ML083100284

Request for Relief Related to Inservice Inspection Relief Requests IR-056 and IR-057

ML083100284
Person / Time
Site:	Perry
Issue date:	12/16/2008
From:	Russell Gibbs Plant Licensing Branch III
To:	Bezilla M FirstEnergy Nuclear Generation Corp
Goodwin, Cameron/DORL, 415-3719
References
TAC MD8198, TAC MD8199
Download: ML083100284 (12)

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-s-" ~O December 16, 2008 Mr. Mark B. Bezilla Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY -A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO.1 - REQUEST FOR RELIEF RELATED TO INSERVICE INSPECTION RELIEF REQUESTS NOS. IR-056 AND IR-057 (TAC NOS. MD8198 AND MD8199)

Dear Mr. Bezilla:

By letter to the Nuclear Regulatory Commission (NRC) dated February 20, 2008 (Agencywide Documents Access and Management System Accession No. ML080580410), FirstEnergy Nuclear Operating Company, submitted relief requests (RRs) Nos. IR-056, Rev. 0, and IR-057, Rev. O. RR IR-056, Rev. 0, proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

Section IX inspection requirements regarding examination of certain components within the reactor pressure vessel (RPV) at the Perry Nuclear Power Plant, Unit NO.1. As an alternative to the ASME Code requirements, the Boiling Water Reactor Vessel and Internals Project guidelines was proposed. RR IR-057, Rev. 0, proposed an alternative to the volumetric examination of the RPV shell-to-flange weld based on impracticality. The requests are for the second 1O-year inservice inspection interval.

The NRC staff has completed its review of RRs IR-056, Rev. 0 and IR-057, Rev. O. The details of the NRC staff's review are included in the enclosed safety evaluation. Accordingly, RR IR-056, Rev. 0, is authorized pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i) based on the NRC staff's determination that the alternative provides an acceptable level of quality and safety. Relief is granted for RR IR-057 pursuant to 10 CFR 50.55a(g)(6)(i). RR IR-057, Rev. 0, is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Si~~

Russell Gibbs, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUESTS NOS. IR-056 AND IR-057 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY PERRY NUCLEAR POWER PLANT, UNIT NO.1 DOCKET NO. 50-440

1.0 INTRODUCTION

The Nuclear Regulatory Commission (NRC, the Commission) staff has reviewed and evaluated the information provided by FirstEnergy Nuclear Operating Company (the licensee), in its letter dated February 20,2008 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML080580410), which proposed its second 10-year interval inservice inspection (lSI) program plan for Relief Request (RR) Nos. IR-056, Rev. 0, and IR-057, Rev. 0 for Perry Nuclear Power Plant, Unit NO.1 (PNPP). The licensee also provided additional information for RR IR-056 in its letter dated August 28,2008 (ADAMS Accession No. ML082490156).

2.0 REGULATORY EVALUATION

The lSI of the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME Code) Class 1,2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g), except where specific relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i). Section 50.55a(a)(3) of 10 CFR states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if: (1) the proposed alternatives would provide an acceptable level of quality and safety or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 1O-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of Record for the Enclosure

-2 PNPP, second 10-year interval lSI program is the 1989 Edition of the ASME Code,Section XI with no Addenda.

3.0 TECHNICAL EVALUATION

3.1 RR No. IR-056, Rev. 0 ASME Code Component ASME Code,Section XI, Class 1, Examination Category B-N-2 (Integrally Welded Core Support Structures and Interior Attachments to Reactor Vessels). ASME Code,Section XI, Examination Category B-N-2, Item No. B13.40, Core Support Structure.

ASME Code Requirements ASME Code,Section XI, Table IWB-2500-1, Examination Category B-N-2 requires a VT-3 visual examination of the accessible surfaces of the core support structure components during each lSI interval.

Licensee's Basis for RR (As Stated)

In accordance with 10 CFR 50.55a(a)(3)(i), FirstEnergy is requesting a proposed alternative to the [ASME] Code requirements provided above on the basis that the use of the Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines discussed below will provide an acceptable level of quality and safety.

The BWRVIP Inspection and Evaluation (I&E) guidelines have recommended aggressive specific inspection by Boiling Water Reactor (BWR) operators to completely identify material condition issues with BWR components. A wealth of inspection data has been gathered during these inspections across the BWR industry.

The I&E guidelines focus on specific and susceptible components, specify appropriate inspection methods capable of identifying real anticipated degradation mechanisms, and require re-examination at conservative intervals. In contrast, the [ASME] Code inspection requirements were prepared before the BWRVIP initiative and have not evolved with BWR inspection experience.

Use of this proposed alternative will maintain an adequate level of quality and safety and avoid unnecessary inspections, while conserving radiological dose.

Licensee's Proposed Alternative Examination (As Stated)

In lieu of the requirements of the ASME [Code,] Section XI, the proposed alternative is detailed in attached Table 1 for Examination Category B-N-2, Item No. B13.40

[components].

-3 FirstEnergy will satisfy the [ASME Code,Section XI,] Examination Category B-N-2, Item No. B13.40 requirements as described in Table 11 in accordance with BWRV/P guideline requirements. This relief request proposes to utilize the identified BWRVIP guidelines in lieu of the associated [ASME] Code requirements, including examination method, examination volume, frequency, training, successive and additional examinations, flaw evaluations, and reporting.

Not all the components addressed by these guidelines are [ASME] Code components.

The particular guidelines that are applicable to the subject [ASME] Code components are:

1. BWRVIP-03, "BWR Vessel and Internals Project, Reactor Pressure Vessel and Internals Examination Guidelines,"

2. BWRVIP-26-A, "BWR Top Guide Inspection and Flaw Evaluation Guidelines,"

3. BWRVIP-38, "BWR Shroud Support Inspection and Flaw Evaluation Guidelines,"

4. BWRVIP-47-A, "BWR Lower Plenum Inspection and Flaw Evaluation Guidelines,"

5. BWRVIP-76, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines,"

(replaced BWRVIP-01, -07, and -63) and

6. BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines."

Table 1 compares present ASME [Code,Section XI,] Examination Category B-N-2, Item No. B13.40 requirements with the above current BWRVIP guideline requirements, as applicable to [PNPP]. Table 22 provides the inspection history for [PNPP] Core Support Structures.

Any deviations from the referenced BWRVIP Guidelines for the duration of the proposed alternative will be appropriately documented and communicated to the NRC, per the BWRVIP Deviation Disposition Process. Currently, FirstEnergy does not have any deviations from the subject guidelines.

Implementation of the proposed alternative actions of this relief request will be subject to inspection by an Authorized Inspection Agency.

Licensee's Comparison of ASME Code Examination Requirements to BWRVIP Examination Requirements (As Stated)

The following discussion provides a comparison of the examination requirements provided in ASME [Code,] Section XI, Examination Table IWB-2500-1, Item No. B13.40, to the examination requirements in the BWRVIP guidelines. Specific BWRVIP guidelines are provided as examples for comparisons. This comparison also includes a discussion of the examination methods.

1 Table 1 - "Comparison of ASME Examination Category B-N-2 Requirements with BWRVIP Guidance Requirements for BWR/6" was reproduced in this SE. See Attachment 1 of this SE.

2 Table 2 is not included in this SE and can be found in the licensee's letter dated January 20,2008 (ADAMS Accession No. ML080580410).

- 4 ASME Code Requirement - B13.40 - Core Support Structure (B-N-2)

The ASME Code requires a VT-3 [visual] examination of accessible surfaces of the integrally welded core support structure each 10-year interval. In a BWRl6 boiling water reactor, the welded core support structure has primarily been considered the shroud itself and the shroud support structure, including the shroud support plate (annulus floor), the shroud support ring, the shroud support welds, and the shroud support legs (if accessible). Historically, this requirement has been interpreted and satisfied differently across the industry. [ASME Code,Section XI, Table IWB-2500] Category B-N-2 is titled, "Integrally Welded Core Support Structures and Interior Attachments to Reactor Vessels." However, since the title for [ASME Code,Section XI, Table IWB-2500, Category B-N-2,] Item No. B13.40 simply states, "Core Support Structure," some plants, including Perry, have also applied the examination requirements to other core support structures such as the Control Rod Guide Tubes, Core Plate and Top Guide assembly.

The proposed alternate examinations replace this ASME [Code] requirement with specific BWRVIP guidelines that examine susceptible locations for known relevant degradation mechanisms.

• The [ASME] Code requires a VT-3 [visual examination] of accessible surfaces

[during] each 10-year [lSI] interval

• The BWRVIP requires as a minimum the same examination method (VT-3) as the [ASME] Code for integrally welded Core Support Structure [components], and for specific areas, requires either an enhanced visual examination technique (EVT-1) [enhanced visual examination] or ultrasonic examination (UT).

BWRVIP recommended examinations of core support structure [components], are focused on the known susceptible areas of this structure, including the welds and associated weld heat affected zones. As a minimum, the same or superior visual examination technique is required for examination at the same frequency as the [ASME Code] examination requirements. In many locations, the BWRVIP guidelines require a volumetric examination of the susceptible welds at a frequency identical to the [ASME]

Code requirement.

The BWRVIP requires an EVT-1 or UT of core support structure [components]. The core shroud and shroud support plate are used as examples for comparison between the [ASME] Code and BWRVIP examination requirements as shown below.

Comparison to BWRVIP Requirements BWR Core Shroud Examination and Flaw Evaluation Guidelines (BWRVIP-76)

• The [ASME] Code requires a VT-3 examination of accessible surfaces every 10 years.

• BWRVIP-76 requires an EVT-1 examination from the inside and outside surface where accessible or UT examination of select circumferential welds, that have not been structurally replaced with a shroud repair, at a calculated "end of interval"

-5 (EOI) that will vary depending upon the amount of flaws present, but not to exceed ten years.

Comparison to BWRVIP Requirements - BWR Shroud Support Inspection and Flaw Evaluation Guidelines (BWRVIP-38)

• The [ASME] Code requires a VT-3 examination of accessible surfaces every 10 years.

• The BWRVIP requires examinations of the support plate-to-shroud weld (H8) and support plate-to-reactor vessel weld (H9). Examination coverage is required to be (100% [minus] Flaw Tolerance [%]) or 10% of the weld length, whichever is greater.

Examinations are to be performed by EVT-1 or UT from the annulus or UT from the

[reactor pressure vessel] RPV outside surface. Reinspection depends upon the amount of flaws present, but not to exceed six years for EVT-1 or ten years for UT.

In summary, the BWRVIP recommended examinations specify locations that are known to be vulnerable to BWR relevant degradation mechanisms rather than "all surfaces",

[and] the BWRVIP examination methods (EVT-1 or UT) are superior to the [ASME] Code required VT-3 [visual] for flaw detection and characterization. The BWRVIP examination frequency is equivalent to, or more frequent than, the examination frequency required by the [ASME] Code. The superior flaw detection and characterization capability, with an equivalent or more frequent examination frequency and the comparable flaw evaluation criteria, results in the BWRVIP criteria providing a level of quality and safety equivalent to, or superior to, that provided by the [ASME] Code requirements.

Licensee's RAJ Response Dated August 28, 2008 (As Stated)

The following supplemental information was provided in response to a request for additional information (RAJ) that was provided on July 31, 2008. In the original submittal of the proposed alternatives the licensee discussed BWRVIP-76, but did not discuss the effects of BWRVIP-100 on their alternative inspection program. The effects of BWRVIP-100 are only addressed in the licensee's response to the subsequent request for additional information. Therefore we have included the docketed RAI. The NRC RAI questions are repeated below, in bold, and are followed by the licensee's responses for the PNPP.

NRC Question: Section 4.1 item 5 of the BWRVIP-100-A report, "Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds," dated August 2006, states that fracture toughness values of stainless steel materials that are exposed to neutron fluence values greater than 1 X 1021 nlcm 2 (E > 1 MeV) are lower than those used in Appendix C of the BWRVIP-76 report, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines." Discuss the following:

(1) Confirm that your planned inspections of the PNPP core shroud and/or core shroud repair hardware for the second 10-year lSI interval are consistent with both BWRVIP-76 and BWRVIP-100-A;

- 6 Licensee's Response to Request 1: PNPP's core shroud is an un-repaired core shroud and in accordance with Boiling Water Reactor Vessel and Internals Project (BWRVIP) report BWRVIP-76, it is categorized as a Category B Shroud. As such, full volumetric (ultrasonic) and/or two-sided surface examination of the H3, H4, H6A, and H7 horizontal welds are required. These welds have already been ultrasonically examined twice during the second 10-year Inservice Inspection (lSI) interval: in RF07 (1999) and in RF010 (2005). The RF07 examinations were performed before BWRVIP-100 (Reference 1[31) was published in December 2001. Given the coverages achieved in RF07, and in accordance with BWRVIP-76 requirements, the shroud was scheduled for re-inspection in RF010. Prior to RF010, the BWRVIP-100 requirements were considered and an evaluation of the shroud fluence at the end of Cycle 10 (EOC1 O) was performed. The results of the evaluation are documented in Report GE-NE-0000-0025 6721-RO (Reference 2[41). The peak fluence for weld H4 was predicted to be 1.21 x 1021 n/crn" [E>1.0MeV]. The peak fluence for the other welds was predicted to be below 1 x 1021 n/crn" [E>1.0MeV]. With the fluence for weld H4 exceeding 1 x 1021 n/crn", the requirements of BWRVIP-100 would have been applied if there was a need to perform flaw evaluations. However, when H4 was examined during RF010, the coverage achieved was 99% and no flaws were identified, so no flaw evaluations were required.

Given the improved coverages achieved in RF010, the re-inspection interval for the core shroud welds is ten years (RF015), which will be in the third 10-year interval and is beyond the scope of IR-056, Rev. O. In conclusion, the inspections completed for the core shroud are consistent with the guidelines of BWRVIP-76 and BWRVIP-100, and based on the RF010 examination results, no further core shroud inspections are scheduled for the second 10-year [lSI] interval.

(2) NRC Question: Identify components that will be inspected to BWRVIP guidelines and have a neutron fluence greater than 1 X 1021 nlcm 2 (E > 1 MeV);

Licensee's Response to Request 2: As stated in the response to Request 1, the neutron fluence for weld H4 was predicted per BWRVIP guidance to be greater than 1 x 1021 n/crn" [E>1.0MeV] and based on the RF010 examination results, no further core shroud inspections are scheduled for the second 10-year [lSI] interval.

(3) NRC Question: For components with neutron fluence greater than 1 X 1021 n/cm 2(E > 1 MeV), identify the fracture toughness to be used to determine the inspection requirements for the core shroud. Explain how the fracture toughness is used to determine the inspection requirements in accordance with BWRVIP-76.

Licensee's Response to Request 3: As discussed in the response to Request 1, the fluence for weld H4 exceeded 1 x 1021 n/crn" [E>1.0MeV] and the peak fluence for the other welds was predicted to be below 1 x 1021 n/cm" [E> 1.0MeV]. [Weld] H4 was examined during RF010, and the coverage achieved was 99% with no flaws identified 3 Reference 1 is from the licensee's RAI response and is not included in this SE (ADAMS Accession No. ML082490156).

4 Reference 2 is from the licensee's RAI response and is not included in this SE (ADAMS Accession No. ML082490156).

-7 Therefore, no flaw evaluations were required for weld H4 and fracture toughness considerations are not applicable. In accordance with Figure 2-2 of BWRVIP-76, for Category B shroud welds where the cracking is less than 10% of the inspected length of the weld, and the inspected length of the weld is greater than 50% of the length of the weld, the inspection requirements are taken directly from Table 2_1[5].

NRC Staff Evaluation

The ASME Code requires that the accessible surfaces of the core support structure receives a VT-3 visual examinations each 10-year lSI interval. The licensee has proposed an alternative to the ASME Code requirements. The licensee has proposed to use various BWRVIP guideline requirements for the identified vessel internal components.

The NRC staff reviewed the information provided by the licensee in its submittals dated January 20, 2008 and August 28, 2008, regarding its proposed alternatives to the ASME Code lSI requirements and the technical bases for the licensee's proposed alternative lSI requirements. The NRC staff reviewed the status of each of the referenced BWRVIP technical reports and found all of the referenced BWRVIP reports to be acceptable, with any additional conditions associated with the implementation of the subject BWRVIP reports outlined in the corresponding NRC staff safety evaluation (SE) for that report. Therefore, based on the information in the licensee's submittals, the NRC staff has confirmed that the licensee's proposed alternatives are consistent with the technical bases documented in the BWRVIP reports cited in Section 3.0 of this SE.

The NRC staff has determined that since the licensee's proposed alternatives are consistent with the determinations that were made in the NRC staff's SEs which approved each of the cited BWRVIP reports, the BWRVIP inspection requirements incorporated into the licensee's proposed alternative lSI requirements will identify aging degradation of the subject core support structure components in a timely manner. Therefore, the NRC staff has determined that the implementation of the inspection requirements specified in the licensee's proposed alternative will ensure that the integrity of the core support structure components will be maintained with an acceptable level of quality and safety.

3.2 RR No. IR-OS7, Rev. 0 ASME Code Components lSI Examination Identification 1B13-AE Number 4 Shell Ring-to-RPV Shell Flange Circumferential Seam Weld.

ASME Code Requirements ASME Code,Section XI, Table IWB-2500-1, Category B-A, Item No, B1.30, requires that essentially 100 percent of the RPV shell-to-flange weld examination volume as defined by ASME Code,Section XI, Figure IWB-2500-4 be examined. Per Sub-Article 1-2100, the UT 5 Table 2-1 is not included in this SE (ADAMS Accession No. ML082490156).

- 8 examination of the RPV welds is to be conducted in accordance with ASME Code Section V, Article 4, of as supplemented by ASME Code,Section V, Table 1-2000-1.

"Essentially 100%", as clarified by ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds, is greater than 90% coverage of the examination volume, or surface area, as applicable. ASME Code Case 1\1-460 has been approved for use by the NRC in Regulatory Guide 1.147, Revision 15, Inservice Inspection Code Case Acceptability (RG 1.147).

Licensee's Basis for RR (As Stated)

This weld was examined in [RFO 10] (2005), and 100% coverage could not be obtained Composite coverage was calculated as approximately 68% (refer to Figures 16 and 23 for coverage plots and calculations). It is impractical to obtain significantly more coverage than achieved due to the limitations presented by the flange side geometry and interference from the flange leak-off drain line. Examinations were performed from the outside diameter of the RPV shell as follows:

• No scans were performed from the flange side of the weld.

• From the shell side, scans for axially-oriented flaws (Le., parallel scans) were limited to about 58.4% of the required volume.

• From the shell side, scans for circumferentially-oriented flaws (Le., transverse scans) were performed from one beam direction providing about 76.8% coverage of the required volume.

Licensee's Proposed Alternative Examination (As Stated)

Adequate coverage for circumferential flaws was obtained with acceptable examination results to assure that the structural integrity of the flange is being maintained. The weld also receives a VT-2 [visual] examination each refueling outage. Additionally, during operations, Reactor Coolant System (RCS) unidentified leakage within the drywell is monitored, with a Technical Specifications (TS) limit of 5 gpm [gallons per minute].

As stated in [the PNPP] TS Bases, the 5 gpm limit is a small fraction of the calculated flow from a critical crack in the primary system piping. Therefore, relief is requested from obtaining 100% coverage of the required examination volume per 10 CFR 50.55a(g)(5)(iii).

NRC Staff Evaluation

The ASME Code requires that the RPV shell-to-flange weld be essentially 100 percent volumetrically examined as defined by ASME Code,Section XI, Figure IWB-2500-4. The

3. Figures 1 and 2 are not included in this SE and can be found in the licensee's letter dated January 20, 2008 (ADAMS Accession No. ML080580410).

-9 licensee is requesting relief from the ASME Code requirements because it was unable to examine essentially 100 percent of the RPV shell-to-flange weld. The geometry of the flange side of the RPV shell-to-flange weld and interference from the flange leak-off drain line prevents the licensee from performing the ASME Code-required examination. The licensee would have to redesign the RPV shell-to-flange weld in order for it to meet the ASME Code-required examinations, which would place a burden on the licensee. Therefore, the NRC staff has determined that based on the above, the ASME Code requirements are impractical.

The licensee obtained an aggravate coverage of 68 percent of the RPV shell-to-llange weld. In addition the RCS system receives a VT-2 visual examination each refueling outage. During plant operations unidentified leakage from the RCS is monitored within the drywell. Based on the volumetric coverage obtained, the NRC staff has determined that any significant degradation, if present, would have been detected during the examinations performed to the maximum extent practical on the subject weld. Furthermore, the NRC staff has determined that the volumetric examinations and VT-2 visual examinations performed provide reasonable assurance of structural integrity of the RPV shell-to-flange weld.

4.0 CONCLUSION

For RR IR-056, Rev. 0, based on the information provided in the licensee's submittals, the NRC staff concludes that the alternative, as summarized in Table 1, will ensure that the integrity of the core support structure components is maintained with an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the licensee's proposed alternative is authorized for the second 1O-year lSI interval.

For RR IR-05?, Rev. 0, the NRC staff concludes that in order for the licensee obtain the ASME Code-required volumetric examination of essentially 100 percent of the RPV shell-to-f1ange weld, the subject weld would have to be redesigned and that would be a burden on the licensee.

Therefore, the ASME Code requirements are impractical and the aggravate coverage of 68 percent of the RPV shell-to-flange weld and VT-2 visual examination each refueling outage provides reasonable assurance of structural integrity of the RPV shell-to-flange weld.

Therefore, the NRC staff concludes that relief is granted for RR IR-05?, Rev. 0, pursuant to 10 CFR 50.55a(g)(6)(i) for the second 10-year lSI interval at PNPP.

The NRC staff has also determined that granting relief for RR IR-05? pursuant to 10 CFR 50.55a(g)(6)(i) is authorized by law and will not endanger life or property, or the common defense and security, and is otherwise in the public interest given due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the authorized Nuclear Inservice Inspector.

Principal Contributor: T. McLellan, NRR Date: December 16, 2008

TABLE 1 c _... _.. __ .. - f ASME E ... _............. _.. c-_ ..- _. B-N-2 Reauirements With BWRVIP Guid ----- -R...................... ""' ........ _. BWR/6 (1)

ASME Item No. Core Support Structure ASME Exam ASME ASME Applicable BWRVIP Exam BWRVIP BWRVIP Frequency Scope Table rlNB Components Exam Frequency BWRVIP Scope Exam 2SCO-1 Document B13.40 Shroud Support Plate Accessible VT-3 Each 10 BWRVIP-38, Welds H8 EVT-1 or UT Based on as-found conditions, to a Surfaces year 3.2.2, andH9"') maximum 6 years for one side EVT-1 , 10 Interval Figures 3-4, 3 years for UT 5

Shroud Support Legs Accessible BWRVIP-38, Welds H10, Per When accessible Surfaces 3.2.3 H11 and H12 BWRVIP-38 (beneath core NRC SER plate; rarely (7/24/00),

accessible) inspect with appropriate method'?

when available Shroud Horizontal welds BWRVIP-76, Welds HINT EVT-1 or UT Based on as-found conditions, to a 2.2 Figure 2-2 as applicable maximum 6 years for one side EVT-1 ,10 Iyears for UT Shroud Vertical welds BWRVIP-76, Vertical and EVT-1 or UT Maximum 6 years for one-sided EVT-1 ,10 2.3,3-3, Ring Segment years for UT; only required when horizontal Figures 2-4, 3 Welds welds are found to contain flaws exceeding 2,3-3 certain limits or the shroud is a repaired Accessible shroud ShroudRepairs\"'1 Surfaces VT-3 BWRVIP-76, Tie-Rod Per repair designer recommendations per 3.5,3.6 Repair BWRVIP-76 Top Guide and Top Guide Grid BWRVIP-26-A , Top Guide VT-3 Each 10-year Interval 3.2, Table 3-2 Studs Core Support Plate BWRVIP-25, None for N/A N/A 3.2 BWRl6 Table 3.2 Control Rod Guide Tubes BWRVIP-47-A CRGTBody EVT-1 of body 10% of the CRGT Assemblies within 12 (CRGTs) Accessible 3.2, Welds and welds and VT years Surfaces Table 3.3 Fuel Support 3 of pins and Pins and Lugs lugs NOTES:

1) This Table provides an overview of the requirements. For more details, refer to ASME Section XI, Table IWB-2500-1, and the appropriate BWRVIP document.

2) For Perry this results in a requirement of 10% of the weld length. However, for H9 essentially 100% of the weld length was ultrasonically examined

3) Perry's shroud is a Category B un-repaired shroud.

4) When inspection tooling and methodologies are available, they will be utilized to establish a baseline inspection of these welds. Until such time, and as committed to in BWRVIP-47-A, Section 3.2.5, visual inspections of the lower plenum area (which includes the shroud support legs) will be performed to the extent practical when access is made available through non-routine refueling outage activities (e.g, jet pump disassembly). .

Attachment 1

Mr. Mark B. Bezilla December 16, 2008 Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A290 P.O. Box 9?, 10 Center Road Perry,OH 44081-009?

SUB.JECT: PERRY NUCLEAR POWER PLANT, UNIT NO.1 - REQUEST FOR RELIEF RELATED TO INSERVICE INSPECTION RELIEF REQUESTS NOS. IR-056 AND IR-05? (TAC NOS. MD8198 AND MD8199)

Dear Mr. Bezilla:

By letter to the Nuclear Regulatory Commission (NRC) dated February 20, 2008 (Agencywide Documents Access and Management System Accession No. ML080580410), FirstEnergy Nuclear Operating Company, submitted relief requests (RRs) Nos. IR-056, Rev. 0, and IR-05?, Rev. O. RR IR-056, Rev. 0, proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

Section IX inspection requirements regarding examination of certain components within the reactor pressure vessel (RPV) at the Perry Nuclear Power Plant, Unit No.1. As an alternative to the ASME Code requirements, the Boiling Water Reactor Vessel and Internals Project guidelines was proposed. RR IR-05?, Rev. 0, proposed an alternative to the volumetric examination of the RPV shell-to-flange weld based on impracticality. The requests are for the second 10-year inservice inspection interval.

The NRC staff has completed its review of RRs IR-056, Rev. 0 and IR-05?, Rev. O. The details of the NRC staff's review are set forth in the enclosed safety evaluation. Accordingly, RR IR-056, Rev. 0, is authorized pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i) based on the NRC staff's determination that the alternative provides an acceptable level of quality and safety. Relief is granted for RR IR-05? pursuant to 10 CFR 50.55a(g)(6)(i). RR IR-05?, Rev. 0, is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Sincerely, IRA!

Russell Gibbs, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrPMPerry JAdams, EDO Rill RidsNrrDciCvib RidsOgcRp RidsRgn3MailCenter RidsNrrAdes RidsAcrsAcnw&mMailCenter TMcLellan, NRR RidsNrrLAEWhitt RidsNrrDorlLpl3-2 RidsNrrDorlDpr Accession Number- ML083100284 'Concurrence via ML083040490 OFFICE LPL3-2/PM LPL3-2/LA DCI/CPNB OGC LPL3-2/BC NAME SMeighan EWhitt MMitcheli' BMizuno RGibbs DATE 12/16/08 12/16/08 10/29/08 11 121 108 12/16/08 OFFICIAL RECORD COPY