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Category:Letter type:L
MONTHYEARL-23-207, License Amendment Request (LAR) for Adoption of TSTF-264-A Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2024-01-24024 January 2024 License Amendment Request (LAR) for Adoption of TSTF-264-A Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs L-24-017, 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative2024-01-24024 January 2024 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative L-23-171, CFR 50.55a Request Number VR-9. Revision 0, Feedwater Check Valve Exercising Test Frequency2023-12-0808 December 2023 CFR 50.55a Request Number VR-9. Revision 0, Feedwater Check Valve Exercising Test Frequency L-23-244, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation L-23-238, Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 202023-11-10010 November 2023 Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 20 L-23-052, Submittal of the Updated Safety Analysis Report, Revision 232023-10-27027 October 2023 Submittal of the Updated Safety Analysis Report, Revision 23 L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-206, Ohio National Pollutant Discharge Elimination System (NPDES) Permit 3IB00016 MD2023-09-12012 September 2023 Ohio National Pollutant Discharge Elimination System (NPDES) Permit 3IB00016 MD L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual L-23-001, License Amendment Request to Remove the Table of Contents from the Technical Specifications2023-08-0707 August 2023 License Amendment Request to Remove the Table of Contents from the Technical Specifications L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-174, 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative2023-07-19019 July 2023 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative L-23-146, License Renewal Application for the Perry Nuclear Power Plant2023-07-0303 July 2023 License Renewal Application for the Perry Nuclear Power Plant L-23-050, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-22022 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-051, Plan, Nineteenth Inservice Inspection Summary Report2023-06-22022 June 2023 Plan, Nineteenth Inservice Inspection Summary Report L-22-249, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A Revision 2, Change TS 3.8.1. AC Sources-Operating. to Clarify the Power Factor Requirements When Performing Diesel Gener2023-06-0505 June 2023 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A Revision 2, Change TS 3.8.1. AC Sources-Operating. to Clarify the Power Factor Requirements When Performing Diesel Gener L-23-134, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-23023 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report L-23-121, Annual Radiological Effluent Release Report2023-04-26026 April 2023 Annual Radiological Effluent Release Report L-23-122, Annual Radiological Environmental Operating Report2023-04-26026 April 2023 Annual Radiological Environmental Operating Report L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-049, Core Operating Limits Report for Operating Cycle 202023-03-30030 March 2023 Core Operating Limits Report for Operating Cycle 20 L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage L-23-085, 1 to Emergency Plan2023-03-10010 March 2023 1 to Emergency Plan L-23-057, Energy Harbor Nuclear Corp Retrospective Premium Guarantee2023-02-20020 February 2023 Energy Harbor Nuclear Corp Retrospective Premium Guarantee L-23-017, Mid-Cycle Revisions to the Core Operating Limits Report for Operating Cycle 192023-01-31031 January 2023 Mid-Cycle Revisions to the Core Operating Limits Report for Operating Cycle 19 L-22-271, Emergency Plan2022-12-20020 December 2022 Emergency Plan L-22-272, Supplement to License Amendment Request to Revise the Methodology Used for Flood Hazard Analysis (EPID L-2021-LLA-0067) and Withdrawal of Exemption Requests (EPIDs L-2021-LLE-0022 and L-2021-LLE-0023)2022-12-16016 December 2022 Supplement to License Amendment Request to Revise the Methodology Used for Flood Hazard Analysis (EPID L-2021-LLA-0067) and Withdrawal of Exemption Requests (EPIDs L-2021-LLE-0022 and L-2021-LLE-0023) L-22-263, Spent Fuel Storage Cask Registration2022-12-12012 December 2022 Spent Fuel Storage Cask Registration L-22-254, Emergency Plan for Perry Nuclear Power Plant, Including EAL Matrix Revision 222022-11-18018 November 2022 Emergency Plan for Perry Nuclear Power Plant, Including EAL Matrix Revision 22 L-22-250, Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 192022-11-0808 November 2022 Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 19 L-22-221, Supplement to Application to Revise the Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2022-10-18018 October 2022 Supplement to Application to Revise the Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position L-22-201, Submittal of Evacuation Time Estimates2022-09-12012 September 2022 Submittal of Evacuation Time Estimates L-22-050, Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual2022-08-0909 August 2022 Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual L-20-239, Application to Revise the Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2022-08-0505 August 2022 Application to Revise the Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position L-22-171, Response to Request for Additional Information Regarding Proposed Inservice Inspection Alternative IR-0632022-07-14014 July 2022 Response to Request for Additional Information Regarding Proposed Inservice Inspection Alternative IR-063 L-22-099, Supplement to License Amendment Request to Revise the Methodology Used for Flood Hazard Analysis2022-06-0101 June 2022 Supplement to License Amendment Request to Revise the Methodology Used for Flood Hazard Analysis L-22-104, Annual Radiological Environmental Operating Report2022-04-28028 April 2022 Annual Radiological Environmental Operating Report L-22-110, Response to Request for Additional Information Re 10CFR50.55a Request Number VR-12, Revision 0, Request for Relief from Containment Isolation Valve ASME OM Code Requirement2022-04-28028 April 2022 Response to Request for Additional Information Re 10CFR50.55a Request Number VR-12, Revision 0, Request for Relief from Containment Isolation Valve ASME OM Code Requirement L-22-105, Annual Radiological Effluent Release Report2022-04-27027 April 2022 Annual Radiological Effluent Release Report L-22-082, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-23023 March 2022 Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations L-22-056, Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage2022-03-22022 March 2022 Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage L-22-052, Deviation from BWRVIP-42 Revision 1-A, BWR Vessel and Internals Project, Low Pressure Coolant Injection (LPCI) Coupling Inspection and Flaw Evaluation Guidelines2022-03-16016 March 2022 Deviation from BWRVIP-42 Revision 1-A, BWR Vessel and Internals Project, Low Pressure Coolant Injection (LPCI) Coupling Inspection and Flaw Evaluation Guidelines L-22-073, Submittal of the Decommissioning Funding Status Report for Perry Nuclear Power Plant2022-03-16016 March 2022 Submittal of the Decommissioning Funding Status Report for Perry Nuclear Power Plant L-22-023, Retrospective Premium Guarantee2022-02-17017 February 2022 Retrospective Premium Guarantee L-21-282, Proposed Inservice Inspection Alternative IR-0632022-01-0505 January 2022 Proposed Inservice Inspection Alternative IR-063 L-21-280, 10 CFR 50.55a Request Number VR-12, Revision 0, Request for Relief from Containment Isolation Valve ASME OM Code Requirements2022-01-0505 January 2022 10 CFR 50.55a Request Number VR-12, Revision 0, Request for Relief from Containment Isolation Valve ASME OM Code Requirements L-21-259, 10 CFR 50.55a Requests Number VR-10 and VR-11, Inservice Valve Testing2021-12-28028 December 2021 10 CFR 50.55a Requests Number VR-10 and VR-11, Inservice Valve Testing L-21-287, Submittal of Revision 22 to Updated Safety Analysis Report (Supplement Letter)2021-12-20020 December 2021 Submittal of Revision 22 to Updated Safety Analysis Report (Supplement Letter) 2024-01-24
[Table view] Category:Safety Evaluation
MONTHYEARML23292A2972023-11-17017 November 2023 Table of Contents LAR (L-2023-LLA-0111) ML23234A1702023-10-0303 October 2023 Issuance of Amendment No. 199 Regarding Administrative Changes to the Renewed Facility Operating License and Technical Specifications ML23237B4282023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 2, Draft Conforming License Amendments ML23237B4302023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0000) (Public) ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 ML23172A2852023-08-23023 August 2023 Safety Evaluation Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML22284A1442023-02-0303 February 2023 Issuance of Amendment No. 200 Regarding the Revision of Methodology Used for Flood Hazard Analysis ML22348A1372023-01-0505 January 2023 Issuance of Amendment No. 199 to Adopt TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 ML22252A2212022-09-30030 September 2022 Authorization and Safety Evaluation for Alternative Request IR-063 ML22210A0102022-09-16016 