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Category:Code Relief or Alternative
MONTHYEARML22252A2212022-09-30030 September 2022 Authorization and Safety Evaluation for Alternative Request IR-063 ML22187A2592022-07-12012 July 2022 Issuance of Relief Proposed Alternative Request Vr 12, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval ML22136A1132022-06-21021 June 2022 Issuance of Relief Proposed Alternative Requests VR-10, Revision 0, and VR-11, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval (EPIDs L-2021-LLR-0096; L-2021-LLR-0097) ML21123A2892021-05-0404 May 2021 Issuance of Relief Request Vr 7, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval ML21110A6092021-04-26026 April 2021 Issuance of Relief Requests Vr 3, Revision 0, and Vr 5, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval ML20363A0062021-01-29029 January 2021 Issuance of Relief Proposed Alternative Request Associated with Fourth 10-Year Inservice Inspection Interval L-21-047, 10 CFR 50.55a Request Numbers VR-3 and VR-5, Valve Testing Extension2021-01-28028 January 2021 10 CFR 50.55a Request Numbers VR-3 and VR-5, Valve Testing Extension ML20311A6582020-11-10010 November 2020 Issuance of Relief Proposed Alternative Request Associated with Fourth Ten Year Interval Inservice Inspection Interval L-20-256, Request to Use Provision in Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2020-09-28028 September 2020 Request to Use Provision in Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI ML20266G2652020-09-24024 September 2020 Correction Letter for Relief Request IR-062 Regarding Weld Examination Coverage for the Third Inservice Inspection Interval ML20252A0262020-09-18018 September 2020 Relief Request IR-062 Regarding Weld Examination Coverage for the Third Inservice Inspection Interval ML20189A0032020-07-10010 July 2020 Relief Request PR-3 for Fourth 10-Year Pump and Valve Inservice Testing Program L-19-145, 10 CFR 50.55a Request in Support of the Fourth 10-Year Inservice Inspection (ISI) Interval2020-01-0606 January 2020 10 CFR 50.55a Request in Support of the Fourth 10-Year Inservice Inspection (ISI) Interval ML19072A0852019-03-15015 March 2019 Correction to Request for Alternatives Related to Inservice Testing Program for the Fourth 10 Year Inservice Testing Interval ML19029A0902019-02-25025 February 2019 Request for Alternatives Related to Inservice Testing Program for the Fourth 10-Year Inservice Testing Interval (EPID Nos. L-2018-LLR-0092, 0093, 0094, 0095, and 0096) ML19037A0412019-02-25025 February 2019 Request for Alternative to Use ASME Code Case N-831 ML18023A6252018-01-29029 January 2018 Approval of Alternative to Use BWRVIP Guidelines in Lieu of Certain ASME Code Requirements (CAC No. MG0149; EPID 2017-LLR-0112) (L-17-183) ML18004A1222018-01-22022 January 2018 FENOC-Beaver Valley, Davis-Besse, and Perry - Alternative for the Use of ASME Code Case N-513-4 (CAC Nos. MG0120, MG0121, MG0122, and MG0123; EPID L-2017-LLR-0088) ML17270A0302017-10-16016 October 2017 Approval of Alternative to Use ASME Code Case N-513-4 for Repair of Emergency Service Water System Piping (CAC No. MG0130; EPID L-2017-LLR-0080)(L-17-278) ML16328A1252017-01-23023 January 2017 Relief from the Requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) (TAC No. MF7780 - MF7783) ML1202501092012-01-31031 January 2012 Safety Evaluation in Support of 10 CFR 50.55A Requests for the Third 10-Year In-Service Inspection Interval JAFP-11-0112, Relief Request (RR-8), Alternative Examination Requirements for Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius Sections Using American Society of Mechanical Engineers Code Case N-702 and BWRVIP-108NP2011-10-0303 October 2011 Relief Request (RR-8), Alternative Examination Requirements for Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius Sections Using American Society of Mechanical Engineers Code Case N-702 and BWRVIP-108NP ML1110501052011-04-19019 April 2011 Withdrawal of Requested Licensing Action 10 CFR 50.55A Relief Requests in Support of the Third 10-Year In-Service Inspection Interval, IR-001 and IR-013 ML1032006682010-11-19019 November 2010 Relief Request VR-7, One Time Replacement Frequency Extension ML0928900322009-10-22022 October 2009 Safety Evaluation of Relief Requests for Perry Third 10-Year Pump and Valve Inservice Testing Program ML0926406902009-10-0808 October 2009 Relief Request, PR-3 for Third 10-Year Pump and Valve Inservice Testing Program, TAC ME0820 ML0829607292008-12-29029 December 2008 Request for Relief Related to Inservice Inspection Relief Request IR-054 ML0831002842008-12-16016 December 2008 Request for Relief Related to Inservice Inspection Relief Requests IR-056 and IR-057 L-08-347, Eight Separate In-Service Testing Program 10 CFR 50.55a Alternatives Requests in Support of the Third Ten-Year Interval2008-11-18018 November 2008 Eight Separate In-Service Testing Program 10 CFR 50.55a Alternatives Requests in Support of the Third Ten-Year Interval ML0703607332007-03-0909 March 2007 Request for Relief No. VR-14 Regarding Emergency Service Water Manual Valve Testing Frequency ML0620604472006-07-17017 July 2006 50.55a Request for Alternative Testing Frequency ML0435500732005-01-13013 January 2005 Request to Use Later American Society of Mechanical Engineers Code Edition and Addenda, Request No. IR-053 ML0410400232004-03-31031 March 2004 License Amendment Request Pursuant to 10 CFR 50.90 and Relief Request Pursuant to 10 CFR 50.55a(a)(3) Related to the Testing of Safety/Relief Valves ML0311503132003-05-16016 May 2003 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 ML0217204622002-06-10010 June 2002 Submittal of In-Service Testing Program Relief Request from Perry Nuclear Power Plant 2022-09-30
[Table view] Category:Letter
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FENOC 1"%10 Perry Nuclear Power Station Center Road FirstEnergyNuclear OperatingCompany Perry,Ohio 44081 L. William Pearce 440-280-5382 Vice President Fax: 440-280-8029 July 17, 2006 PY-CEI/NRR-2971 L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 50.55a Request for Alternative Testing Frequency Ladies and Gentlemen:
In accordance with 10 CFR 50.55a(a)(3)(i), First Energy Nuclear Operating Company (FENOC) hereby submits a 1 OCFR50.55a request for the Perry Nuclear Power Plant (PNPP) In-Service Testing Program. Attachment I contains Valve Relief Request VR-14, which proposes implementation of alternate testing frequency for Emergency Service Water manual valves. Valve Relief Request VR-14 identifies the affected valves, the applicable test requirements, the basis of the proposed relief request as well as proposed alternate test requirements. FENOC desires to implement the proposed alternative for the remainder of its second 120-month interval, which began November 18, 1998.
FENOC requests approval by December 15, 2006 based on the quarterly testing frequency.
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. Gregory A.
Dunn, Manager - Fleet Licensing, at (330) 315-7243.
Very Iyy
Attachment:
- 1. Valve Relief Request VR-14 cc: NRC Project Manager NRC Resident Inspector NRC Region III ADbA'7
Attachment 1 PY-CEI/NRR-2971 L Page 1 of 3 Valve Relief Request VR-14 Systems: Emergency Service Water (P45)
Valves: 1P45-F525, 1P45-F526, and 1P45-F527 Category: B Class: 3 Function: The Emergency Service Water (ESW) System supplies cooling water to equipment required for normal and emergency shutdown of the reactor. It can also provide water to the site Fire Protection System, the Fuel Pool Cooling and Cleanup (FPCC) System, the Emergency Closed Cooling Water (ECCW) System, the Residual Heat Removal (RHR) System (to provide Containment flooding), the Standby Liquid Control System, and the ESW Screen Wash System.
The source of water for the ESW System is Lake Erie. The water enters two intake structures and travels through the intake tunnel to the plant.
Before reaching the plant, the tunnel divides into two branches. One branch goes to the Service Water pump house and the other branch goes to the ESW pump house forebay. From the forebay, the water flows into the pump suction basin and supplies the three ESW pumps. After passing through the heat loads, the water from all the pumps is collected in one discharge header and directed to the Discharge Tunnel Entrance Structure. In the Discharge Tunnel Entrance Structure, the water is directed into an impact wall to absorb the high velocity shock and to redirect the flow of water into the Discharge Tunnel, which returns the water to the lake.
An alternate intake pathway is provided in the event the normal intake tunnel and structures become unavailable. A branch tunnel connects the discharge tunnel and the ESW pump house forebay. Two parallel sluice gates normally isolate this branch but will automatically open if the normal source of water is not available. The discharge tunnel then becomes the intake pathway. An alternate discharge pathway to the lake is provided for instances when the discharge tunnel can not be used. Flow is directed to three overflow standpipes in the Auxiliary Building, which direct the ESW discharge flow to the lake via a swale (a low-lying strip of land at the east end of the site). 1P45-F525, 1P45-F526, and 1P45-F527 are the manual valves that are dosed to divert flow to the swale.
Attachment 1 PY-CEI/NRR-2971 L Page 2 of 3 Test Requirements: OM(10)-4.2.1; Valve Exercising Test 4.2.1.1 Exercise Testing Frequency. Active Category A and B valves shall be tested nominally every 3 months, except as provided by paras.
4.2.1.2, 4.2.1.5, and 4.2.1.7.
The code of record for Perry is currently ASME Code Section XI, 1989 Edition, Subsections IWP and IWV, which invoke the use of ASME/ANSI OM, Part 6 for Pumps, and ASME/ANSI OM, Part 10 for Valves. The current OM Code Edition and Addenda for Perry is the ASME/ANSI OM-1 987 with OMa-1 988 Addenda. The current code does not individually specify the need for testing of manual valves. However, in interpreting the scope (Para. 1.1) statement and considering the lack of a specific exclusion (Para.
1.2), the valves are considered Category B (valves for which seat leakage is inconsequential for fulfillment of the required function(s), as specified in Para. 1.4). As such, OM-10 requires these valves to be exercised at least once each quarter.
Basis for Relief: The ESW manual swale valves are located in the Auxiliary Building. If the ESW intake structure were to collapse, the environment of this location would remain benign. Therefore, no harsh environment would exist when the valves are required to be closed to align to the swale.
Historical evidence from the beginning of commercial operation reveals that these valves have been exercised open and closed a total of 44 times through June 1, 2006. No adverse conditions have been identified during the exercising of these valves. Based on the previous performance of these valves, extended testing frequency would not result in a negative impact to the necessary functionality of the valves.
ASME OM Code 1998 Edition, with 1999 Addenda in conjunction with 10CFR50.55a(b)(3)(vi), provides a precedent for the alternate testing frequency. Specifically, Paragraph ISTC-3540, Manual Valves of the ASME OM Code 1998 Edition with 1999 Addenda, states:
ISTC-3540 Manual Valves. Manual valves shall be full-stroke exercised at least once every 5 years, except where adverse conditions may require the valve to be tested more frequently to ensure operational readiness. Any increased testing frequency shall be specified by the owner. The valve shall exhibit the required change of obturator position.
10 CFR 50.55a(b)(3)(vi) requires manual valves to be exercised at least once every 2 years provided no adverse conditions exist
Attachment I PY-CEI/NRR-2971 L Page 3 of 3 versus the OM Code 1998 Edition, with 1999 Addenda allowable frequency of once every 5 years. These valves are considered to be in a benign environment for the designated accident scenario.
Additionally, historical evidence indicates no negative maintenance or failure trends for these valves. Therefore, in accordance with 10CFR50.55a(a)(3)(i), it is requested that the proposed alternative be authorized to exercise the manual ESW valves once every two years as opposed to quarterly, since this alternative testing frequency provides an acceptable level of quality and safety.
Alternate Testing: Manually exercise these valves at least once every two (2) years.