Text

– Issuance of Amendment No. 202 to Adopt TSTF-276, Revision 2, Revise DG Full Load Rejection Test
	ML23353A001
Person / Time
Site:	Perry
Issue date:	02/21/2024
From:	Scott Wall; Plant Licensing Branch III
To:	Penfield R; Energy Harbor Nuclear Corp
	Wall S
References
	EPID L-2023-LLA-0079
	Download: ML23353A001 (1)
	v • d • e

February 21, 2024

Mr. Rod L. Penfield 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. 202 TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TSTF-276, REVISION 2, REVISE DG [DIESEL GENERATOR] FULL LOAD REJECTION TEST (EPID L-2023-LLA-0079)

Dear Mr. Penfield:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 202 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 June 5, 2023. The amendment modifies the NOTES in TS 3.8.1, AC [Alternating Current] Sources - Operating, Surveillance Requirements (SR) 3.8.1.9, 3.8.1.10 and 3.8.1.14, consistent with Technical Specification Task Force (TSTF)

Traveler TSTF-276, Revision 2, Revise DG [Diesel Generator] full load rejection test. The NOTES allow the SRs to be performed at a specified power factor with clarifications addressing situations when the power factor cannot be achieved.

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. 202 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. 202 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 June 5, 2023, 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 -

2. Accordingly, the license is amended by changes to the Technical Specif ications, as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-58 is her eby 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. 202, 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

Jeffrey A. Whited, 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: February 21, 2024 ATTACHMENT TO LICENSE AMENDMENT NO. 202

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

3.8-8 3.8-8 3.8-11 3.8-11

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. 202, 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. 201, 202 AC Sources - Operating 3.8.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.1.9 ------------------------------NOTES-----------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3).

However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG rejects a load greater than or equal In accordance to its associated single largest post-accident load. with the Following load rejection, engine speed is maintained Surveillance less than normal plus 75% of the difference between Frequency nominal speed and the overspeed trip setpoint, or Control Program 15% above nominal, whichever is less.

SR 3.8.1.10 ------------------------------NOTES-----------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3).

However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG does not trip and voltage is In accordance maintained 4784 V for Division 1 and 2 DGs and with the 5000 V for Division 3 DG during and following a Surveillance load rejection of a load 5600 kW for Division 1 Frequency and 2 DGs and 2600 kW for Division 3 DG. Control Program

(continued)

PERRY - UNIT 1 3.8-8 Amendment No. 202 AC Sources - Operating 3.8.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.1.14 ------------------------------NOTES-----------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. Credit may be taken for unplanned events that satisfy this SR.

3. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.9 for Division 1, 2, and 3 DGs. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

In accordance Verify each DG operates for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: with the Surveillance

a. For 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 6800 kW and 7000 kW Frequency for Division 1 and 2 DGs, and 2860 kW for Control Program Division 3 DG; and

b. For the remaining hours of the test loaded 5600 kW and 7000 kW for Division 1 and 2 DGs, and 2600 kW for Division 3 DG.

(continued)

PERRY - UNIT 1 3.8-11 Amendment No. 202 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-276, REVISION 2, REVISE DG [DIESEL GENERATOR] FULL LOAD REJECTION TEST

AMENDMENT NO. 202 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 June 5, 2023 February 21, 2024 ADAMS Accession No. ML23156A550 Principal Contributors to Safety Evaluation C. Ashley, NRR E. Kleeh, NRR H. Kodali, NRR

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 Spec ifications Task Force (TSTF) Traveler TSTF-276, Revision 2, Revise DG [Diesel Generator] full load rejection test (TSTF-276)

(Agencywide Documents Access and Management System (ADAMS) Accession No. ML003672387), and the associated U.S. Nuclear Regulatory Commission (NRC) staff approval of TSTF-276 (ML003730788).

The proposed changes would modify the NOTES in TS 3.8.1, AC [Alternating Current]

Sources - Operating, Surveillance Requirements (SR) 3.8.1.9, 3.8.1.10 and 3.8.1.14, to require that these SRs be performed at a specified power factor (PF) of 0.9 with clarifications addressing situations when that PF cannot be achieved. The changes are consistent with TSTF-276, Revision 2.

Enclosure 2

1.1 System Descriptions

As described in Section 8.3, Onsite Power Systems, of the PNPP Updated Safety Analysis Report (USAR) (ML23303A135), the PNPP Class 1E AC Electrical Power Distribution System AC sources consist of the offsite power and the onsite standby power sources. The Class 1E AC distribution system supplies electrical power to three divisional load Groups (divisions), with each division powered by an independent 4.16 kilo-volt (KV) Class 1E engineered safety features (ESF) bus. Each ESF bus receives power from the 345 kV grid through two separate, independent offsite AC power circuits and a dedicated onsite DG for each circuit. The offsite AC power circuits are designed and located to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions.

Each DG must also be capable of accepting required loads within the assumed loading sequence intervals and must continue to operate until offsite power can be restored to the ESF buses. The DG continuous service rating is 7000 kW for Divisions 1 and 2 and is 2600 kW for Division 3, with 10 percent overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any 24-hour period.

Additional DG capabilities must be demonstrated to meet SR 3.8.1.9, SR 3.8.1.10, and SR 3.8.1.14.

These surveillances are performed with the DG synchronized with offsite power. When the DG is not synchronized with offsite power, the PF is determined by plant load and cannot be adjusted.

1.2 Description of Proposed Changes to Adopt TSTF 276

PNPP SR 3.8.1.9, 3.8.1.10, and 3.8.1.14, state, in part, that when a DG is synchronized with offsite power for load rejection or endurance and margin testing, the SR shall be performed at a PF of 0.9.

The proposed change requires the DG to be tested under load conditions that are as close to design basis conditions as possible. Under such circumstances, the proposed change allows the surveillances to be performed at a PF as close as practicable to 0.9.

The current NOTE for SR 3.8.1.9 states:

NOTES-----------------------------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed at a power factor < 0.9.

The revised NOTE for SR 3.8.1.9 would state:

NOTES-----------------------------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed at a power factor < 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

The current SR 3.8.1.10 states:

NOTE-------------------------------------------------

This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However, credit may be taken for unplanned events that satisfy this SR.

Verify each DG operating at a power factor 0.9 does not trip and voltage is maintained 4784 V for Division 1 and 2 DGs and 5000 V for Division 3 DG during and following a load rejection of a load > 5600 kW for Division 1 and 2 DGs and > 2600 kW for Division 3 DG.

The revised SR 3.8.1.10 would state:

NOTES-----------------------------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 (not applicable to Division 3). However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG does not trip and voltage is maintained 4784 V for Division 1 and 2 DGs and 5000 V for Division 3 DG during and following a load rejection of a load > 5600 kW for Division 1 and 2 DGs and > 2600 kW for Division 3 DG.

The current SR 3.8.1.14 states:

NOTES-----------------------------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG operating at a power factor 0.9 operates for > 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded > 6800 kW and 7000 kW for Division 1 and 2 DGs, and > 2860 kW for Division 3 DG; and

b. For the remaining hours of the test loaded > 5600 kW and 7000 kW for Division 1 and 2 DGs, and > 2600 kW for Division 3 DG.

The revised SR 3.8.1.14 would state:

NOTES-----------------------------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. Credit may be taken for unplanned events that satisfy this SR.

3. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.9 for Division 1, 2, and 3 DGs. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for > 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded > 6800 kW and 7000 kW for Division 1 and 2 DGs, and > 2860 kW for Division 3 DG; and

b. For the remaining hours of the test loaded > 5600 kW and 7000 kW for Division 1 and 2 DGs, and > 2600 kW for Division 3 DG.

2.0 REGULATORY EVALUATION

The NRC staff applied the following requirements to evaluate LAR:

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion (GDC) 17, Electric power systems, requires, in part, that an onsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The onsite electric power supplies including the batteries and the onsite electric distribution system shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. In ad dition, this criterion requires provisions to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the

loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

GDC 18, Inspection and testing of electric power systems, requires, in part, that electric power systems important to safety be designed to permit appropriate periodic inspection and testing to demonstrate operability and functional performance.

10 CFR 50.36, Technical Specifications, requires, in part, that the operating license of a nuclear production facility include TS. Paragraph 50.36 (c)(3) requires that the TS include SRs, which 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, that the limiting conditions for operation will be met.

The proposed changes discussed in this evaluation relate to the SR category.

The staff considered the following NRC guidance documents to evaluate the LAR:

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 standard technical specifications (STS) 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).

