywell penetrations, but not to their fiberglass fabric seal.

Thus, the functions of EN, SPB, and SSR will be removed from the intended functions for this component.

Perry Nuclear Power Plant Response to RCI NCSG RCI-10338-R1 L-24-226 Attachment 2 Page 3 of 6 For the component Shield building electrical penetration seals and sealant, the functions of EN and SSR do not apply to the elastomer seals and sealant for Shield building electrical penetrations. Thus, the functions of EN and SSR will be removed from the intended functions for this component.

Additionally, in LRA Table 2.4.4-1 and the corresponding LRA Table 3.5.2-4, the following changes regarding functions were identified:

For the component Penetration sealant (fire) the functions of EN, SPB, FLB and SNS are cited. Further review has confirmed that function of these fire penetration seals is limited to that of a fire barrier. Also, the penetration sealant components are safety related, such that the function SNS does not apply. Accordingly, the functions of EN, SPB, FLB, and SNS will be removed from the intended functions for the component Penetration sealant (fire).

For the component seismic isolation joint, since the component performs a fire barrier function, it also performs the function of support required to meet the Commissions regulations for regulated events. Accordingly, SRE will be added to the intended functions for the component seismic isolation joint.

For the component SRV Tailpipe Penetration Boot Seals, the boot seal material is identified as unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer. Since the boot seal component performs a fire barrier function, it also performs the function of support required to meet the Commissions regulations for regulated events. Since these boot seals are safety related and do not perform a flood barrier function, the functions of FLB and SNS will be removed from the intended functions for the component SRV Tailpipe Penetration Boot Seals.

See the proposed changes to the intended functions for LRA Tables 3.5.2-1 and 3.5.2-4 below.

Proposed changes to LRA Table 3.5.2-1:

Table Row Component Type Intended Function 92 Drywell mechanical penetration (fiberglass fabric)

FB, SRE [Delete (EN, SPB, SSR)]

93 Drywell mechanical penetration (fiberglass fabric)

FB, SRE [Delete (EN, SPB, SSR)]

94 Drywell mechanical penetration (fiberglass)

FB, SRE [Delete (EN, SPB, SSR)]

95 Drywell mechanical penetration (fiberglass)

FB, SRE [Delete (EN, SPB, SSR)]

149 Shield building electrical penetration seals and sealant SPB, FB, SRE [Delete (EN, SSR)]

150 Shield building electrical penetration seals and sealant SPB, FB, SRE [Delete (EN, SSR)]

151 Shield building electrical penetration seals and sealant SPB, FB, SRE [Delete (EN, SSR)]

153 Shield building electrical penetration seals and sealant SPB, FB, SRE [Delete (EN, SSR)]

Perry Nuclear Power Plant Response to RCI NCSG RCI-10338-R1 L-24-226 Attachment 2 Page 4 of 6 Table Row Component Type Intended Function 155 Shield building electrical penetration seals and sealant SPB, FB, SRE [Delete (EN, SSR)]

156 Shield building electrical penetration seals and sealant SPB, FB, SRE [Delete (EN, SSR)]

Proposed changes to LRA Table 3.5.2-4:

Table Row Component Type Intended Function 253 Penetration sealant (fire)