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MONTHYEARML18054B6002018-02-21021 February 2018 Drywell General Area Heat Detectors License Amendment Request - Pre-Submittal Meeting, Perry Nuclear Power Plant, February 21, 2018 Project stage: Meeting ML18065A1392018-03-15015 March 2018 Summary of February 21, 2018, Public Meeting with Firstenergy Nuclear Operating Company Regarding a Proposed Revision to the Perry Nuclear Power Plant, Unit 1, Fire Protection Program Project stage: Meeting 2018-02-21
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MONTHYEARML23291A0572023-10-25025 October 2023 Environmental Scoping Meeting Related to the Perry Nuclear Power Plant, Unit 1 License Renewal Application - Virtual Meeting Slides ML23291A0702023-10-18018 October 2023 Environmental Scoping Meeting Related to the Perry Nuclear Power Plant, Unit 1 License Renewal Application - In-person Meeting Slides ML23046A1682023-02-16016 February 2023 License Renewal Application - 2nd Safety Pre-Application Meeting, February 16, 2023 (Perry Slides) ML23044A2122023-02-14014 February 2023 February 14, 2023, Second Perry Nuclear Power Plant License Renewal Environmental Pre-application Public Meeting - Energy Harbor Slides ML23044A2082023-02-14014 February 2023 February 14, 2023, Second Perry Nuclear Power Plant License Renewal Environmental Pre-application Public Meeting - NRC Slides ML22200A2222022-07-21021 July 2022 License Renewal Application - Safety Pre-Application Meeting July 21, 2022 (Perry Slides) ML22199A0232022-07-21021 July 2022 July 21, 2022, Perry Nuclear Power Plant License Renewal Environmental Pre-application Public Meeting - NRC Slides ML22199A0352022-07-21021 July 2022 July 21, 2022, Perry Nuclear Power Plant License Renewal Environmental Pre-application Public Meeting - Energy Harbor Slides ML22201A0052022-07-19019 July 2022 License Renewal Application - Safety Pre-Application Meeting July 21, 2022 (NRC Slides) ML21176A1992021-06-25025 June 2021 Slideshow Presentation for 2020 End -of-Cycle Public Meeting for Davis-Besse and Perry ML21047A1522021-02-16016 February 2021 Slides - Perry Pre-Application Flooding 2/16/2021 Meeting Slides (L-2021-LRM-10016) ML20210M0712020-07-27027 July 2020 Combined End-of-Cycle 2019 Public Meeting Slide Presentation ML18054B6002018-02-21021 February 2018 Drywell General Area Heat Detectors License Amendment Request - Pre-Submittal Meeting, Perry Nuclear Power Plant, February 21, 2018 ML17205A0362017-07-19019 July 2017 Presentation for 2016 Perry EOC Open House ML16307A4052016-09-14014 September 2016 R-III Rug 15 Sep 16 Presentation ML16047A1332016-02-0909 February 2016 February 9, 2016, Public Meeting Slides for License Amendment Request for Drain Down of Upper Containment Pool in Mode 3 ML14079A0912014-03-18018 March 2014 NRC - Perry 2013 Annual Assessment Public Meeting Slides ML13294A5972013-10-21021 October 2013 FENOC Presentation Slides for Public Meeting September 24, 2013 ML13281A5302013-10-15015 October 2013 Meeting Slide for FENOC - NRC Pre-Submittal Meeting Request for Licensing Action ML13101A1432013-04-10010 April 2013 NRC 2012 Annual Assessment Presentation ML13101A1522013-04-10010 April 2013 2012 Annual Assessment Presentation ML12269A0612012-09-26026 September 2012 FENOC Presentation for 2012-09-26 Public Meeting ML12094A2932012-04-0303 April 2012 Licensee Slides for Annual Assessment Meeting ML12086A2002012-03-26026 March 2012 NRC Slides Regarding Perry Nuclear Plant EOC Meeting for Cy 2011 ML1122408232011-08-11011 August 2011 Annual Assessment Meeting, 2010 Reactor Oversight Program ML1122805732011-08-11011 August 2011 Licensee Presentation Slides from 2010 EOC Meeting 8/11/11 ML1117303602011-06-21021 June 2011 FENOC Licensee Slides for 6-21-11 All FENOC Meeting ML1021500852010-07-28028 July 2010 Licensee Slides for Perry; July 28, 2010; Annual Assessment