L-25-128, Application to Revise Technical Specifications to Adopt TST-597, Eliminate LCO 3.0.3 Mode 2 Requirement

Application to Revise Technical Specifications to Adopt TST-597, Eliminate LCO 3.0.3 Mode 2 Requirement

ML25231A303
Person / Time
Site:	Perry
Issue date:	08/19/2025
From:	Tony Brown Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-25-128
Download: ML25231A303 (1)

Text

V!S L-25-128 August 19, 2025 A TIN: 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 I

Terry Brown Vice President, Perry Nuclear Power Plant 10 Center Rd P.O. Box97 Perry, OH 44081 10CFR50.90 Application to Revise Technical Specifications to Adopt TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement" In accordance with 10 CFR 50.90, Vistra Operations Company LLC is submitting a request for an amendment to the Technical Specifications (TS) for Perry Nuclear Power Plant (PNPP).

Vistra Operations Company LLC requests adoption of TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement,"

which is an approved change to the Standard Technical Specifications into the PNPP TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

Vistra Operations Company LLC requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRC's acceptance review. Once approved, the amendment shall be implemented within 90 days.

There are no regulatory commitments contained in this letter. If there are any questions, or if additional information is required, please contact Mr. Jack Hicks, Senior Manager, Fleet Licensing, at (254) 897-6725 or J ack.Hicks@vistracorp.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 15, 2025.

G555 SI ERP.,\ DRIVE rnvI NG, TEXAS 75039 o 214-S12-4EOO VISTP-t'.CO RP.COM

Perry Nuclear Power Plant, Unit No. 1 L-25-128 Page 2 Attachments: 1. Evaluation of Proposed Changes 2.

Proposed Technical Specification Changes (Mark-Up) 3.

Revised Technical Specification Page 4.

Proposed Technical Specification Bases (Mark-Up) - For Information Only cc:

NRC Region III Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board Evaluation of Proposed Change Page 1 of 3

Subject:

Application to Revise Technical Specifications to Adopt TSTF-597, Eliminate LCO 3.0.3 Mode 2 Requirement

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion

4.0 ENVIRONMENTAL CONSIDERATION

Page 2 of 3

1.0 DESCRIPTION

Vistra Operations Company LLC (Vistra OpsCo) requests adoption of TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement," which is an approved change to the Standard Technical Specifications (STS), into the Perry Nuclear Power Plant, Unit No. 1 (PNPP) Technical Specifications (TS). TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Vistra OpsCo has reviewed the safety evaluation for TSTF-597 provided to the Technical Specifications Task Force in a letter dated December 26, 2024. This review included the NRC staffs evaluation, as well as the information provided in TSTF-597. Vistra OpsCo has concluded that the justifications presented in TSTF-597 and the safety evaluation prepared by the NRC staff are applicable to PNPP and justify this amendment for the incorporation of the changes to the PNPP TS.

2.2 Variations Vistra OpsCo is not proposing any variations from the TS changes described in TSTF-597 or the applicable parts of the NRC staffs safety evaluation.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Vistra Operations Company LLC (Vistra OpsCo) requests adoption of TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement," which is an approved change to the Standard Technical Specifications (STS), into the PNPP TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

Vistra OpsCo has evaluated if a significant hazards consideration is involved with the proposed amendment(s) 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 change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The time required to shut down the plant after entering LCO 3.0.3 is not an initiator of any accident previously evaluated.

Under the proposed change, the TS continue to require the plant to shut down and enter Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. The consequences of any accident previously evaluated during the revised LCO 3.0.3 shutdown requirements are no different than the consequences of the same accident during the existing times.

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?

Page 3 of 3 Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the current plant operating practice for all other TS required shutdowns.

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

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

Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

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

Based on the above, Vistra OpsCo concludes that the proposed change presents no 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.

3.2 Conclusion 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.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Proposed Technical Specification Changes (Mark-Up)

(1 page follows)

LCO Applicability 3.0 PERRY - UNIT 1 3.0-1 Amendment No. 144 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; ab.

MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and bc.

MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)

Revised Technical Specification Page (1 page follows)

LCO Applicability 3.0 PERRY - UNIT 1 3.0-1 Amendment No.

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and b.

MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only (1 page follows)

LCO Applicability B 3.0 PERRY - UNIT 1 B 3.0-4 Revision No. 12 BASES LCO 3.0.3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met.

b.

The LCO is no longer applicable.

c.

A Condition exists for which the Required Actions have now been performed.

d.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering the next lower MODE applies. If a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 32 is entered in 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br />, then the time allowed for reaching MODE 43 is the next 1128 hours0.0131 days <br />0.313 hours <br />0.00187 weeks <br />4.29204e-4 months <br />, because the total time for entering MODE 43 is not reduced from the allowable limit of 3713 hours0.043 days <br />1.031 hours <br />0.00614 weeks <br />0.00141 months <br />.

Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, Fuel Pool Water Level. LCO 3.7.7 has an Applicability of During movement of irradiated fuel (continued)