L-20-197, Response to Request for Additional Information Regarding Request to Extend License Expiration Date by Recapturing Low-Power Testing Time

Response to Request for Additional Information Regarding Request to Extend License Expiration Date by Recapturing Low-Power Testing Time

ML20212L544
Person / Time
Site:	Perry
Issue date:	07/30/2020
From:	Payne F Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2020-LLA-0053, L-20-197
Download: ML20212L544 (4)

Text

energy Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant harbor 10 Center Road P.O. Box97 Perry, Ohio 44081 Frank R. Payne 440-280-5382 Site Vice President, Peny Nuclear July 30, 2020 L-20-197 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Regarding Request to Extend License Expiration Date by Recapturing Low-Power Testing Time (EPID L-2020-LLA-0053)

By Letter dated March 26, 2020 {Accession No. ML20086K773), Energy Harbor Nuclear Corp. requested an amendment to Operating License NPF-58 for Perry Nuclear Power Plant, Unit No. 1 {PNPP). The proposed amendment would recapture low power testing time by extending the PNPP operating license expiration date approximately 7.7 months.

By email dated July 1, 2020, the Nuclear Regulatory Commission (NRC) staff requested additional information to complete their review of the proposed amendment.

A response to the NRC staff request for additional information is attached. The response provided with this letter has no impact on the no significant hazards consideration transmitted by the March 26, 2020 letter.

Once approved, the amendment shall be implemented within 30 days of receipt. There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager, Fleet Licensing, at {330) 696-7208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July~' 2020.

lr u Sincerely,/l _ ~

Frank R. Payne

Perry Nuclear Power Plant L-20-197 Page 2

Attachment:

Response to July 1, 2020 NRC Staff Request For Additional Information cc: NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety board

Attachment L-20-197 Response to July 1, 2020 NRC Staff Request For Additional Information Page 1 of 2 By email dated July 1, 2020, the NRC staff requested additional information to complete their review of the Perry Nuclear Power Plant license amendment proposed in a March 26, 2020 Energy Harbor Nuclear Corp. letter (Accession No. ML20086K773).

The N RC staff's request is provided below in bold type and is followed by the Energy Harbor Nuclear Corp. response.

RAI-EEOB-01 Section 2.4, "Description of the Proposed Change," of the LAR states:

The proposed amendment would revise the expiration date specified in PNPP facility operating license No. NPF-58, Condition 2.H, to recapture low-power testing time. The expiration date of PNPP's facility operating license would be revised so that it would expire 40 years from the date of issuance of the facility operating license, as opposed to 40 years from the date of issuance of the fuel loading and low-power testing license as permitted by 10 CFR 50.51, "Continuation of license."

Section 2.1.4, "Electrical Equipment," of the LAR states:

Electrical equipment that is required to perform a design safety function is designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents in accordance with GDC 4.

Based on its review of the LAR, the staff finds that the licensee did not describe considerations given for any significant aging degradations of electrical equipment subject to 10 CFR 50.49 during the period of operation of PNPP at low-power testing.

(1) To ensure that the environmental qualification of electrical equipment subject to 10 CFR 50.49 does not exceed the end-of-installed life condition as a result of the proposed change, the staff requests the licensee to explain how they have assessed the impact of the proposed change on the environmental qualification of electrical equipment.

Response

Perry Nuclear Power Plant equipment required to be qualified by 10 CFR 50.49, "Environmental qualification of electric equipment important to safety for nuclear power plants," has been identified and qualified in accordance with the applicable standards and regulatory guides. For equipment with age-degradable subcomponents that limit qualified life, a replacement plan is implemented to ensure the installed equipment remains qualified.

Attachment L-20-197 Page 2 of 2 The scope of the current Environmental Qualification Program includes the required electrical equipment determined in accordance with 10 CFR 50.49. The installed life of a component is defined in the program as the interval from installation to removal. To maintain compliance with 10 CFR 50.49, the installed life plus shelf life, where applicable, may not be greater than the determined qualified life, where the qualified life is defined as the period of time prior to a design basis accident for which satisfactory performance can be demonstrated for a specific set of service conditions . To maintain the installed plant equipment in a qualified condition, the equipment must be replaced prior to exceeding the evaluated qualified life unless it can be shown that the installed equipment will remain bounded by the established qualification.

Based on the above, environmentally qualified Perry Nuclear Power Plant electrical equipment is maintained in a qualified condition for its installed life, has an installed life that is independent of the start or expiration date of the plant operating license, and will continue to be capable of performing associated design functions during the requested operating license expiration date extension period.