ML21035A170

Issuance of Amendment No. 192, Regarding Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

ML21035A170
Person / Time
Site:	Perry
Issue date:	03/01/2021
From:	Scott Wall Plant Licensing Branch III
To:	Payne F Energy Harbor Nuclear Corp
Wall S
References
EPID L-2020-LLA-0211
Download: ML21035A170 (22)

Text

March 1, 2021 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. 192, REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (RPV WIC) ENHANCEMENTS (EPID L-2020-LLA-0211)

Dear Mr. Payne:

The U.S Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 192 to Renewed Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1 (Perry). The amendment consists of changes to the technical specifications (TS) in response to your application dated September 24, 2020, as supplemented by [[letter::L-21-053, Supplemental Information Regarding Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements|letter dated February 2, 2021]].

Energy Harbor Nuclear Corp. (EHNC) requested that the NRC process the proposed amendment under the Consolidate Line Item Improvement Process (CLIIP). The proposed changes revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF)-582, Revision 0, RPV WIC Enhancements, and the associated NRC staff safety evaluation of TSTF-582.

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 No. 50-440

Enclosures:

1. Amendment No. 192 to NPF-58

2. Safety Evaluation 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. 192 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 September 24, 2020, as supplemented by [[letter::L-21-053, Supplemental Information Regarding Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements|letter dated February 2, 2021]] 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. 192, 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: 2021.03.01 Salgado 14:43:52 -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: March 1, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 192 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 1.02-2a 1.02-2a 3.3-43a 3.3-43a 3.3-43b 3.3-43b 3.3-43c 3.3-43c 3.3-43d --

3.3-43e --

3.3-74 3.3-74 3.5-1 3.5-1 3.5-8 3.5-8 3.5-9 3.5-9 3.8-20 3.8-20

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. 192, 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. 191, 192

Definitions 1.1 1.1 Definitions (continued)

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, for all penetration flow paths below the TAF except;

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

PERRY - UNIT 1 1.0-2a Amendment No. 192 184

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

---

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.

OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.

PERRY - UNIT 1 3.3-43a Amendment No. 192184

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

---

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

These SRs apply to each Function in Table 3.3.5.2-1.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program PERRY - UNIT 1 3.3-43b Amendment No. 192184

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE MODES OR REQUIRED OTHER CHANNELS SPECIFIED PER ALLOWABLE FUNCTION CONDITIONS FUNCTION VALUE

1. RHR System Isolation

a. Reactor Vessel Water (a) 2 in one trip 177.1 Level - Low, Level 3 system inches

2. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (a) 2 in one trip 127.6 Level - Low Low, Level 2 system inches (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

PERRY - UNIT 1 3.3-43c Amendment No. 192184

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channel in trip. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

PERRY - UNIT 1 3.3-74 Amendment No. 19269

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of eight safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

---

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

LCO 3.0.4.b is not applicable to High Pressure Core Spray (HPCS).

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status.

B. HPCS System B.1 Verify by administrative 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. means RCIC System is OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System to 14 days OPERABLE status.

(continued)

PERRY - UNIT 1 3.5-1 Amendment No. 192184

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required High Pressure Core Spray In accordance (HPCS) System, the: with the Surveillance

a. Suppression pool water level is 16 ft 6 in; or Frequency Control Program

b. Condensate storage tank water volume is 249,700 gal.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance subsystem, the piping is filled with water from the with the pump discharge valve to the injection valve. Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.5-8 Amendment No. 192184

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 Frequency 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. with the Surveillance Frequency Control Program PERRY - UNIT 1 3.5-9 Amendment No. 192184

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------------------------------NOTE------------------------------

The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.14, and SR 3.8.1.16.

