ML20289A101

NRR E-mail Capture - Final 2nd Round RAI - Perry Request for Relief - Proposed Alternative Request IR-056, Rev. 3

ML20289A101
Person / Time
Site:	Perry
Issue date:	10/05/2020
From:	Scott Wall NRC/NRR/DORL/LPL3
To:	Lashley P Energy Harbor Nuclear Corp
Wall, S P
References
L-2020-LLR-0004
Download: ML20289A101 (4)

Text

From: Wall, Scott Sent: Monday, October 5, 2020 1:10 PM To: Lashley, Phil H (EH)

Cc: Morgan, Jeffrey D.

Subject:

Final 2nd Round RAI - Perry Request for Relief - Proposed Alternative Request IR-056, Rev. 3 (EPID: L-2020-LLR-0004)

Dear Mr. Lashley,

By letter dated January 6, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20006D984), FirstEnergy Nuclear Operating Company (FENOC) requested U.S. Nuclear Regulatory Commission (NRC) approval of proposed alternatives to the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), for the fourth 10-year inservice inspection (ISI) Program for the Perry Nuclear Power Plant (PNPP).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(z)(1), Acceptable level of quality and safety, FENOC requested approval to implement alternative BWRVIP Guidelines in lieu of ASME Code Section XI Table IWB-2500-1 Examination Category B-N-1 and B-N-2 requirements.

By order dated December 2, 2019, the NRC staff approved the direct and indirect transfers of several FENOC-owned and operated plants, including PNPP. Under the new set-up, Energy Harbor Corp would indirectly own the plants as a parent company, Energy Harbor Nuclear Generation LLC would directly own the plants, and Energy Harbor Nuclear Corp. would have authority to operate the plants. On February 27, 2020, Energy Harbor Nuclear Corp., informed the NRC that the transaction closed on February 27, 2020 and that it adopted and endorsed the outstanding commitments, licensing actions, applications and similar items on dockets submitted by FENOC on behalf of the licensees. Accordingly, Energy Harbor Nuclear Corp.

(EHNC, the licensee) is now authorized to act as agent for Energy Harbor Nuclear Generation, LLC, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility at PNPP.

The NRC staff has reviewed the submittals and determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). By email sent October 1, 2020, the EHNC staff indicated that a response to the RAIs would be provided within 30 days of this email (November 4, 2020).

If you have questions, please contact me at 301-415-2855 or via e-mail at Scott.Wall@nrc.gov.

Scott P. Wall, LSS BB, BSP Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov Docket No. 50-440

Enclosure:

Request for Additional Information

cc: Listserv RAI-NVIB (IR-056)

REQUEST FOR ADDITIONAL INFORMATION PROPOSED ALTERNATIVE TO AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE IR-056, REVISION 3 ENERGY HARBOR NUCLEAR CORP.

ENERGY HARBOR NUCLEAR GENERATION, LLC PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440 INTRODUCTION By letter dated January 6, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20006D984), the licensee submitted a relief request, IR-056, Revision 3, (Proposed Alternative) to certain requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), for the fourth 10-year in-service inspection (ISI) Program for the Perry Nuclear Power Plant, Unit 1 (PNPP).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(z)(1), the licensee requested approval to implement alternative BWRVIP Guidelines in lieu of ASME Code Section XI Table IWB-2500-1 Examination Category B-N-1 and B-N-2 requirements. The licensees proposed alternative applies to the fourth ISI interval.

In order for the staff to determine if the proposed alternative may be authorized pursuant to 10 CFR 50.55a(z)(1), the staff requests the licensee provide the following additional information.

APPLICABLE REGULATION AND GUIDANCE The regulations in 10 CFR 50.55a(g)(4) state, in part, that ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI of the applicable editions and addenda of the ASME Code to the extent practical within the limitations of design, geometry, and materials of construction of the components.

The regulations in 10 CFR 50.55a(z) state, in part, that alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (1) the proposed alternative provides 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. In order for the staff

to determine if the proposed alternative may be authorized pursuant to 10 CFR 50.55a(z)(1), the staff requests the licensee provide the following additional information.

RAI-NVIB-03 (IR-056)

During the review, the staff noted that on page 3 of the January 6, 2020 submittal, the licensee referenced BWRVIP-48, Revision 1, BWR Vessel and Internals Project: BWR Vessel [Internal Diameter] Attachment Welds Inspection and Flaw Evaluation Guidelines, which is not approved by the staff. However, the staff has approved the BWRVIP-48-A report.

(a) The staff requests that if the licensee intends to use BWRVIP-48, Revision 1, in lieu of BWRVIP-48-A, provide a summary of the revised changes between BWRVIP-48-A and BWRVIP-48, Revision 1.

(b) Based on these changes, justify why BWRVIP-48, Revision 1 may be implemented as an acceptable basis for inspection of the applicable RPV interior attachments welds without prior NRC approval of the methods in BWRVIP-48, Revision 1.

Hearing Identifier: NRR_DRMA Email Number: 818 Mail Envelope Properties (MN2PR09MB5019F6914FCDCC1F7C09C21F920C0)

Subject:

Final 2nd Round RAI - Perry Request for Relief - Proposed Alternative Request IR-056, Rev. 3 (EPID: L-2020-LLR-0004)

Sent Date: 10/5/2020 1:09:44 PM Received Date: 10/5/2020 1:09:45 PM From: Wall, Scott Created By: Scott.Wall@nrc.gov Recipients:

"Morgan, Jeffrey D." <jdmorgan@energyharbor.com>

Tracking Status: None "Lashley, Phil H (EH)" <phlashley@energyharbor.com>

Tracking Status: None Post Office: MN2PR09MB5019.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5943 10/5/2020 1:09:45 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: