ML053260443

License Amendment Request Pursuant to 10 CFR 50.90: Clarify Wording of Emergency Closed Cooling Water Surveillance Requirement 3.7.10.2

ML053260443
Person / Time
Site:	Perry
Issue date:	11/15/2005
From:	Richard Anderson FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PY-CEI/NRR-2917L
Download: ML053260443 (14)

Text

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

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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. -

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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.