The following SRs are applicable for AC sources In accordance required to be OPERABLE: with applicable SRs SR 3.8.1.1 SR 3.8.1.6 SR 3.8.1.2 SR 3.8.1.9 SR 3.8.1.3 SR 3.8.1.10 SR 3.8.1.4 SR 3.8.1.14 SR 3.8.1.5 SR 3.8.1.16 PERRY - UNIT 1 3.8-20 Amendment No. 192184

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 192 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

1.0 INTRODUCTION

Energy Harbor Nuclear Corp. (EHNC, or the licensee) requested changes to the technical specifications (TSs) for Perry Nuclear Power Plant, Unit No. 1 (PNPP) by license amendment request (LAR), dated September 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20268C198), as supplemented by [[letter::L-21-053, Supplemental Information Regarding Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements|letter dated February 2, 2021]] (ADAMS Accession No. ML21034A417). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed LAR under the Consolidate Line Item Improvement Process (CLIIP). The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF)-582, Revision 0, RPV WIC Enhancements, (TSTF-582) (ADAMS Accession No. ML19240A260) and the associated NRC staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333).

The boiling water reactor (BWR) RPV design includes multiple penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup (RWCU), and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release. Drain Time is the time it would take for the water inventory in and above the RPV to drain to the TAF.

The supplemental [[letter::L-21-053, Supplemental Information Regarding Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements|letter dated February 2, 2021]], provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on November 3, 2020 (85 FR 69654).

Enclosure 2

1.1 Proposed TS Changes to Adopt TSTF-582 In accordance with NRC staff-approved TSTF-582, the licensee proposed changes that would revise the TSs related to RPV WIC to incorporate operating experience and to correct errors and omissions that the licensee incorporated into the PNPP TSs when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448). Specifically, the licensee proposed the following changes to adopt TSTF-582:

The Drain Time definition in TS 1.1 would be revised to move the examples of common mode failure mechanisms to the Bases and delete seismic events.

In TS 1.1, Drain Time definition, the exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are that are locked, sealed, or otherwise secured would be revised to apply the exception for manual or automatic valves that are closed and administratively controlled.

The Actions of TS 3.3.5.2 would be revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

TS 3.3.5.2, Required Action B.2 requires calculating Drain Time with a Completion Time of immediately. The Required Action would be renumbered as A.2.2 and revised to state, Initiate action to calculate Drain Time.

TS 3.5.1 Actions Note, the first use of the acronym HPCS would be defined and the definition would be removed from Condition B.

TS 3.5.2 and TS 3.3.5.2 would be revised to eliminate the requirement for a manual emergency core cooling system (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start. TS 3.5.2 Surveillance Requirements (SRs) related to manual initiation using the ECCS signal (such as verifying automatic alignment of valves on an initiation signal) would be eliminated. Related to this change, the TS 3.3.5.2 functions, SRs, and Actions that only support manual initiation using an ECCS signal (including interlocks and minimum flow instruments) would be eliminated.

SR 3.5.2.6, that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, would be modified by the addition of two notes. The first Note would replace the existing SR that the ECCS subsystem be run through the recirculation line with a Note that states that operation may be through the test return line. The second Note would permit crediting normal operation of the low-pressure ECCS subsystem for performance of the SR.

TS 3.8.2, AC [Alternating Current] Sources - Shutdown, SR 3.8.2.1, would be revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. TSTF-542 eliminated the automatic ECCS initiation in Modes 4 and 5.

1.2 Additional Proposed TS Changes The licensee proposed to make the following additional changes:

TS 3.3.8.1, Loss of Power (LOP) Instrumentation, would be revised to delete When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown. from the Applicability.

SR 3.8.2.1 would be revised to add SR 3.8.1.7, SR 3.8.1.15, and SR 3.8.1.18 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

The NRC staff notes that the above proposed changes are consistent with TSTF-583-T, Revision 0, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330).

1.3 Editorial Variations The licensee indicated that the following variations from TSTF-582 are administrative:

The PNPP TS utilize different numbering and titles than the Standard Technical Specifications (STSs) on which TSTF-582 was based. Specifically, the numbering in TS 3.3.5.2 differs from what is shown in the TSTF. Additionally, the titles in Table 3.3.5.2-1 differ from what is shown in the TSTF.

The PNPP TS contain an error within SR 3.8.2.1 for TS 3.8.2 AC Sources - Shutdown.

The proposed change would eliminate reference to SR 3.8.1.8 from the note in SR 3.8.2.1.

2.0 REGULATORY EVALUATION

The regulation at Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2) requires that TSs include LCOs. Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.

