L-23-001, License Amendment Request to Remove the Table of Contents from the Technical Specifications

License Amendment Request to Remove the Table of Contents from the Technical Specifications

ML23220A044
Person / Time
Site:	Perry
Issue date:	08/07/2023
From:	Penfield R Energy Harbor Nuclear Corp
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-23-001
Download: ML23220A044 (1)

Text

m energy Energy Harbor Nuclear Corp.

~ harbor Perry Nuclear Power Plant 10 Center Road Perry, Ohio 44081

Rod L. Penfield 440-280-5382 Site Vice President, Perry Nuclear

August 7, 2023 L-23-001 10 CFR 50.90

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 License Amendment Request to Remove the Table of Contents from the Technical Specifications

In accordance with 10 CFR 50.90, Energy Harbor Nuclear Corp. hereby requests an amendment to Facility Operating License No. NPF-58 to revise the Technical Specifications (TS) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP). The proposed amendment would remove the table of contents (TOC) from the TS and place it under licensee control.

provides the evaluation of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change.

The proposed amendment does not involve a significant hazard consideration as determined per 1 O CFR 50.92, "Issuance of amendment." Also, pursuant to 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

Approval of the proposed amendment is requested by February 29, 2024. Once approved, the amendment shall be implemented within 90 days.

Perry Nuclear Power Plant L-23-001 Page2

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 August _7_, 2023.

Rod L. Penfield

Attachments:

1. Evaluation of the Proposed Change

2. Proposed Technical Specification Changes (Mark-Up)

cc: NRC Region Ill Administrator NRC Resident Inspector N RR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board Attachment 1 L-23-001

Evaluation of the Proposed Change Page 1 of 6

Subject:

Removal of the Table of Contents from the Technical Specifications 1.0

SUMMARY

DESCRIPTION

2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Analysis 4.4 Conclusions

6.0 REFERENCES

L-23-001 Page 2 of 6

1.0

SUMMARY

DESCRIPTION

This evaluation supports the Energy Harbor Nuclear Corp. request to amend Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1 (PNPP). The proposed changes would revise the Technical Specifications (TS) to remove the table of contents (TOC) from the TS and place it under licensee control.

2.0 DETAILED DESCRIPTION

The proposed change would remove the TOC from the TS and place it under Energy Harbor Nuclear Corp. (licensee) control. No TS pages will be issued as a result of this proposed change. The TOC for the TS is not being eliminated. Following approval of this license amendment request (LAR), the responsibility for maintenance and issuance of updates to the TS TOC will transfer from the Nuclear Regulatory Commission (NRC) to Energy Harbor Nuclear Corp. The TOC will no longer be included in the TS and as such will no longer be part of the TS (Appendix A to the Facility Operating License).

3.0 TECHNICAL EVALUATION

The TOC does not meet the criteria specified in 10 CFR 50.36 requiring its inclusion within a plants TS. 10 CFR 50.36(b) states, in part:

Each license authorizing operation of a production or utilization facility of a type described in § 50.21 or § 50.22 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 § 50.34.

The result of the Energy Harbor Nuclear Corp. review indicates that the TS TOC was not listed in the regulation as one of the categories listed in 10 CFR 50.36(c).

10 CFR 50.36(a) indicates that a license application may provide other information associated with the TS and gives an example of this information (the TS bases), but also clearly indicates that the bases are not a part of the TS. 10 CFR 50.36(a)(1) states:

Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

Additionally, the Writers Guide for Plant-Specific Improved Technical Specifications (Reference 1) was reviewed for guidance. The writers guide refers to the TOC as Technical Specification Front Matter, which also includes the Title Page and List of L-23-001 Page 3 of 6

Effective Pages. The writers guide describes the TS content as starting with Chapter 1, Use and Application, and does not include the TOC as part of the content of the TS.

A TOC for the TS will be maintained under Energy Harbor Nuclear Corp. control. The TOC will be issued by Energy Harbor Nuclear Corp. in conjunction with the implementation of NRC-approved TS amendments that alter the TOC.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

10 CFR 50.36(a)(1) states:

Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

Like the TS bases, the TOC does not meet the criteria specified in 10 CFR 50.36 for inclusion within a plants TS.

Energy Harbor Nuclear Corp. has evaluated this change against the applicable regulatory requirements as described above. Based on this, there is reasonable assurance that the health and safety of the public, following approval of this change, will remain unaffected.

4.2 Precedent

A similar request was approved for Wolf Creek Generating Station, Unit 1 (Reference 2) on August 16, 2022. Amendment 233 was issued to remove the TOC from the TS.

A similar request was approved for Exelon Generation Company, LLC units (Reference 3) on December 18, 2019. The amendments issued to remove the TOC from the TS for each unit are as follows:

- Amendments 204 and 204 for Braidwood Station, Units 1 and 2, respectively;

- Amendments 210 and 210 for Byron Station, Units 1 and 2, respectively;

- Amendments 264 and 257 for Dresden Nuclear Power Station, Units 2 and 3, respectively;

- Amendment 330 for James A. FitzPatrick Nuclear Power Plant;

- Amendment 135 for R. E. Ginna Nuclear Power Plant;

- Amendments 240 and 226 for LaSalle County Station, Units 1 and 2, respectively; L-23-001 Page 4 of 6

- Amendments 238 and 201 for Limerick Generating Station, Units 1 and 2, respectively;

- Amendments 240 and 178 for Nine Mile Point Nuclear Station, Units 1 and 2, respectively;

- Amendments 330 and 333 for Peach Bottom Atomic Power Station, Units 2 and 3, respectively;

- Amendments 277 and 272 for Quad Cities Nuclear Power Station, Units 1 and 2, respectively.

4.3 No Significant Hazards Consideration Analysis

In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Energy Harbor Nuclear Corp. requests an amendment to Facility Operating License No. NPF-58 to revise the Technical Specifications (TS) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP). The proposed amendment would remove the table of contents (TOC) from the TS and place it under licensee control.

Energy Harbor Nuclear Corp. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

The proposed amendment is administrative and affects control of a document, the TOC, listing the specifications in the plant TS. Transferring control from the Nuclear Regulatory Commission (NRC) to Energy Harbor Nuclear Corp. does not affect the operation, physical configuration, or function of plant equipment or systems. The proposed amendment does not impact the initiators or assumptions of analyzed events; nor does it impact the mitigation of accidents or transient events.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed amendment does not involve a physical alteration of the plant (that is, no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed amendment does not alter any assumptions made in the safety analysis.

L-23-001 Page 5 of 6

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

The proposed amendment is administrative. The TOC is not required by regulation to be in the TS. Removal does not impact any safety assumptions or have the potential to reduce a margin of safety. The proposed amendment involves a transfer of control of the TOC from the NRC to Energy Harbor Nuclear Corp. No change in the technical content of the TS is involved.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Energy Harbor Nuclear Corp. concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Technical Specifications Task Force, TSTF-GG-05-01, Writers Guide for Plant-Specific Improved Technical Specifications, Revision 1, dated August 2010.

L-23-001 Page 6 of 6

2. Letter from Samson S. Lee (U.S. NRC) to Mr. Cleveland Reasoner (Wolf Creek Nuclear Operating Corporation), Wolf Creek Generating Station, Unit 1 -

Issuance of Amendment No. 233 RE: Removal of Table of Contents from the Technical Specifications (EPID L-2022-LLA-0008), dated August 16, 2022 (ADAMS Accession No. ML22199A294).

3. Letter from Blake Purnell (U.S. NRC) to Mr. Bryan C. Hanson (Exelon Generation Company, LLC), Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Dresden Nuclear Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; R. E. Ginna Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments to Remove Table of Contents from Technical Specifications (EPID L-2019-LLA-0125), dated December 18, 2019 (ADAMS Accession No. ML19302E700).

Attachment 2 L-23-001

Proposed Technical Specification Changes (Mark-Up)

(4 pages follow)

TABLE OF CONTENTS

1.0 USE AND APPLICATION 1.1 Definitions... 1.0-1 1.2 Logical Connectors... 1.0-8 1.3 Completion Times. 1.0-11 1.4 Frequency.. 1.0-24

2.0 SAFETY LIMITS (SLs) 2.1 SLs.. 2.0-1 2.2 SL Violations. 2.0-1

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY. 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY. 3.0-4

3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM).... 3.1-1 3.1.2 Reactivity Anomalies.... 3.1-5 3.1.3 Control Rod OPERABILITY.... 3.1-7 3.1.4 Control Rod Scram Times... 3.1-12 3.1.5 Control Rod Scram Accumulators. 3.1-15 3.1.6 Control Rod Pattern. 3.1-18 3.1.7 Standby Liquid Control (SLC) System.. 3.1-20 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves.. 3.1-24

3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR).. 3.2-1 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)... 3.2-2 3.2.3 LINEAR HEAT GENERATION RATE (LHGR). 3.2-3

3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation. 3.3-1 3.3.1.2 Source Range Monitor (SRM) Instrumentation 3.3-10 3.3.2.1 Control Rod Block Instrumentation 3.3-15 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation 3.3-20 3.3.3.2 Remote Shutdown System.. 3.3-24 3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation.3.3-26 3.3.4.2 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation.. 3.3-29 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation.. 3.3-32 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation.. 3.3.43a 3.3.5.3 Reactor Core Isolation Cooling (RCIC) System Instrumentation.. 3.3-44 3.3.6.1 Primary Containment and Drywell Isolation Instrumentation... 3.3-48 3.3.6.2 Residual Heat Removal (RHR) Containment Spray System Instrumentation 3.3-60

(continued)

PERRY - UNIT 1 i Amendment No. 184 TABLE OF CONTENTS

3.3 INSTRUMENTATION (continued) 3.3.6.3 Suppression Pool Makeup (SPMU) System Instrumentation 3.3-64 3.3.6.4 Relief and Low-Low Set (LLS) Instrumentation... 3.3-68 3.3.7.1 Control Room Emergency Recirculation (CRER) System Instrumentation.. 3.3-70 3.3.8.1 Loss of Power (LOP) Instrumentation.. 3.3-74 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring... 3.3-77

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 Recirculation Loops Operating 3.4-1 3.4.2 Flow Control Valves (FCVs) 3.4-6 3.4.3 Jet Pumps.. 3.4-8 3.4.4 Safety/Relief Valves (S/RVs).. 3.4-10 3.4.5 RCS Operational LEAKAGE... 3.4-12 3.4.6 RCS Pressure Isolation Valve (PIV) Leakage.. 3.4-14 3.4.7 RCS Leakage Detection Instrumentation.. 3.4-16 3.4.8 RCS Specific Activity.... 3.4-19 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown... 3.4-21 3.4.10 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown..... 3.4-24 3.4.11 RCS Pressure and Temperature (P/T) Limits.. 3.4-26 3.4.12 Reactor Steam Dome Pressure. 3.4-32

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating.3.5-1 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control.. 3.5-6 3.5.3 RCIC System. 3.5-10

3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment - Operating. 3.6-1 3.6.1.2 Primary Containment Air Locks. 3.6-3 3.6.1.3 Primary Containment Isolation Valves (PCIVs) 3.6-9 3.6.1.4 Primary Containment Pressure. 3.6-20 3.6.1.5 Primary Containment Air Temperature. 3.6-21 3.6.1.6 Low-Low Set (LLS) Valves. 3.6-22 3.6.1.7 Residual Heat Removal (RHR) Containment Spray System 3.6-24 3.6.1.8 Feedwater Leakage Control System (FWLCS).. 3.6-26 3.6.1.9 Main Steam Shutoff Valves.... 3.6-27 3.6.1.10 Primary Containment - Shutdown 3.6-29 3.6.1.11 Containment Vacuum Breakers. 3.6-31 3.6.1.12 Containment Humidity Control... 3.6-34 3.6.2.1 Suppression Pool Average Temperature.. 3.6-36

(continued)

