ML21050A111

NRR E-mail Capture - Perry Nuclear Power Plant - Request for Additional Information for Proposed Alternative Requests VR-4, Rev. 0 and VR-6, Rev. 0

ML21050A111
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-0010, L-2021-LLR-0011
Download: ML21050A111 (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 Requests VR-4, Rev.

0 and VR-6, Rev. 0 (EPID: L-2021-LLR-0010, L-2021-LLR-0011)

Dear Mr. Lashley,

By letter dated February 8, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21039A409), Energy Harbor Nuclear Corp (the licensee) submitted three (3) 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-4 & VR-6)

REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUESTS VR-4 AND VR-6 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 February 8, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML21039A409), Energy Harbor Nuclear Corp. (EHNC, the licensee) submitted relief requests (RRs) Nos. VR-4, Revision 0, VR-6, Revision 0, and VR-8, 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-4, Revision 0, VR-6, Revision 0, and VR-8, 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-4) RAI-EMIB-01 In the February 8, 2021 submittal, the licensee requests a one-time extension of the test frequency requirements scheduled to be performed during the spring 2021 refueling outage for specific check valves at Perry.

• Please clarify which test frequencies are being extended. For example, will the quarterly frequency tests for 1E22-F0621 and 1E22-F0622 still be performed on a quarterly basis, or will these also be extended per this request?

(VR-4) RAI-EMIB-02 With respect to 1E22-F0621 and 1E22-F0622, the licensee states that engineering review of the test results revealed that the valves consistently demonstrated acceptable results. With respect to 1M51-F0531A/B, 1M51-F0532A/B, and 1M51-F0618A/B, the licensee states that a review of surveillance testing pertinent to the 1M51 combustible gas control check valves has revealed that there have been no failures of valves unable to meet acceptance criteria.

• Please briefly describe the evaluation of test results that support the licensees determination that the valves will be able to perform their safety function over the requested test interval extension for these valves.

(VR-6) RAI-EMIB-01 With respect to the valves listed in the VR-6 request, the licensee states that based on several years of valve test history and other information for the specific listed valves, there is reasonable assurance that the valves will remain operationally ready until the 2023 refueling outage.

• Please briefly describe the evaluation of test results that support the licensees determination that the valves will be able to perform their safety function over the requested test interval extension for these valves.

(VR-6) RAI-EMIB-02 For some valves listed in the VR-6 request, the licensee states that valve obturator position is confirmed by verifying that remote position indication accurately reflects valve stem travel direction as observed locally. The staff notes that stem travel will not verify the remote position indicating lights if the valve stem-disc connection has separated.

• Please describe an appropriate method to verify the valve remote indicating lights as required in paragraph ISTC-3700, Position Verification Testing, of the ASME OM Code (2012 Edition) with the condition in 10 CFR 50.55a(b)(3)(xi).

(VR-6) RAI-EMIB-03 Some valves listed in the VR-6 request are stated as being passive but also are containment isolation valves.

• Please explain the basis for specifying a valve as passive that has a safety function to close.

Hearing Identifier: NRR_DRMA Email Number: 1031 Mail Envelope Properties (MN2PR09MB50193911AAB3EA224AA5044F92859)

Subject:

Final RAI - Perry Request for Relief - Proposed Alternative Requests VR-4, Rev.

0 and VR-6, Rev. 0 (EPID: L-2021-LLR-0010, L-2021-LLR-0011)

Sent Date: 2/18/2021 4:42:22 PM Received Date: 2/18/2021 4:42:24 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 6738 2/18/2021 4:42:24 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: