ML070650335

Perry Response to Request for Additional Information Regarding License Amendment Request Related to Emergency Diesel Generator Surveillance Testing Voltage and Frequency Limits

ML070650335
Person / Time
Site:	Perry
Issue date:	02/22/2007
From:	Pearce L W FirstEnergy Nuclear Operating Co
To:	Document Control Desk, NRC/NRR/ADRO
References
PY-CEI/NRR-3015L, TAC MC8997
Download: ML070650335 (4)

Text

FENOC Oft"%C395 Ghent Road FirstEnergy Nuclear Operating Company Akron, Ohio 44333 February 22, 2007 PY-CEI/NRR-3015L 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Perry Nuclear Power Plant Docket No. 50-440

Subject:

Response to Request for Additional Information Regarding License Amendment Request Related to Emergency Diesel Generator Surveillance Testing Voltage and Frequency Limits (TAC No. MC8997)This letter provides a response to the Nuclear Regulatory Commission (NRC) Request for Additional Information dated January 9, 2007, pertaining to the FirstEnergy Nuclear Operating Company (FENOC) Perry Nuclear Power Plant License Amendment Request submitted on November 21, 2005 (PY-CEI/NRR-2918L).

The proposed amendment would revise Technical Specification (TS) Surveillance Requirements associated with TS 3.8.1 to modify the acceptance criteria for Emergency Diesel Generator start test requirements to provide minimum voltage and frequency limits and to clarify other limits as steady state parameters.

This change implements the provisions of Technical Specification Task Force (TSTF) Traveler 163, Revision 2.There are no regulatory commitments contained in this letter or its attachment.

If there are any questions or if additional information is required, please contact Mr. Henry L. Hegrat, Supervisor

-FENOC Fleet Licensing, at 330-315-6944.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 22, 2007.Lamar W. Pearce Vice President-Nuclear

Attachment:

"Response To Request For Additional Information cc: NRC Project Manager NRC Resident Inspector NRC Region III State of Ohio PY-CEI/NRR-3015L Attachment Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION The following Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI)was received by letter dated January 9, 2007, regarding the license amendment request submitted for the Perry Nuclear Plant (PNPP) on November 21, 2005 (PY-CEI/NRR-2918L).

The proposed amendment would revise Technical Specification (TS) Surveillance Requirements (SRs) associated with TS 3.8.1 to modify the acceptance criteria for Emergency Diesel Generator (EDG) start tests to provide minimum voltage and frequency limits and to clarify other limits as steady state parameters.

This change implements the provisions of Technical Specification Task Force (TSTF) Traveler 163, Revision 2. The NRC RAI and the corresponding response are provided below.NRC REQUEST In reviewing FirstEnergy Nuclear Operating Company's (FENOC's) submittal dated November 21, 2005, related to Emergency Diesel Generator (EDG) Surveillance Testing Voltage and Frequency Limits, for the Perry Nuclear Power Plant, Unit I (Perry), the NRC staff has determined that the following information is needed in order to complete its review: While reviewing the submittal, NRC staff noted that the proposed change to Surveillance Requirement (SR) 3.8.1.2 was not one of the changes included in Technical Specification Task Force Traveler (TSTF) 163. During the review of the proposed change to SR 3.8.1.2, the NRC staff noticed that Note 3 to this SR is incomplete and is not consistent with the similar Note 2 of SR 3.8.1.2 of the Improved Standard Technical Specifications (ISTS). That is, the last sentence of the note, which states that "when modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met," is missing.The purpose of the second part of the note in the ISTS is to ensure that, when the modified start procedure is not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 are demonstrated during the monthly testing. The change requested to SR 3.8.1.2, in this license amendment request, taken with the existing note, presents concerns to the NRC staff.With respect to the above, describe how Perry conducts its monthly EDG testing. If a"modified start" test procedure is not used for this testing, explain how the testing and acceptance criteria demonstrates compliance with the requirements of 10 CFR 50.36 and support the applicable facility safety analyses.RESPONSE SR 3.8.1.2 of the current PNPP TS requires the EDG to be started from a standby condition every 31 days to achieve a voltage between 3900 Volts and 4400 Volts, and a frequency between 58.8 Hertz and 61.2 Hertz, with no required time limits.SR 3.8.1.7.a of the current PNPP TS requires the Division 1 and 2 EDGs to be started from a standby condition every 184 days to achieve a voltage between 3900 Volts and 4400 Volts, and a frequency between 58.8 Hertz and 61.2 Hertz, in less than or equal to 10 seconds.

W,. 'I -PY-CEI/NRR-3015L Attachment Page 2 of 3 In addition, SR 3.8.1.7.b verifies that when started from a standby condition, the Division 3 EDG achieves a frequency of at least 58.8 Hertz in less than or equal to 10 seconds, and a voltage between 3900 Volts and 4400 Volts and a frequency between 58.8 Hertz and 61.2 Hz in less than or equal to 13 seconds.As stated in the TS Bases for 3.8.1.2, the capability to limit the starting speed of the EDGs (modified start), is not currently available on the PNPP EDGs. Therefore, fast starts are performed on the EDGs for both the 31-day and 184-day Surveillance requirements.

In the near future, the PNPP staff plans to incorporate a design modification to the EDGs that will allow the capability to conduct modified starts.The following PNPP Surveillance Instructions (SVIs) satisfy the EDG start and load tests for both SR 3.8.1.2 and 3.8.1.7:* SVI-E22-T1317, "Diesel Generator Start And Load Division 1"" SVI-E22-T1 318, "Diesel Generator Start And Load Division 2"" SVI-E22-T1319, "Diesel Generator Start And Load Division 3" The acceptance criterion (Section 5.3) in the above SVIs requires each EDG to start and achieve the required voltage and frequency within the above time requirements after the start signal from standby conditions.

In addition, PNPP administrative procedure PAP-1705,"Diesel Generator Reports and Records," requires recording and evaluating the time to reach proper speed and voltage for all EDG starts. The data recorded via this procedure supports trend analysis of EDG start and run performance.

Whenever a normal fast start is performed, the design basis time limits specified in SR 3.8.1.7 are applicable.

Anytime it is known that a TS SR's requirements are not met, the associated TS equipment is considered to be inoperable.

This is explained in the TS Bases for SR 3.0.1, which state: "Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the SRs; or b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

[emphasis added]" In accordance with this guidance, although the design basis time limits are not specifically addressed in SR 3.8.1.2, the acceptance criteria of SR 3.8.1.7 are always applicable when performing EDG start Surveillances if a modified start is not being performed.

There is no benefit to modifying the NOTE in SR 3.8.1.2, since the existing PNPP TS SRs assure that applicable Limiting Conditions for Operation are met.During the development of the Improved Technical Specifications for the PNPP, the last sentence of the NOTE to SR 3.8.1.2 was not included, because the requirement to meet start time criteria is effectively established by SR 3.8.1.7. The proposed changes to SRs 3.8.1.2 and 3.8.1.7 are not affected by the presence or absence of the subject portion of the Note.As required by 10 CFR 50.36 (b), the PNPP Operating License includes Technical Specification Surveillance Requirements.

The PNPP SR testing and acceptance criteria for PY-CEI/NRR-3015L Attachment Page 3 of 3 the EDGs demonstrate compliance with the EDG start time requirements that are assumed for the Design Basis Accidents addressed in Chapters 6 and 15 of the PNPP Updated Safety Analysis Report. The EDG start time testing criteria required per the existing PNPP TS SRs and as proposed by the amendment submitted on November 21, 2005, equally support the applicable facility safety analyses.

With the implementation of the proposed amendment, the PNPP TS SRs will continue to assure that the EDGs are maintained within safety limits and that the applicable Limiting Conditions for Operation are met as specified within 10 CFR 50.36 (c)(3).