PERRY - UNIT 1 ii Amendment No. 184 TABLE OF CONTENTS

3.6 CONTAINMENT SYSTEMS (continued) 3.6.2.2 Suppression Pool Water Level 3.6-39 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling.. 3.6-40 3.6.2.4 Suppression Pool Makeup (SPMU) System. 3.6-42 3.6.3.1 Deleted 3.6.3.2 Primary Containment and Drywell Hydrogen Igniters. 3.6-46 3.6.3.3 Combustible Gas Mixing System... 3.6-49 3.6.4.1 Secondary Containment.. 3.6-51 3.6.4.2 Secondary Containment Isolation Valves (SCIVs).. 3.6-53 3.6.4.3 Annulus Exhaust Gas Treatment (AEGT) System.. 3.6-56 3.6.5.1 Drywell 3.6-59 3.6.5.2 Drywell Air Lock 3.6-61 3.6.5.3 Drywell Isolation Valves.. 3.6-65 3.6.5.4 Drywell Pressure... 3.6-69 3.6.5.5 Drywell Air Temperature.. 3.6-70 3.6.5.6 Drywell Vacuum Relief System. 3.6-71

3.7 PLANT SYSTEMS 3.7.1 Emergency Service Water (ESW) System - Divisions 1 and 2 3.7-1 3.7.2 Emergency Service Water (ESW) System - Division 3. 3.7-3 3.7.3 Control Room Emergency Recirculation (CRER) System.... 3.7-4 3.7.4 Control Room Heating, Ventilation, and Air Conditioning (HVAC)

System.... 3.7-8 3.7.5 Main Condenser Offgas.. 3.7-11 3.7.6 Main Turbine Bypass System. 3.7-13 3.7.7 Fuel Pool Water Level.. 3.7-14 3.7.8 Deleted 3.7.9 Deleted 3.7.10 Emergency Closed Cooling Water (ECCW) System.. 3.7-19 3.7.11 Flood Protection 3.7-21

3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating. 3.8-1 3.8.2 AC Sources - Shutdown. 3.8-17 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8-21 3.8.4 DC Sources - Operating. 3.8-24 3.8.5 DC Sources - Shutdown. 3.8-28 3.8.6 Battery Parameters.. 3.8-32 3.8.7 Distribution Systems - Operating.. 3.8-36 3.8.8 Distribution Systems - Shutdown.. 3.8-38

3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks. 3.9-1 3.9.2 Refuel Position One-Rod-Out Interlock... 3.9-2 3.9.3 Control Rod Position... 3.9-4

(continued)

PERRY - UNIT 1 iii Amendment No. 200 TABLE OF CONTENTS

3.9 REFUELING OPERATIONS (continued) 3.9.4 Control Rod Position Indication.... 3.9-5 3.9.5 Control Rod OPERABILITY - Refueling. 3.9-7 3.9.6 Reactor Pressure Vessel (RPV) Water Level - Irradiated Fuel.. 3.9-8 3.9.7 Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods... 3.9-9 3.9.8 Residual Heat Removal (RHR) - High Water Level.. 3.9-10 3.9.9 Residual Heat Removal (RHR) - Low Water Level... 3.9-13

3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation 3.10-1 3.10.2 Reactor Mode Switch Interlock Testing 3.10-4 3.10.3 Single Control Rod Withdrawal - Hot Shutdown 3.10-6 3.10.4 Single Control Rod Withdrawal - Cold Shutdown. 3.10-9 3.10.5 Single Control Rod Drive (CRD) Removal - Refueling 3.10-13 3.10.6 Multiple Control Rod Withdrawal - Refueling.. 3.10-16 3.10.7 Control Rod Testing - Operating.. 3.10-18 3.10.8 SHUTDOWN MARGIN (SDM) Test - Refueling 3.10-19 3.10.9 Suppression Pool Makeup - MODE 3 Upper Containment Pool Drain-Down 3.10-23

4.0 DESIGN FEATURES 4.1 Site Location 4.0-1 4.2 Reactor Core 4.0-1 4.3 Fuel Storage. 4.0-2

5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility.. 5.0-1 5.2 Organization. 5.0-2 5.3 Unit Staff Qualifications.. 5.0-4 5.4 Procedures 5.0-5 5.5 Programs and Manuals.. 5.0-6 5.6 Reporting Requirements 5.0-16 5.7 High Radiation Area 5.0-19

PERRY - UNIT 1 iv Amendment No. 200