ML18271A208

NRR E-mail Capture - RAI Related to Request to Revise Perry'S Technical Specifications to Extend Containment Leak Rate Test Intervals

ML18271A208
Person / Time
Site:	Perry
Issue date:	09/27/2018
From:	Kimberly Green Plant Licensing Branch III
To:	Lashley P FirstEnergy Nuclear Operating Co
References
L-2018-LLA-0055
Download: ML18271A208 (3)

Text

NRR-DMPSPEm Resource From: Green, Kimberly Sent: Thursday, September 27, 2018 3:22 PM To: Lashley, Phil H. (phlashley@firstenergycorp.com)

Cc: Spiesman, Benjamin L.; Lentz, Thomas A. (Licensing) (talentz@firstenergycorp.com);

Minniti, Matthew J.

Subject:

RAI Related to Request to Revise Perry's Technical Specifications to Extend Containment Leak Rate Test Intervals (EPID L-2018-LLA-0055)

Attachments: Perry RAI.docx

Dear Mr. Lashley:

By letter dated March 7, 2018, FirstEnergy Nuclear Operating Company (FENOC) submitted an amendment request for Perry Nuclear Power Plant, Unit No. 1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18066A648). The proposed amendment would revise Technical Specification (TS) 5.5.12, Primary Containment Leakage Rate Testing Program, to allow for permanent extension of Appendix J containment leakage testing intervals for Types A and C.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified an area where additional information is needed to complete its review.

A draft RAI was previously transmitted to you by email dated September 26, 2018. Mr. Ben Spiesman, of your staff, stated that a clarification call was unnecessary; therefore, the RAI remains unchanged from what was previously transmitted. A response to the attached RAI is requested within 30 days from the date of this email.

The NRC staff considers that timely responses to RAIs 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) 415-1627.

Sincerely, Kimberly Green (301) 415-1627 kimberly.green@nrc.gov 1

Hearing Identifier: NRR_DMPS Email Number: 593 Mail Envelope Properties (Kimberly.Green@nrc.gov20180927152100)

Subject:

RAI Related to Request to Revise Perry's Technical Specifications to Extend Containment Leak Rate Test Intervals (EPID L-2018-LLA-0055)

Sent Date: 9/27/2018 3:21:59 PM Received Date: 9/27/2018 3:21:00 PM From: Green, Kimberly Created By: Kimberly.Green@nrc.gov Recipients:

"Spiesman, Benjamin L." <blspiesman@firstenergycorp.com>

Tracking Status: None "Lentz, Thomas A. (Licensing) (talentz@firstenergycorp.com)" <talentz@firstenergycorp.com>

Tracking Status: None "Minniti, Matthew J." <mjminniti@firstenergycorp.com>

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

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1415 9/27/2018 3:21:00 PM Perry RAI.docx 22417 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION FIRSTENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET NUMBER 50-440 EPID L-2018-LLA-0055 By application dated March 7, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18066A648) FirstEnergy Nuclear Operating Company (FENOC) proposed a change to the Perry Nuclear Power Plant (PNPP) Technical Specification (TS) 5.5.12, Primary Containment Leakage Rate Testing Program, to allow for permanent extension of Appendix J containment leakage testing intervals.

On page 13 of the enclosure to the license amendment request (LAR), Table 3.2.2-1, PNPP Type A Test History, for 2009 shows that the Leakage 95% Upper Confidence Level, wt. %/day was 0.1195, and the Total Leakage As-Found wt. %/day was 0.1382, and includes Note 2 that states:

ILRT as-found leak rate test data contains 95 percent upper confidence limit and all penalties assigned including leakage value adjustments from Type B and C component repairs performed prior to the ILRT test and sump level changes during the ILRT test.

On page 18 of the enclosure, FENOC states:

The 95 percent upper confidence limit for the 2009 ILRT was 0.1195 weight percent per day. Combining the 95 percent upper confidence limit with the MNPLR for the Type B and C pathways provides the performance leakage rate.

The performance leakage rate for the 2009 ILRT was 0.1435 weight percent per day, which is less than 1.0 La (0.20 weight percent per day).

It is not clear to the NRC staff what the correct value is for evaluating the 2009 ILRT results.

RAI SCPB-1:

Clarify which value is to be used to judge the 2009 ILRT results, and provide the basis for the difference between the 0.1382 and the 0.1435 total leakage values (for 2009) cited in the LAR.