ML22348A137
| ML22348A137 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/05/2023 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Payne F Energy Harbor Nuclear Corp |
| References | |
| EPID L-2022-LLA-0108 | |
| Download: ML22348A137 (1) | |
Text
January 5, 2023 Mr. Frank R. Payne Site Vice President Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant P.O. Box 97, SB306 Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 199 TO ADOPT TSTF-541, REVISION 2, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION (EPID L-2022-LLA-0108)
Dear Mr. Payne:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 199 to Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1. This amendment consists of changes to the license and technical specifications (TSs) in response to your application dated August 5, 2022, as supplemented by letter dated October 18, 2022.
The amendment revises certain Surveillance Requirements (SRs) to add exceptions that consider the SR to be met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position. The revisions are consistent with Technical Specifications Task Force Traveler (TSTF)-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position.
F. Payne A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-440
Enclosures:
- 1. Amendment No. 199 to NPF-58
- 2. Safety Evaluation
- 3. Notice and Environmental Finding cc: Listserv
ENERGY HARBOR NUCLEAR CORP.
ENERGY HARBOR NUCLEAR GENERATION, LLC DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 199 License No. NPF-58
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment filed by Energy Harbor Nuclear Corp., et al.,1 dated August 5, 2022, as supplemented by letter dated October 18, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
1 Energy Harbor Nuclear Corp. is authorized to act as agent for Energy Harbor Nuclear Generation, LLC and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.
Enclosure 1
- 2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-58 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 199, are hereby incorporated into the license.
Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. This license amendment is effective as of its date of its issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Nancy Nancy L. L. Salgado Date: 2023.01.05 Salgado 15:40:05 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License No. NPF-58 and Technical Specifications Date of Issuance: January 5, 2023
ATTACHMENT TO LICENSE AMENDMENT NO. 199 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 FACILITY OPERATING LICENSE NO. NPF-58 DOCKET NO. 50-440 Facility Operating License No. NPF-58 Replace the following page of Facility Operating License No. NPF-58 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change REMOVE INSERT Technical Specifications Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
REMOVE INSERT 3.5-5 3.5-5 3.5-9 3.5-9 3.5-12 3.5-12 3.6-25 3.6-25 3.6-58 3.6-58 3.7-2 3.7-2 3.7-3 3.7-3 3.7-7 3.7-7
C. This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level Energy Harbor Nuclear Corp. is authorized to operate the facility at reactor core power levels not in excess of 3758 megawatts thermal (100% power) in accordance with the conditions specified herein.
(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 199, are hereby incorporated into the license. Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3) Antitrust Conditions
- a. Energy Harbor Nuclear Generation LLC shall comply with the antitrust conditions delineated in Appendix C to this license; Appendix C is hereby incorporated into this license.
Amendment No. 198, 199
ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.1.5 ------------------------------NOTE-------------------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem In accordance actuates on an actual or simulated automatic with the initiation signal, except for valves that are locked, Surveillance sealed, or otherwise secured in the actuated Frequency position. Control Program SR 3.5.1.6 ------------------------------NOTE-------------------------------
Valve actuation may be excluded.
Verify the ADS actuates on an actual or simulated In accordance automatic initiation signal. with the Surveillance Frequency Control Program SR 3.5.1.7 ------------------------------NOTE-------------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify each ADS valve actuator strokes when In accordance manually actuated. with the Surveillance Frequency Control Program SR 3.5.1.8 ------------------------------NOTE-------------------------------
ECCS actuation instrumentation is excluded.
Verify the ECCS RESPONSE TIME for each ECCS In accordance injection/spray subsystem is within limits. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.5-5 Amendment No. 199
RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.5 ---------------------------NOTES--------------------------------
- 1. Operation may be through the test return line.
- 2. Credit may be taken for normal system operation to satisfy this SR.
Operate the required ECCS injection/spray In accordance subsystem for 10 minutes. with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating In accordance a penetration flow path actuates to the isolation with the position on an actual or simulated isolation signal, Surveillance except for valves that are locked, sealed, or Frequency otherwise secured in the actuated position. Control Program SR 3.5.2.7 ----------------------------NOTE---------------------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray subsystem In accordance can be manually operated, except for valves that are with the locked, sealed, or otherwise secured in the actuated Surveillance position. Frequency Control Program PERRY - UNIT 1 3.5-9 Amendment No. 199
RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.3.5 ------------------------------NOTE-------------------------------
Vessel injection may be excluded.
Verify the RCIC System actuates on an actual or In accordance simulated automatic initiation signal, except for with the valves that are locked, sealed, or otherwise secured Surveillance in the actuated position. Frequency Control Program PERRY - UNIT 1 3.5-12 Amendment No. 199
RHR Containment Spray System 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1 ---------------------------------NOTE-----------------------------
RHR containment spray subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the RHR cut in permissive pressure in MODE 3 if capable of being manually realigned and not otherwise inoperable.
Verify each RHR containment spray subsystem In accordance manual, power operated, and automatic valve in the with the flow path that is not locked, sealed, or otherwise Surveillance secured in position is in the correct position. Frequency Control Program SR 3.6.1.7.2 Verify each RHR pump develops a flow rate of In accordance 5250 gpm on recirculation flow through the with the associated heat exchangers to the suppression INSERVICE pool. TESTING PROGRAM SR 3.6.1.7.3 Verify each RHR containment spray subsystem In accordance automatic valve in the flow path actuates to its with the correct position on an actual or simulated automatic Surveillance initiation signal, except for valves that are locked, Frequency sealed, or otherwise secured in the actuated Control Program position.
SR 3.6.1.7.4 Verify each spray nozzle is unobstructed. Following maintenance which could result in nozzle blockage.
PERRY - UNIT 1 3.6-25 Amendment No. 199
AEGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each AEGT subsystem for 15 continuous In accordance minutes. with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required AEGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each AEGT subsystem actuates on an In accordance actual or simulated initiation signal, except for with the dampers that are locked, sealed, or otherwise Surveillance secured in the actuated position. Frequency Control Program PERRY - UNIT 1 3.6-58 Amendment No. 199
ESW System-Div. 1 and 2 3.7.1 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not AND met.
B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both ESW Division 1 and Division 2 subsystems inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each required Division 1 and 2 ESW In accordance subsystem manual, power operated, and automatic with the valve in the flow path servicing safety related Surveillance systems or components, that is not locked, sealed, Frequency or otherwise secured in position, is in the correct Control Program position.
SR 3.7.1.2 Verify each required Division 1 and 2 ESW In accordance subsystem actuates on an actual or simulated with the initiation signal, except for valves that are locked, Surveillance sealed, or otherwise secured in the actuated Frequency position. Control Program PERRY - UNIT 1 3.7-2 Amendment No. 199
ESW System-Div. 3 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Service Water (ESW) System-Division 3 LCO 3.7.2 The Division 3 ESW subsystem shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ESW Division 3 A.1 Declare High Pressure Immediately subsystem inoperable. Core Spray System inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify each required Division 3 ESW subsystem In accordance manual, power operated, and automatic valve in the with the flow path servicing safety related systems or Surveillance components, that is not locked, sealed, or otherwise Frequency secured in position, is in the correct position. Control Program SR 3.7.2.2 Verify the Division 3 ESW subsystem actuates on an In accordance actual or simulated initiation signal, except for valves with the that are locked, sealed, or otherwise secured in the Surveillance actuated position. Frequency Control Program PERRY - UNIT 1 3.7-3 Amendment No. 199
CRER System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.3.3 Verify each CRER subsystem actuates on an In accordance actual or simulated initiation signal, except for with the dampers and valves that are locked, sealed, or Surveillance otherwise secured in the actuated position. Frequency Control Program SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program.
PERRY - UNIT 1 3.7-7 Amendment No. 199
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ADOPTION OF TSTF-541, REVISION 2, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS IN THE ACTUATED POSITION AMENDMENT NO. 199 TO FACILITY OPERATING LICENSE NO. NPF-58 ENERGY HARBOR NUCLEAR CORP.
ENERGY HARBOR NUCLEAR GENERATION, LLC PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440 Application (i.e., initial and supplement) Safety Evaluation Date August 5, 2022 January 5, 2023 ADAMS Accession No. ML22217A087 Principal Contributor to Safety Evaluation October 18, 2022 R. Elliott, NRR ML22291A436
1.0 INTRODUCTION
Energy Harbor Nuclear Corp. (the licensee) requested changes to the technical specifications (TSs) for Perry Nuclear Power Plant (PNPP) by license amendment request (LAR, application).
The proposed amendment is based on Technical Specifications Task Force (TSTF) Traveler (TSTF)-541, Revision 2, Add Exceptions to Surveillance Requirements [SRs] for Valves and Dampers Locked in the Actuated Position (TSTF-541) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19240A315), and the associated U.S.
Nuclear Regulatory Commission (NRC or Commission) staff safety evaluation (SE) of TSTF-541 (ML19323E926).
Limiting conditions for operation (LCOs) of a TS identify the lowest functional capability or performance level of equipment required for safe operation of the facility. The SRs are requirements relating to test, calibration, or inspection, to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Several existing SRs require the licensee to verify that each train of specified trains actuates on an actual or simulated actuation signal. When the trains actuate, valves and dampers within the trains will, if needed, reposition to their actuated position, which is the position appropriate to respond to the transient or accident that caused the actuation. The Enclosure 2
proposed amendment would eliminate the need to verify that a damper or valve has repositioned if the damper or valve is secured in its actuated position by adding a phrase to each SR as described in section 1.2 of this SE.
1.1 System Descriptions The following provides the system descriptions for the affected SR for each system in the licensees LAR:
The emergency core cooling system is designed to limit the release of radioactive materials to the environment following a loss-of-coolant accident (LOCA) and consists of the high-pressure core spray (HPCS) system, the low-pressure core spray (LPCS) system, the low- pressure coolant injection (LPCI) mode of the residual heat removal (RHR) system, and the automatic depressurization system. The purpose of SR 3.5.1.5 is to verify the automatic initiation logic of HPCS, LPCS, and LPCI, will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions on receipt of an actual or simulated actuation signal. In addition, SR 3.5.1.5 demonstrates that the HPCS system will automatically restart on a reactor pressure vessel (RPV) low water level signal that follows an RPV high water level trip and that the suction is automatically transferred from the condensate storage tank (CST) to the suppression pool on either a CST low water level signal or a suppression pool high water level signal.
The function of the reactor core isolation cooling (RCIC) system is to respond to transient events by providing makeup coolant to the reactor. The purpose of SR 3.5.3.5 is to verify the system operates as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions on receipt of an actual or simulated actuation signal.
The RHR containment spray system is designed to mitigate the effects of primary containment bypass leakage and low-energy line breaks. The purpose of SR 3.6.1.7.3 is to verify that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal.
The function of the annulus exhaust gas treatment (AEGT) system is to ensure that radioactive materials that leak from the primary containment into the secondary containment following a design-basis accident (DBA) are filtered and adsorbed prior to exhausting to the environment.
The purpose of SR 3.6.4.3.3 is to verify that each AEGT subsystem starts and isolation dampers open on receipt of an actual or simulated initiation signal or on a manual initiation from the control room. This SR also ensures that the operates throughout its emergency operating sequence for the LOCA signal.
The emergency service water (ESW) system, Divisions 1 and 2, is designed to provide cooling water for the removal of heat from unit auxiliaries, such as the standby diesel generators, RHR heat exchangers, and the emergency closed cooling water system heat exchangers to supply cooling water to the equipment required for a safe reactor shutdown following a DBA or transient. The ESW system, Divisions 1 and 2, also provides cooling to unit components, as required, during normal shutdown and reactor isolation modes. During a DBA, the equipment required only for normal operation is isolated and cooling is directed to only safety-related equipment. The purpose of SR 3.7.1.2 is to verify the ESW system, Divisions 1 and 2, will automatically switch to the position to provide cooling water exclusively to safety-related
equipment and that the ESW pumps in each subsystem will automatically start during an event by using an actual or simulated initiation signal.
The ESW system, Division 3, provides cooling water for the removal of heat from components of the Division 3 HPCS system. The purpose of SR 3.7.2.2 is to verify that the automatic valves of the ESW system-Division 3 will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident using an actual or simulated initiation signal. This SR also verifies that the Division 3 ESW pump will automatically start on an actual or simulated initiation signal.
The control room emergency recirculation (CRER) system provides a radiologically controlled environment from which occupants can safely operate the unit following a DBA. The purpose of SR 3.7.3.3 is to verify that each subsystem starts and operates on an actual or simulated actuation signal and the isolation dampers close within 10 seconds.
The licensee also requested to apply TSTF-541 to the RPV water inventory control LCO which was not included in the scope of TSTF-541. RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel (TAF) as required by Safety Limit (SL) 2.1.1.3. The LCO for RPV water inventory control requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A DRAIN TIME of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to SL 2.1.1.3 and can be managed as part of normal plant operation. The purpose of SR 3 5.2.6 is to verify that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal. SR 3.5.2.7 verifies that a required LPCI subsystem or LPCS system can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV.
1.2 Description of Proposed Changes to Adopt TSTF 541 In accordance with NRC staff-approved TSTF-541, the licensee proposed to revise certain SRs by adding exceptions to the SRs for automatic valves or dampers that are locked, sealed or, otherwise, secured in the actuated position. The proposed revisions, therefore, allow the licensee to meet the LCOs without having to test for actuation those values or dampers that are already secured in the actuated position. Specifically, each licensee proposed the following changes to adopt TSTF-541. The proposed new text is shown in italics.
SR 3.5.1.5: Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.5.3.5: Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.6.1.7.3: Verify each RHR containment spray subsystem automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.6.4.3.3: Verify each AEGT subsystem actuates on an actual or simulated initiation signal, except for dampers that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.1.2: Verify each required Division 1 and 2 ESW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.2.2: Verify the Division 3 ESW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.3.3: Verify each CRER subsystem actuates on an actual or simulated initiation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
1.3 Additional Proposed TS Changes In addition to the changes proposed consistent with the traveler discussed in section 1.1, the licensee proposed the following variations.
1.3.1 Editorial Variations The licensee noted that PNPP TSs have different titles than the equivalent systems in the approved TSTF-541.
1.3.2 Other Variations The licensee noted that PNPP has been approved for a surveillance frequency control program (SFCP). Therefore, the Frequency for the affected SRs in the PNPP TS is In accordance with the Surveillance Frequency Control Program.
The licensee proposed the following changes that were not included in the approved TSTF-541.
The changes are shown in italics:
SR 3.5.2.6: Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.5.2.7: Verify the required ECCS injection/spray subsystem can be manually, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
These SRs were added to the standard technical specifications (STSs) by the approved TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ML18292A816), as
modified by TSTF-582, RPV WIC Enhancements (ML21034A417). Neither TSTF traveler had not been approved by the NRC or incorporated into the STS at the time TSTF-541 was developed.
2.0 REGULATORY EVALUATION
The regulation under Title 10 of the Code of Federal Regulations (10 CFR) 50.36(b) requires that:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information.] The Commission may include such additional technical specifications as the Commission finds appropriate.
Additionally, under 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The considerations for issuance of operating licenses in 10 CFR 50.57(a)(3) provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
The LAR asks for changes to SRs, which are controlled by 10 CFR 50.36(c)(3) (saying that SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met). Accordingly, the amended SRs that no longer require verification of valves and dampers already in, and secured in, their actuated positions, must continue to provide reasonable assurance that the LCOs will be met, and the other standards of 10 CFR 50.36(c)(3) will be met.
The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition (SRP), March 2010 (ML100351425).
As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable STS (i.e., the current STS), as modified by NRC-approved travelers. In addition, the guidance states that comparing the change to previous STS can help clarify the TS intent. The current STS that is applicable to PNPP is:
NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, dated September 2021 (ML21271A582 and ML21271A596, respectively).]
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes to Adopt TSTF-541 The NRC staff compared the licensees proposed TS changes in section 1.2 of this SE against the changes approved in TSTF-541 for PNPP. In accordance with SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-541 are applicable to the PNPP TSs.
because PNPP is a General Electric boiling water reactor (BWR), Type 6 (BWR/6), design and the NRC staff approved the TSTF-541 changes for General Electric BWR/6 designs. Therefore, the NRC staff concludes that the licensees proposed changes to the PNPP TSs are consistent with TSTF-541.
As defined in STS 1.1 for the TSs listed above, a train shall be operable:
when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
The proposed SRs would exclude the need to verify actuation of dampers and valves that do not, in fact, actuate (e.g., change position) in response to an actuation signal. The licensees LAR contains the following statements:
While the proposed exceptions permit automatic valves and dampers that are locked, sealed, or otherwise secured in the actuated position to be excluded from the SR in order to consider the SR met, the proposed changes will not permit a system that is made inoperable by locking, sealing, or otherwise securing an automatic valve or damper in the actuated position to be considered operable. As stated in the SR 3.0.1 Bases, Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:
- a. The systems or components are known to be inoperable, although still meeting the SRs.
Energy Harbor Nuclear Corp. acknowledges that under the proposed change, the affected valves and dampers may be excluded from the SR when locked, sealed or otherwise secured in the actuated position. However, if the safety analysis assumes movement from the actuated position following an event, or the system is rendered inoperable by locking, sealing, or otherwise securing the valve or damper in the actuated position, then the system cannot perform its specified safety function and is inoperable regardless of whether the SR is met.
Energy Harbor Nuclear Corp. acknowledges for components for which the SR allowance can be utilized, the SR must be verified to have been met within its required Frequency after removing the valve or damper from the locked, sealed or otherwise secured status. If the SR exception is utilized to not test the actuation of a valve or damper and the specified Frequency of the SR is exceeded without testing the component, the SR must be performed on the component when it is returned to service in order to meet the SR.
Given the statements provided on the docket to adopt TSTF-541, the NRC staff determined that there is reasonable assurance that the licensee will continue to properly control affected equipment in accordance with existing regulations and requirements when using the exceptions added to the respective SRs.
The amended SRs will continue to require the licensee to verify that valves and dampers that must actuate to perform their safety functions and support functions are able to change position.
Conversely, the NRC staff finds that it is not necessary to verify actuation of valves and dampers that are already in their actuated positions, and are locked, sealed, or otherwise secured in those positions Therefore, the NRC staff determined that the amended TSs and revised SRs for PNPP will continue to meet 10 CFR 50.36(c)(3) because the revised SRs will continue to provide reasonable assurance that necessary quality of systems and components is maintained and that the LCOs will be met.
3.2 Additional Proposed TS Changes 3.2.1 Editorial The licensee noted that the TSs for PNPP has different numbering and titles than STS. The NRC staff finds that the different TS numbering and title changes are acceptable because they do not substantively alter TS requirements.
3.2.2 Other Variations There are two variations requested by the licensee described in section 1.3.2 above. The first variation is that the licensee stated that they have an SFCP in their TSs, so the surveillances do not provide frequencies. Rather, they state that the frequencies are in accordance with the SFCP. The NRC staff reviewed this variation and determined that it has no impact on the applicability of TSTF-541 as the acceptability of the TSTF-541 changes is unrelated to the surveillance interval of the affected SRs.
The second proposed variation by the licensee described in section 1.3.2 of this SE is to allow the TSTF-541 exceptions to be applied to SRs not included in the scope of TSTF-541 and do not have a similar allowance to that provided by TSTF-541 in the STS. Specifically, the licensee proposed revisions to SR 3.5.2.6 and SR 3.5.2.7 for the reactor pressure vessel water inventory control LCO.
The NRC staff reviewed the proposed changes to SR 3.5.2.6 and SR 3.5.2.7 and determined that these SRs are similar to the type of SRs included in TSTF-541, Revision 2, and the proposed changes are equivalent. Specifically, the proposed changes to these SRs would exclude the need to verify actuation or repositioning of valves that do not that do not need to actuate or reposition to perform their safety function in response to an actuation signal because they are secured in a position where they are already performing their safety function. The amended SRs would still require the licensee to verify that the affected valves and dampers that must reposition to perform their safety functions and support functions are able to change position when they are not locked in their actuated position.
The NRC staff reviewed the justification provided in TSTF-541, Revision 2, and the associated NRC staff SE, and found that it was equally applicable to the proposed changes to these SRs.
Therefore, the proposed changes are acceptable to the NRC staff for the same reasons discussed in Section 3.1 of this SE. Specifically, the NRC staff finds that it is not necessary to verify actuation or repositioning of valves that are locked, sealed, or otherwise secured in their actuated positions for SR 3.5.2.6 and SR 3.5.2.7.
Based on this, the NRC staff determined that the amended TSs and revised SRs for PNPP will continue to meet 10 CFR 50.36(c)(3) because the revised SRs will continue to provide reasonable assurance that necessary quality of systems and components is maintained and that the LCOs will be met 3.3 TS Change Consistency The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with the terminology and formatting requirements of Chapter 16.0 of the SRP and are therefore acceptable.
4.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. 199 TO FACILITY OPERATING LICENSE NO. NPF-58 ENERGY HARBOR NUCLEAR CORP.
ENERGY HARBOR NUCLEAR GENERATION, LLC PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440 Application (i.e., initial and supplement) Safety Evaluation Date August 5, 2022 January 5, 2023 ADAMS Accession No. ML22217A087 October 18, 2022 ML22291A436
1.0 INTRODUCTION
Energy Harbor Nuclear Corp. (the licensee) requested changes to the technical specifications (TSs) for Perry Nuclear Power Plant (PNPP) by license amendment request (LAR, application).
The proposed amendment is based on Technical Specifications Task Force (TSTF) Traveler (TSTF)-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (TSTF-541) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19240A315), and the associated U.S.
Nuclear Regulatory Commission (NRC) staff safety evaluation (SE) of TSTF-541 (ML19323E926).
The supplement dated October 18, 2022, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 4, 2022 (87 FR 60213).
2.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of Ohio official was notified of the proposed issuance of the amendment on December 14, 2022. The State official had no comments.
3.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR part 20 or change surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration in the Federal Register on October 4, 2022 (87 FR 60213), and there has been no public comment on such finding.
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in Enclosure 3
10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
ML22348A137 *via memo OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC*
NAME SWall SRohrer VCusumano DATE 12/14/2022 12/14/2022 12/12/2022 OFFICE OGC - NLO NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME DRoth NSalgado SWall DATE 12/21/2022 01/05/2023 01/05/2023