ML22213A036

Safety Pre-Application Meeting Summary

ML22213A036
Person / Time
Site:	Perry
Issue date:	08/29/2022
From:	Vaughn Thomas NRC/NRR/DNRL/NLRP
To:	Penfield R Energy Harbor Nuclear Corp
Vaughn Thomas-NRR/DNRL/NLRP 3014155897
References
Download: ML22213A036 (5)

Text

August 29, 2022 Rod L. Penfield Site Vice President, Perry Nuclear Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant P.O. Box 97, Mail Stop A-PY-A290 Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1, LICENSE RENEWAL APPLICATION - PUBLIC MEETING

SUMMARY

OF PRE-SUBMITTAL MEETING

Dear Mr. Penfield:

By letter dated May 13, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20134H987), Energy Harbor Nuclear Corporation (Energy Harbor, or the applicant), submitted a letter of intent to submit a license renewal application (LRA) for Perry Nuclear Power Plant (PNPP, or Perry), Unit 1.

On July 21, 2022, an Observation Meeting was held between the U.S. Nuclear Regulatory Commission (NRC, or the staff) and representatives of Energy Harbor. The purpose of the meeting was to discuss the expected content of the upcoming submittal of the LRA for Perry.

The meeting notice and agenda dated June 7, 2022, is available at ML22201A542. The staff presentation is available at ML22201A005, and the applicants presentation is available at ML22200A222. A list of participants is provided as Enclosure 1. A similar meeting was held the same day, with a focus on the environmental review. A summary of that meeting is available at ML22213A036.

The NRC staff began with a brief overview of the license renewal (LR) process. The process consists of two tracks: the Environmental review and the Safety review. During the meeting, the staff shared a tentative schedule for the safety review of the application. For an application submission date of July 2023, the final licensing decision is to be determined pending the completion of the environmental review. For the Perry LRA, the NRC staff intends to incorporate process improvements and lessons learned from previous LRA reviews, and as a result, will aim to issue one single safety evaluation report, in support of one single meeting with the Advisory Committee on Reactor Safeguards.

Energy Harbor began its presentation with a brief background about the direct transfer of operating authority and direct transfer of ownership; and the current status of its LRA. Perry Unit 1 current license was issued on November 13, 1986 and is set to expire November 7, 2026.

Perry was granted an exemption which allows Energy Harbor to submit a license renewal application for Perry at least three years prior to the expiration of its existing license and, if the application is sufficient, to still receive timely renewal protection.

R. Penfield Energy Harbor also discussed its approach for developing the Perry LRA. The applicant indicated that it intends to leverage the format and content contained in NUREG-1800, Revision 2, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SPR-LR), and NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL-LR)

Report, and Regulatory Guide 1.188, Revision 2, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, in the development of its application. The NRC staff asked questions regarding the use of additional regulatory guidance such as License Renewal Interim Staff Guidance (LR-ISGs); and the incorporation of lessons learned from previous applications such as Turkey Point and Peach Bottom in its development of the Perry LRA. Energy Harbor stated that it intends to use the guidance in the LR-ISGs and will review and incorporate previous request for additional information from Peach Bottom and Turkey Point.

Energy Harbor presented its scoping and screening approach, highlights of its aging management review (AMR) process and its aging management programs (AMPs) that are applicable to Perry and also the ones that are not applicable to Perry. For the AMRs, the applicant stated that Perry AMR line items will be compared with the GALL-LR report, and that the AMR results will be conducted using a methodology that is consistent with current standards, Nuclear Energy Institute (NEI) NEI 95-10, Revision 6, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, and the GALL-LR. Perry is expected to have a total of 43 AMPs, all of which were developed to maximize consistency with the GALL-LR report. Of the 43 AMPs, 32 are existing programs, while 11 are new programs. A total of 13 AMPs is expected to be consistent with the GALL-LR report; there will be no site-specific AMPs; and none of the programs are expected to contain exceptions to the GALL-LR report.

