ML17193A382
| ML17193A382 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/18/2017 |
| From: | Kimberly Green Plant Licensing Branch III |
| To: | Hamilton D FirstEnergy Nuclear Operating Co |
| Green K J/LPL3/301-415-1627 | |
| References | |
| CAC MF8693 | |
| Download: ML17193A382 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David B. Hamilton Site Vice President July 18, 2017 FirstEnergy Nuclear Operating Company Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - CORRECTION TO SAFETY EVALUATION FOR LICENSE AMENDMENT NO. 177 (CAC NO. MF8693)
Dear Mr. Hamilton:
On June 29, 2017, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment No. 177 to Facility Operating License No. NPF-58 for the Perry Nuclear Power Plant, Unit No. 1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17163A354). The amendment revised Technical Specifications (TS) 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 from the TSs and replacing them with diesel operating time requirements consistent with NRG-approved Revision 1 to Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control."
During FENOC's review of the amendment, it identified an error in the NRC staff's safety evaluation on page 5. In the safety evaluation, the last portion of the first paragraph reads:
The use of "greater than or equal to" for the low volume 6 day supply is identified as a deviation from the approved TSTF Traveler in the LAR. Although it is a deviation from the language used in the approved traveler, this is equivalent to the current TSs because the current low volume level numeric requirement is preceded by a less-than-or-equal sign. No other parts of Condition A and Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application.
The second sentence in the above cited text erroneously states "less-than-or-equal sign."
Instead, the sentence should state "greater-than-or-equal sign."
The proposed correction does not change any of the conclusions in the safety evaluation associated with the amendment, and does not affect the associated notice to the public.
Enclosed, please find corrected safety evaluation page 5.
Hamilton D. If you have any questions regarding this matter, I can be reached at (301) 415-1627 or Kimberly.Green@nrc.gov.
Docket No. 50-440
Enclosure:
Sincerely, Kimberly J. Green, Senior Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Correction to Page 5 of the Safety Evaluation cc w/encl: Distribution via ListServ
ENCLOSURE PERRY NUCLEAR POWER PLANT, UNIT NO. 1 FACILITY OPERATING LICENSE NPF-58 DOCKET NO. 50-440 AMENDMENT NO. 177 CORRECTED PAGE 5 OF THE SAFETY EVALUATION 3.2 Proposed Change to Actions Table for TS 3.8.3, "Diesel Fuel. Oil Lube Oil. and Starting Air" Currently, Condition A is entered when the fuel oil volume requirement is not met, and Condition B is entered when the tube oil inventory requirement is not met. The current TS Bases state that the numerical volume requirements in Condition A and Condition B are based on volumes less than a 7-day supply but at least a 6-day supply. The proposal would remove the volumetric requirements from the TS and would modify Condition A and Condition B to add a duration-based requirement such that the Conditions are entered when the stored fuel oil and lube oil inventory is less than a 7-day supply, but greater or equal to a 6-day supply for one or more DGs. The use of "greater than or equal to" for the low volume 6 day supply is identified as a deviation from the approved TSTF Traveler in the LAR. Although it is a deviation from the language used in the approved traveler, this is equivalent to the current TSs because the current low volume level numeric requirement is preceded by a greater-than-or-equal sign. No other parts of Condition A and Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application.
Section 3.3 below discusses the methodology the licensee will use to calculate the stored diesel fuel oil and lube oil numerical volume basis. The use of this methodology will ensure that the 7-day and 6-day supply of stored diesel fuel oil and lube oil for each DG that dictate Condition entry will continue to be calculated in accordance with NRC approved methods.
Based on the above evaluation, the NRC staff considers the change to the TS 3.8.3 Actions Table to be acceptable.
3.3 Proposed Change to SRs 3.8.31 and 3.8.3.2 Currently, SRs 3.8.3.1 and 3.8.3.2 require the licensee to verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. The licensee proposes to revise SRs 3.8.3.1 and 3.8.3.2 to reflect the change in LCO requirements, namely, that a 7-day supply (rather than a specified numerical volume) be available for each DG. As a result, SRs 3.8.3.1 and 3.8.3.2 would require the licensee to verify that the stored diesel fuel oil and lube oil inventory is greater than or equal to a 7-day supply for each DG.
No other revision to these SRs is proposed. The licensee proposes to remove the current numerical volume requirement from the TS, and replace it with the associated current 7-day supply basis for fuel oil and lube oil for each OG.
The licensee describes the methodology used in determining the 7-day as we!! as the 6-day supply of stored diesel fuel oil and lube oil for each diesel generator on page 5 of 6 of the LAR as follows:
The specific volume of fuel oil equivalent to a 7 and 6-day supply is calculated using the NRC approved methodology described in Regulatory Guide 1.137, Revision 1, "Fuel-Oil Systems for Standby Diesel Generators" and ANSl-N195 1976, "Fuel Oil Systems for Standby Diesel-Generators." The specific volume of lube oil equivalent to a 7-day and 6-day supply is based on the diesel generator manufacturer's consumption values for the run time of the diesel generator Additionally, on pages 3 and 4 of the LAR, the licensee clarified how the volume of fuel necessary to support operation of the standby DGs is managed at the site:
ML17193A382 OFFICE NRR/DORULPL3/PM NRR/DORL/LPL3/LA NAME KGreen SRohrer DATE 07 /13/17 07/13/17 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME DWrona KGreen DATE 07/17/17 07/18/17