PY-CEI-NRR-1951, Forwards Supplemental Info Re Previous Applications for Amend to License NPF-58 for Conversion of Current TS to TS Based on NUREG-1434, Improved BWR6 TS, Per Discussions W/ NRC Re Acceptability of Proposed Changes to LCO 3.0.4

Forwards Supplemental Info Re Previous Applications for Amend to License NPF-58 for Conversion of Current TS to TS Based on NUREG-1434, Improved BWR6 TS, Per Discussions W/ NRC Re Acceptability of Proposed Changes to LCO 3.0.4

ML20083Q179
Person / Time
Site:	Perry
Issue date:	05/18/1995
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20083Q182	List: ML20083Q199 PY-CEI-NRR-1951, Forwards Supplemental Info Re Previous Applications for Amend to License NPF-58 for Conversion of Current TS to TS Based on NUREG-1434, Improved BWR6 TS, Per Discussions W/ NRC Re Acceptability of Proposed Changes to LCO 3.0.4
References
RTR-NUREG-1434 PY-CEI-NRR-1951, NUDOCS 9505250155
Download: ML20083Q179 (4)

Text

-..

7 i '%b '

GNTERCOR ENERGY PERRY NUCLEAR POWER PLANT Mail Address: Donald C. Shelton 10 CENTER ROAD b RR , O 10 44081 PERRY, OHIO 44081 NUCLEAR (216) 259-3731 May 18, 1995 PY-CEI/NRR-1951L United States Nuclear Regulatory Commission Document Control Desk Vashington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Supplemental Submittal for Conversion of Current Technical Specifications to Technical Specifications Based on NUREG-1434, " Improved BVR6 Technical Specifications," Revision 0 Gentlemen Enclosed is supplemental information related to previous applications for amendment of the Facility Operating License (NPF-58) Appendix A Technical Specifications for the Perry Nuclear Power Plant (PNPP). This supplements the application made December 16, 1993 by letter PY-CEI/NRR-1732L, as revised by letter PY-CEI/NRR-1880L dated November 7, 1994, and letter PY-CEI/NRR-1944L dated May 5, 1995.

This information addresses minor discrepancies and items needing clarification found during various reviews and discussions with the NRC staff. Attachment 1 provides a brief explanation of the reason for each change. Attachment 2 provides a mark up of the proposed changes to the Technical Specification and Bases pages and justifications. The remaining justifications, Significant Hazards Considerations, and Environmental Considerations provided in the December 16, 1993 and November 7, 1994 applications remain valid.

Attachment 3 provides a matrix of items totally and partially relocated from the current Technical Specifications. The matrix identifies each relocated Technical Specification (by its current number), the corresponding new location (e.g., the Updated Safety Analysis Report),

and the applicable regulation or requirement (e.g., 10 CFR 50.59) that provides controls on future changes to these requirements.

During discussions with the Staff concerning the acceptability of the proposed changes to LCO 3.0.4, the Staff identified a concern regarding inoperable Emergency Core Cooling System (ECCS) actuation instrumentation in HODES 4 and 5. In H0 DES 1, 2, and 3, the ECCS instrumentation LCO provides specific Required Actions and Completion Times if an inoperable instrument results in a loss of ECCS actuation capability. PNPP will put in place administrative controls to ensure that losses of ECCS instrumentation actuation capability in MODES 4 and 5 vill have compensatory actions taken consistent with those required in MODES 1, 2, and 3.

opee:w comxn-es I cweionnectec uw ne"9 9505250155 950518 l bex I" PDR ADOCK 05000440 j g p PDR -

7 ,

• i .

I 1

PY-CEI/NRR-1951L May 18, 1995 Page 2 of 2 In accordance with the request in your letter dated May 10, 1995, PNPP is requesting an implementation date of no later than 120 days following the end of the next refueling outage. That outage is currently scheduled to begin in January 1996 and be complete in March 1996.

If you have questions or require additional information, please contact Mr. James D. Kloosterman, Manager - Regulatory Affairs at (216) 280-5833.

Very tr yours, CSO sc Attachments cc: NRC Project Manager NRC Resident Inspector Office NRC Region III State of Ohio

7 ,

T .

I, Donald C. Shelton, being duly sworn state that (1) I am Senior Vice President, Nuclear of the Centerior Service Company, (2) I am duly authorized to execute and file this certification on behalf of The Cleveland Electric Illuminating Company and Toledo Edison Company, and as the duly authorized agent for Duquesne Light Company, Ohio Edison Company, and Pennsylvania Power Company, and (3) the statements set forth herein are true and correct t best of my knowledge, information and belief.

[ J Donald C. Shelton Sworn to and subscribed before me, the / day of (144 ,

/9']f . /

._ A2) Y

/ jnor Noisy Publ!c, State of Ohio IAy Commitrion Expiras F.eb. 20, 2000

\groodinL30 County)

CODED /8838/SC

~'

3 . -

PY-CEI/NRR-1951L Attachment 1 Page 1 of 1 Information is listed belov explaining the nature of the changes resulting from discussions with the NRC improved Technical Specifications (ITS) Project Manager. The changes: clarify material already submitted to the NRC; do not change actions, frequencies, setpoints, or allovable values in either the current Technical Specifications (CTS) or ITS; and are editorial or administrative in nature. Furthermore, the changes have no safety significance.

1. CTS Table 3.3.2-1 was changed to identify the deletion of system -

isolations resulting from delta temperature signals. A revised markup of the CTS and a Discussion of Change are included which reflect material already included in the ITS markup.

2. Footnote (b) for Table 3.3.7.1-1 was clarified and made consistent with other similar footnotes by deleting the word "or" and adding "and" as noted. The original site concern which resulted in the proposed use of "or" was that an individual might not understand the convention and think that all three conditions vould have to be met simultaneously in order to use the footnote. This issue vill be addressed in training.

3. CTS Figure 3.4.1.1-1 and LCO 3.4.1.1 have been combined to form ITS Figure 3.4.1-1. This is more clearly explained with the new Discussion of Change A.12.

4. A Note was added to ITS 3.4.6 Required Action A.1. This Note was in the original version of NlIREG-1434, but was deleted in the conversion process by the BVR6 plants. During reviews, the NRC staff decided that the Note should be retained. The Note, as modified to agree with CTS, is added.

5. Amendment 60 to the Perry Nuclear Power Plant Technical Specifications implemented a portion of the changes requested by PY-CEI/NRR-1576L, but did not grant the portion of the changes referenced in Discussion of Change A.3 in CTS 3.6.1.2.

Therefore, Discussion of Change A.3 is not applicable and is being deleted. Further review of this item indicates that the j

CTS Discussion of Change A.1 is applicable to this change and

' the CTS markup has been changed to reference this Discussion of Change instead of A.3.

6. The mark up of CTS 3.4.1.4 is changed slightly to delete Discussion of Change LA.1 which no longer applies as a result of deleting the proposed requirement for a Pressure and Temperature Limits Report in the ITS. The change was made correctly elsewhere and was reflected properly in the mark up of the ITS.

7. Discussion of Change H.1 for CTS 3.8.2.1 is revised to reflect that the surveillance frequency was changed from seven days to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, not 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

-