Meeting ML1021500692010-07-28028 July 2010 NRC Slides for Perry, July 28, 2010; Annual Assessment Meeting ML1009102662010-03-31031 March 2010 Slides FENOC and NRC Senior Management Briefing, 3-31-10 ML0932101992009-11-12012 November 2009 NRC Slides from Public Meeting with Firstenergy Nuclear Operating Company ML0932005842009-11-12012 November 2009 FENOC Presentation for NRC Public Meeting ML0920900792009-07-21021 July 2009 Licensee Slides from End of Cycle - Public Meeting ML0920900682009-07-21021 July 2009 Slides for Perry Nuclear Power Plant Annual Assessment Meeting, Reactor Oversight Program - Cy 2008 ML0811506052008-04-24024 April 2008 Summary of Public Meeting with Firstenergy Nuclear Operating Co. to Discuss the 2007 Perry End-of-Cycle Performance Assessment ML0801604842008-01-0909 January 2008 Slides - FENOC Public Meeting, Senior Management Briefing, January 9, 2008 ML0708602462007-03-21021 March 2007 Perry EOC Cy 2006 Slides FENOC (CAL Closure - Public Meeting) ML0708602302007-03-21021 March 2007 Slides, Perry Annual Assessment Meeting Reactor Oversight Process - Cy 2006. 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Drywell General Area Heat DetectorsLicense Amendment RequestPre-Submittal MeetingPerry Nuclear Power Plant February 21, 2018 Drywell General Area Heat DetectorsLicense Amendment RequestIntroductions:
-Mike Koberling, Manager, Perry Design Engineering
-Phil Lashley, Supervisor, FENOC Fleet Licensing
-Marc Kuntz, Supervisor, Perry Nuclear Electrical/I&C Engineering
-Jim Emley, FENOC Fleet Licensing
-Aaron Cyphert, Perry Nuclear Electrical/I&C Engineering 2
Drywell General Area Heat DetectorsLicense Amendment RequestAgenda-Purpose of Proposed Change in Perry Fire Protection Program-Regulatory Bases
-PNPP Design
-Technical Justification
-Summary-Open Discussion 3
Drywell General Area Heat Detectors License Amendment RequestPurpose of Proposed Change in Perry Fire Protection Program-The drywell general area heat detection system is degraded due to high temperatures in the drywell.
-Temporary modifications and supplemental actions have been put in place to compensate for the degraded condition.
-Engineering evaluation has concluded that the function of the drywell general area fire detection is no longer required.
-Proposed License amendment requesting NRC approval to abandon the drywell general area heat detectors in
-place is planned.4 Drywell General Area Heat Detectors License Amendment RequestRegulatory Bases
-PNPP Fire Protection Program (FPP) was reviewed under NUREG-0800, Section 9.5
-1; BTP CMEB 9.5
-1; and 10 CFR 50, Appendix R.
-PNPP is not a 10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979" plant.
-PNPP's Operating License (OL) was issued in March 1986.
-In SER Supplement 8, dated January 1986, NRC concluded that the PNPP FPP satisfied BTP CMEB 9.5
-1 and GDC 3.
5 Drywell General Area Heat Detectors License Amendment RequestRegulatory Bases (continued)
-PNPP Operating License contains standard fire protection license condition.
-Licensee can make changes as long as the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
-NRC Generic Letter 86
-10 provided guidance on the process for making FPP changes.
-If the change impacts the FPP that could result in a non
-conformance with 10 CFR 50, Appendix R or some other aspect of the approved FPP, then NRC approval is required.
-The proposed PNPP change is in non
-compliance with BTP CMEB 9.5-1.6 Drywell General Area Heat Detectors License Amendment RequestRegulatory Bases (continued)
-NRC Regulatory Guide 1.189 provides guidance on making FPP changes.
-Reiterates standard license condition wording concerning "adverse impact."
-FPP changes that adversely affect the ability to achieve and maintain safe shutdown in the event of a fire and are not in compliance with regulatory requirements need prior NRC approval.
