ML031150313
| ML031150313 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/16/2003 |
| From: | Anthony Mendiola NRC/NRR/DLPM/LPD3 |
| To: | Kanda W FirstEnergy Nuclear Operating Co |
| SANDS S, NRR/DLPM, 415-3154 | |
| References | |
| TAC MB7513 | |
| Download: ML031150313 (7) | |
Text
May 16, 2003 Mr. William R. Kanda Vice President - Nuclear FirstEnergy Nuclear Operating Company P.O. Box 97 10 Center Road Perry, OH 44081
SUBJECT:
PERRY NUCLEAR POWER PLANT - RELIEF REQUEST FOR THE IN-SERVICE TESTING PROGRAM FOR IMPLEMENTATION OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE OPERATIONS AND MAINTENANCE CODE CASE OMN-2 (TAC. NO. MB7513)
Dear Mr. Kanda:
By letter dated June 10, 2002, FirstEnergy Nuclear Operating Company (FENOC), requested relief for the Perry Nuclear Power Plant (PNPP) Inservice Testing Program (IST). The relief request, VR-11, proposes implementation of American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code Case, OMN-2, Thermal Relief Valve Code Case, OM Code-1995, Appendix I, at PNPP. The relief request identifies the affected components, the applicable code requirements, the description and basis of the proposed relief request, as well as the proposed alternate requirements.
In its submittal dated June 10, 2002, FENOC (licensee) requested relief from certain ASME inservice testing requirements for pressure relief valves at its PNPP. The relief request (VR-11) proposes to extend the surveillance interval for those pressure relief valves whose only overpressure function is to protect isolated components from fluid expansion caused by changes in fluid temperature.
The U.S. Nuclear Regulatory Commission staff has completed its review of the licensees relief request VR-11. The staff finds that the proposed extension of the surveillance interval may be authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the proposed alternative provides an acceptable level of quality and safety. The alternative is authorized for relief request VR-11 for the duration of the second 10-year IST interval, which ends November 18, 2008.
Sincerely,
/RA/
Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-440
Enclosure:
Safety Evaluation cc w/encl: See next page
Perry Nuclear Power Plant, Unit 1 cc:
Mary E. OReilly FirstEnergy Corporation 76 South Main St.
Akron, OH 44308 Resident Inspectors Office U.S. Nuclear Regulatory Commission P.O. Box 331 Perry, OH 44081-0331 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4531 Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, OH 44060 Mr. Vernon K. Higaki Manager - Regulatory Affairs FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P.O. Box 97, A210 10 Center Road Perry, OH 44081 Timothy Rausch, Plant Manager FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P.O. Box 97, SB306 Perry, OH 44081 Mayor, Village of North Perry North Perry Village Hall 4778 Lockwood Road North Perry Village, OH 44081 Donna Owens, Director Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P. O. Box 4009 Reynoldsburg, OH 43068-9009 Carol OClaire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235-7150 Mayor, Village of Perry P.O. Box 100 Perry, OH 44081-0100 Dennis Clum Radiological Assistance Section Supervisor Bureau of Radiation Protection Ohio Department of Health P.O. Box 118 Columbus, OH 43266-0118 Zack A. Clayton DERR Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149 Chairman Perry Township Board of Trustees 3750 Center Road, Box 65 Perry, OH 44081 Daniel Z. Fisher Transportation Department Public Utilities Commission 180 East Broad Street Columbus, OH 43215-3793
May, 2003 Mr. William R. Kanda Vice President - Nuclear FirstEnergy Nuclear Operating Company P.O. Box 97 10 Center Road Perry, OH 44081
SUBJECT:
PERRY NUCLEAR POWER PLANT - RELIEF REQUEST FOR THE IN-SERVICE TESTING PROGRAM FOR IMPLEMENTATION OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE OPERATIONS AND MAINTENANCE CODE CASE OMN-2 (TAC. NO. MB7513)
Dear Mr. Kanda:
By letter dated June 10, 2002, FirstEnergy Nuclear Operating Company (FENOC), requested relief for the Perry Nuclear Power Plant (PNPP) Inservice Testing Program (IST). The relief request, VR-11, proposes implementation of American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code Case, OMN-2, Thermal Relief Valve Code Case, OM Code-1995, Appendix I, at PNPP. The relief request identifies the affected components, the applicable code requirements, the description and basis of the proposed relief request, as well as the proposed alternate requirements.
In its submittal dated June 10, 2002, FENOC (licensee) requested relief from certain ASME inservice testing requirements for pressure relief valves at its PNPP. The relief request (VR-11) proposes to extend the surveillance interval for those pressure relief valves whose only overpressure function is to protect isolated components from fluid expansion caused by changes in fluid temperature.
The U.S. Nuclear Regulatory Commission staff has completed its review of the licensees relief request VR-11. The staff finds that the proposed extension of the surveillance interval may be authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the proposed alternative provides an acceptable level of quality and safety. The alternative is authorized for relief request VR-11 for the duration of the second 10-year IST interval, which ends November 18, 2008.
Sincerely,
/RA/
Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-440 DISTRIBUTION:
PUBLIC PD3-2 r/f WRuland
Enclosure:
Safety Evaluation AMendiola SSands THarris cc w/encl: See next page HNieh GGrant, RIII ACRS OGC GHill(2)
SUnikewicz ADAMS Accession Number: ML031150313
- See previous concurrence OFFICE PM:LPD3-2 LA:LPD3-2 SC:EMEB
- SC:LPD3-2 NAME SSands THarris DTerao RHoefling AMendiola DATE 5/16/03 5/16/03 4/29/03 5/3/03 5/16/03 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST VR-11 TO THE SECOND 10-YEAR INTERVAL INSERVICE TESTING PROGRAM FIRSTENERGY NUCLEAR OPERATING COMPANY, PERRY NUCLEAR POWER PLANT, DOCKET NO. 50-440
1.0 INTRODUCTION
By letter dated June 10, 2002, FirstEnergy Nuclear Operating Company (FENOC),
submitted relief request VR-11 for the Perry Nuclear Power Plant (PNPP) second 10-year interval inservice testing (IST) program for pumps and valves.
In relief request VR-11, the licensee has proposed to extend the surveillance interval for those pressure relief valves whose only overpressure function is to protect isolated components from fluid expansion caused by changes in fluid temperature.
2.0 REGULATORY EVALUATION
Title 10 Part 50.55a of the Code of Federal Regulations (10 CFR 50.55a) requires that IST of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves be performed in accordance with the ASME Boiler and Pressure Vessel Code (ASME Code),Section XI and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. The Code of Record for PNPP is the 1989 Edition of the ASME Code,Section XI which references the ASME OM Standards, Parts 6 and 10 for IST of pumps and valves, respectively. However, for relief valves the PNPP Code of Record is the 1995 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), which was previously authorized by the U. S. Nuclear Regulatory Commission (NRC) staff in Valve Relief Request, VR-6. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility. Section 55a of 10 CFR, authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the code requirements which are acceptable to the staff.
Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants.
By letter dated June 10, 1999, FENOC, submitted its second 10-Year IST program for pumps and valves for PNPP, which began on November 19, 1998, and ends on November 18, 2008. The program for relief valves was developed in accordance with the requirements of the 1995 Edition of ASME OM Code (Appendix I).
The NRCs findings with respect to authorizing alternatives and granting or denying the IST program relief request are given below.
3.0 TECHNICAL EVALUATION
The NRC staff has reviewed the licensees regulatory and technical analysis in support of the request for relief from ASME OM Code IST requirements which are described in of the licensees submittal.
3.1 Relief Request No. VR-11 In relief request VR-11 to the PNPP second interval 10-Year IST program, the licensee has requested relief from the Class 2 and 3 pressure relief valve test frequency requirements of ASME OM 1995, Appendix I, Paragraphs I 1.1, I 1.3.5(a), I 1.3.5(b), and 1.3.5(c) for the relief valves listed below.
The licensee proposes to implement Code Case OMN-2, Thermal Relief Valve Code Case, OM Code-1995, Appendix I, which allows either testing or replacement of certain relief valves every 10 years. The following list are the components affected by this relief request:
Component ID Component ID Component ID Component ID Component ID Component ID 1E12-F005 1E12-F017A 1E12-F017B 1E12-F017C 1E12-F025A 1E12-F025B 1E12-F025C 1E21-F031 1E22-F014 1E22-F035 1E51-F017 0G41-F548A 0G41-F548B 1G33-F646 1G50-F823 1P42-F540 1P42-F566A 1P42-F566B 1P42-F566C 1P42-F570 1P43-F851 1P43-F852 1P45-F517 1P45-F520 1P45-F543A 1P45-F543B 1P45-571A 1P45-F571B 0P47-F574A 0P47-F574B 0P47-F574C 1P50-F606 1P54-F5604 1P87F277 3.1.1 Licensees Basis For Requesting Relief In its request for relief, the licensee states that 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.
A review of applicable PNPP system design specifications and over pressure protection analysis generated this list of relief valves.
3.1.2 Alternative Testing The licensee has proposed to implement the requirements of Code Case OMN-2 Thermal Relief Valve Code Case, OM Code-1995, Appendix I. Testing of pressure relief valves whose only function is to protect isolated components from fluid expansion caused by changes in fluid temperature will be performed once every 10 years on each device unless performance data indicates more frequent testing is needed to assure device function. In lieu of testing, PNPP proposes an option to replace these devices every 10 years unless performance data indicates more frequent replacement is needed to assure device function.
3.1.3 Evaluation The licensee has proposed to implement the requirements of Code Case OMN-2 Thermal Relief Valve Code Case, OM Code-1995, Appendix I. Thermal relief valves are defined in the Code case as relief valves whose only overpressure protection function is to protect isolated components from fluid expansion caused by changes in fluid temperature. In lieu of the testing requirements of ASME OM Code-1995, Appendix I, Paragraphs 1.3.5(a), 1.3.5(b), and 1.3.5(c), relief valves which are considered to be thermal relief valves may be replaced once every 10 years unless performance data indicates more frequent replacement is needed to assure device function. Paragraph 1.3.5(a) requires that each Class 2 and 3 relief valve be tested every 10 years with a minimum of 20 percent of the valves tested within any 48-month period which have not been previously tested. Paragraph 1.3.5(b) specifies requirements for replacing valves with pretested valves.
Paragraph 1.3.5(c) establishes requirements for test acceptance criteria and requirements for testing additional valves. Code Case OMN-2 was intended to be used at facilities where their IST program was developed in accordance with ASME OM Code-1995. With regard to acceptability of the Code Case to the NRC, the staff reviewed activities of the Code Committee related to the development of this Code Case. In making its determination to reduce the testing requirements for thermal relief valves, the Code committee performed a review of the NPRDS database to assess the quantity and type of thermal relief valve failures. The Code committee determined that the failure rates of thermal relief valves are limited. The Code committee concluded that the low number of failure rates support the 10-year test interval or replacement frequency and the elimination of sample expansion if the failures were discovered during testing. In its evaluation of the Code Case for approval and inclusion in its new Regulatory Guide 1.192, the NRC has concluded that there are no outstanding issues with the proposed testing for thermal relief valves.
The NRC has completed an evaluation of Code Case OMN-2, which allows relaxation of testing requirements for relief valves identified as thermal reliefs. The evaluation did not identify any limitations or modifications necessary for the acceptability of this Code case to be used in conjunction with the OM Code-1995, Appendix I. Thermal relief valves are not defined in Appendix I. No related requirements have been identified in OM Code-1995 that would be related to thermal relief valves. On this basis, the staff finds that the licensee's alternative provides an acceptable level of quality and safety.
4.0 CONCLUSION
The staff concludes that the licensees proposed alternative is authorized pursuant to 10 CFR 50.55(a)(3)(i) on the basis that is provides an acceptable level of quality and safety. This alternative is authorized for the remainder of the second 10-year IST interval, which ends on November 18, 2008.
5.0 REFERENCES
5.2 10 CFR 50.55a(3)(i).
5.3 ASME Code for Operation and Maintenance of Nuclear Power Plants, 1995 Edition.
5.4 ASME OMN-2, Thermal Relief Valve Code Case, OM Code-1995, Appendix I.
5.5 Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, thru Supplement 1, April 4, 1995.
5.6 NUREG 1482, Guidelines for Inservice Testing at Nuclear Power Plants, Rev 0.
5.7 NRR Office Instruction LIC-102, Relief Request Reviews.
5.8 Perry Nuclear Power Plant, Inservice Testing (IST) Program, Second 10-Year Inspection Program, Docket Nos. 50-440.
Principal Contributor: S. Unikewicz Date: