L-21-060, Response to Request for Additional Information Regarding 10 CFR 50.55a Request Number SR-2, Revision 0, Snubber Testing Extension
| ML21039A785 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/08/2021 |
| From: | Penfield R Energy Harbor Nuclear Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EPID L-2021-LLR-0005, L-21-060 | |
| Download: ML21039A785 (8) | |
Text
energy harbor Rod L. Penfield Site Vice President, Perry Nuclear February 8, 2021 L-21-060 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Regarding Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant 10 Center Road P.O. Box 97 Perry, Ohio 44081 440-280-5382 10 CFR 50.55a Request Number SR-2, Revision 0, Snubber Testing Extension (EPID: L-2021-LLR-0005)
By letter dated January 15, 2021 (Accession No. ML21018A004 )), Energy Harbor Nuclear Corp. submitted 10 CFR 50.55a request SR-2, Revision 0, to the Nuclear Regulatory Commission (NRC). Request SR-2 proposed a one-time extension of operational readiness testing for certain Perry Nuclear Power Plant snubbers scheduled for testing during the upcoming spring 2021 refueling outage. By email dated February 1, 2021, the NRC staff requested additional information regarding 10 CFR 50.55a request SR-2. The Energy Harbor Nuclear Corp. response to the NRC request is attached.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager, Fleet Licensing, at (330) 696-7208.
Sincerely, Penfield, Rod 55166 Rod L. Penfield
Attachment:
Penfield, Rod 55166 sitevp I am approving this document Feb 8 2021 4:12 PM Docu~
Response to Request for Additional Information
Perry Nuclear Power Plant L-21-060 Page 2 cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager
Attachment L-21-060 Response to Request for Additional Information Page 1 of 6 Each NRC staff request for additional information (RAI) is provided below in bold text and is followed by the Energy Harbor Nuclear Corp. response.
RAI-EMIB-01 Section 4, Reason for Change, of the January 15, 2021 request, states, in part, that licensee groups the PNPP program snubbers into three Defined Test Plan Groups (DTPGs), PSA mechanical snubbers (37 plan), Lisega hydraulic snubbers (10% plan), and E-systems hydraulic snubbers (10% plan). The 37 plan requires 37 randomly selected snubbers from the DTPG, while the 10% test plan requires 10% of each DTPG to be tested for operational readiness during each fuel cycle.
The table in Section 1 of the request represents the population of snubbers scheduled to be tested under the snubber test plan for the spring 2021 refueling outage, excluding snubbers that will still be monitored for or changed in support of service life monitoring. There are 909 PSA mechanical snubbers subject to the 37 plan. Of the 37 randomly selected PSA mechanical snubbers, 28 are listed in Section 1 and the remaining nine snubbers were excluded. There are 82 Lisega hydraulic snubbers subject to the 10% plan. Of the nine selected Lisega hydraulic snubbers, five are listed in Section 1 and the remaining four snubbers were excluded.
Subparagraph ISTD-5240, Test Frequency, requires that tests of snubbers from the facility shall be performed every refueling cycle. Subparagraph ISTD-5261, Sample Plan, of the paragraph ISTD-5260, Testing Sample Plans, states that the snubber of each DTPG shall be tested either (a) the 10% testing plan or (b) the 37 testing sample plan. The selected snubber tables in Section 1 do not include nine PSA snubbers and five Lesega hydraulic snubbers. The ASME OM Code, Subsection ISTD, requires that the 37 sample testing or 10% sample testing plans for snubber testing shall be performed during a refueling outage. The ASME OM Code, Subsection ISTD, does allow splitting of 37 sampling and 10% sampling plans.
- Please clarify the splitting of the sampling plans and make appropriate changes to alternative request for NRC authorization
Response
The nine PSA mechanical snubbers and four Lisega hydraulic snubbers that were not originally included in Section 1, ASME Code Components Affected, have been added to the list of affected snubbers shown below. The list of affected snubbers shown below hereby replaces the list of snubbers provided in Section 1 of Request SR-2.
Attachment L-21-060 Page 2 of 6 PSA Mechanical Snubbers:
Safety Significant Snubbers - Subject to the 37 Plan Snubber Component Number Snubber Model Last Visual Exam Date Date Last Tested or Replaced Service Life End Date 1B21-H0013 PSA-35 3/25/2017 4/10/1999 4/30/2049 1B21-H0065 (NW)
PSA-35 3/25/2017 2/6/1993 2/6/2033 1B21-H0119 (NE)
PSA-35 3/8/2017 9/26/1997 11/18/2047 1B21-H0410 PSA-35 3/18/2017 3/2/1994 11/18/2047 1C11-H0693 PSA-1/4 3/8/2019 3/15/1999 10/30/2050 1C41-H5020 PSA-1/4 3/11/2019 4/18/1992 11/18/2047 1E12-H0325 PSA-10 3/10/2019 11/18/1987 11/18/2027 1E12-H0333 PSA-3 3/10/2019 11/18/1987 11/18/2027 1E12-H0345 PSA-3 2/20/2019 2/19/2009 11/18/2047 1E12-H0365 PSA-10 3/4/2019 11/18/1987 11/18/2027 1E12-H0383 PSA-1 3/7/2019 2/15/2005 5/12/2052 1E12-H0410 PSA-35 3/6/2019 3/25/2003 3/11/2041 1E12-H0422 PSA-3 3/7/2019 2/26/2007 11/18/2047 1E12-H0542 PSA-1/2 3/7/2019 3/26/1999 11/18/2047 1E12-H0730 PSA-35 3/7/2019 2/13/1996 11/18/2047 1E12-H0760 PSA-1 3/20/2019 2/6/2001 11/18/2047 1E12-H0762 PSA-1 3/5/2019 4/18/1992 11/18/2047 1E12-H0782 (Top)
PSA-1 3/7/2019 11/18/1987 11/18/2027 1E12-H2299 PSA-1/2 3/21/2019 5/1/1992 11/18/2047 1E21-H0004 PSA-35 3/20/2017 11/18/1987 11/18/2027 1E21-H0008 PSA-10 3/7/2019 3/21/2007 11/18/2047 1E22-H0053 PSA-3 3/8/2019 3/30/2011 11/18/2047 1E22-H0060 PSA-10 3/8/2019 3/11/2003 11/18/2047 1G33-H0219 PSA-10 3/27/2017 2/15/1996 11/18/2047 1G41-H0070 PSA-1 3/29/2019 3/10/1994 11/18/2047 1G41-H0145 PSA-10 3/4/2019 11/18/1987 11/18/2027 1G41-H0151 (Bot)
PSA-3 3/18/2019 9/29/1990 11/18/2047 1G41-H0450 (West)
PSA-3 2/27/2019 11/18/1987 11/18/2027
Attachment L-21-060 Page 3 of 6 PSA Mechanical Snubbers:
Safety Significant Snubbers - Subject to the 37 Plan (continued)
Snubber Component Number Snubber Model Last Visual Exam Date Date Last Tested or Replaced Service Life End Date 1G41-H5001 (Top)
PSA-3 3/4/2019 3/13/2013 11/18/2047 1N11-H0284 PSA-35L 3/14/2017 3/26/1992 11/18/2047 1N27-H0224 PSA-35 3/27/2017 3/11/2017 11/18/2047 1P11-H0063 PSA-35 3/7/2019 11/18/1987 11/18/2027 1P42-H0051 PSA-3 3/25/2019 3/20/2015 11/18/2047 1P42-H0388 PSA-1 3/18/2019 2/12/2009 11/18/2047 1P45-H0132 (N)
PSA-3 3/18/2019 2/23/2017 7/21/2043 1P45-H0183 PSA-10 3/25/2019 2/28/1996 11/18/2047 1P45-H0353 (TOP)
PSA-3 3/25/2019 5/9/1992 11/18/2047 Lisega Hydraulic Snubbers:
Safety Significant Snubbers Subject to the 10% Plan Snubber Component Number Snubber Model Last Visual Exam Date Date Last Tested or Replaced Service Life End Date 1B21-H0445 304256RC1 3/9/2017 3/11/2015 7/11/2023 1B21-H0453 305253RF3 3/9/2017 6/20/2013 10/20/2021 1E12-H0109 304256RE1 3/5/2019 2/13/2009 3/2/2039 1E12-H0790 304256RE1 2/18/2019 2/15/2019 2/18/2059 1E21-H0039 304256RE1 2/18/2019 2/15/2019 2/18/2059 1E21-H0050 (W) 306256RE2 2/20/2019 2/14/1996 2/19/2036 1E51-H0072 305253RF3 3/9/2017 3/1/2017 7/9/2025 1E51-H0073 304256RC1 3/16/2017 3/21/2013 7/21/2021 1E51-H2078 301856RE2 3/16/2017 3/20/2013 7/20/2021
Attachment L-21-060 Page 4 of 6 E-Systems Hydraulic Snubbers:
Safety Significant Snubbers - Subject to the 10% Plan Snubber Component Number Snubber Model Last Visual Exam Date Date Last Tested or Replaced Service Life End Date 1B21-G7080-S104A 50 KIP 3/27/2017 5/7/2011 5/21/2035 1B33-G7068B-S373B 100 KIP 3/27/2019 3/27/2019 3/12/2029 1E12-H0316 20 KIP 3/10/2019 2/6/2001 2/6/2041 1N27-H0001 50 KIP 3/27/2017 4/4/2013 4/4/2037 1N27-H0018 70 KIP 3/27/2017 3/22/2017 3/27/2041 1N27-H0019 70 KIP 3/27/2019 4/15/2013 4/15/2037 The third paragraph of the January 15, 2021, request SR-2, Section 4, is hereby revised to read as follows:
The table in Section 1 of this request represents the population of snubbers that were scheduled to be tested under the snubber test plan for the spring 2021 refueling outage. There are 909 PSA mechanical snubbers subject to the 37 plan, and the 37 randomly selected snubbers are listed in Section 1. There are 82 Lisega hydraulic snubbers subject to the 10% plan, and the nine selected snubbers are listed in Section 1.
There are 53 E-Systems hydraulic snubbers subject to the 10% plan, and the six selected snubbers are listed in Section 1.
RAI-EMIB-02 Section 6, Duration of Proposed Alternative, states, in part, that the proposed alternative is requested for use during the PNPP fourth 10-year IST interval.
Response
The PNPP fourth 10-year IST interval start date was May 18, 2019, and the end date is May 17, 2029.
RAI-EMIB-03 Section 1, The ASME Code Component Affected, provides a list of snubbers included in the alternative request SR-2, Revision 0. For operational readiness of snubbers, Subsection ISTD-3000, General Requirements, requires (1) Visual Examination, (2) Functional Testing, and (3) Service Life Monitoring.
- Please provide the history of visual examination and testing and replaced history of snubbers listed in Section 1 (when these were tested or replaced).
Attachment L-21-060 Page 5 of 6
Response
The response to RAI-EMIB-01 provides the date when each snubber was last tested or replaced.
RAI-EMIB-04 Section 5, Proposed Alternative and Basis for Use, second paragraph describes the alternative request as the elimination of spring 2021 refueling outage snubber testing. The regulation in 10 CFR 50.55a(z)(2) allows the NRC to authorize the proposed alternative, but not to eliminate the testing altogether.
The NRC staff considers this alternative request to propose a one-time extension of the ASME OM Code IST of snubbers listed in the Section 1 of the submittal to the spring 2023 refueling outage in lieu of spring 2021 refueling outage.
- Please clarify (and revise, as necessary) whether this is the case or if the request is to eliminate the spring 2021 refueling outage snubber testing.
Response
The first sentence of the second paragraph in Section 5 is hereby revised to read as follows.
Based on the PNPP snubber test history, the proposed one-time extension of scheduled snubber operational readiness testing from the spring of 2021 refueling outage to the spring of 2023 refueling outage will not impact the ability of the affected snubbers to perform their intended safety function.
The intent of the alternative is to extend testing of the affected components from the spring of 2021 refueling outage to the spring of 2023 refueling outage, with testing to resume during the spring of 2023 refueling outage.
RAI-EMIB-05 Section 5, Proposed Alternative and Basis for Use, second paragraph, second sentence states that Since 2011, there have been approximately 260 tests of program snubbers with only four snubber test failures related to operational readiness testing. These test failures occurred in the PSA DTPG (Defined Testing Plan Group) and were captured in the PNPP corrective action program. PNPP is using The 37 testing Plan, for PSA DTPG as per ISTD-5260, Testing Sample Plans, and ISTD-5400, The 37 Testing Plan. The licensee states that since 2011 there were four failed snubbers. Snubber failures while using the 37 testing plan requires additional 18 or 19 snubbers to be tested as specified by ISTD-5421, Additional Sample Size, and ISTD-5420, The 37 Testing Sample Plan Additional Testing.
- Please clarify and explain the number of additional snubbers tested and their results due to four failed snubbers.
Attachment L-21-060 Page 6 of 6
Response
The four test failures are as follows:
Snubber 1E12H0280 was selected for the 37 plan scope during the spring of 2017 refueling outage and failed testing. This resulted in an expansion of scope by 19 snubbers. There were no additional test failures in the expanded scope.
Two snubbers (1N22H0127 and 1E12H0322) selected for the 37 plan scope during the spring of 2015 refueling outage failed testing. Failure of snubber 1N22H0127 resulted in an expansion of scope by 18 snubbers. There were no additional test failures in this expanded scope. Failure of snubber 1E12H0322 resulted in an expansion of scope by 19 snubbers. There were no additional test failures in this expanded scope.
Snubber 1H22H0365 was selected for the 37 plan scope during the spring of 2013 refueling outage and failed testing. This resulted in an additional expansion of scope by 19 snubbers. There were no additional test failures in the expanded scope.
RAI-EMIB-06 Section 5, fifth paragraph, states that visual examination interval specified in ASME OM Code, Table ISTD-4252-1, Visual Examination Table, has been extended for applicable PNPP snubbers to at least once every 10 years in accordance with ASME Code Case OMN-13.
- Please provide the visual examination history of the snubbers included in the SR-2, Section 1 for one-time extension of the snubber testing.
Response
The response to RAI-EMIB-01 provides the date of the last visual examination for each of the listed snubbers.
RAI-EMIB-07 Section 5, sixth paragraph states that this request does not impact the service life monitoring program. As required by ISTD-6200, Service Life Evaluation, the service life will be evaluated. The licensee did not provide the current service life of snubbers listed in Section 1.
- Please provide the current service life of each snubbers listed in the Section 1, for which relief is requested.
Response
The response to RAI-EMIB-01 provides the date that the service life ends for each of the listed snubbers.