ML070360733
| ML070360733 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/09/2007 |
| From: | Russell Gibbs NRC/NRR/ADRO/DORL/LPLIII-2 |
| To: | Pearce L FirstEnergy Nuclear Operating Co |
| Wengert, Thomas | |
| References | |
| TAC MD2898 | |
| Download: ML070360733 (8) | |
Text
March 9, 2007 Mr. L. William Pearce Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant, Unit 1 Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT 1 - REQUEST FOR RELIEF NO.
VR-14 REGARDING EMERGENCY SERVICE WATER MANUAL VALVE TESTING FREQUENCY (TAC NO. MD2898)
Dear Mr. Pearce:
By letter to the Nuclear Regulatory Commission (NRC) dated July 17, 2006, FirstEnergy Nuclear Operating Company (the licensee), submitted Relief Request VR-14 for the second 10-year interval inservice testing program at the Perry Nuclear Power Plant, Unit 1 (Perry).
The licensee requested relief from certain inservice testing requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI for Emergency Service Water manual valves.
The NRC staffs evaluation of Relief Request VR-14 is enclosed. The NRC staff has concluded that, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(f)(4)(iv), Relief Request VR-14 is approved on the basis that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC staffs approval.
Sincerely,
/RA/
Russell A. Gibbs, Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440
Enclosure:
Safety Evaluation cc w/encl: See next page
Mr. L. William Pearce March 9, 2007 Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant, Unit 1 Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT 1 - REQUEST FOR RELIEF NO.
VR-14 REGARDING EMERGENCY SERVICE WATER MANUAL VALVE TESTING FREQUENCY (TAC NO. MD2898)
Dear Mr. Pearce:
By letter to the Nuclear Regulatory Commission (NRC) dated July 17, 2006, FirstEnergy Nuclear Operating Company (the licensee), submitted Relief Request VR-14 for the second 10-year interval inservice testing program at the Perry Nuclear Power Plant, Unit 1 (Perry).
The licensee requested relief from certain inservice testing requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI for Emergency Service Water manual valves.
The NRC staffs evaluation of Relief Request VR-14 is enclosed. The NRC staff has concluded that, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(f)(4)(iv), Relief Request VR-14 is approved on the basis that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC staffs approval.
Sincerely,
/RA/
Russell A. Gibbs, Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC LPL3-2 R/F RidsOgcRp YWong, NRR RidsNrrDorlLpl3-2 RidsAcrsAcnwMailCenter RidsNrrPMTWengert RidsNrrDciCptb RidsNrrLAEWhitt RidsRgn3MailCenter RidsNrrDorlDpr Accession Number: ML070360733 NRR-028 OFFICE LPL3-2/PM LPL3-2/LA CPTB/BC OGC LPL3-2/BC NAME TWengert:mw EWhitt JMcHale TCampbell RGibbs DATE 3/6/2007 3/5/2007 2/28/2007 3/7/2007 3/9/2007 OFFICIAL RECORD COPY
Perry Nuclear Power Plant, Unit 1 cc:
David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-18 76 South Main Street Akron, OH 44308 Resident Inspector's Office U.S. Nuclear Regulatory Commission P.O. Box 331 Perry, OH 44081-0331 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4531 Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, OH 44060 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A210 P.O. Box 97, 10 Center Road Perry, OH 44081-0097 Mayor, Village of North Perry North Perry Village Hall 4449 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 Joseph J. Hagan Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GHE-315 395 Ghent Road Akron, OH 44333 Gary R. Leidich President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308
Perry Nuclear Power Plant, Unit 1 cc:
Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GHE-115 395 Ghent Road Akron, OH 44333 Richard Anderson Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE SECOND 10-YEAR INSERVICE TESTING PROGRAM INTERVAL RELIEF REQUEST VR-14 FIRSTENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated July 17, 2006, FirstEnergy Nuclear Operating Company (FENOC), the licensee, for Perry Nuclear Power Plant, Unit 1 (Perry), requested relief from certain inservice testing (IST) requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
Section XI for Emergency Service Water (ESW) manual valves.
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) IST program intervals in accordance with the specified Section XI of the ASME Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been approved or relief has been requested by the licensee and granted by the Nuclear Regulatory Commission (NRC) pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b),
subject to the NRCs approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. 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 the facility. Section 50.55a authorizes the NRC to impose alternatives and to grant relief from ASME Code requirements upon making necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Revision 1, Guidance for Inservice Testing at Nuclear Power Plants.
In accordance with 50.55a(f)(4)(ii), licensees are required to comply with the provisions of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of the 120-month IST program interval. At Perry, the code of record for the second 10-year interval is the 1989 Edition of the ASME Code. The IST program was developed in accordance with the requirements of the 1989 Edition of the ASME Code by implementation of the 1987 ASME/American National Standards Institute Operations and Maintenance (OM) Standards Part 1, Part 6, and Part 10 (OM-1, OM-6, and OM-10) for IST of safety and relief devices, pumps, and valves.
3.0 TECHNICAL EVALUATION
3.1 Relief Request VR-14 3.1.1 Code Requirements The licensee requested relief from OM-10, paragraph 4.2.1, which requires that active Category A and B valves be tested nominally every 3 months, except as provided by paragraphs 4.2.1.2, 4.2.1.5, and 4.2.1.7. Relief was requested for the following ESW valves:
1P45-F525 1P45-F526 1P45-F527 3.1.2 Licensees Basis for Requesting Relief In its letter dated July 17, 2006, the licensee stated:
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 of the necessary functionality of the valves.
ASME OM Code [Code for Operation and Maintenance of Nuclear Power Plants] 1998 Edition, with 1999 Addenda in conjunction with 10 CFR 50.55a(b)(3)(vi), provides a precedent for the alternate testing frequency. Specifically, paragraph ISTC-3540 of the ASME OM Code 1998 Edition with 1999 Addenda, states:
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 be exercised at least once every 2 years provided no adverse conditions exist versus the [ASME] 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.
3.1.3 Licensees Proposed Alternative Testing The licensee proposes to exercise the emergency service water (ESW) manual valves at least once every two years in lieu of once every quarter.
3.1.4
NRC Staff Evaluation
The licensee proposes to exercise the ESW manual valves once every two years in accordance with ASME OM Code 1998 Edition, with 1999 Addenda, paragraph ISTC-3540, as further clarified in 10 CFR 50.55a(b)(3)(vi).
10 CFR 50.55a(f)(4)(iv) states that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC staffs approval. Portions of editions and addenda may be used provided that all related requirements of the respective editions and addenda are met.
The 1995 Edition up to and including the 2003 Addenda of the ASME OM Code was incorporated by reference in 10 CFR 50.55a(b) in 2004 (69 FR 58820), but the NRC placed a limitation to require that manual valves be exercised on a 2-year interval rather that the 5-year interval specified in the Code. Therefore, the rule change to 10 CFR 50.55a(b)(3)(vi) set the maximum exercise interval for ESW manual valves at 2 years, provided adverse conditions do not require more frequent testing. The ESW manual valves are located in a benign environment, and historical records reveal no evidence of adverse conditions such as lubricant hardening or degraded components. The licensees proposed alternative complies with the requirements in ASME OM Code, 1999 Addenda, paragraph ISTC-3540, as further clarified in 10 CFR 50.55a(b)(3)(vi).
4.0 CONCLUSION
The NRC staff concludes that the proposed alternative related to the exercise frequency of ESW manual valves, is approved pursuant to 10 CFR 50.55a(f)(4)(iv) based on the incorporation by reference of the 1995 Edition up to and including the 2003 Addenda of the ASME OM Code in 10 CFR 50.55a(b). This alternative meets the requirements of the ASME OM Code 1998 Edition, with 1999 Addenda, paragraph ISTC-3540, as further clarified in 10 CFR 50.55a(b)(3)(vi). In addition, the ESW valves meet the requirement that no adverse conditions exist for these valves.
Principal Contributor: Y. Wong, NRR Date: March 9, 2007