The regulation at 10 CFR 50.36(c)(3) requires that TSs include items in the category of 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, and that the LCOs 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 (ADAMS Accession No. 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 Standard Technical Specifications, General Electric, BWR/6 Plants, NUREG-1434, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, respectively), as modified by NRC-approved travelers.

Traveler TSTF-582 revised the STSs related to RPV WIC to incorporate operating experience and to correct editorial errors in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448). The NRC approved TSTF-542, Revision 2, on December 20, 2016 (ADAMS Package Accession No. ML16343B066). The NRC staff approved TSTF-582 under the CLIIP in letter dated August 13, 2020 (ADAMS Accession No. ML20219A333). The TSTF-582 SE states that a licensee may adopt the STS changes approved in TSTF-582, if the licensee has already adopted the STS changes approved in TSTF-542.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-582 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against the changes approved in TSTF-582. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-582 are applicable to PNPP TSs because PNPP is a BWR/6 design and the NRC staff approved the TSTF-582 changes for BWR/6 designs. The licensee meets the TSTF-582 SE provision for adoption of TSTF-582 since the licensee adopted Traveler TSTF-542 on dated December 12, 2018 (ADAMS Accession No. ML18292A816) in Amendment No. 184, for PNPP. Therefore, the NRC staff concludes that the licensees proposed changes to the PNPP TSs in Section 1.0 of this SE are acceptable in that they are consistent with TSTF-582 and the terms for use stated in the NRC staffs SE of TSTF-582.

The NRC staff finds that proposed changes to the TS 1.1 definition and LCOs 3.3.5.2, 3.3.8.1, and 3.5.1 correctly specify the lowest functional capability or performance levels of equipment required for safe operation of the facility in accordance with 10 CFR 50.36(c)(2)(i). Also, the NRC staff finds that proposed changes to the Actions of LCOs 3.3.5.2 and 3.5.1 are adequate remedial actions to be taken until each LCO can be met provide protection to the health and safety of the public, thereby satisfying 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed revisions to the SRs in TS 3.3.5.2, 3.5.2, and 3.8.2 continue to provide 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 in accordance with 10 CFR 50.36(c)(3).

Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 10 CFR 50.36(c)(3) as discussed in Section 3.0 of the NRC staffs SE of TSTF-582.

3.2 Additional Proposed TS Changes 3.2.1 Proposed TS Changes to Adopt TSTF-582 Refer to Section 1.2 of this SE for proposed changes.

3.2.1.1 TS 3.3.8.1, Applicability The licensee stated that TS 3.8.2 does not require automatic start and loading of a diesel generator (DG) within 10 seconds and within 13 seconds for Division 3 on an ECCS initiation signal or a loss of offsite power signal. Currently, TS 3.3.8.1, Loss of Power (LOP)

Instrumentation, is applicable in Modes 1, 2, and 3, and when the associated DG is required to

be operable by TS 3.8.2. The NRC staff confirmed that TS 3.8.2 no longer requires automatic start and loading of a DG on an LOP signal. The NRC staff finds it acceptable to revise the Applicability of LCO 3.3.8.1 by deleting When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown, because the LOP instrumentation that generates the LOP signal does not need to be operable when the DG is required to be operable by TS 3.8.2. Therefore, the NRC staff concludes that the LCO applicability changes will continue to provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2).

3.2.1.2 SR 3.8.2.1 LCO 3.8.2, AC Sources-Shutdown, requires one offsite circuit and one DG capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, Distribution Systems-Shutdown, to be operable in shutdown conditions. The existing SR 3.8.2.1 lists the TS 3.8.1 SRs that are applicable in shutdown conditions with some exceptions.

