L-21-077, Response to Request for Additional Information Re 10 CFR 50.55a Request Number SR-2 Revision 0 Snubber Testing Extension

Response to Request for Additional Information Re 10 CFR 50.55a Request Number SR-2 Revision 0 Snubber Testing Extension

ML21050A417
Person / Time
Site:	Perry
Issue date:	02/19/2021
From:	Penfield R Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID: L-2021-LLR-0005, L-21-077
Download: ML21050A417 (4)

Text

energy Energy Harbor Nuclear Corp.

harbor Perry Nuclear Power Plant 10 Center Road Perry, Ohio 4408 1 Rod L. Penfield 440-280-5382 Site Vice President, Perry Nuclear February 19, 2021 L-21-077 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington , DC 20555-0001

Subject:

Perry Nuclear Power Plant Docket No. 50-440 , License No. NPF-58 Request for Additional Information RAI-EMIB-08 Response Regarding 10 CFR 50.55a Request Number SR-2 1 Revision 0 1 Snubber Testing Extension

{EPID: L-2021-LLR-0005)

By letter dated January 15, 2021 (Accession No. ML21018A004)), Energy Harbor Nuclear Corp. submitted 10 CFR 50.55a request SR-2, Revision 0, to the Nuclear Regulatory Commission (NRC). Request SR-2 proposed a one-time extension of operational readiness testing for certain Perry Nuclear Power Plant snubbers scheduled for testing during the upcoming spring 2021 refueling outage. By letter dated February 8, 2021 (Accession No. ML21039A785), Energy Harbor Nuclear Corp.

responded to an NRC request for additional information. By email dated February 16, 2021, the NRC staff requested additional information regarding 10 CFR 50.55a request SR-2. The Energy Harbor Nuclear Corp. response to the February 16, 2021 NRC request is attached.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required , please contact Mr. Phil H. Lashley, Manager, Fleet Licensing, at (330) 696-7208.

Sincerely, Pe nfi eld, Rod 55 166 site vp Pen.field, Rod 55166 I am approving this document Feb 19202 1 2:20 PM Do,u~ .

Rod L. Penfield

Perry Nuclear Power Plant L-21-077 Page 2

Attachment:

Response to Request for Additional Information cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager

Attachment L-21-077 Response to Request for Additional Information Page 1 of 2 The NRC staff request for additional information (RAI) is provided below in bold text and is followed by the Energy Harbor Nuclear Corp. response.

RAI-EMIB-08 (Follow-up to RAI-EMIB-01)

By letter dated February 8, 2021 (ADAMS Accession No. ML21039A785), the licensee responded to NRC-requested additional information. In its response to RAI-EMIB-01, the licensee provided the Service Life End Date of some of the Lisega Hydraulic Snubbers 10% plan. Specifically:

Lisega Snubber Service Life End Date 1B21-H0453 10/20/2021 1E51-H0073 7/21/2021 1E51-H2078 7/21/2021 ASME OM Code, Subsection ISTD-6000 requires snubbers be replaced or reconditioned as required to ensure that the service life is not exceeded between surveillance inspections, during a period when the snubber is required to be operable. If the indicated service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be re-evaluated or the snubber shall be replaced or reconditioned so as to extend its service life beyond the date of the next scheduled service life review.

For the three snubbers above, the service life will end in July 2021 and October 2021, and the licensee is requesting for one-time extension until Spring 2023. The Service Life End Date of all the above specified Lisega Hydraulic Snubbers is much lower than the Spring 2023.

• Please explain how these snubbers will continue to perform their operation readiness function until Spring 2023 refueling outage.

Response

Energy Harbor Nuclear Corp. is not proposing an alternative to ASME OM Code, Subsection ISTD-6000, Service Life Monitoring, requirements for the three identified Lisega snubbers with service life ending in 2021.

In accordance with ASME OM code, subsection ISTD 5311, Initial Sample Size and Composition, the 10% sample population for the Lisega hydraulic snubber defined test plan group was composed according to ISTD-5311(b), that states in part:

The sample shall be generally representative as specified in subpara.

ISTD-5311(a), but may also be selected from snubbers concurrently scheduled for seal replacement or other similar activity related to service life monitoring.

Attachment L-21-077 Page 2 of 2 The three identified Lisega snubbers were included in the sample population for this reason, and Energy Harbor Nuclear Corp. plans to replace these snubbers with new snubbers in the Spring of 2021 refueling outage in accordance with service life requirements and to support their operational readiness through the Spring 2023 refueling outage and beyond.