ML22187A259

Issuance of Relief Proposed Alternative Request Vr 12, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval

ML22187A259
Person / Time
Site:	Perry
Issue date:	07/12/2022
From:	Nancy Salgado NRC/NRR/DORL/LPL3
To:	Penfield R Energy Harbor Nuclear Corp
Wall S, NRR/DORL/LPL3
References
EPID L-2022-LLR-0004
Download: ML22187A259 (10)

Text

July 12, 2022 Mr. Rod L. Penfield Site Vice President Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant P.O. Box 97, Mail Stop A-PY-A290 Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF RELIEF RE: PROPOSED ALTERNATIVE REQUEST VR-12, REVISION 0, ASSOCIATED WITH THE FOURTH 10-YEAR INSERVICE TESTING INTERVAL (EPID L-2022-LLR-0004)

Dear Mr. Penfield:

By letter dated January 5, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22005A351), as supplemented by letter dated April 28, 2022 (ML22118A873), Energy Harbor Nuclear Corp. (the licensee) submitted alternative request No. VR-12, Revision 0, to the U.S. Nuclear Regulatory Commission (NRC) for the use of alternatives to certain inservice testing (IST) program requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the Perry Nuclear Power Plant, Unit 1 (PNPP).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1), the licensee requested to use the proposed alternative in VR-12, Revision 0, on the basis that the proposed alternative will provide an acceptable level of quality and safety.

The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1). Therefore, the NRC staff authorizes the proposed alternative in VR-12, Revision 0, for the fourth 10-year IST interval at PNPP which began May 18, 2019, and is scheduled to expire May 17, 2029.

All other requirements in the ASME OM Code for which relief was not specifically requested and approved in this request remains applicable.

R. Penfield If you have any questions, please contact the Senior Project Manager, Scott Wall, at 301-415-2855 or e-mail at Scott.Wall@nrc.gov.

Sincerely, Digitally signed by Nancy Nancy L. L. Salgado Date: 2022.07.12 Salgado 12:30:08 -04'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Safety Evaluation cc: Listserv

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALTERNATIVE REQUEST VR-12, REVISION 0 FOURTH 10-YEAR INTERVAL INSERVICE TESTING INTERVAL ENERGY HARBOR NUCLEAR CORP.

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated January 5, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22005A351), as supplemented by letter dated April 28, 2022 (ML22118A873), Energy Harbor Nuclear Corp. (the licensee) submitted alternative request for VR-12, Revision 0, to the U.S. Nuclear Regulatory Commission (NRC or Commission) for the use of alternatives to certain inservice testing (IST) program requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the Perry Nuclear Power Plant, Unit 1 (PNPP).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1), the licensee requested to use the proposed alternative in VR-12, Revision 0, on the basis that the proposed alternative will provide an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

The NRC regulations in 10 CFR 50.55a(f)(4) state, in part, that throughout the service life of a boiling- or pressurized-water cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the IST requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components. The IST requirements for pumps and valves that are within the scope of the ASME OM Code but are not classified as ASME Code Class 1, Class 2, or Class 3, may be satisfied as an augmented IST program in accordance with 10 CFR 50.55a(f)(6)(ii) without requesting relief under 10 CFR 50.55a(f)(5) or alternatives under 10 CFR 50.55a(z). This use of an augmented IST program may be acceptable provided the basis for deviations from the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, demonstrates an acceptable level of quality and safety, or that implementing the code provisions would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, where documented and available for NRC review.

Enclosure

The NRC regulations in 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, state the following:

When implementing paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section

[10 CFR 50.55a], licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies.

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.

3.0 TECHNICAL EVALUATION

The information provided by the licensee in support of the requests for alternatives to ASME OM Code requirements has been evaluated and the bases for disposition are documented below.

Applicable Code Edition and Addenda

The 2012 Edition of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a with conditions, is applicable to the current 10-year IST program interval at PNPP.

Duration of the Alternative The duration of the proposed alternatives is for the fourth 10-year ISI interval, which began on May 18, 2019, and is scheduled to end on May 17, 2029.

3.1 Proposed Alternative VR-12, Revision 0 3.1.1 ASME Code Components Affected The request applies to the components in the following table:

Table 1 Valve Number Valve Name System OM ASME Category Code Class 1P87-F046 DRYWELL FLOOR DRN Post Accident Sample A 2 SUMP PEN ISOL VLV System 1P87-F049 RX RECIRC AND RWCU Post Accident Sample A 2 CONT PEN ISOL VLV System 1P87-F052 DRYWELL FLOOR DRN Post Accident Sample A 2 SUMP PEN ISOL VLV System

1P87-055 RX RECIRC AND RWCU Post Accident Sample A 2 CONT PEN ISOL VLV System 1P87-F037 SUP POOL WATER Post Accident Sample A 2 SAMPLE ISOL VLV System 1P87-F083 SUPP POOL RETURN Post Accident Sample A 2 ISOL VLV System 1P87-F0264 SUPP POOL RETURN Post Accident Sample A 2 ISOL VLV System 1D23-F010A SUPR POOL LEVEL A Containment Atmosphere A 2 DRY LEG ISOL VALVE Monitoring 1D23-F010B SUPR POOL LEVEL B Containment Atmosphere A 2 DRY LEG ISOL VALVE Monitoring 1D23-F020A CNTMT PRESS A Containment Atmosphere A 2 CNTMT ISOL VALVE Monitoring 1D23-F020B CNTMT PRESS B Containment Atmosphere A 2 CNTMT ISOL VALVE Monitoring 1D23-F030A CNTMT DW A DIFF Containment Atmosphere A 2 PRESS-CNTMT LEG Monitoring 1D23-F030B CNTMT DW B DIFF Containment Atmosphere A 2 PRESS-CNTMT LEG Monitoring 1D23-F040A CNTMT DW A DIFF Containment Atmosphere A 2 PRESS-DW LEG Monitoring 1D23-F040B CNTMT DW B DIFF Containment Atmosphere A 2 PRESS-DW LEG Monitoring 1D23-F050 SUPR POOL LEVEL C Containment Atmosphere A 2 DRY LEG ISOL VLV Monitoring 1G43-F050A SUPR POOL LEVEL A Suppression Pool Makeup A 2 WET LEG ISOL VALVE 1G43-F050B SUPR POOL LEVEL B Suppression Pool Makeup A 2 WET LEG ISOL VALVE 1G43-F060 SUPR POOL LEVEL C Suppression Pool Makeup A 2 WET LEG ISOL VALVE 1M17-F055 CNTMT VACUUM A Containment Vacuum A 2 CNTMT ISOL VALVE Relief 1M17-F065 CNTMT VACUUM B Containment Vacuum A 2 CNTMT ISOL VALVE Relief Abbreviations Containment CNTMT ll CONT Differential DIFF Drain DRN Drywell DW Isolation ISOL Penetration PEN Pressure PRESS Suppression SUP ll SUPP ll SUPR Reactor RX Reactor Water Cleanup RWCU Recirculation RECIRC Valve VLV

3.1.2 Applicable Code Requirements ASME OM Code, Subsection ISTC, paragraph ISTC-3600, Position Verification Testing, states, in part:

Valves with remote position indicators shall be observed locally at least once every 2 yr [years] to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation.

3.1.3 Reason for Request In its submittal dated January 5, 2022, as supplemented by a letter dated April 28, 2022, the licensee provided the following reason for its request:

In accordance with 10 CFR 50.55a, Codes and standards, paragraph (z)(1), an alternative is proposed to ASME OM Code, 2012 Edition, subsection ISTC-3700 for select valves. The basis of the request is that the proposed alternative valve position verification frequencies and leakage tests provide an acceptable level of quality and safety. The current regulation does not allow the test frequency to be altered or adjusted based on existing NRC approved testing, past test performance results, likelihood of failure, nor consequence of failure. The proposed alternative will allow the performance of valve position indication verification and leakage testing to credit existing Code and NRC approved test methodologies and frequencies and be commensurate with the valve's risk ranking.

