Letter Sequence Response to RAI |
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MONTHYEARML0519402052005-07-0505 July 2005
License Amendment Request Pursuant to 10CFR50.90: Revision of Technical Specification Surveillance Requirement 3.3.1.3.5 Which Revises the Enabled Region for the Oscillation Power Range Monitors
Project stage: Request
ML0600604842006-01-17017 January 2006
RAI Related to Oscillation Power Range Monitors
Project stage: RAI
ML0608906522006-03-22022 March 2006
Response to a Request for Additional Information Associated with a Proposed License Amendment Request to Revise the Oscillation Power Range Monitors Enabled Region
Project stage: Response to RAI
ML0618700962006-06-30030 June 2006
Technical Specification, Modifies the Existing TS 3.3.1.3, Oscillation Power Range Monitor (OPRM) Instrumentation, Surveillance Requirement 3.3.1.3.5
Project stage: Other
ML0611605772006-06-30030 June 2006
Amendment, Modifies the Existing TS 3.3.1.3, Oscillation Power Range Monitor (OPRM) Instrumentation, Surveillance Requirement 3.3.1.3.5
Project stage: Other
2006-01-17
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Text
FENOC 1%10 Perry Nuclear Powrer Station Center Road FirstEnergyNuclear Operating Company Perry Ohio 44081 L. William Pearce 440-280-5382 Vice President Fax: 440-280-8029 March 22, 2006 PY-CEI/NRR-2942L 10 CFR 50.90 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440
- Response to a Request for Additional Information Associated with a Proposed License Amendment Request to Revise the Oscillation Power Range Monitors Enabled Region (TAC NO. MC7489)
Ladies and Gentlemen:
This letter provides the response to the Nuclear Regulatory Commission Request for Additional Information dated January 17, 2006 pertaining to the Perry Nuclear Power Plant License Amendment Request (LAR) submitted on July 5, 2005 (PY-CEI/NRR-2853L). The LAR would modify Technical Specification (TS) 3.3.1.3, 'Oscillation Power Range Monitor (OPRM) Instrumentation," Surveillance Requirement (SR) 3.3.1.3.5 by changing the thermal power level at which the OPRMs are "not bypassed" (enabled to perform their design function) from > 28.6% rated thermal power to 2 23.8% rated thermal power.
There are no regulatory commitments contained in this letter or its attachment.
If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager - FENOC Fleet Licensing, at (330) 315-7243.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March 22, 2006.
L. W. Pearce
Attachment:
- 1. Response to a Request for Additional Information cc: NRC Project Manager NRC Resident Inspector NRC Region III State of Ohio
(
ou
Attachment 1 PY-CEI/NRR-2942L Page 1 of 2 Response to a Request for Additional Information By letter dated January 17, 2006, the Nuclear Regulatory Commission (NRC) requested additional information relative to a license amendment request made by the FirstEnergy Nuclear Operating Company (FENOC) regarding a modification to Technical Specification (TS) 3.3.1.3, 'Oscillation Power Range Monitor (OPRM) Instrumentation," for the Perry Nuclear Power Plant (PNPP). This submittal provides the response to the NRC request.
- 1. NRC Request:
On page 1 of the cover letter, the second paragraph states that the Perry Nuclear Plant, Unit 1 (Perry) is currently operating with the oscillation power range monitors enabled at >23.8-percent rated thermal power. This is below the TS value of 28.6-percent rated thermal power. Please document the historical basis for the
-- 238-percent rated thermal power value.
- 1. Response:
Licensing Topical Report NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996, requires the OPRM Trip function to be enabled when the power level is greater than 30% of rated and the core flow is less than 60% of rated. Below 30% rated thermal power or above 60% rated core flow, thermal hydraulic instabilities are not expected to occur. Above 30% rated thermal power and less than 60% rated core flow, the potential for thermal hydraulic instabilities exists; hence, the OPRMs must be capable of detecting and suppressing power oscillations to ensure the Minimum Critical Power Ratio (MCPR)
Safety Limit is not exceeded should an instability event occur.
In April 2000, a License Amendment Request (LAR) to incorporate the OPRM instrumentation into the Perry TS was submitted to the NRC for review and approval.
The proposed OPRM Limiting Condition of Operability (LCO) Applicability was 225% rated thermal power. This value was chosen to be consistent with the Applicability conditions for the LCOs included in TS Section 3.2, "Power Distribution Limits." The power level proposed for enabling the OPRM trip function (capable of causing a Reactor Protection System channel trip) was > 30% rated thermal power.
PNPP implemented a power uprate to 105% power during Summer 2000. In order to -
maintain the percent of rated power values listed in the TS Applicability, Required Action, and Surveillance Requirement sections consistent with the pre-uprate thermal power levels, the percent of rated power values were adjusted by dividing the value by 1.05. For example, the LCO Applicability conditions of TS Section 3.2 were revised to 293.8% rated thermal power (25% divided by 1.05).
In January 2001, a revision to the OPRM LAR was submitted to change the proposed OPRM LCO Applicability to Ž23.8% rated thermal power to maintain consistency with the Applicability conditions of TS Section 3.2. Additionally, the power level proposed for enabling the OPRM trip function was reduced to > 28.6% rated thermal power (30%
divided by 1.05). The OPRM LAR was approved in February 2001 and implemented in March 2001.
Attachment 1 PY-CEI/NRR-2942L Page 2 of 2 Due to a number of issues associated with the OPRMs, General Electric issued a 10CFR21 notification regarding the operability of the OPRMs in June 2001. The resolution of these issues was to perform plant-specific OPRM calculations. In August 2004, when the OPRMs were restored to operability, the power level used for enabling the OPRM trip function was 23.8% rated thermal power. This is conservative with respect to the current TS value of > 28.6% rated thermal power.
- 2. NRC Request:
On page 4 of Attachment 2, the fourth paragraph states that General Electric developed an analytical method which can be used to explain the interactive corrective action (ICA) and enabled regions. The methodology is called backup stability protection (BSP) analysis and is used to redraw the power to flow map.
The BSP analysis uses plant-specific inputs to develop decay ratios. The decay ratios are then used to adjust the ICA regions in order to provide stability protection. Please summarize the Perry-specific applicability for decay ratio.
- 2. Response:
The PNPP fuel and core designs are developed in accordance with the NRC-approved Licensing Topical Report NEDE-2401 1-P-A, "General Electric Standard Application for Reactor Fuel," (GESTAR II) (reference PNPP Updated Final Safety Analysis Report, Section 4.2). This topical report describes the processes by which the fuel vendor develops fuel and core designs, and how these designs are evaluated and limits are established.
GESTAR II, Section 1.2.8, Stability, states that new fuel designs and core designs will be evaluated for stability concerns. To accomplish this, a decay ratio analysis will be performed using the ODYSY procedure and ODYSY computer code.
The current version of the ODYSY procedure and ODYSY computer code are discussed in the NRC-approved Licensing Topical Report, NEDC-32992P-A, "ODYSY, Application for Stability Licensing Calculations," July 2001. This version of the ODYSY procedure and computer code was approved for incorporation into Amendment 27 of GESTAR II as documented in an NRC Safety Evaluation dated July 16, 2004.
The Perry-specific decay ratio paramfietes ued in'the current PNPP Cycle 11 fuel and -
core design stability evaluation were developed using this version of the ODYSY procedure and computer code.
