ML021720462

Submittal of In-Service Testing Program Relief Request from Perry Nuclear Power Plant

ML021720462
Person / Time
Site:	Perry
Issue date:	06/10/2002
From:	Kanda W FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PY-CEI/NRR-2642L
Download: ML021720462 (3)

Text

Perry Nuclear Power Plant FENOC10 Center Road FfrstEnergy Ncear FEO OeratingCorpman~y P.O. Box 97 Perry Ohio 44081 June 10, 2002 PY-CEI/NRR-2642L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Submittal of In-Service Testing Program Relief Request Ladies and Gentlemen:

In accordance with 10 CFR 50.55a(a)(3)(i), a relief request for the Perry Nuclear Power Plant (PNPP) In-Service Testing Program is being requested. Attachment 1 contains Relief Request VR-1 1, which proposes implementation of American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code Case, OMN-2, "Thermal Relief Valve Code Case, OM Code-1 995, Appendix I." Relief Request VR-i 1 identifies the affected components, the applicable code requirements, the description and basis of the proposed relief request, as well as the proposed alternate requirements.

PNPP desires to implement Relief Request VR-1 1 during its second 120-month interval.

If you have any questions, or require additional information, please contact Mr. Gregory A. Dunn, Manager-Regulatory Affairs, at (440) 280-5305.

Very truly yours, William R. Kanda Vice President - Nuclear Attachment cc: NRC Resident Inspector NRC Project Manager NRC Region III

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Attachment 1 PY-CEI/NRR-2642L Page 1 of 2 Valve Relief Request VR-11 Systems: Residual Heat Removal, Low Pressure Core Spray, High Pressure Core Spray, Reactor Core Isolation Cooling, Fuel Pool Cooling and Cleanup, Emergency Closed Cooling, Emergency Service Water, Control Complex Chilled Water, Fire Protection, Reactor Water Cleanup, Post Accident Sampling, Liquid Radwaste, Nuclear Closed Cooling and Containment Vessel Chilled Water Systems.

Valves:

1E12-F005 1E12-F017A 1El 2-F01 7B 1 El 2-F01 7C 1 El 2-F025A 1El 2-F025B 1E12-F025C 1E21 -F031 1E22-F014 1 E22-F035 1E51-F017 0G41 -F548A 0G41 -F548B 1G33-F646 1G50-F823 1 P42-F540 1 P42-F566A 1P42-F566B 1P42-F566C 1P42-F570 1P43-F851 1 P43-F852 1 P45-+517 1P45-F520 1P45-F543A 1P45-F543B 1P45-F571A 1P45-F571B 0P47-F574A 0P47-F574B 0P47-F574C 1P50-F606 1P54-F5604 1 P87-F277 Category: C and AC Class: 2 and 3 Function: These devices provide pressure relief to protect isolated components from fluid expansion caused by changes in fluid temperature.

Test Requirement: Class 2 and 3 relief valves within the scope of the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code 1995, Appendix I, paragraph 1 1.1, shall be tested per the requirements of ASME OM Code 1995, Appendix I, paragraphs I 1.3.5(a), (b), and (c).

Basis for Relief: The ASME OM Code Committee performed a review of the Nuclear Plant Reliability Database System (NPRDS) database and determined that the failure rates of thermal relief valves was limited.

As a result, the Code Committee developed Code Case OMN-2 which permits a 10-year valve test or replacement frequency as well as elimination of the test sample expansion if a test failure were to occur.

This Code Case is in the process of being approved for generic use by the NRC as documented in Draft Regulatory Guide DG-1089, "Operation and Maintenance Code Case Acceptability, ASME OM Code", December 2001.

The Perry Nuclear Power Plant (PNPP) staff desires to exercise this Code Case prior to final approval of the regulatory guide.

Therefore, the PNPP staff is submitting this relief request for review and approval.

Attachment 1 PY-CEI/NRR-2642L Page 2 of 2 A review of the system design specifications and over pressure protection analysis generated the aformentioned list of thermal relief valves.

Alternate Testing: Implement the alternative requirements of Code Case OMN-2 for the testing or replacement of ASME Code Class 2 and 3 thermal relief valves.

Code Case OMN-2 allows Class 2 and 3 pressure relief valves to be tested or replaced once every 10 years, unless performance data indicates more frequent testing or replacement is needed to assure valve function.

Pursuant to 10 CFR 50.55a(a)(3)(i), implementation of the alternative requirements of Code Case OMN-2 will provide an acceptable level of quality and safety.