3.1.4 Licensees Proposed Alternative In its submittal dated January 5, 2022, as supplemented by a letter dated April 28, 2022, the licensee described its proposed alternative as follows:

ISTC-3700 states valves with remote position indicators shall be observed locally at least once every two years to verify that valve operation is accurately indicated. For certain valves at PNPP, 10 CFR 50, Appendix J, Type C testing (specifically, local leak rate testing (LLRT)) is credited to meet the position indication verification requirement. For certain isolation valves on instrument lines that penetrate containment, the inservice testing program utilizes 10 CFR 50, Appendix J, Type C testing methodology to meet the leakage rate and position indication verification requirements. Energy Harbor Nuclear Corp. is proposing to adopt the 10 CFR 50, Appendix J, Option B-Performance-Based Requirements program consistent with [Nuclear Energy Institute] NEI 94-01, Revision 3-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, for PNPP. This program allows LLRT intervals to be extended up to 75 months for valves with a history of satisfactory testing, which entails completion of two consecutive periodic as-found tests where the results of each test are within the allowable administrative limits.

Energy Harbor Nuclear Corp. proposes an alternative to the ASME OM Code, ISTC-3700 requirements, to perform the valve supplemental position verification at a frequency consistent with 10 CFR 50, Appendix J, Type C testing. The NRC approved the use of Option B at PNPP on September 9, 1997 (ML021840313).

The method used at PNPP is a pressure test using LLRT equipment. This method involves pressurizing the containment penetration volume and verifying the penetration remains pressurized while the valve is indicating closed on the main control room board. The valve is then opened using the control switch in the main control room. A decrease in pressure is then verified along with valve position indicating open in the main control room. This method satisfies the requirement for position indication verification and ensures that the indicating system accurately reflects the valve position. The subject valves are all in category A and are all containment isolation valves (CIV) per the plant safety analysis. All the subject valves have a safety function to close to isolate containment during a loss-of-coolant accident (LOCA) when required. Since these valves are CIV, they are individually seat leakage tested in accordance with 10 CFR 50, Appendix J, Option B or the inservice testing program. The subject valves are designed that the position of the valve is not locally observable. The coil position is internal to the valve body and not observable in either the energized or de-energized state.

In the closed direction, the requirements will be met by verifying proper remote indicating lights in conjunction with measured leakage of 1,000 standard cubic centimeters per minute or less for pneumatically tested valves, and 0.5 gallons per minute or less for hydrostatically tested valves using local leak rate testing equipment. These measurements are obtained during execution of test instructions to satisfy the requirements of ASME OM Code-2012, Subsection ISTC-3700, Position Verification Testing.

In the open direction, the requirements will be met by verifying proper remote indicating lights in conjunction with a pressure drop when the valves are opened at test pressure. This is measured immediately following the position verification testing in the closed position described in the preceding paragraph. The test instructions will include acceptance criteria for flow in conjunction with pressure drop to verify accurate indication of obturator position using local leak rate testing equipment. These measurements will be obtained during execution of test instructions to satisfy the requirements of ASME OM Code 2012, Subsection ISTC-3700, Position Verification Testing.

These tests meet the requirements of 10 CFR 50.55a(b)(3)(xi) to verify accurate obturator indication for the valves listed in Table 1 of the letter dated January 5, 2022.

3.1.5 Basis for Use In its January 5, 2022, submittal, the licensee provides a detailed description of the basis for its alternative request. The NRC staff summarizes the licensees description of the basis for use of its alternative request in the following paragraph.

The 10 CFR 50, Appendix J, Type C LLRT intervals may be extended up to 75 months for valves. The NRC has endorsed NEI 94-01, Revision 3-A, as providing an acceptable level of quality and safety. Valves must pass two successful as-found leakage tests to qualify for a 75-month test frequency. A valve demonstrates acceptable performance when it exhibits leakage below the assigned administrative limits. Valves that do not meet the performance standard are tested every refueling interval, in accordance with 10 CFR Part 50, Appendix J, which is more frequent than the most limiting frequency requirement for supplemental position verification of up to two years. The valves in Table 1 have met the performance standard for extension to a 75-month period. A review of the Energy Harbor Nuclear Corporation maintenance and Code-required performance history at PNPP concluded that the valves listed in Table 1 have been reliable. The ASME OM Code, 2012 Edition, requirements for the valves listed in Table 1 have been met, including position indication verification and leakage testing.

This was determined by a review of recorded performance history for the valves in Table 1, which dates back to 2011. All valves were found to have performed satisfactorily. This finding was also supported by a search of condition reports dating back to 2011. There was only one condition report for impaired design, but the valve was later declared satisfactory after evaluation. Therefore, obtaining position verification and leakage testing at a test interval longer than the frequencies specified in ASME OM Code, 2012 Edition, and controlled by 10 CFR Part 50, Appendix J, Option B-Performance-Based Requirements, provides an acceptable level of quality and safety. For the valves listed in Table 1, performing the position verification over an interval consistent with 10 CFR Part 50, Appendix J, aligns with the frequency of an NRC-endorsed testing program. Therefore, the past performance of the valves in Table 1, coupled with the utilization of the robust, performance-based, program requirements from 10 CFR Part 50, Appendix J, Option B, justify that the proposed alternative provides an acceptable level of quality and safety.

3.2 NRC Staff Evaluation The licensee has proposed an alternative test in lieu of the requirements in ASME OM Code, Subsection ISTC, paragraph ISTC-3700, for the valves listed in Table 1 of this SE. Specifically, the licensee proposes to perform the supplemental position verification testing required by 10 CFR 50.55a(b)(3)(xi) in conjunction with the Type C tests (which measure containment isolation valve leakage rates) at a frequency in accordance with the 10 CFR Part 50, Appendix J, Option B, schedule. The applicable valves would initially be tested at the required interval schedule, which is currently every 2 years, as specified by ASME OM Code, Subsection ISTC, paragraph ISTC-3700. Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended to a maximum of 75 months. Any position indication testing failure would require the component to return to the initial interval of every 2 years until good performance can again be established.

To provide reasonable assurance that the testing performed in accordance with Alternative Request VR-12, Revision 0, will meet the requirements of 10 CFR 50.55a(b)(3)(xi), the licensee supplemented Alternative Request VR-12, Revision 0, by a letter dated April 28, 2022, to describe the verification of the valve position indication in both the closed and open directions.

For the closing valve direction, the licensee stated that the requirements will be met by verifying proper remote indicating lights in conjunction with measured leakage of 1,000 standard cubic centimeters per minute or less for pneumatically tested valves, and 0.5 gallons per minute or less for hydrostatically tested valves using local leak rate testing equipment. The licensee reported that these measurements will be obtained during implementation of test instructions to satisfy the requirements of ASME OM Code (2012 Edition), Subsection ISTC, paragraph ISTC-3700, as incorporated by reference in 10 CFR 50.55a.

For the opening valve direction, the licensee stated that the requirements will be met by verifying proper remote indicating lights in conjunction with a pressure drop when the valves are opened at test pressure. The licensee will perform this measurement immediately following the position verification testing in the closed position. The licensees test instructions will include acceptance criteria for flow in conjunction with pressure drop to verify accurate indication of obturator position using local leak rate testing equipment. The licensee will obtain these measurements during implementation of the test instructions to satisfy the requirements of ASME OM Code (2012 Edition), Subsection ISTC, paragraph ISTC-3700, as incorporated by reference in 10 CFR 50.55a.

Based on the information described above for the valves listed in Table 1 of this safety evaluation, the NRC staff finds that (1) previous IST testing including position verification testing for these valves indicates the valves acceptable historical performance; (2) no current concerns with the performance of these valves have been identified; and (3) periodic maintenance activities are not modified by this request. Therefore, the proposed Alternative Request VR-12, Revision 0, provides an acceptable level of quality and safety for the extension of the valve position indication testing interval for the valves listed in Table 1 of this safety evaluation for PNPP.

4.0 CONCLUSION

As set forth above, the NRC staff finds that proposed Alternative Request VR-12, Revision 0, for the valves listed in Table 1 of this safety evaluation will provide an acceptable level of quality and safety for the fourth 10-Year IST Program interval at PNPP, which began on May 18, 2019, and is scheduled to end on May 17, 2029. Accordingly, the NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(1) for Alternative Request VR-12, Revision 0. Therefore, the NRC authorizes the use of proposed Alternative Request VR-12, Revision 0, for the fourth 10-Year IST Program interval at PNPP.

All other ASME OM Code requirements, as incorporated by reference in 10 CFR 50.55a, for which relief or an alternative was not specifically requested, and granted or authorized (as appropriate), in the subject request remain applicable.

Principal Contributors: Thomas G. Scarbrough, NRR Date: July 12, 2022

ML22187A259

• via memo OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DEX/EMIB/BC* NRR/DORL/LPL3/BC SWall SRohrer SBailey NAME (KZeleznock for) NSalgado DATE 07/05/22 07/08/22 07/05/22 07/12/22