ML061240248

Safety Evaluation for Administrative Changes to the Technical Specifications (Clarification)

ML061240248
Person / Time
Site:	Perry
Issue date:	05/09/2006
From:	Kobetz T NRC/NRR/ADRO/DIRS/ITSB
To:	Dan Collins NRC/NRR/ADRO/DORL/LPLF
Hearn, P, NRR/DIRS, 301-415-1189
References
Download: ML061240248 (4)

Text

May 9, 2006 MEMORANDUM TO: Daniel S. Collins, Acting Chief Pant Licensing Branch F Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Timothy J. Kobetz, Chief /RA/

Technical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation

SUBJECT:

PERRY NUCLEAR POWER PLANT UNIT 1 SAFETY EVALUATION FOR ADMINISTRATIVE CHANGES TO THE TECHNICAL SPECIFICATIONS (TS)

By the letter dated November 15, 2005, the FirstEnergy Nuclear Operating Company, the licensee, submitted a License Amendment Request (LAR) to revise the technical specifications (TS) of the Perry Nuclear Power Plant, Unit 1. The licensee is requesting to revise TS Section 3.7.10, Emergency Closed Cooling Water System in order to clarify wording in Surveillance Requirement 3.7.10.2. The attached Safety Evaluation addresses the proposed administrative Technical Specifications changes. Our SER concludes the licensees administrative TS revisions are acceptable.

Enclosure:

As stated CONTACT: Pete Hearn, NRR 301-415-1189 pch@nrc.gov

ML061240248 OFFICE TSS:IROB:DIPM SC:TSS:IROB:DIPM NAME PCHearn TJKobetz DATE 05/09/2006 05/09/2006 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTS TO FACILITY OPERATING LICENSE PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET N0. 50-440

1. INTRODUCTION Pursuant to 10 CFR 50.90, on November 15, 2005, FirstEnergy Nuclear Operating Company, the licensee, submitted a License Amendment Request (LAR) to amend the Perry Nuclear Power Plant, Unit 1 License. The LAR proposes to revise the Perry Nuclear Power Plant Technical Specifications (TS) to clarify the wording to Surveillance Requirement (SR) 3.7.10.2 of the Emergency Closed Cooling Water (ECCW) System TS. The current wording of SR 7.10.2 requires verification that the automatic valves actuate on an actuation signal. The Bases for SR 3.7.10.2 identifies more than the valves require testing; this Bases also requires the verification of the automatic start capability of the ECCW pump in each subsystem.

Therefore, the licensee is proposing to revise the SR wording to clarify that the SR requires the verification of the actuation of the entire ECCW System.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (Act) requires applicants for nuclear power plant operating licenses to include technical specifications as part of the license. These technical specifications are derived from the plant safety analyses.

The staff reviewed the proposed changes for compliance with 10 CFR 50.36 and agreement with the precedent as established in NUREG-1431. In general, licensees cannot justify technical specification changes solely on the basis of adopting the model STS. To ensure this, the staff makes a determination that proposed changes maintain adequate safety. Changes that result in relaxation (less restrictive condition) of current TS requirements require detailed justification.

In general, there are two classes of changes to technical specifications: (1) changes needed to reflect contents of the design basis (technical specifications are derived from the design basis),

and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of technical specifications over time. This amendment deals with the second class of change; namely, administrative changes that reflect the current configuration of the plant.

Licensees may revise the technical specifications to adopt improved standard technical specification format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensees current requirement, or (3) the change is less restrictive than the licensees current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.

Enclosure

3.0 TECHNICAL EVALUATION

The Licensees TS revision proposes to make changes that are editorial, administrative or provide clarification. In order for these changes to be acceptable the staff must determine that the editorial, administrative and clarification changes do not alter the TS requirements.

The licensee proposes to revise the Perry Nuclear Power Plant Technical Specifications (TS) to clarify the wording to Surveillance Requirement (SR) 3.7.10.2 of the Emergency Closed Cooling Water (ECCW) System TS. The proposed revision involves applying the SR to the entire ECCW System rather than just the automatic valves. The proposed revision brings SR 3.7.10.2 within the requirements in the TS Bases 3.7.10 to test the entire ECCW System.

The staff concludes that the licensees proposed changes are acceptable since they maintain plant safety by satisfying the Perry TS Bases and conform to the requirements of 10 CFR 50.36.

4.0 Conclusion The licensees proposed changes in this LAR are editorial in nature, reflect the current configuration of the plant and do not change the TS requirements. The staff finds the proposed changes are technically justified, comply with 10 CFR 50.36 and are consistent with the standard technical specifications. On this basis, the NRC staff concludes that the proposed changes to the TS of the Perry Nuclear Power Plant are acceptable.

The Commission has concluded, on the basis of considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and, (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.