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Category:Letter
MONTHYEARIR 05000440/20230042024-01-30030 January 2024 Integrated Inspection Report 05000440/2023004 L-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 IR 05000440/20234022024-01-10010 January 2024 Cyber Security Inspection Report 05000440/2023402 ML24003A8032024-01-0303 January 2024 Notification of NRC Fire Protection Team Inspection Request for Information ML23321A0472023-12-20020 December 2023 Letter to Rod L. Penfield - Perry Nuclear Power Plant, Unit 1 - License Renewal Regulatory Audit Regarding the Environmental Review of the License Renewal Application 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 IR 05000440/20230112023-11-28028 November 2023 Biennial Problem Identification and Resolution Inspection Report 05000440/2023011 IR 05000440/20234032023-11-27027 November 2023 Security Baseline Inspection Report 05000440/2023403 ML23292A2972023-11-17017 November 2023 Table of Contents LAR (L-2023-LLA-0111) 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 ML23292A2482023-10-19019 October 2023 Fws to NRC, Federal Agency Coordination Under ESA Section 7 for Perry Nuclear Plant, Unit 1, License Renewal, and Concurrence with Not Likely to Adversely Affect Determination for Northern Long-eared Bat ML23292A2472023-10-19019 October 2023 Fws to NRC, Perry Nuclear Plant, Unit 1, License Renewal List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected IR 05000440/20230032023-10-11011 October 2023 Integrated Inspection Report 05000440/2023003 ML23249A1032023-10-0303 October 2023 Letter to Rod L. Penfield, Site Vice President-Perry Nuclear Power Plant, Unit 1-Notice of Intent to Conduct Scoping Process and Prepare an Environmental Impact Statement ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure ML23261C3642023-09-25025 September 2023 License Renewal Application Online Reference Portal ML23261B0192023-09-25025 September 2023 Aging Management Audit Plan Regarding the License Renewal Application Review ML23256A3592023-09-22022 September 2023 Determination of Acceptability and Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding the Energy Harbor Nuclear Corp. 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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 ML23144A3562023-05-25025 May 2023 Information Meeting with a Question and Answer Session to Discuss NRC 2022 End of Cycle Plant Performance Assessment of Perry Nuclear Power Plant, Unit 1 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 ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) IR 05000440/20230012023-05-0404 May 2023 Integrated Inspection Report (05000440/2023001) L-23-122, Annual Radiological Environmental Operating Report2023-04-26026 April 2023 Annual Radiological Environmental Operating Report L-23-121, Annual Radiological Effluent Release Report2023-04-26026 April 2023 Annual Radiological Effluent Release Report 2024-01-30
[Table view] Category:License-Application for Facility Operating License (Amend/Renewal) DKT 50
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-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-23-001, 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-23-146, License Renewal Application for the Perry Nuclear Power Plant2023-07-0303 July 2023 License Renewal Application for the Perry Nuclear Power Plant 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 CP-202300157, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-14014 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments 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-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-22-099, 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 ML21106A0202021-04-0707 April 2021 Enclosure a - Evaluation of Proposed Change L-20-240, License Amendment Request to Adopt TSTF-002, Relocate the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank to Licensee Control2021-03-0505 March 2021 License Amendment Request to Adopt TSTF-002, Relocate the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank to Licensee Control L-20-129, Emergency Plan Amendment Request2020-12-28028 December 2020 Emergency Plan Amendment Request L-20-166, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements2020-09-24024 September 2020 Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements L-20-188, ISFSI, Davis-Besse Unit 1, and ISFSI, Perry, Unit 1, and ISFSI, Decommissioning Trust: Amendments to Decommissioning Trust Agreements to Update Company Names2020-06-26026 June 2020 ISFSI, Davis-Besse Unit 1, and ISFSI, Perry, Unit 1, and ISFSI, Decommissioning Trust: Amendments to Decommissioning Trust Agreements to Update Company Names L-19-274, License Amendment