ML070260170

RAI Related to Revising Mode 4 Residual Heat Removal Shutdown Requirements

ML070260170
Person / Time
Site:	Perry
Issue date:	02/09/2007
From:	Thomas Wengert NRC/NRR/ADRO/DORL/LPLIII-2
To:	Pearce L FirstEnergy Nuclear Operating Co
Wengert, Thomas
References
TAC MD2140
Download: ML070260170 (6)

Text

February 9, 2007 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 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO REVISING MODE 4 RESIDUAL HEAT REMOVAL SHUTDOWN COOLING REQUIREMENTS TO ADD A DEFAULT CONDITION ADDRESSING SITUATIONS WHEN CONDITION A CANNOT BE MET WITHIN ITS COMPLETION TIME (TAC NO. MD2140)

Dear Mr. Pearce:

By letter to the Nuclear Regulatory Commission (NRC) dated June 1, 2006, FirstEnergy Nuclear Operating Company submitted a request to revise MODE 4 residual heat removal shutdown cooling requirements to add a default condition addressing situations when Condition A cannot be met within its completion time, for the Perry Nuclear Power Plant, Unit 1.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on January 25, 2007, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1486.

Sincerely,

/RA/

Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Request for Additional Information cc w/encl: See next page

Mr. L. W. Pearce February 9, 2007 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 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO REVISING MODE 4 RESIDUAL HEAT REMOVAL SHUTDOWN COOLING REQUIREMENTS TO ADD A DEFAULT CONDITION ADDRESSING SITUATIONS WHEN CONDITION A CANNOT BE MET WITHIN ITS COMPLETION TIME (TAC NO. MD2140)

Dear Mr. Pearce:

By letter to the Nuclear Regulatory Commission (NRC) dated June 1, 2006, FirstEnergy Nuclear Operating Company submitted a request to revise MODE 4 residual heat removal shutdown cooling requirements to add a default condition addressing situations when Condition A cannot be met within its completion time, for the Perry Nuclear Power Plant, Unit 1.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on January 25, 2007, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1486.

Sincerely,

/RA/

Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMTWengert RidsNrrLAEWhitt RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr RidsNrrDirsItsb RidsNrrDssSbwb ALewin, NRR DWoodyatt, NRR ADAMS Accession Number:ML070260170 NRR-088 OFFICE LPL3-2/PM LPL3-2/LA ITSB/BC LPL3-2/BC (A)

NAME TWengert:mw EWhitt TKobetz MMarshall DATE 2/7/2007 1/26/2007 2/8/2007 2/9/2007 OFFICIAL RECORD COPY

Perry Nuclear Power Plant, Unit 1 cc:

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

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

REQUEST FOR ADDITIONAL INFORMATION PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-440 In reviewing the FirstEnergy Nuclear Operating Companys (FENOCs) submittal dated June 1, 2006, related to a request to revise MODE 4 residual heat removal shutdown cooling requirements to add a default condition addressing situations when Condition A cannot be met within its completion time, for the Perry Nuclear Power Plant, Unit 1 (Perry), the NRC staff has determined that the following information is needed in order to complete its review:

1. Discuss how Perry could comply with the proposed Technical Specifications (TSs) while simultaneously in Condition A and proposed Condition B of TS 3.4.10, if there was no means available to work towards the establishment of an alternate method of decay heat removal.

Background:

If proposed Condition B of TS 3.4.10, ?RHR [Residual Heat Removal]

Shutdown Cooling System - Cold Shutdown is entered, Required Actions of Condition A must still be carried out in accordance with TS 1.3, Completion Times. TS 1.3 states a required actions condition remains in effect and the required actions apply until the condition no longer exists or the unit is not within the limiting condition for operation (LCO) applicability. Example 1.3-2 in TS 1.3 provides a discussion on simultaneously being in two conditions, A and B, as a result of the completion time for Condition A not being met, and therefore entering Condition B.

TS 3.4.10 Condition A, Required Action A.1 states: ?Verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (a separate condition entry is allowed for each RHR shutdown cooling subsystem).

Page 3 of the license amendment request (LAR) states: ?In parallel with this LAR for TS 3.4.10, the Perry performance improvement initiative is tracking a plant design change to incorporate a new alternate decay heat removal method for Mode 4. The new method will be capable of maintaining Cold Shutdown Mode 4 conditions early in a forced outage (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after attaining Hot Shutdown Mode 3). Prior to making this new alternate decay heat removal method available, TS compliance issues could still occur. This is the result of not being able to take any required actions for Condition A because there is no means to establish an alternate method of decay heat removal for each inoperable subsystem. Per TS 1.3, Required Actions of Condition A must be worked on, even if Required Actions of proposed Condition B are completed.

Enclosure