ML17114A153

NRR E-mail Capture - Draft RAI for Perry LAR Re TSTF-501, Revision 1

ML17114A153
Person / Time
Site:	Perry
Issue date:	04/06/2017
From:	Kimberly Green Plant Licensing Branch III
To:	Lashley P FirstEnergy Corp
References
Download: ML17114A153 (4)

Text

NRR-PMDAPEm Resource From: Green, Kimberly Sent: Thursday, April 06, 2017 3:47 PM To: Lashley, Phil H. (phlashley@firstenergycorp.com)

Cc: Heintz, Calvin J. (cjheintz@firstenergycorp.com)

Subject:

Draft RAI for Perry LAR re TSTF-501, Revision 1 Attachments: Perry draft RAI Sent to FENOC.docx

Dear Mr. Lashley:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated October 27, 2016, FirstEnergy Nuclear Operating Company submitted a request to modify the Perry Nuclear Power Plant, Unit 1, technical specifications (TSs) to revise TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by removing the current stored diesel fuel oil and lube oil numerical volume requirements in the TS and placing them in the TS Bases so that they may be modified under licensee control, and the TS would also be modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator. The proposed changes are consistent with NRC-approved Revision 1 to Technical Specification Task Force (TSTF)

Improved Standard Technical Specifications (STS) Change Traveler TSTF-501, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. Attached, please find a draft request for additional information (RAI).

The draft RAI is being sent to ensure that the questions are understandable, the regulatory basis for the questions is clear, and to determine if the information was previously docketed. This email and the attachment do not convey or represent an NRC staff position regarding the FENOC's request.

Please let me know if you need a call to clarify the staffs request.

Sincerely, Kimberly Green, Sr. Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation (301) 415-1627 kimberly.green@nrc.gov 1

Hearing Identifier: NRR_PMDA Email Number: 3463 Mail Envelope Properties (Kimberly.Green@nrc.gov20170406154700)

Subject:

Draft RAI for Perry LAR re TSTF-501, Revision 1 Sent Date: 4/6/2017 3:47:06 PM Received Date: 4/6/2017 3:47:00 PM From: Green, Kimberly Created By: Kimberly.Green@nrc.gov Recipients:

"Heintz, Calvin J. (cjheintz@firstenergycorp.com)" <cjheintz@firstenergycorp.com>

Tracking Status: None "Lashley, Phil H. (phlashley@firstenergycorp.com)" <phlashley@firstenergycorp.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1706 4/6/2017 3:47:00 PM Perry draft RAI Sent to FENOC.docx 35605 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION FIRSTENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-440 By letter dated October 27, 2016, FirstEnergy Nuclear Operating Company (FENOC, or licensee), submitted a license amendment request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16302A055). The proposed amendment would revise the Perry Nuclear Power Plant, Unit 1, Technical Specification 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, by removing the current stored diesel fuel oil and lube oil numerical volume requirements in the TS and placing them in the TS Bases so that they may be modified under licensee control. The TS would also be modified so that the stored diesel fuel oil and lube oil inventory will require that a 7-day supply be available for each diesel generator. The additional information below is needed to support the NRC staffs continued technical review of the license amendment request (LAR).

RAI 1: General Design Criterion (GDC) 17, Electric Power Systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, requires that an onsite electric power system and an offsite electric power system be provided to permit functioning of structures, systems, and components important to safety. In addition, GDC 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, testability, and reliability. Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50 establishes overall quality assurance requirements for the design, construction, and operation of structures, systems, and components important to safety.

Regulatory Guide 1.137, Regulatory Position 1 states that ANSI N195-1976 provides a method acceptable to the NRC staff for complying with the pertinent requirements of General Design Criterion 17 of Appendix A to 10 CFR Part 50. Regulatory Position 1.c states that the fuel oil storage requirements should either be based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity or calculations based on the time-dependent loads of the diesel generator. Consistent with RG 1.137, Revision 1, Perry Nuclear Power Plant is designed with stored diesel fuel oil inventory requirement that a 7-day supply be available for each diesel generator.

State which calculation method in ANSI N195-1976 has been used to calculate the 7-day fuel oil volume, the time dependent method or the conservative alternative method. If the time dependent method was used, please confirm that the calculation includes a minimum margin of 10 percent.

RAI 2: Regulatory Guide 1.137, Regulatory Position 1 states that ANSI N195-1976 provides a method acceptable to the NRC staff for complying with the pertinent requirements of General Design Criterion 17 of Appendix A to 10 CFR Part 50. Regulatory Position 1.c states that the

fuel oil storage requirements should either be based on the assumption that the diesel generator operates continuously for 7 days or based on the time-dependent loads of the diesel generator.

TSTF-501 was issued to address how the requirements on diesel fuel oil may continue to change in the future and the addition of additives to compensate for the issues associated with ultra low sulfur diesel (ULSD) discussed in Information Notice 2006-22 may further affect the volumetric energy content and the stored diesel fuel oil volume requirements. As described in NRC Information Notice 2006-22, the incorporation of ULSD fuel oil instead of low sulfur diesel fuel oil is expected to reduce the available energy content by 1.2 percent or more. These changes could result in insufficient stored fuel oil volume in order to ensure that the volume provides for at least 7 days of diesel generator operation.

Are the fuel oil quantity values currently in the Technical Specifications (TSs) and the diesel generator manufacturer's fuel consumption values based on ULSD fuel? If not, specify the type of fuel used to calculate the fuel oil values. Provide discussion on how use of ULSD fuel has been accounted for in the design for compliance with the 7-day TS requirement.

RAI 3: Regulatory Guide 1.137, Revision 1, endorses ASTM D975-77 for assuring the quality of the oil stored in the fuel-oil supply tank. Regulatory Position 2.b states, in part, that Prior to adding new fuel oil to the supply tanks, onsite samples of the fuel oil should be taken. The latest version of ASTM D975, Standard Specification for Diesel Fuel Oils, allows manufacturers to add up to five percent biodiesel in the fuel oil without labeling. Discuss whether or not the fuel oil consumption rate used in your fuel oil storage calculation takes into account up to five percent biodiesel allowed by ASTM D975. If fuel oil is received without biodiesel at Perry, explain how that is achieved.

RAI 4: 10 CFR 50.36(b) states that, Each license authorizing operation of a production or utilization facility of a type described in § 50.21 or § 50.22 will include technical specifications.

The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34. The Commission may include such additional technical specifications as the Commission finds appropriate.

As indicated in a letter to the TSTF dated April 3, 2014 (Agencywide Documents Access and Management System Accession No. ML14084A512), the NRC staff has determined that the licensee must identify the NRC-approved calculation methodology in the final safety analysis report. FENOC did not provide any regulatory commitments in the license amendment request.

Provide a commitment consistent with the one described in the referenced letter, or explain why a commitment is not needed.