The licensee stated that Regulatory Guide (RG) 1.108, Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants, guidelines are used in establishing preoperational and periodic test procedures for the standby (Division 1 and 2) and high pressure core spray (HPCS) (Division 3) DGs at PNPP. The final revision of RG 1.1.08, Revision 1, was issued in August 1977 (ML12216A011). In the Federal Register (58 FR 41813) dated August 5, 1993, the NRC withdrew RG 1.108 since the guidance in RG 1.108 has been updated and incorporated into Revision 3 of RG 1.9, Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class IE Onsite Electric Power Systems at Nuclear Power Plants, dated July 1993 (ML003739929). However, the withdrawal of RG 1.108 does not alter any prior or existing licensing commitments based on its use.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-276

The NRC staffs evaluation is applicable to SR 3.8.1.9, SR 3.8.1.10 and SR 3.8.1.14.

SR 3.8.1.9 demonstrates the capability to reject the single largest load while maintaining a specified margin to the overspeed trip.

SR 3.8.1.10 demonstrates the DG capability to reject a full load, that is, maximum expected accident load, without overspeed tripping or exceeding the predetermined voltage limits.

SR 3.8.1.14 verifies conformance with RG 1.9, Revision 3, position 2.2.9 which requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of which is at a load equivalent to the continuous rating of the DG, and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of which is at a load equivalent to 110 percent of the continuous duty rating of the DG.

The NRC staff reviewed the information provided in the LAR, USAR Section 8.3, and NUREG-1434. PNPP performs SR 3.8.1.9, 3.8.1.10, and 3.8.1.14 with the DG synchronized with offsite power. When the DG is synchronized with offsite power, a PF 0.9 reflects loading under design basis accident conditions. When the DG is not synchronized with offsite power, the PF is determined by plant load and cannot be adjusted. W hen the plant is shutdown, the loads on ESF buses are light, then the PF should be close to 0.9 while still maintaining acceptable voltages on ESF buses.

The proposed change to these SRs is addition of the NOTE (revision of Note 2 for SR 3.8.1.9 shown in bold):

If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

This NOTE is consistent with NUREG-1434 and TSTF-276-A, Rev 2.

If grid voltage is higher than typical, the additional DG field excitation current required to achieve a 0.9 PF results in the ESF bus voltage (for DG being tested) exceeding its maximum steady state voltage limit. This typically occurs when the plant is shut down with light loading on the specific ESF bus for the DG being tested, and its voltage cannot be lowered sufficiently to achieve a 0.9 PF. Thus, the PF should be maintained as close as practicable to a 0.9 while still maintaining acceptable ESF bus voltage.

Another instance when PF cannot be maintained at 0.9 is when the DG excitation level exceeds the DG allowed excitation level. If this occurs, the power factor shall be maintained as close as practicable to 0.9 without exceeding the DG excitation limits.

Load test overload protection is provided by a single underfrequency relay. With the DG synchronized to offsite power, if the DG overloads during load testing, this relay acts to trip the Class 1E offsite source breakers while leaving the DG connected to the bus. The alternate DGs

will remain operable and in a standby condition during the performance of the SR and would not be susceptible to a common grid disturbance and a common cause failure.

In the LAR, the licensee stated that procedure precautions ensure that testing is not performed under potentially adverse external plant conditions (such as storms, unstable grid conditions, and so forth). These three SR changes do not significantly affect the ability of these surveillances to verify that the DG can perform its safety function.

A PF of 0.9 is desired when performing the three surveillances and can normally be achieved when performing them with the DG synchronized wi th offsite power. However, this PF may not be achievable if (1) grid voltage is higher than usual or (2) DG excitation levels exceed maximum excitation level of the DG. Under these conditions, the power factor shall be maintained as close as practicable to a 0.9 PF.

Based on the above, the NRC staff finds that the proposed NOTE (1) provides flexibility in the DG testing to ensure that the plant safety systems are not challenged by the surveillance tests, (2) continues to meet the intent of the SRs, and (3) will be applied as described in the TSTF traveler. Therefore, the staff finds the proposed NOTE acceptable.

The proposed change also removes the requirement to verify each DG operating at a power factor 0.9 from SR 3.8.1.10 and 3.8.1.14.

