ML21050A107
| ML21050A107 | |
| 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-0009 | |
| Download: ML21050A107 (4) | |
Text
From:
Wall, Scott Sent:
Thursday, February 18, 2021 4:42 PM To:
Lashley, Phil H (EH)
Cc:
Morgan, Jeffrey D.
Subject:
Final RAI - Perry Request for Relief - Proposed Alternative Request VR-7, Rev.
Dear Mr. Lashley,
By letter dated January 29, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21031A002), Energy Harbor Nuclear Corp (the licensee) submitted a relief request (RR) for Perry Nuclear Power Plant (PNPP) proposing a one-time extension of testing for certain Perry check 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-7)
REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST VR-7 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 29, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21031A002), Energy Harbor Nuclear Corp. (the licensee) submitted relief request (RR) No. VR-7, 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).
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 request VR-7, 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-7) RAI-EMIB-01 In the January 29, 2021 submittal, the licensee states that From 2003 to present, the leakage tests performed for all four check valves has met the acceptance criterion.
Please provide specific testing results (for example, a table indicating dates of tests and results for each valve) that illustrate the test history with sufficient detail to support an extension of the test interval until the 2023 refueling outage.
Clarify if the test results mentioned are inclusive of the three types of IST tests specified in the IST Program Plan.
(VR-7) RAI-EMIB-02 The January 29, 2021 submittal specifies under Section 2 that the 2012 Edition, Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants, of the ASME OM Code is applicable to the VR-7 request. In that Subsection ISTD is applicable to dynamic restraints (snubbers), this reference appears to be in error.
Please correct this reference as appropriate.
(VR-7) RAI-EMIB-03 The NRC staff compared the licensees submittal to the version of the IST Program Plan available to the NRC staff (ADAMS Accession No. ML20045E972) and noted apparent differences between the submittal and the IST Program Plan. Please confirm the information with respect to the differences noted below:
All four check valves in the request are listed as Valve Category AC in the IST Program Plan, but Valve Category C in the submittal.
The IST Program Plan indicates these four check valves are subject to the following test requirements: exercise open (quarterly), exercise closed (refueling outage), and LD (Other Category A valves requiring seat leakage tests per the OM Code). The proposed alternative requests a one-time extension of check valve exercise testing scheduled for the spring 2021 refueling outage. Please clarify which of the three tests are being requested for extension by the proposed alternative
Hearing Identifier:
NRR_DRMA Email Number:
1030 Mail Envelope Properties (MN2PR09MB501989108362F3541A37DD7F92859)
Subject:
Final RAI - Perry Request for Relief - Proposed Alternative Request VR-7, Rev. 0 (EPID: L-2021-LLR-0009)
Sent Date:
2/18/2021 4:41:59 PM Received Date:
2/18/2021 4:42:02 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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