The applicant also provided an overview of its assessment and evaluation method for the Perry time limited aging analyses (TLAAs); and the operating experience (OE), including industry and site OE review. The applicant intends to compare the identified potential TLAAs to the TLAAs of other LR applications; the SRP-LR and industry documents such as the NEI 95-10, Revision 6 document, and the Electric Power Research Institute (EPRI) Report, TR-105090, Guidelines to Implement the License Renewal Requirements of 10 CFR 54 for Integrated Plant Assessments and Time-Limited Aging Analyses. During the discussion, the NRC staff reminded the applicant that any topical reports used to support the TLAAs need to be approved by the NRC staff.

The applicant concluded the meeting by stating that the Perry LRA is on track to be submitted in July 2023 and that Energy Harbor is currently planning for a second pre-submittal meeting in January 2023.

R. Penfield Two members of the public asked questions and/or made comments on various topics, including:

- flooding and global warming

- high-burnup fuel

- emergency planning

- harvesting program, including inspection, testing and modeling If you have any questions, please feel free to contact me at Vaughn.Thomas@nrc.gov.

Sincerely, Vaughn Thomas, Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

List of Attendees cc w/encl: ListServ

R. Penfield

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1, LICENSE RENEWAL APPLICATION - PUBLIC MEETING

SUMMARY

OF PRE-SUBMITTAL MEETING DATED: AUGUST 29, 2022 DISTRIBUTION E-MAIL PUBLIC RidsNrrDnlr Resource VThomas, NRR/DNRL LGibson, NRR/DNRL TSmith, NMSS/REFS LRakovan, NMSS/REFS BSmith, NRR/DNRL BThomson, NRR/DNRL SWall, NRR/DORL NSalgado, NRR/DORL DRoth, OGC SBurnell, HQ/OPA LWilkins, OCA DMcIntyre, HQ/OPA VMitlyng, RIII/OPA ABarker, RIII/FCO JLaral, RIII/DRP SAtack RIII/DRS JSteffes, RIII, SRI JJance, RIII, RI JBensi@EnergyHarbor.com ADAMS Accession Number: ML22213A036 *via e-mail NRR-106 OFFICE NRR/DNRL/NLRP/PM NRR/DNRL/NLRP/LA NAME VThomas YEdmonds DATE 07/29/2022 08/09/2022 OFFICE NRR/DNRL/NLRP/BC NRR/DNRL/NLRP/PM NAME LGibson VThomas DATE 08/25/2022 08/29/2022 OFFICIAL RECORD COPY

List of Attendees All attendees participated remotely.

NRC Attendees: Energy Harbor Attendees:

Ali Rezai Barry Schneidman Allen Hiser Benjamin Spiesman Andrew Johnson Doug Reeves Andrew Prinaris George Kyle Angie Buford Justin Truxall Bart Fu Mark Bensi Bernie Thomson Mohammed Alvi Brian Allik Paul Roney Brian Lee Stuart Thickman Carolyn Fairbanks Theodore Hilston Chang Li Tobias Kostner Christopher Tyree Steven Dort Cory Parker Ryan Lighty David Dijamco David Nold Constellation Nuclear Emma Haywood Casey A Muggleston Fred Forsaty John Hilditch George Thomas Lydia S. Dworakowski Gregory Makar Gordon Curran Additional Attendees:

James Gavula Amit Kalia James Medoff Arnie, K Jessica Hammock Connie Kline Joel Jenkinsf Daniel Green John Tsao Dominic Edgar Logalbo Lance Rakovan Eric Ashley Michael Lauren Gibson John Grimm Leslie Terry Joseph Herbert Bashore Lydiana Alvarado Kathy Nesser Michael Benson Michael Keegan Paul Klein Patricia Marida Robert Davis Peter John Donahue Seung Min Ramiz Gilada Tony Gardner Todd Evans Varoujan Kalikian William J. Baker Vaughn Thomas Enclosure