SR 3.8.1.10 and SR 3.8.1.14, require that these surveillances be performed at a specified PF of 0.9. When performing this surveillance test at power and synchronized with offsite power, a PF of 0.9 should normally be able to be achieved. When the DG is not synchronized to offsite power, the PF is based on plant load and therefore, the PF cannot be adjusted because adequate load may not be available. In the LAR, the licensee stated that the proposed changes are consistent with NUREG-1434 and TSTF-276, Revision 2. This is based on PNPP TSs conforming to, to a practical extent, the suggested wording in NUREG-1434 and adhering to inserts recommended by TSTF-276 for SR NOTE changes when specified DG PF cannot be maintained during performance of the DG full load rejection test. The NRC staff finds that the removal of operating at a power factor 0.9 from SR 3.8.1.10 and 3.8.1.14, compliments the addition of the NOTE, and for the same reasons discussed above, is acceptable.

The TSTF traveler describes expanding the TS Bases to reflect the allowance and justification for the acceptability of the allowance. The licensee stated that changes to the affected TS Bases will be incorporated into PNPP TS Bases in accordance with the TS Bases Control Program following issuance of the amendment. The licensee provided these changes in of the LAR for information only. The NRC staff verified the statement that will be added to the PNPP TS Bases and that it is consistent with TSTF-276; therefore, the staff has no objections to the proposed changes to the TS Bases.

As required by the current SR 3.8.1.9, SR 3.8.1.10 and SR 3.8.1.14, the DGs will continue to be tested in any mode of operation with the revised SRs. The DGs are considered operable during performance of the SRs. The proposed NOTE requires that the SRs continue to be performed at the current bounding power factor limit of 0.9, and if not possible, at a power factor as close as practicable to the current limit. The NRC staff c oncludes that the proposed NOTE will not impact the current operability requirement for the DGs since it ensures that the DGs are safely tested to demonstrate their ability to perform their safety design functions.

In addition to the above changes, the licensee proposed to renumber the current NOTE in SR 3.8.1.10 as NOTE 1 and revise NOTE to NOTES, with the addition of the new NOTE as NOTE 2. The NRC staff concludes that these ch anges are editorial and do not change the intent of the SRs. Therefore, the proposed changes are acceptable.

3.2 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.

3.3 Technical Conclusion

The NRC staff reviewed the proposed changes to PNPP TS SR 3.8.1.9, SR 3.8.1.10 and SR 3.8.1.14 for DG testing. The SRs currently require the DGs to operate within specified power factor limits when synchronized with the grid during the tests. The changes would revise the SRs by replacing the surveillance statement regarding the power factor limits with a new note that is consistent with TSTF-276, Revision 2. Based on the above technical evaluation, the staff concludes that the proposed TS changes provide reasonable assurance of the availability of equipment required to mitigate the consequences of design basis accidents. Thus, the NRC staff concludes that the proposed TS changes continue to comply with the requirements of 10 CFR 50.36(c), GDC 17, and GDC 18. Therefore, the NRC staff finds the proposed changes 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. 202 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 June 5, 2023 February 21, 2024 ADAMS Accession No. ML23156A550

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)-276, Revision 2, Revise DG [Diesel Generator] full load rejection test (TSTF-276)

(Agencywide Documents Access and M anagement System (ADAMS) Accession No. ML003672387), and the associated U.S. Nuclear Regulatory Commission (NRC, the Commission) staff approval of TSTF-276 (ML003730788).

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 October 6, 2023. 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. 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 August 8, 2023 (88 FR 53537), and there has been no public comment on such find ing. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 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.

Enclosure 3

ML23353A001 *via email OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC(A)

NAME SWall SRohrer (ABaxter/for) SMehta (ARussell/for)

DATE 12/18/2023 12/20/2023 12/20/2023 OFFICE NRR/DEX/EEEB/BC* OGC - NLO NRR/DORL/LPL3/BC NAME MWendell MCarpentier JWhited DATE 12/11/2023 01/17/2024 02/20/2024 OFFICE NRR/DORL/LPL3/PM NAME SWall DATE 02/21/2024

v t e Letter Sequence Approval
EPID:L-2023-LLA-0079, TSTF-276 (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2023-06-05 [Table View]

ML23353A001

Text

SUBJECT:

Dear Mr. Penfield:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

1.0 INTRODUCTION

2.0 STATE CONSULTATION

3.0 ENVIRONMENTAL CONSIDERATION

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