TS SR 3.8.1.7 and SR 3.8.1.15 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 10 seconds for Divisions 1 and 2 and within 13 seconds for Division 3 and required steady state voltage and frequency ranges. The 10 or 13-second start requirement associated with the DG automatic start supports the assumptions in the design basis LOCA analysis. The NRC staff confirmed that 10 or 13-second timing is not required during a manual DG start to respond to a draining event, which has a minimum Drain Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In addition, SR 3.8.1.2, which requires the DG to start from standby conditions and achieve the required steady state voltage and frequency ranges, is applicable under SR 3.8.2. The NRC staff finds that the SR 3.8.1.7 and SR 3.8.1.15 testing for the DGs capability to achieve required steady state voltage and frequency ranges will be performed in SR 3.8.1.2 since SR 3.8.1.2 provides the test for this DG capability. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.7 and SR 3.8.1.15 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

TS SR 3.8.1.18 states, Verify for Division 1 and 2 DGs, the sequence time is within +/- 10% of design for each load sequence timer. This SR verifies the 10-percent load sequence time interval tolerance between each sequenced load block when loads are sequentially connected to the engineered safety features (ESF) bus by relay logic schemes that perform a function equivalent to a load sequencer while the DG is tied to the ESF bus. TS 3.5.2 requires manual starting of the equipment for water injection to respond to a draining event so that the DG will be manually loaded during a draining event. No other postulated events require automatic loading of the DG during shutdown conditions. The NRC staff confirmed that with respect to SR 3.8.18, the relay logic schemes that perform a function equivalent to a load sequencer are used for the automatic loading of the DG and are not used during a manual loading of the DG. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.18 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

The NRC staff finds that the proposed changes to revise SR 3.8.2.1 are acceptable because the remaining applicable SRs will continue to demonstrate the operability of the required AC power sources and, as such, ensure the availability of the AC power required to operate the plant in a safe manner and mitigate postulated events during shutdown conditions. Therefore, the NRC staff finds the proposed changes to SR 3.8.2.1 are acceptable because the changes continue to assure that the necessary quality of systems and components is maintained, that facility

operation will be within safety limits, and that the associated LCO will continue to be met in accordance with 10 CFR 50.36(c)(3).

3.2.2 Editorial The licensee noted that PNPP TS 3.3.5.2 have different numbering and Table 3.3.5.2-1 have different titles than STS for the RPV WIC related TS. The NRC staff finds that the different TS numbering and title changes are acceptable because they are editorial clarifications and do not substantively change TS requirements.

The licensee proposed to correct an error by deleting SR 3.8.1.8 from Note 1 within SR 3.8.2.1 for TS 3.8.2 AC Sources - Shutdown. For this SR to be met, the following SRs must be met:

SR 3.8.1.1 through SR 3.8.1.7, SR 3.8.1.9 through 3.1.8.16, SR 3.1.8.18, and SR 3.1.8.19.

Additionally, Note 1 of SR 3.8.2.1 lists certain SRs that are not required to be performed in order to meet SR 3.8.2.1. The licensee stated that SR 3.8.1.8 is listed, but not a requirement to meet SR 3.8.2.1. The licensee also stated that this is a legacy error from the initial conversion to the Improved Standard Technical Specifications. The NRC Staff reviewed the proposed change and finds it acceptable because SR 3.8.1.8 is not requirement to meet SR 3.8.2.1 and deleting SR 3.8.1.8 from Note 1 does not affect the applicability of TSTF-582 to the PNPP TS

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of Ohio official was notified of the proposed issuance of the amendment on January 3, 2021. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes 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, and there has been no public comment on such finding November 3, 2020 (85 FR 69654). 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 amendments.

6.0 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 Commission's 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.

Principal Contributors: T. Sweat, NRR S. Wall, NRR Date of Issuance: March 1, 2021

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 192, REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (RPV WIC) ENHANCEMENTS (EPID L-2020-LLA-0211) DATED MARCH 1, 2021 DISTRIBUTION Public RidsNrrPMPerry Resource (hard copy)

RidsACRS_MailCTR Resource RidsRgn3MailCenter Resource RidsNrrDssStsb Resource RidsNrrLASRohrer Resource RidsRgn3MailCenter Resource Accession No.: ML21035A170 *via email OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA* NRR/DSS/STSB/BC*

NAME SWall SRohrer VCusumano DATE 02/09/2021 02/08/2021 02/10/2021 OFFICE NRR/DORL/LPL3/BC* NRR/DORL/LPL3/PM*

NAME NSalgado SWall DATE 02/26/2021 03/01/2021 OFFICIAL RECORD COPY