7 Drywell General Area Heat Detectors License Amendment RequestRegulatory Bases (continued)
-NEI 02-03, "Guidance for Performing a Regulatory Review of Proposed Changes to the Approved Fire Protection Program"
-Provides guidance for determining whether prior NRC approval is required for changes to the approved FPP.
-"Not adversely affected" means to ensure that one train necessary to achieve hot shutdown is free of fire damage AND that fire damage to at least one train necessary to achieve cold shutdown is limited.
-Per NEI 02
-03, an example that could require NRC approval is removing detection systems from areas having low combustible loading because the evaluation demonstrates that fire damagewould be limited to a single safe shutdown train.
8 Drywell General Area Heat Detectors License Amendment RequestPNPP Drywell Fire Protection Design
-Two independent methods exist for achieving safe shutdown. The drywell contains equipment for both shutdown methods.
-Combustibles contained within this drywell area are primarily comprised of cable insulation, lubricating oil, hydraulic fluids, grease, and motor winding insulation.
-Total drywell fire loading is less than 52,000 BTU/square foot.
-Corresponds to a fire severity of approximately 39 minutes.
-Drywell walls and penetrations above the suppression pool have a three hour fire rating.
9 Drywell General Area Heat Detectors License Amendment RequestPNPP Design (continued)
-Two heat detection systems located within the drywell.
-One system is used for fire warning and local suppression system activation for the reactor recirculation pumps.
-The second system is for general drywell area heat detection used for fire warning.
-The drywell general area heat detectors consist of 39 detectors located within the drywell.
-When a general area heat detector reaches its actuation temperature, an alarm signal is sent to the fire and security computer located in the fire control monitoring station located in the control room.
10 Drywell General Area Heat Detectors License Amendment RequestPNPP Design (continued)
-In addition to the two primary fire detection systems located in the drywell, additional means of drywell temperature monitoring are available to the control room
-Drywell cooling system includes temperature detectors mounted in the ductwork and temperature detectors located in the drywell.
-Containment atmosphere monitoring system has temperature detectors located in the drywell.
11 Drywell General Area Heat Detectors License Amendment RequestTechnical Justification of Proposed Change
-The safe shutdown analysis evaluated the fire zone against the requirements of 10 CFR 50, Appendix R, Section III.G.
-If a fire occurred in this fire zone, either Method A or Method B would be available to achieve and maintain safe shutdown.
-Redundant methods are separated by distance or radiant energy shields in accordance with 10 CFR 50, Appendix R, Sections III.G.2.d and III.G.2.f.
12 Drywell General Area Heat Detectors License Amendment RequestTechnical Justification of Proposed Change (continued)
-The installation of a fire detection system and an automatic fire suppression system in this fire zone, in accordance with 10 CFR 50, Appendix R, Section III.G.2.e., was not credited to protect safe shutdown components and circuits.
-If a fire was detected by the drywell general area heat detectors during normal operation, the time to enter the drywell would exceed the burn time associated with the drywell combustible loading.
-The plant response would effectively be the same with or without the drywell general area heat detection.
13 Drywell General Area Heat Detectors License Amendment RequestTechnical Justification of Proposed Change (continued)
-Drywell three
-hour fire barrier protection.
-An exposure fire from other areas affecting equipment in this fire zone is not credible.
-Most combustible material is concentrated in the area of the reactor recirculation pumps.
-Carbon dioxide system with dedicated heat detection, will continue to provide detection and mitigation for these hazards.
-Cable insulation is a large component of the combustible material in the drywell fire zone.
-The majority of this cable is routed in conduit. Extensive damage from a fire in this fire zone is not reasonably expected.
14 Drywell General Area Heat Detectors License Amendment RequestSummary-The proposed license amendment will request approval of a change to Perry FPP to abandon the drywell general area heat detection system in
-place.-The proposed change deviates from BTP CMEB 9.5
-1, therefore NRC approval is required.
-Evaluation of the change concludes that the change is technically acceptable.
-The license amendment is planned to be submitted to the NRC in April 2018.-NRC approval is requested by February 2019 to support the spring 2019 refueling outage.
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