ML023520320
| ML023520320 | |
| Person / Time | |
|---|---|
| Site: | Perry  (NPF-058) |
| Issue date: | 12/05/2002 |
| From: | Kanda W FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PY-CEI/NRR-2673L | |
| Download: ML023520320 (2) | |
Text
FENOC Perry Nuclear Power Plant 10 Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081 William R. Kanda 440-280-5579 Vice President - Nuclear Fax 440-280-8029 December 5, 2002 PY-CEI/NRR-2673L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 Withdrawal of a License Amendment Request and Update of a Previous Commitment Ladies and Gentlemen:
This letter withdraws a license amendment request. The request being withdrawn was submitted in a letter dated February 11, 2002 (PY-CEI/NRR-2609L), which proposed Technical Specification changes based on Alternative Source Term radiological calculations for the Fuel Handling Accident. It will be replaced by a submittal which requests NRC review and approval of the radiological calculations.
This letter also updates a commitment that would have been updated by the withdrawn amendment request. This update relates to the use of appropriate administrative controls during handling of fuel which is not "recently irradiated fuel", as defined in the Technical Specification Bases. A letter dated January 7, 1999 (PY-CEI/NRR-2354L) contained the original commitment, made in support of License Amendment 102. At the time of the original commitment, a revision to NUMARC 93-01 "Industry Guideline For Monitoring The Effectiveness Of Maintenance At Nuclear Power Plants" was being developed, so a commitment was made to the draft version of the document. NUMARC 93-01 Revision 3 has since been completed, therefore it is appropriate to update the original commitment to the wording contained in Section 11.3.6.5 of the final Revision 3 document. The exact wording of the updated commitment is included as Attachment 1.
If you have questions or require additional information, please contact Mr. Vernon K. Higaki, Manager - Regulatory Affairs, at (440) 280-5294.
Very truly yours, Attachment cc: NRC Project Manager NRC Resident Inspector NRC Region III State of Ohio PY-CEIINRR-2673L Page 1 of 1 The following table identifies the actions that are considered to be regulatory commitments. Any other actions discussed in this document represent intended or planned actions, are described for the NRC's information, and are not regulatory commitments. Please notify the Manager Regulatory Affairs at the Perry Nuclear Power Plant of any questions regarding this document or any associated regulatory commitments.
Commitments
- 1. As part of the Nuclear Regulatory Commission (NRC) resolution of the proposed Shutdown Rule (1997), the Maintenance Rule, 10 CFR 50.65, was revised to require licensees to assess the impact on shutdown safety before removing equipment from service for maintenance. The industry, through the Nuclear Energy Institute (NEI), developed guidance to implement this new requirement Section 11.3.6.5 of NUMARC 93-01 "Industry Guideline For Monitoring The Effectiveness Of Maintenance At Nuclear Power Plants", Revision 3, contains the final approved wording on how the industry is addressing Containment during plant shutdown periods. License Amendment 102 (March 1999), which provided the original approval for handling irradiated fuel under Shutdown Safety controls at PNPP, contained a commitment to a draft version of this NUMARC document. This commitment is hereby updated to commit to Revision 3 of NUMARC 93-01, Section 11.3.6.5. This ensures that a building closure plan is in effect and ventilation systems remain available to monitor and filter a release from a Fuel Handling Accident.
Note: The exact wording from NUMARC 93-01, Section 11.3.6.5 is as follows:
"In addition to the guidance in NUMARC 91-06, for plants which obtain license amendments to utilize shutdown safety administrative 'controls in lieu of Technical Specification requirements on primary or secondary containment operability and ventilation system operability during fuel handling or core alterations, the following guidelines should be included in the assessment of systems removed from service:
"During fuel handling/core alterations, ventilation system and radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the RCS decays fairly rapidly. The basis of the Technical Specification operability amendment is the reduction in doses due to such decay.
The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay, and to avoid unmonitored releases.
A single normal or contingency method to promptly close primary or secondary containment penetrations should be developed. Such prompt methods need not completely block the penetration or be capable of resisting pressure. The purpose is to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored."