ML063250127

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Correction of Safety Evaluation for Amendment Dated October 27, 2006
ML063250127
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 11/30/2006
From: Marshall M
NRC/NRR/ADRO/DORL/LPLIII-2
To: Pearce L
FirstEnergy Nuclear Operating Co
Wengert, Thomas
References
TAC MC8970
Download: ML063250127 (6)


Text

November 30, 2006 Mr. L. W. Pearce Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1 - CORRECTION OF SAFETY EVALUATION FOR AMENDMENT DATED OCTOBER 27, 2006 (TAC NO.

MC8970)

Dear Mr. Pearce:

On October 27, 2006, the Nuclear Regulatory Commission (NRC) issued Amendment No. 139, to Facility Operating License No. NPF-58, for the Perry Nuclear Power Plant, Unit 1. The amendment was in response to your application dated November 15, 2005.

The amendment modified the technical specifications to clarify the wording of emergency closed cooling water (ECCW) Surveillance Requirement (SR) 3.7.10.2. This letter transmits a correction to the NRC staffs safety evaluation (SE) associated with the aforementioned amendment number. The correction deletes an incorrect clause describing how the physical boundary of the safety-related ECCW system subsystems have been made passive.

The NRC staff has resolved this error by correcting the appropriate section in the SE, which did not impact the conclusions of the NRC staffs original SE. The corrected SE page is included as an enclosure to this letter and replaces the associated page in the original NRC staffs SE.

If there are any questions concerning this matter, please contact Tom Wengert at (301) 415-4037.

Sincerely,

/RA/

Michael L. Marshall, Jr., Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Corrected SE page 2 cc w/encls: See next page

Mr. L. W. Pearce November 30, 2006 Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1 - CORRECTION OF SAFETY EVALUATION FOR AMENDMENT DATED OCTOBER 27, 2006 (TAC NO.

MC8970)

Dear Mr. Pearce:

On October 27, 2006, the Nuclear Regulatory Commission (NRC) issued Amendment No. 139, to Facility Operating License No. NPF-58, for the Perry Nuclear Power Plant, Unit 1. The amendment was in response to your application dated November 15, 2005.

The amendment modified the technical specifications to clarify the wording of emergency closed cooling water (ECCW) Surveillance Requirement (SR) 3.7.10.2. This letter transmits a correction to the NRC staffs safety evaluation (SE) associated with the aforementioned amendment number. The correction deletes an incorrect clause describing how the physical boundary of the safety-related ECCW system subsystems have been made passive.

The NRC staff has resolved this error by correcting the appropriate section in the SE, which did not impact the conclusions of the NRC staffs original SE. The corrected SE page is included as an enclosure to this letter and replaces the associated page in the original NRC staffs SE.

If there are any questions concerning this matter, please contact Tom Wengert at (301) 415-4037.

Sincerely,

/RA/

Michael L. Marshall, Jr., Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Corrected SE page 2 cc w/encls: See next page DISTRIBUTION:

PUBLIC RidsNrrLAEWhitt GHill, OIS (2)

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PERRY NUCLEAR POWER PLANT, UNIT 1 -

CORRECTION TO OCTOBER 27, 2006, SAFETY EVALUATION PAGE 2 ENCLOSURE

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the proposed change for compliance with 10 CFR 50.36 and for consistency with the precedent established in NUREG-1434, Standard Technical Specifications [STSs] General Electric Plants, BWR/6. The change would make the SR 3.7.10.2 wording consistent with the more standard wording of the system actuation SRs in TS 3.7.1, [Standby Service Water (SSW)] System and [Ultimate Heat Sink (UHS)];

TS 3.7.2, High Pressure Core Spray (HPCS) Service Water System (SWS); and TS 3.7.3,

[Control Room Fresh Air (CRFA)] System, of NUREG-1434. In the licensees amendment request dated November 15, 2005, the licensee noted that an ECCW specification is not included in NUREG-1434 because the ECCW system is a Perry-specific plant design.

The current wording of SR 3.7.10.2 requires that automatic valves in ECCW actuate on an actuation signal. However, the TS Bases for the SR identify that more than just valves are tested. The TS Bases state, This Surveillance also verifies the automatic start capability of the ECCW pump in each subsystem. During development of the Perry improved STSs, no direct template existed for the wording of SR 3.7.10.2, since NUREG-1434 did not include an ECCW specification. Therefore, wording similar to the original Perry TS SR was incorporated. The non-standard wording focused on valve actuation, since the original ECCW system 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 TS 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 of NUREG-1434. This is accomplished by revising SR 3.7.10.2 to read, Verify each ECCW subsystem actuates on an actual or simulated initiation signal.

The licensees amendment request rewords SR 3.7.10.2 to more clearly state that the actuation capability of the entire ECCW system must continue to be tested. This change also ensures consistency with the standard wording in SRs for TSs 3.7.1, 3.7.2, and 3.7.3 as described in NUREG-1434 and for verifying the overall system actuation as described in the Perry TS Bases. The NRC staff determined that this is an administrative clarification and the rewording of SR 3.7.10.2 does not change the technical content of the specification.

The NRC staffs position, in general, is that there are two classes of TS changes: (1) changes needed to reflect contents of the design basis (as mentioned above, TSs 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 TSs over time.

The NRC staff concludes that this amendment involves the second class of changes; namely, administrative changes that reflect the current configuration of the plant and consistency with the TS Bases. Furthermore, the licensees proposed changes are acceptable since they conform to the standard wording in NUREG-1434 and continue to meet the requirements of 10 CFR 50.36, and 10 CFR Part 50, Appendix A, Criterion 44.

Perry Nuclear Power Plant, Unit 1 cc:

David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-18 76 South Main Street Akron, OH 44308 Resident Inspector's Office U.S. Nuclear Regulatory Commission P.O. Box 331 Perry, OH 44081-0331 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road Lisle, IL 60532-4531 Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, OH 44060 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A210 P.O. Box 97, 10 Center Road Perry, OH 44081-0097 Mayor, Village of North Perry North Perry Village Hall 4449 Lockwood Road North Perry Village, OH 44081 Donna Owens, Director Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 Reynoldsburg, OH 43068-9009 Carol OClaire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235-7150 Mayor, Village of Perry P.O. Box 100 Perry, OH 44081-0100 Dennis Clum Radiological Assistance Section Supervisor Bureau of Radiation Protection Ohio Department of Health P.O. Box 118 Columbus, OH 43266-0118 Zack A. Clayton DERR Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149 Chairman Perry Township Board of Trustees 3750 Center Road, Box 65 Perry, OH 44081 Daniel Z. Fisher Transportation Department Public Utilities Commission 180 East Broad Street Columbus, OH 43215-3793 Joseph J. Hagan Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GHE-315 395 Ghent Road Akron, OH 44333 Gary R. Leidich President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308

Perry Nuclear Power Plant, Unit 1 cc:

Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GHE-115 395 Ghent Road Akron, OH 44333 Richard Anderson Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308