September 2022 Energy Harbor Fleet- Issuance of Amendments Regarding Adoption of TSTF 554, Revise Reactor Coolant Leakage Requirements ML22242A0022022-09-12012 September 2022 Issuance of Amendments to Adopt TSTF 569, Revision 2, Revise Response Time Testing Definition ML22227A0682022-09-0202 September 2022 Alternative to Certain Inservice Testing Requirements in the American Society of Mechanical Engineers Code for Operation and Maintenance for Certain Target Rock Solenoid Valves ML22126A0082022-08-0909 August 2022 Issuance of Amendment No. 194 Revise Technical Specifications Related to Reactor Protection System Instrumentation P7 ML22161B0332022-07-28028 July 2022 Issuance of Amendment No. 193 Regarding Revision of Surveillance Requirements to Remove Shutdown Limitation ML22187A2592022-07-12012 July 2022 Issuance of Relief Proposed Alternative Request Vr 12, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval ML22136A1132022-06-21021 June 2022 Issuance of Relief Proposed Alternative Requests VR-10, Revision 0, and VR-11, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval (EPIDs L-2021-LLR-0096; L-2021-LLR-0097) ML22083A0272022-03-23023 March 2022 Safety Evaluation -Harris Safety Evaluation -EPID L-2021-LLA-0149 - Revise TS Related to Reactor Protection System ML22020A0072022-03-10010 March 2022 Issuance of Amendment No. 192 Regarding Removal of Extraneous Content and Requirements from the Renewed Facility Operating License and Technical Specifications ML22010A2812022-03-0404 March 2022 Issuance of Amendments to Adopt TSTF-577, Rev. 1 Revised Frequencies for Steam Generator Tube Inspections (EPID L-2021-LLA-0161 ML21351A4722022-02-10010 February 2022 Issuance of Amendment No. 190 Regarding Revision to Containment Spray Nozzle Test Frequency ML21320A0012022-01-20020 January 2022 Issuance of Amendment No. 189 to Regarding Administrative Change to Reflect Development of a Technical Requirements Manual ML21316A2482022-01-19019 January 2022 Issuance of Amendment No. 188, Regarding Revision of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML21322A2602022-01-10010 January 2022 Issuance of Amendment No. 197 Regarding the Adoption of TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystem, and TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Oper ML21270A1122021-11-16016 November 2021 Issuance of Amendment No. 196 Regarding Changes to the Emergency Plan ML21271A0782021-11-0505 November 2021 Issuance of Amendment No. 195 Regarding the Adoption of TSTF-230, Add New Condition B to LCO 3.6.2.3, 'Rhr Suppression Pool Cooling' ML21155A2132021-08-26026 August 2021 Plant ML21158A2122021-07-12012 July 2021 Issuance of Amendment No. 194 Regarding the Adoption of TSTF-002, Relocate the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank to Licensee Control ML21113A0132021-05-0606 May 2021 Request for Use of a Later Edition of ASME Boiler and Pressure Vessel Code, Section XI for Repair and Replacement Activities ML21123A2172021-05-0505 May 2021 Issuance of Relief Requests Vr 4, Revision 0, Vr 6, Revision 0, and Vr 8, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval (EPIDs L 2021 Llr 0010, L 2021 Llr 0011, L 2021 Llr 0012 COVID-19 ML21123A2892021-05-0404 May 2021 Issuance of Relief Request Vr 7, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval ML21081A0702021-04-27027 April 2021 Issuance of Amendment No. 193 Regarding the Adoption of TSTF-500, DC Electrical Rewrite - Update to TSTF-360 ML21047A4702021-04-0808 April 2021 Issuance of Amendment No. 185 Regarding Reduction of Reactor Coolant System Minimum Flow Rate and Update to the Core Operating Limits Report References ML21047A3142021-04-0202 April 2021 Issuance of Amendment No. 184 Regarding Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times RITSTF Initiative 4B ML21033B0072021-03-22022 March 2021 Issuance of Amendment No, 183 to Correct Non-Conservative Technical Specification Related to Reactor Coolant System Pressure/Temperature Limits ML21069A0642021-03-18018 March 2021 Alternative to ASME Section XI Code Requirements to Defer Repair of Emergency Service Water System Socket Weld ML21035A1322021-03-16016 March 2021 Issuance of Amendment No. 182 Regarding Technical Specifications Related to Accident Monitoring Instrumentation, and Refueling Operations Instrumentation ML21063A2532021-03-0505 March 2021 Issuance of Relief Request SR-2, Revision 0, from Certain Requirements of the ASME OM Code (EPID L-2021-LLR-0005 (COVID-19)) ML21063A1572021-03-0404 March 2021 Safety Evaluation for Alternative Request SR-2, Revision 0 Related to one-time Extension Snubbers Testing to ASME OM Code for the Fourth 10-year Inservice Interval at Perry Nuclear Power Plant Unit 1, Docket Nos. 50-440 ML21035A1702021-03-0101 March 2021 Issuance of Amendment No. 192, Regarding Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements ML21029A3352021-02-16016 February 2021 Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML20363A0062021-01-29029 January 2021 Issuance of Relief Proposed Alternative Request Associated with Fourth 10-Year Inservice Inspection Interval ML20259A5122020-12-0808 December 2020 Issuance of Amendment No. 181 Regarding Adoption of 10 CFR Part 50, Appendix J, Option B, for Type B and C Testing and for Permanent Extension of Type a, B, and C Leak Rate Testing Frequencies(L-2019-LLA-0256) ML20311A6582020-11-10010 November 2020 Issuance of Relief Proposed Alternative Request Associated with Fourth Ten Year Interval Inservice Inspection Interval ML20300A2062020-11-0909 November 2020 Duke Fleet - Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML20281A2792020-10-13013 October 2020 Correction Letter to Amendment No. 179 Regarding Departure from Nucleate Boiling Ratio Safety Limit to Address Transition to New Fuel Type 2023-09-28
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Progress Energy OCT 0 4 2007 Serial: HNP-07-138 10 CFR 50.36 Ms. M. G. Vaaler, HNP Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR TECHNICAL ASSISTANCE - RESOLUTION OF THE IMPACT OF AIR HANDLER UNAVAILABILITY ON TECHNICAL SPECIFICATION EQUIPMENT BASED ON INTERPRETATION OF GL 80-30 DATED APRIL 10, 1980 AND NRC LETTER TO PERRY NUCLEAR STATION DATED APRIL 5, 2002 (ML020950074)
Dear Ms. Vaaler:
Recent discussions between the Harris Nuclear Plant staff and the NRC Resident Inspectors at HNP have identified the need for clarification of issues concerning the impact of ventilation system air handler unavailability on Technical Specification (TS) equipment operability based on guidance found in GL 80-30 and an NRC Letter to Perry Nuclear Station. GL 80-30 is dated April 10, 1980, and is entitled "Clarification of the Term 'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by Technical Specifications." The referenced NRC Letter from the NRC to Perry Nuclear Station (ML020950074) was dated April 5, 2002, and had a subject line stating "Application of Generic Letter 80-30 Guidance to an Inoperable Non-Technical Specification Support Subsystem."
Background
In its letter to Perry Nuclear station, the NRC finds that "the TS definition of operability does not require a TS subsystem's necessary support function to meet the single-failure design criterion. Thus no TS limits the duration of the non-TS support subsystem outage, even though the single-failure design requirement of the supported TS system is not met. However, by assessing and managing risk in accordance with [10 CFR 50.65] (a)(4), the licensee can determine an appropriate duration for the maintenance activity." The letter goes on to point out that should a risk assessment support a period of unavailability for longer than 90 days for the support subsystem then a 10 CFR 50.59 evaluation would be required. The letter also clarifies that "This allowance would be permitted regardless of whether the maintenance is corrective or preventive."
Progress Energy Carolinas, Inc.
Harris Nuclear Planw A 00(
P. 0 Box165 New Hill NC 27562
4 HNP-07-138 Page 2 HNP acknowledges the need to demonstrate that any allowed period of unavailability of a support subsystem function which supports TS required systems is acceptable in accordance with 10 CFR 50.65(a)(4) and that the requirements of 10 CFR 50.59 still apply if a system were to be out of service for more than 90 days.
However, HNP does not find any information in the NRC letter to Perry to indicate that its clarification of GL 80-30 is based on specific design or probabilitic risk assessment results related to the Perry Nuclear Station.
Requested Action Please provide clarification concerning the generic applicability of the NRC position as presented in the NRC letter to Perry Nuclear Station, "Application of GL 80-30 Guidance to an Inoperable Non-Technical Specification Support Subsytem," dated April 5, 2002.
Coordination This request was discussed between HNP representatives, Mr. Phillip O'Bryan -
HNP Senior Resident Inspector, and yourself. It was agreed that HNP should request clarification through its project manager. It is requested that the NRC review and respond to this Request for Technical Information.
Please refer any question regarding this submittal to Mr. Dave Corlett at (919) 362-3137.
Sincerely, David H. Corlett Supervisor - Licensing/Regulatory Programs Harris Nuclear Plant DHC/khv
Attachment:
- 1. NRC Letter to Mr. Guy Campbell, Perry Nuclear Station dated April 5, 2002 (ML020950074)
C:
Mr. P. B. O'Bryan, NRC Sr. Resident Inspector Dr. W. D. Travers, NRC Regional Administrator Document Control Desk, NRC
Attachment 1 to SERIAL: HNP-07-138 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO, NPF-63 REQUEST FOR TECHNICAL ASSISTANCE - RESOLUTION OF THE IMPACT OF AIR HANDLER UNAVAILABILITY ON TS EQUIPMENT BASED ON INTERPRETATION OF GL 80-30 DATED APRIL 10, 1980 AND NRC LETTER TO PERRY NUCLEAR STATION DATED APRIL 5, 2002 (ML020950074)
NRC Letter to Mr. Guy Campbell, Perry Nuclear Station dated April 5, 2002 (ML020950074)
Page Al-1 of 6
April 5, 2002 Mr. Guy G. Campbell Vice President - Nuclear, Perry FirstEnergy Nuclear Operating Company P.O. Box 97, A200 Perry, OH 44081
SUBJECT:
APPLICATION OF GENERIC LETTER 80-30 GUIDANCE TO AN INOPERABLE NON-TECHNICAL SPECIFICATION SUPPORT SUBSYSTEM
Dear Mr. Campbell:
Recent discussions with your staff have focused on the performance of on-line maintenance on systems that provide a support function (i.e., a support system). Specifically, your staff has questioned how to address the single-failure design criterion for support systems that are not included in the technical specifications (TSs) that provide a support function for systems that are included in the TSs.
The staff has reviewed the guidance of Generic Letter 80-30, "Clarification of the Term
'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by Technical Specifications," that allows a plant to temporarily depart from the single-failure design criterion when the plant is operating within a TS action requirement. In the enclosure, the staff has clarified the application of this guidance to non-TS support systems, and in particular to those that have two 100 percent capacity subsystems, such as Perry's ventilation system, with each subsystem capable of fully supporting both trains of TS equipment. The need for this clarification was highlighted by concerns about the conduct of on-line maintenance on Perry's ventilation system. This clarification of the existing generic guidance was developed by the TS Section of the Office of Nuclear Reactor Regulation's Operating Reactor Improvement Program.
Please feel free to contact me at (301) 415-1364 if you have any questions.
Sincerely, IRA!
Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-440
Enclosure:
As stated cc w/encl: See next page
ML020950074 OFFICE PM:LPD3 LA:LPD3 BtC:RORP SC:LPD3 NAME DPickett THarris W\/Beckner*
AMendiola DATE 04/05/02 04/05/02 0,4/02/02 04/05/02
- See 4/2/02 memo from WBeckner to SBajwa Guy G. Campbell Perry Nuclear Power Plant, Unit 1 FirstEnergy Nuclear Operating Company cc:
Mary E. O'Reilly FirstEnergy Corporation 76 South Main St.
Akron, OH 44308 Carol O'Claire, Chief, Radiological Branch Ohio Emergency Management Agency Resident Inspector's Office 2855 West Dublin Granville Road U.S. Nuclear Regulatory Commission Columbus, OH 43235-7150 P.O. Box 331 Perry, OH 44081-0331 Mayor, Village of Perry P.O. Box 100 Regional Administrator, Region III Perry, OH 44081-0100 U.S. Nuclear Regulatory Commission 801 Warrenville Road Dennis Clum Lisle, IL 60532-4531 Radiological Assistance Section Supervisor Bureau of Radiation Protection Sue Hiatt Ohio Department of Health OCRE Interim Representative P.O. Box 118 8275 Munson Columbus, OH 43266-0118 Mentor, OH 44060 Zack. A. Clayton Gregory A. Dunn DERR Manager - Regulatory Affairs Ohio Environmental Protection Agency FirstEnergy Nuclear Operating Company ATTN: Mr. Zack A. Clayton Perry Nuclear Power Plant P.O. Box 1049 P.O. Box 97, A210 Columbus, OH 43266-0149 Perry, OH 44081 Chairman William R. Kanda, Plant Manager Perry Township Board of Trustees FirstEnergy Nuclear Operating Company 3750 Center Road, Box 65 Perry Nuclear Power Plant Perry, OH 44081 P.O. Box 97, SB306 Perry, OH 44081 Daniel Z. Fisher Transportation Department Mayor, Village of North Perry Public Utilities Commission North Perry Village Hall 180 East Broad Street 4778 Lockwood Road Columbus, OH 43215-3793 North Perry Village, OH 44081 Donna Owens, Director Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P. O. Box 4009 Reynoldsburg, OH 43068-9009
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO APPLICATION OF GENERIC LETTER 80-30 GUIDANCE TO AN INOPERABLE 100 PERCENT CAPACITY NON-TECHNICAL SPECIFICATION SUPPORT SUBSYSTEM FIRSTENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-440 Technical Specifications (TSs) play an important part in the risk management of maintenance activities by limiting the duration of safety equipment outages. Because a failure to meet a system's TS limiting condition for operation usually involves a loss of redundancy, the affected system cannot withstand a single-failure and still perform its intended safety function. TSs provide a time by which the design-basis must be restored (see Generic Letter (GL) 80-30). This staff position is acceptable because, by limiting the duration of plant operation with inoperable safety equipment, the TSs manage the associated increase in risk to an acceptable level.
For plant operation with only one or two TS-required components inoperable, probabilistic risk assessment has indicated that the TS strategy for managing risk is usually conservative. But for operation with multiple TS-required components inoperable, TSs may actually allow operation that is non-conservative compared to the established risk guidelines. One reason for this is that the Nuclear Regulatory Commission never intended TSs to fully address inoperable components in several systems at the same time. Therefore, in addition to observing the limitations of TSs, licensees must also assess and manage risk associated with maintenance activities in accordance with paragraph (a)(4) of 10 CFR 50.65, the "maintenance rule," which
- states, Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.
The operability requirements for non-TS support systems are linked to the TS operability requirements of the systems they support, by the TS definition of operability:
A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or ENCLOSURE
emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
Thus, TSs also play a role in managing the risk associated with maintenance on non-TS support systems.
In most designs, the non-TS support system has two subsystems, each supporting just one TS train of safety equipment. The duration of the maintenance activity is limited by the Required Action Completion Times of the supported TS system(s). In this case, because the outage time of the non-TS support system is limited by the supported system TSs, the plant is temporarily allowed to depart from the single-failure design criterion, but the licensee may not rely solely on the TS limitations. As noted above, the licensee must still assess and manage risk in accordance with (a)(4).
In some designs, the non-TS support system has two redundant 100 percent capacity subsystems, each capable of supporting both TS trains. Loss of one support subsystem does not result in a loss of support for either train of TS equipment. Both TS trains remain operable, despite a loss of support function redundancy, because the TS definition of operability does not require a TS subsystem's necessary support function to meet the single-failure design criterion.
Thus, no TS limits the duration of the non-TS support subsystem outage, even though the single-failure design requirement of the supported TS systems is not met. However, by assessing and managing risk in accordance with (a)(4), the licensee can determine an appropriate duration for the maintenance activity. Use of administrative controls to implement such a risk-informed limitation is an acceptable basis for also allowing a temporary departure from the design-basis configuration during such maintenance. Although not expected, were a licensee to determine that its risk assessment would permit the support subsystem to be inoperable for more than 90 days, then the licensee would have to evaluate the maintenance configuration as a change to the facility under 10 CFR 50.59, including consideration of the single-failure design criterion.
For the unusual non-TS support system design configuration described, the preceding is a clarification of the previous staff position (GL 80-30) regarding when a temporary departure from the single-failure design criterion is allowed. This allowance would be permitted regardless of whether the maintenance is corrective or preventive.
Regarding the situation in which the non-TS support subsystem is discovered to be in a degraded or non-conforming condition, the licensee must make a prompt determination of operability, as discussed in GL 91-18. If the non-TS support subsystem is determined to be inoperable, then the licensee must determine whether the subsystem's support function is actually needed to support operability of the supported TS systems. In some situations, the licensee may be able to establish other means to temporarily provide the required support function. If the support function is required, then the risk-management strategies of the TSs and (a)(4), as described above for planned maintenance, will determine the appropriate actions and time limits to return the non-TS support subsystem to operable status, or to shut down the plant.
Principal Contributor: C Harbuck, RORP, NRR Date: