ML21050A103
| ML21050A103 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/18/2021 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Lashley P Energy Harbor Nuclear Corp |
| Wall S | |
| References | |
| L-2021-LLR-0007, L-2021-LLR-0008 | |
| Download: ML21050A103 (4) | |
Text
From:
Wall, Scott Sent:
Thursday, February 18, 2021 4:40 PM To:
Lashley, Phil H (EH)
Cc:
Morgan, Jeffrey D.
Subject:
Final RAI - Perry Request for Relief - Proposed Alternative Requests VR-3, Rev.
0 and VR-5, Rev. 0 (EPID: L-2021-LLR-0007, L-2021-LLR-0008)
Dear Mr. Lashley,
By letter dated January 28, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21028A796), Energy Harbor Nuclear Corp (the licensee) submitted two (2) relief requests (RRs) for Perry Nuclear Power Plant (PNPP) proposing one-time extensions of testing for certain PNPP valves scheduled for the upcoming spring 2021 refueling outage.
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 phone call on February 18, 2021, the EHNC staff indicated that a response to the RAIs would be provided by February 22, 2021.
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-EMIB (VR-3 & VR-5)
REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUESTS VR-3 AND VR-5 FOURTH 10-YEAR INTERVAL INSERVICE TESTING INTERVAL 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 28, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML21028A796), Energy Harbor Nuclear Corp. (EHNC, the licensee) submitted relief requests (RRs) Nos. VR-3, Revision 0, and VR-5, Revision 0, to the U.S.
Nuclear Regulatory Commission (NRC) for the use of alternatives to specific requirements in the 2012 Edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Perry Nuclear Power Plant (PNPP) associated with the fourth 10-year interval inservice testing (IST) interval.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested to use the proposed alternatives in requests VR-3, Revision 0, and VR-5, Revision 0, on the basis that complying with the requirements of the OM Code would result in hardship without a compensating increase in the level of quality and safety.
In order for the U.S. Nuclear Regulatory Commission (NRC) staff to determine if the proposed alternative may be authorized pursuant to 10 CFR 50.55a(z)(2), the staff requests the licensee provide the following additional information.
APPLICABLE REGULATION AND GUIDANCE The regulations in Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(f)(4),
Inservice testing standards requirement for operating plants, states, in part, that valves that are within the scope of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) must meet the inservice testing (IST) requirements set forth in the ASME OM Code; and that valves that are within the scope of the ASME OM Code, but are not classified as ASME BPV Code Class 1, 2, or 3, may be satisfied as part of an augmented IST program 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)(2), the staff requests the licensee provide the following additional information.
(VR-3) RAI-EMIB-01 In the January 28, 2021 submittal, the licensee proposes a one-time extension of the test frequency and position verification requirements scheduled to be performed during the spring 2021 refueling outage for specific valves at PNPP.
Please clarify if the proposed extension is a one-time extension of the test frequency for the leakage rate testing and position verification requirements.
(VR-5) RAI-EMIB-01
In the January 28, 2021 submittal, the licensee discusses a proposed alternative to the 48-month required test interval by the ASME OM Code for relief valves 1C41-F029B and 1E51-F018. The IST Program Plan and the ASME OM Code, Appendix I, Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants, subsection I-1350, Test Frequency, Classes 2 and 3 Pressure Relief Valves, paragraph (a), 10-Yr Test Interval, indicate a 10-year test interval. Later in the submittal, the licensee references a 10-year test interval.
Please clarify the 48-month test interval that is being discussed in the submittal.
(VR-5) RAI-EMIB-02 The licensee discusses valves 1C41-F029B and 1E51-F018 both being in groups of two.
Please discuss the test results and performance of the other valves in these groups in support of the proposed extension of the test interval for 1C41-F029B and 1E51-F018.
Hearing Identifier:
NRR_DRMA Email Number:
1029 Mail Envelope Properties (MN2PR09MB50195D90B0254B5DE321619B92859)
Subject:
Final RAI - Perry Request for Relief - Proposed Alternative Requests VR-3, Rev.
0 and VR-5, Rev. 0 (EPID: L-2021-LLR-0007, L-2021-LLR-0008)
Sent Date:
2/18/2021 4:39:40 PM Received Date:
2/18/2021 4:39:43 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:
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