Request for Adoption of Technical Specification Task Force (Tsft) Traveler TSTF-500, Revision 2, DC Electrical Rewrite-Update to TSFT-3602020-04-24024 April 2020 License Amendment Request for Adoption of Technical Specification Task Force (Tsft) Traveler TSTF-500, Revision 2, DC Electrical Rewrite-Update to TSFT-360 L-19-265, License Amendment Request to Extend Refueling Special Lifting Devices' Interval for Testing to Verify Continuing Compliance2019-12-18018 December 2019 License Amendment Request to Extend Refueling Special Lifting Devices' Interval for Testing to Verify Continuing Compliance L-19-213, Application to Revise Technical Specifications to Adopt TSTF-564. Safety Limit MCPR2019-12-18018 December 2019 Application to Revise Technical Specifications to Adopt TSTF-564. Safety Limit MCPR L-19-219, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2019-09-25025 September 2019 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-19-200, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI - Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2019-08-29029 August 2019 ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI - Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-19-073, ISFSI, Davis-Besse, Unit 1, ISFSI, and Perry, Unit 1, ISFSI - Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2019-04-26026 April 2019 ISFSI, Davis-Besse, Unit 1, ISFSI, and Perry, Unit 1, ISFSI - Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-18-046, License Amendment Request to Extend Containment Leakage Test Frequency2018-03-0707 March 2018 License Amendment Request to Extend Containment Leakage Test Frequency L-17-350, Application to Revise Technical Specifications to Adopt TSTF-546, Revise APRM Channel Adjustment Surveillance Requirement2018-02-14014 February 2018 Application to Revise Technical Specifications to Adopt TSTF-546, Revise APRM Channel Adjustment Surveillance Requirement L-17-045, Application to Revise Technical Specifications to Adopt TSTF-542. Reactor Pressure Vessel Water Inventory Control.2017-12-0606 December 2017 Application to Revise Technical Specifications to Adopt TSTF-542. Reactor Pressure Vessel Water Inventory Control. L-17-089, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-400-A, Revision 1, Clarify SR on Bypass of DG Automatic Trips2017-06-20020 June 2017 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-400-A, Revision 1, Clarify SR on Bypass of DG Automatic Trips L-17-042, Request for Licensing Action to Revise the Technical Specifications2017-06-0808 June 2017 Request for Licensing Action to Revise the Technical Specifications L-17-043, Request for Licensing Action to Revise the Environmental Protection Plan2017-04-26026 April 2017 Request for Licensing Action to Revise the Environmental Protection Plan L-17-052, Supplemental Request Associated with the License Amendment Request for Upper Containment Pool (Ucp) Gate Installation in Modes 1, 2, and 3, and Drain-Down of the Reactor Cavity Portion of the Ucp in Mode 32017-02-0606 February 2017 Supplemental Request Associated with the License Amendment Request for Upper Containment Pool (Ucp) Gate Installation in Modes 1, 2, and 3, and Drain-Down of the Reactor Cavity Portion of the Ucp in Mode 3 L-16-179, License Amendment Request to Reduce the Reactor Steam Dome Pressure Specified in Technical Specification 2.1.1. Reactor Core Safety Limits.2016-11-0101 November 2016 License Amendment Request to Reduce the Reactor Steam Dome Pressure Specified in Technical Specification 2.1.1. Reactor Core Safety Limits. L-16-236, License Amendment Request for Adoption of Technical Specifications Task Force (Tstr Traveler TSTF-501. Revision 1. Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control2016-10-27027 October 2016 License Amendment Request for Adoption of Technical Specifications Task Force (Tstr Traveler TSTF-501. Revision 1. Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control L-16-304, Supplement to Request for License Amendment Approval Delay2016-10-25025 October 2016 Supplement to Request for License Amendment Approval Delay L-16-083, License Amendment Request for Upper Containment Pool (Ucp) Gate Installation in Modes 1, 2, and 3, and Drain-Down of the Reactor Cavity Portion of the Ucp in Mode 32016-03-15015 March 2016 License Amendment Request for Upper Containment Pool (Ucp) Gate Installation in Modes 1, 2, and 3, and Drain-Down of the Reactor Cavity Portion of the Ucp in Mode 3 L-15-195, Application for Order Consenting to Transfer of Licenses and Approving Conforming License Amendments2015-06-30030 June 2015 Application for Order Consenting to Transfer of Licenses and Approving Conforming License Amendments L-14-271, Request for Licensing Action to Amend Technical Specification 3.8.4, DC Sources - Operating2014-11-24024 November 2014 Request for Licensing Action to Amend Technical Specification 3.8.4, DC Sources - Operating L-13-306, Request for Licensing Action Pursuant to 10 CFR 50.59. 50.67. and 50.90: Full Implementation of Alternative Accident Source Term Design Basis Accident Analyses. and an Associated Technical Specification Change2013-12-0606 December 2013 Request for Licensing Action Pursuant to 10 CFR 50.59. 50.67. and 50.90: Full Implementation of Alternative Accident Source Term Design Basis Accident Analyses. and an Associated Technical Specification Change ML13281A5362013-10-15015 October 2013 Meeting Slide for FENOC Presubmittal Guidance Checklist Part I L-12-397, Request to Amend the Price-Anderson Indemnities and Notification of a Name Change to Documents of Regulatory Interest2013-02-19019 February 2013 Request to Amend the Price-Anderson Indemnities and Notification of a Name Change to Documents of Regulatory Interest ML12249A3592012-09-0505 September 2012 License Amendment Request for Adoption of TSTF-275-A, Rev. 0, Clarify Requirement for EDG Start Signal on Rpv... & TSTF-300-A L-12-064, Request for an Amendment to Revise Technical Specification 3.10.1. Inservice Leak and Hydrostatic Testing Operation, Using the Consolidated Line Item Improvement Process2012-02-22022 February 2012 Request for an Amendment to Revise Technical Specification 3.10.1. Inservice Leak and Hydrostatic Testing Operation, Using the Consolidated Line Item Improvement Process L-11-331, License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating.2011-10-11011 October 2011 License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating. L-11-322, License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating.2011-10-0303 October 2011 License Amendment Request Regarding Use of a Delayed Access Circuit as a Required Offsite Circuit in Technical Specification 3.8.1, AC Sources - Operating. ML1126402462011-09-20020 September 2011 License Amendment Request to Change the Name of an Owner Licensee to Firstenergy Nuclear Generation, LLC L-11-038, License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation2011-04-12012 April 2011 License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation L-10-200, License Amendment Request to Modify Technical Specification 3.1.4, Control Rod Scram Times, to Incorporate TSTF-222-A, Revision 12010-12-15015 December 2010 License Amendment Request to Modify Technical Specification 3.1.4, Control Rod Scram Times, to Incorporate TSTF-222-A, Revision 1 ML1029804462010-10-21021 October 2010 License Amendment Request to Modify Technical Specification 2.1.1, Reactor Core Sls, to Incorporate Revised Safety Limit Minimum Critical Power Ratio Values L-09-074, License Amendment Request to Provide Consistency in Division 3 Emergency Diesel Generator Start Time Technical Specification Surveillance Requirements2009-06-30030 June 2009 License Amendment Request to Provide Consistency in Division 3 Emergency Diesel Generator Start Time Technical Specification Surveillance Requirements L-09-025, ISFSI, and Perry, Application for Technical Specification (TS) Change for Adoption of TSTF-511 Revision 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26.2009-03-25025 March 2009 ISFSI, and Perry, Application for Technical Specification (TS) Change for Adoption of TSTF-511 Revision 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26. L-09-031, Application for Technical Specification Change Regarding Revision of Control Rod Application for Technical Specification Change Regarding Revision of Control2009-03-11011 March 2009 Application for Technical Specification Change Regarding Revision of Control Rod Application for Technical Specification Change Regarding Revision of Control ML0906306722009-03-0909 March 2009 Enclosure 14: Case Study 10: Perry Inability to Follow the RHR-SDC Required - Meeting Summary of the January 27 & 28 Meeting with Nrc/Tstf L-08-325, License Amendment Request No. 08-18 to Incorporate Technical Specification Task Force Travelers 479 and 4972008-11-18018 November 2008 License Amendment Request No. 08-18 to Incorporate Technical Specification Task Force Travelers 479 and 497 L-08-046, Request to Adopt TSTF-476-A, Improved BPWS Control Rod Insertion Process (NEDO-33091), Per the Consolidated Line Item Improvement Process2008-02-20020 February 2008 Request to Adopt TSTF-476-A, Improved BPWS Control Rod Insertion Process (NEDO-33091), Per the Consolidated Line Item Improvement Process 2024-01-24
[Table view] |
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FENOC "10 Perry Nuclear Power Plant Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081.
Richard Anderson 440-280-5579 Vice President-Nuclear Fax: 440-280-8029 November 15, 2005 PY-CEI/NRR-2917L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10 CFR 50.90: Clarify Wording of Emergency Closed Cooling Water Surveillance Requirement 3.7.10.2 A license amendment is requested for the Perry Nuclear Power Plant (PNPP). The requested change modifies the Technical Specifications to clarify the wording of Emergency Closed Cooling Water Surveillance Requirement (SR) 3.7.10.2. Approval of the proposed license amendment is requested by November 15, 2006, to be implemented within 90 days following issuance of the amendment. The approval date was administratively selected to allow for Nuclear Regulatory Commission (NRC) review; the plant does not need this amendment by that date in order to continue safe full power operations.
Attachment 1 describes the change, including an Introduction, Description of Proposed Change, Technical Analysis, Regulatory Analysis, and Environmental Consideration. Attachment 2 provides the Significant Hazards Consideration. Attachment 3 provides a markup of the Technical Specification page. Attachment 4 provides a markup of the Bases pages, for information. Bases changes will be made in accordance with the PNPP Bases Control Program.
Attachment 5 provides a retyped Technical Specification page.
There are no regulatory commitments contained in this letter or its attachments. If there are any questions concerning this matter, please contact Mr. Gregory A. Dunn, Manager - Fleet Licensing, at (330) 315-7243.
Very truly yours, .
for Rc n n Attachr~t cc: NRC Project Manager NRC Resident Inspector NRC Region IlIl State of Ohio A0
I, Alfred J. Cayia l1l, hereby affirm that (1) I am Director, Perry Performance Improvement Department of the FirstEnergy Nuclear Operating Company, (2) I am duly authorized to execute and file this certification as the duly authorized agent for The Cleveland Electric Illuminating Company, Toledo Edison Company, Ohio Edison Company, and Pennsylvania Power Company, and (3) the statements set forth herein are true and correct to the.best of my knowledge, information and belief.
Subscribed to and affirmed before me, the 154 day of NWo\Icr, 200S.
4j P -
KAREN L. JOHNSON Notary Public. State of Ohio my Commission Expires 215108 Recorded In Lake County
Attachment I PY-CEI/NRR-291 7L Page 1 of 2 Introduction A license amendment is requested for the Perry Nuclear Power Plant (PNPP). The requested change modifies the Technical Specifications to clarify the wording of Emergency Closed Cooling Water Surveillance Requirement 3.7.10.2. This will resolve a corrective action in the PNPP Corrective Action Program.
Description of Proposed Change Revise Technical Specification (TS) Surveillance Requirement (SR) 3.7.10.2 for the Emergency Closed Cooling Water (ECCW) System Specification to clarify that this SR verifies actuation of the entire ECCW system rather than just verifying Ovalve" actuation.
Technical Analysis The current wording of SR 3.7.10.2 requires that automatic valves in ECCW actuate on an actuation signal. However, the Bases for the SR identify that more than just valves are tested; they state that
'This Surveillance also verifies the automatic start capability of the ECCW pump in each subsystem."
Therefore, the wording of this SR is revised to clarify that its purpose is to verify actuation of the entire ECCW system, rather than just verifying "valve' actuation. This change makes the SR 3.7.10.2 wording consistent with the more "standard" wording of the system actuation SRs in Section 3.7 of the Technical Specifications, such as the SRs for Specifications 3.7.1, 3.7.2, and 3.7.3.
Copies of these other SRs are included in Attachment 3, pages 1, 2 and 3, for comparison purposes.
The improved Standard Technical Specification (iSTS) document (NUREG-1434) provides the standard wording for system actuation SRs in TS 3.7.1, 3.7.2, and 3.7.3. However, NUREG-1434 does not include an ECCW Specification, because ECCW is a PNPP-specific design. The PNPP ECCW system is a closed loop system designed to provide a heat sink, during a Design Basis Accident (DBA) or transient, for safety-related components in systems such as the low-pressure Emergency Core Cooling System (ECCS) subsystems. ECCW then transfers that heat to the Emergency Service Water (ESW) system, which transports the heat to Lake Erie. More details on the ECCW system are provided in the Bases for TS 3.7.10 and in Updated Safety Analysis Report (USAR) Section 9.2.2.
During development of the PNPP iSTS there was no direct template for the wording of PNPP SR 3.7.10.2, since NUREG-1434 did not include an ECCW Specification. Therefore, wording similar to the original PNPP surveillance requirement was incorporated. That non-standard wording focused on valve actuation, since the original ECCW design required several valves to close after an accident to isolate the safety-related ECCW system from a non-safety cooling water system. The overall system actuation was only addressed in the Bases. Since that time, the physical boundary for the safety-related ECCW subsystems has been made passive. It is therefore appropriate to revise the SR wording to reflect actuation of the total system, consistent with the standard wording of SRs in TS 3.7.1, 3.7.2, and 3.7.3. This is accomplished by revising the SR to read "Verify each ECCW subsystem actuates on an actual or simulated initiation signal."
Changing these words also helps to eliminate another possible misinterpretation. Several Unit 2 and "Common" ECCW valves were kept in service when Unit 2 was abandoned. Those Unit 2 ECCW valves have no link with the Unit 1 ECCW system, which is the system covered by LCO 3.7.10.
However, the current wording of SR 3.7.10.2 could be misinterpreted to apply to the Unit 2 ECCW valves. These Unit 2/Common ECCW valves were kept in service to provide a support function for
Attachment I PY-CEI/NRR-2917L Page 2 of 2 the Unit 1 ESW system, not ECCW. As described in USAR Section 9.2.2.6, the safety-related Unit 1 ESW system is cross-tied into a portion of the Unit 2 ECCW piping so ESW can provide cooling of the Fuel Pool heat exchangers if the normal, non-safety heat exchanger cooling system is lost. In accordance with the Bases Control Program, a Bases change will be processed to clarify this by explaining that the Unit 2 ECCW valves are not related to OPERABILITY of the Unit 1 ECCW subsystems - see example Bases markups in Attachment 4, for information only.
The proposed change to ECCW SR 3.7.10.2 simply rewords the SR to include requirements already stated in the Bases. The existing test procedures already include verification of the ECCW pump start, therefore rewording of the TS SR does not change the method of testing currently being performed on associated components. The reworded SR more clearly states that the ECCW system's total actuation capability must continue to be tested.
Regulatory Analysis This change is consistent with the BWR iSTS format and intent. There are no regulations or Regulatory Guides directly applicable to the wording of this SR. There are no known industry precedents, since the need for correction of the PNPP Technical Specifications is due to the PNPP-specific nature of the existing requirement. Proposed Bases markups are provided in Attachment 4, for information.
Environmental Consideration The proposed Technical Specification change was evaluated against the criteria of 10CFR51.22 for environmental considerations. The proposed change does not significantly increase individual or cumulative occupational radiation exposures, does not significantly change the types or significantly increase the amounts of effluents that may be released off-site and, as discussed in Attachment 2, does not involve a significant hazards consideration. Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in 10CFR51 .22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.
Attachment 2 PY-CEI/NRR-291 7L Page 1 of 2 SIGNIFICANT HAZARDS CONSIDERATION The proposed amendment is requesting Nuclear Regulatory Commission review and approval of changes to the Perry Nuclear Power Plant (PNPP) Technical Specifications (TS).
The change revises TS Surveillance Requirement (SR) 3.7.10.2 for the Emergency Closed Cooling Water (ECCW) System specification. The SR wording is revised to clarify that this SR verifies actuation of the entire ECCW system rather than just verifying 'valve" actuation.
The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Nuclear Regulatory Commission's regulation, 10 CFR 50.92, which states that the operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any previously evaluated; or (3) involve a significant reduction in a margin of safety.
The proposed amendment has been reviewed with respect to these three factors, and it has been determined that the proposed change does not involve a significant hazard because:
- 1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
There are no physical modifications being made to any plant system or component. The only change is to a Surveillance Requirement within the Technical Specifications, in order to improve understanding and avoid misinterpretation of the requirements. The original intent of ECCW SR 3.7.10.2 is maintained by the change being proposed. The revised Technical Specification requirements do not impact initiators of previously evaluated accidents or transients.
The specification being revised is associated with a system used to mitigate the consequences of accidents. The change to the wording of ECCW SR 3.7.10.2 does not impact the capability of the associated system to perform its required function. The reworded ECCW SR more clearly requires that the systems total actuation capability be maintained.
The change does not affect how plant systems are controlled or operated or tested. The change continues to provide confirmation of the capability of plant components to respond as required to mitigate the consequences of events.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
There are no physical modifications being made to any plant system or component, and the proposed change introduces no new method of operation of the plant, or its systems
Attachment 2 PY-CEI/NRR-291 7L Page 2 of 2 or components. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. The proposed change does not involve a significant reduction in a margin of safety.
The change to the ECCW SR continues to ensure the ECCW subsystems are tested on the same periodicity to verify their capability to respond to actuation signals from the Emergency Core Cooling System (ECCS) Instrumentation Functions of Low Water Level and High Drywell Pressure. Therefore, the necessary function of the Technical Specification requirements is maintained, and the proposed change does not involve a significant reduction in a margin of safety.
Based upon the reasoning presented above, the requested change does not involve a significant hazards consideration.
Attachment 3 PY-CEIINRR-2917L ESW System-Div. 1 and 2 Page 1 of 4 3.7.1 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met.
B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both ESW Division 1 and Division 2 subsystems inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each required Division 1 and 2 ESW 31 days subsystem manual, power operated; and automatic valve in the flow path servictih safety related systems or components, that is not locked. sealed, or otherwise secured in position. is in the correct jbsition.
SR 3.7.1.2 Verify each required Division 1 and 2 ESW 24 months subsystem actuates on an actual or simulated initiation signal./
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Attachment 3 PY-CEI/NRR-2917L ESW System-Div. 3 Page 2 of 4 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Service Water (ESW) System-Division 3 LCO 3.7.2 The Division 3 ESW subsystem shall be OPERABLE.
APPLICABILITY: MODES 1. 2. and 3.
ACTIONS . ._._-_.-
CONDITION' REQUIRED ACTION COMPLETION TIME A. ESW Division .3 A.1 Declar'e High Pressure.! Immediately subsystem inoperable. Core'Spray System
-inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY.
SR 3.7.2.1 Verify each required Division 3 ESW31 days subsystem manual, power operated. and automatic valve in the flow path'servicing safety related systems or compon~eftt, that is not locked. sealed. or otherwise secur-ed in position, Is Inthe correct positipr,.
SR 3.7.2.2 Verify the Division 3 ESW subsystem 24 months actuates on an actual or simulated initiation signal.l Pr?3viA-0+0 Sou~ &dK
-Sr rQ~A~or~ 5 ,;,. E-c.,Z SK D LCO 3.7,1o.
PERRY - UNIT I 3.7-3 Amendment No. 115 PY-CEI/NRR-2917L CRER System Page 3 of 4 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRER subsystems E.1 Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in
-irradiated fuel the primary assemblies in the containment and fuel primary containment or handling building.
fuel handling bil.dingior during OPDRVs.'
E.2 Initiate action to Immediatel suspend OPDRVs. -
.~~~~. ...... .......
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRER subsystem for 31 days k 10 continuous hours With the heaters operating."
SR 3.7.3.2 Perform required CRER filter testing in In accordance accordance with the.Ventilation Filter with the VFTP Testing Program (VFTP).
SR 3.7.3.3 Verify each CRER subsystem actuates on an 24 months actual or simula'ted initiation signal.
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PERRY - UNIT 1 3.7-6 Amendment No. 115
Attachment 3 PY-CEI/NRR-291 7L ECCW System Page 4 of 4 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE. FREQUENCY SR 3.7.10.1 Verify each reculredOECCW subsystem manual. 31 days power operated, and automatic valve in the flow path, that is not locked. sealed. or otherwise secured in posit-ion, is in the correct position or can be aligned to the correct. positon.
SR 3.7.10.2 Verify each cft..
ECCW rr-HBd eactuates 24 months I
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PERRY - UNIT 1 3.7-20 Amendment No. 115
Attachment 4 PY-CEI/NRR-291 7L ECCW System Page 1 of 2 B 3.7.10 BASES RHEUM OWLS APPLICABLE The ECCW System satisfies Criterion 3 of the NRC Policy SAFETY ANALYSES Statement.
(continued)
LCO In the event of a DBA. one ECCW subsystem is required to provide the minimum heat removal capability assumed in the safety analysis for the systems to which it supplies cooling water. To ensure this requirement is met, two ECCW subsystems must be OPERABLE. At least one ECCW subsystem will operate assuming the worst single active failure occurs coincident with the loss of offsite power.
An ECCW subsystem is considered OPERABLE when:
- a. The associated pump and surge tank are OPERABLE: and
- b. The associated piping. valves, heat exchanger. and instrumentation and controls required to perform the safety related function are OPERABLE.
The isolation of ECCW to other components or systems may render those components or systems inoperable. but does not affect the OPERABILITY of the ECCW System.
JO APPLICABILITY In MODE 1. the ECCW subsystems are in standby except when required to support RHR. LPCS. or RCIC System operations and testing. In MODES 2 and 3. the ECCW System is operated as necessary to support hot standby conditions or normal plant shutdown and cooldown using the RHR System.
InMODES 4 and 5. the requirements of the ECCW System are determined by the systems they support (Ref. 2).
(continued)
Several valves exist With Unit 2 or"Common" ECCW componen identification numbers (2P42 or OP42), which can be used to align the Unit 1 Emergency Service Water (ESW) system to the spent fuel pool heat exchangers. However, those Unit 2 and "Common" valves are not associated with OPERABILITY of the Unit 1 ECCW subsystems addressed by this LCO.
PERRY - UNIT 1 B 3.7-42 Revision No. 2
Attachment 4 PY-CEI/NRR-291 7L ECCW System Page 2 of 2 B 3.7.10 0ZFFI flu 0 !1" 'Y BASES SURVEILLANCE SR 3.7.10.1 (continued)
REQUIREMENTS Isolation of the ECCW subsystem to components or systems does not necessarily affect the OPERABILITY of the ECCW subsystem. As such, when the ECCW subsystem pump, valves.
and piping are OPERABLE. but a branch connection off the main header is isolated. the associated ECCW subsystem needs to be evaluated to determine if it is still OPERABLE.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
SR 3.7.10.2 This SR verifies that Division 1 and 2 ECC s n-I Simuatedinitiation signan, hy ukre5rver~i-aee-*se\:
(;J K' -the automatic starf/capability of the ECCW pump in eac s"ubsystem.. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this Surveillance to provide complete testing of the safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 24 month Frequency is based on operating experience. and is consistent with a typical industry refueling cycle.
REFERENCES 1. USAR, Section 9.2.2.
- 2. Plant Data Book. Tab R. Section 6.4.9.
PERRY - UNIT 1 B 3.7-44 Revision No. 3
Attachment 5 PY-CEI/NRR-291 7L PROPOSED RETYPED TECHNICAL SPECIFICATION PAGE (1 page follows)
ECCW System 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Verify each required ECCW subsystem manual. 31 days power operated, and automatic valve in the flow path, that is not locked. sealed. or otherwise secured in position, is in the correct position or can be aligned to the correct position.
SR 3.7.10.2 Verif each ECCW subsystem actuates on an 24 months actual or simulated initiation signal.
PERRY - UNIT 1 3.7-20 Amendment No.