ML22200A222

License Renewal Application - Safety Pre-Application Meeting July 21, 2022 (Perry Slides)

ML22200A222
Person / Time
Site:	Perry
Issue date:	07/21/2022
From:	Energy Harbor Nuclear Corp
To:	Vaughn Thomas NRC/NRR/DNRL/NLRP
Thomas V, 301-415-5897
References
Download: ML22200A222 (19)

Text

Perry Nuclear Power Plant (PNPP)

License Renewal (60 Year) Application Pre-Submittal Meeting

July 21, 2022

1 Opening Remarks and Introductions

Opening Remarks

NRC Energy Harbor

Speakers

Mark Bensi (Energy Harbor, LR Team, Project Manager)

Theodore Hilston (Energy Harbor, LR Team, Technical Lead)

Participants Douglas Reeves (Energy Harbor, Director of Site Engineering, Project Sponsor)

Paul Roney (Energy Harbor, LR Team, Mechanical)

Mohammed Alvi (Energy Harbor, LR Team, Structural)

Barry Schneidman (Energy Harbor, LR Team, Mechanical)

George Kyle (Energy Harbor, LR Team, Electrical)

Benjamin Spiesman (Energy Harbor, LR Team, ER/SAMA and OE)

Stuart Thickman (Energy Harbor, LR Team, TLAA)

Steven Dort (Energy Harbor, LR Team, LRA Author)

Justin Truxall (Energy Harbor, AMP implementation Coordinator)

Ryan Lighty(Morgan Lewis, Legal Support)

Confidential, Subject to Confidentiality Agreements2 For Discussion Purposes Only, Non-Disclosable Information Agenda

Background

General Plant Information Application Preparation Approach

- Scoping and Screening

- Aging Management Review (AMR)

- Aging Management Program (AMPs)

- Time-Limited Aging Analyses (TLAA)

- Operating Experience Topics of Interest/Unique PNPP Aspects

- PNPP Unit 2 impact on LR

- PNPP Property Boundaries

- PNPP Flooding LAR

- Pre-PEO LR implementation Schedule and Closing Remarks Questions and Answers

Confidential, Subject to Confidentiality Agreements3 For Discussion Purposes Only, Non-Disclosable Information

Background

Energy Harbor Nuclear Corp.

In March of 2020, the Perry Nuclear Power Plant (PNPP) staff implemented License Amendment 187 that revised the Operating License to reflect a direct transfer of operating authority for the facility from FirstEnergy Nuclear Operating Company (FENOC) to Energy Harbor Nuclear Corp. (EHNC), a direct transfer of ownership of the facility from FirstEnergy Nuclear Generation, LLC (FENGen) to Energy Harbor Nuclear Generation LLC and an indirect transfer of ownership of the facility to Energy Harbor Corp.

Perrys License Renewal Application

Perrys current operating license expires at midnight on 11/07/2026.

Perry was granted an exemption from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR), 10 CFR 54.17(a)s requirement that an application for a renewed license be in accordance with Subpart A of 10 CFR Part 2, and, more specifically, 10 CFR 2.109(b). Section 2.109(b) provides timely renewal protection to licensees that submit sufficient license renewal applications at least five years before the expiration of the existing license. Thus, this exemption allows EHNC to submit a license renewal application for PNPP at least three years prior to the expiration of its existing license and, if the application is sufficient, to still receive timely renewal protection.

Confidential, Subject to Confidentiality Agreements4 For Discussion Purposes Only, Non-Disclosable Information General Plant Information

Perry Nuclear Power Plant, PNPP Unit 1

General Electric BWR-6, Mark III Containment Located in northeast Ohio, 35 miles northeast of Cleveland Current rated core thermal power of 3,758 MWt

- Original licensed core thermal power of 3,579 MWt

- Power Uprate completed in 2000 (Amendment 112, 105% Uprate)

Current gross electrical output of 1,327.6 MWe, net output of 1,277 MWe Plant Operating License issued 11/13/1986

Perry Nuclear Power Plant, PNPP Unit 2

Intended to be nearly identical to Unit 1 Some PNPP structures originally intended to serve as common between both units Construction activities formally terminated in 1994 Some Unit 2 Structures, Systems and Components (SSCs) support Unit 1 operation

- Some Unit 2 SSCs therefore in Unit 1 LR scope

Confidential, Subject to Confidentiality Agreements5 For Discussion Purposes Only, Non-Disclosable Information General Plant Information

Major Plant Structures

1. Unit 1 Reactor Building

2. Unit 2 Reactor Building

3. Unit 1 Turbine Building

4. Unit 2 Turbine Building

5. Control Complex

6. Diesel Generator Building

7. Unit 1 Off-Gas Building

8. Unit 1 Turbine Power Complex 13

9. RadWasteBuilding

10. Emergency Service Water Pumphouse

11. Service Water Pumphouse

12. Water Treatment Building 1

13. Lake Erie (UHS) 11 10 2

14. Switchyard 3 8 5

15. Unit 2 Heater Bay 12 7 9 6 4 15 Not visible in image Unit 1 Auxiliary Building Unit 2 Auxiliary Building 14 Intermediate Building Fuel Handling Building Unit 2 Turbine Power Complex Unit 1 Heater Bay Unit 2 Off-Gas Building

Confidential, Subject to Confidentiality Agreements6 For Discussion Purposes Only, Non-Disclosable Information License Renewal Application Approach

Regulatory Guidance

The License Renewal Application format and content is based on:

- NUREG 1800 Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 2

- NUREG 1801 Generic Aging Lessons Learned (GALL) Report, Revision 2;

- Regulatory Guide 1.188 Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses Revision 2.

Perrys First License Renewal Application

This License Renewal Application is limited to the first 20-year period of extended operation and does not address operation beyond 60 years.

- Regulatory guidance that addresses subsequent license renewal is considered from the perspective of operating experience.

Confidential, Subject to Confidentiality Agreements7 For Discussion Purposes Only, Non-Disclosable Information LR Scoping and Screening

Nuclear Safety Related Structures, Systems and Components, 10CFR54.4(a)(1)

Non-Safety Related Structures, Systems and Components whose failure could affect Safety-Related SSCs, 10CFR54.4(a)(2)

NRC Regulated Events, 10CFR54.4(a)(3)

- Fire Protection (10CFR50.48)

- Environmental Qualification (10CFR50.49)

- Pressurized Thermal Shock (10CFR50.61)

• Not applicable to PNPP

- Anticipated Transient Without Scram (10CFR50.62)

- Station Black Out (10CFR50.63)

Confidential, Subject to Confidentiality Agreements8 For Discussion Purposes Only, Non-Disclosable Information LR Scoping and Screening

Credited by CLB for performing an intended function per 10CFR54.4(a)(1),

(a)(2) or (a)(3)

In scope for 10CFR54.4(a)(2) spatial concerns, not credited in CLB

Example (Partial) of Mechanical Scoping Drawing

Confidential, Subject to Confidentiality Agreements9 For Discussion Purposes Only, Non-Disclosable Information Aging Management Reviews

AMR Process Highlights

Identification of Component Materials Identification of Component Operating Environments Aging Management Review

- Identification of Potential Aging Effects

- Identification of Aging Effects Requiring Management

- Review of Operating and Maintenance History

- Identification of Aging Management Programs Comparison of Aging Management Review Results with the GALL Report Results documented consistent with NEI 95-10 (9-column tables)

- Generic Notes document level of consistency with NUREG-1801

Confidential, Subject to Confidentiality Agreements10 For Discussion Purposes Only, Non-Disclosable Information Aging Management Programs

AMPs Applicable to PNPP (1)

PNPP will have 43 AMPs

- 32 are existing programs

- 13 existing programs will be enhanced for LR purposes

- 11 new programs

- No programs will contain exceptions to NUREG-1801

- No site-specific AMPs

AMPs Not Applicable to PNPP (1)(PWR-Specific AMPs not listed)

X.S1, Concrete Containment Tendon Prestress XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

XI.M22, BoraflexMonitoring XI.M25, BWR Reactor Water Cleanup System XI.S5, Masonry Walls XI.E4, Metal Enclosed Bus

(1)-Preliminary Information

Confidential, Subject to Confidentiality Agreements11 For Discussion Purposes Only, Non-Disclosable Information TLAA and Exemptions Identification

Assessment Method

Keyword search of selected licensing documents to identify potential TLAAs

- Updated Safety Analysis Report (USAR)

- Facility Operating License

- NRC Safety Evaluation Reports (SERs)

- 10 CFR 50.12 Exemption Requests

- EPRI BWRVIP documents (incorporated by reference in the CLB)

Comparison of the identified potential TLAAs to the TLAAs in industry documents

- NUREG-1800, Rev. 2

- NUREG-1801, Rev. 2

- NEI 95-10, Rev. 6

- Electric Power Research Institute (EPRI) Report TR-105090 Comparison of identified potential TLAAs to other LR applicants Review of current exemptions to identify potential TLAAs involved with these exemptions Review of BWRVIP documents referenced in the PNPP BWRVIP implementing procedure

Evaluation Method

Verify TLAA is valid for Period of Extended Operation Verify TLAA can be projected through Period of Extended Operation Verify aging effects evaluated in the TLAA will be adequately managed through Period of Extended Operation

Confidential, Subject to Confidentiality Agreements12 For Discussion Purposes Only, Non-Disclosable Information Operating Experience

Industry (External) OE Review

Review period from GALL Rev. 2 issuance (December 2010 to January 2023)

Includes generic communications such as Bulletins and Information Notices Ensures aging effects not identified in industry guidance documents are addressed by PNPP AMPs Will incorporate Nuclear Energy Institute (NEI) License renewal Task Force (LRTF) Working Group External OE results

Site (Internal) OE Review (Condition Reports)

Review ten-year period of January 2013 through January 2023 Searches performed in EHNC CAP database (DevonWay)

Provides representative set of plant-specific instances of age-related degradation 262 keywords used in extensive OE search Approx. 27,000 results from this search, approx. 6% relevant to LR

Additional OE Information GALL-SLR and SLR-ISGs to be considered as Operating Experience Lessons learned from RAIs/RCIs and supplements to be incorporated into AMRs and AMPs

Confidential, Subject to Confidentiality Agreements13 For Discussion Purposes Only, Non-Disclosable Information PNPP Topics of Interest

PNPP Unit 2

Unit 2 construction formally terminated in 1994 All Unit 2 structures and many systems and components completed Some Unit 2 SSCs support Unit 1 operation Some Unit 2 SSCs therefore in scope for PNPP Unit 1 LRA

- Examples include portions of the Unit 2 Shield Building wall which serves as the wall for the Fuel Handling and Intermediate Buildings; Unit 2 Turbine Power Complex houses active equipment Previous initiatives have been implemented to positively delineate boundaries between active and abandoned/retired Unit 2 equipment

Confidential, Subject to Confidentiality Agreements14 For Discussion Purposes Only, Non-Disclosable Information PNPP Topics of Interest

PNPP Property

PNPP situated on approx.

1030 acres in NE Ohio All property previously owned by subsidiaries of previous parent company (FE)

Several parcels retained by FE during Energy Harbor separation

- PNPP Switchyard

- Quincy Substation

- Southwest area Energy Harbor working to reacquire southwest area and establish easements on switchyard and Quincy Expected to be resolved prior to PNPP LRA submittal Small parcel at southern boundary claimed under eminent domain

- Easement being pursued, also on track for resolution

Confidential, Subject to Confidentiality Agreements15 For Discussion Purposes Only, Non-Disclosable Information PNPP Topics of Interest

Flooding License Amendment Request

In April 2021, PNPP submitted a License Amendment Request (LAR) reconstituting the sites external flood hazard design basis Five major aspects of the LAR

- Methodology change for Local Intense Precipitation (LIP) domain (utilizing FLO-2D Pro computer program)

- Use of Incorporated Barriers (as defined in RG 1.102) for mitigation of LIP effects

- Use of deployable Incorporated Barriers (involves new Tech.

Spec 3.7.11)

- 50.12 Exemption for use of Non-Safety Related barriers

- 50.12 Exemption for use of Non-Safety Related storm drain system Expected approval in Nov. 2022

- LRA based on scope of LAR

Confidential, Subject to Confidentiality Agreements16 For Discussion Purposes Only, Non-Disclosable Information PNPP Topics of Interest

Pre-PEO Implementation Activities

PNPP has a truncated Pre-PEO period due to the License Renewal Application (LRA) submittal date (July 2023) and license expiration (November 2026)

- Requires LR Implementation activities in parallel with LR Application development One-Time Inspections

- 39 of 203 Pre-PEO one-time inspections complete to date, more scheduled by end of year

- PNPP will use the remaining two refueling outages to complete inspections

• 1R19 in 2023, 1R20 in 2025

- Approx. 50% of one-time inspections to be complete by end of the next refueling outage (1R19), with the remainder complete by end of the following refueling outage (1R20)

• One-time Class 1 small bore piping inspections to be performed in 1R19

• Portion of bolting integrity exams to be performed in 1R19 AMP Program Owners identified; majority trained

Confidential, Subject to Confidentiality Agreements17 For Discussion Purposes Only, Non-Disclosable Information Scheduling and Closing Remarks

PNPP is on track to submit the License Renewal Application in July 2023

PNPP plans for the second Pre-Submittal Meeting in January 2023

PNPP will submit a high-quality application which will support efficient Staff reviews

- Highly knowledgeable team with significant LR experience

- Participation in industry working groups and meetings

- Industry Peer Reviews of LRA

- Monitoring on-going applicant processes

- Reviews of recent applicant RAIs, RCIs and Supplements

PNPPs License Renewal Application will be consistent with NRC requirements for initial LRA, industry practices and recent precedent

Confidential, Subject to Confidentiality Agreements18 For Discussion Purposes Only, Non-Disclosable Information Questions and Answers

Confidential, Subject to Confidentiality Agreements19 For Discussion Purposes Only, Non-Disclosable Information