ML21123A289

Issuance of Relief Request Vr 7, Revision 0, Associated with the Fourth 10-Year Inservice Testing Interval

ML21123A289
Person / Time
Site:	Perry
Issue date:	05/04/2021
From:	Robert Kuntz, Nancy Salgado Plant Licensing Branch III
To:	Penfield R Energy Harbor Nuclear Corp
Wall S
References
EPID L-2021-LLR-0009
Download: ML21123A289 (8)

Text

May 4, 2021 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 REQUEST VR-7, REVISION 0, ASSOCIATED WITH THE FOURTH 10-YEAR INSERVICE TESTING INTERVAL (EPID L-2021-LLR-0009 [COVID-19])

Dear Mr. Penfield:

By letter dated January 29, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21031A002), as supplemented by a , L-2021-LLR-0009, L-2021-LLR-0010, and L-2021-LLR-0011)|letter dated February 22, 2021]] (ADAMS Accession No. ML21053A010), Energy Harbor Nuclear Corp. (the licensee) submitted alternative request (AR) 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 alternative in request VR-7, Revision 0, on the basis that complying with the requirements of the ASME OM Code would result in hardship without a compensating increase in the level of quality and safety.

The NRC staff concludes that request VR-7, Revision 0, will provide reasonable assurance that the check valves at PNPP, listed in the licensees request, are operationally ready to perform their safety functions until the spring 2023 refueling outage. The NRC staff finds that complying with the requirements of the ASME OM Code would result in hardship without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC authorizes the use of request VR-7, Revision 0, at PNPP until the next scheduled refueling outage in spring 2023.

The enclosed safety evaluation documents the technical basis for the NRCs verbal authorization of VR-7, Revision 0, on March 3, 2021 (ADAMS Accession No. ML21063A196).

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 Project Manager, Scott Wall, at 301-415-2855 or e-mail at Scott.Wall@nrc.gov.

Sincerely, Digitally signed by Robert F. Robert F. Kuntz Date: 2021.05.04 Kuntz 10:59:24 -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 RELIEF REQUEST VR-7, 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 29, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21031A002), as supplemented by a , L-2021-LLR-0009, L-2021-LLR-0010, and L-2021-LLR-0011)|letter dated February 22, 2021]] (ADAMS Accession No. ML21053A010), Energy Harbor Nuclear Corp. (EHNC, the licensee) submitted alternative request (AR) No. VR-7, Revision 0, to the U.S. Nuclear Regulatory Commission (NRC) for the use of alternative to specific requirements in the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (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 proposed a one-time extension of the testing interval for four specific check valves from the spring 2021 refueling outage (RFO) to the spring 2023 RFO on the basis that complying with the requirements of the ASME OM Code would result in hardship without a compensating increase in the level of quality and safety.

The NRC verbally authorized request VR-7, Revision 0, on March 3, 2021 (ADAMS Accession No. ML21063A196).

2.0 REGULATORY EVALUATION

The NRC regulations in 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, 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.

Enclosure

Regulation 10 CFR 50.55a(z) states, in part, that alternatives to the requirements of 10 CFR 50.55a(f) may be used, when authorized by the NRC, if the licensee demonstrates:

(1) the proposed alternatives would provide 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

3.1 Applicable Code Edition and Addenda The licensees OM Code of Record is the 2012 of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, for the fourth 10-year IST program interval at PNPP, which started on May 18, 2019, and is scheduled to end on May 17, 2029.

3.2 Proposed Alternative VR-7, Revision 0 The IST requirements of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a related to this alternative request, are as follows:

ASME OM Code, Subsection ISTC, Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants, paragraph ISTC-3510, Exercising Test Frequency, states, in part, that:

Active Category A, Category B, and Category C check valves shall be exercised nominally every three months, except as provided by paragraphs ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222.

ASME OM Code, Subsection ISTC-3522, Category C Check Valves, states, in part, that:

If exercising is not practicable during operation at power and cold shutdowns, it shall be performed during refueling outages.

ASME Code Components Affected In its submittal, the licensee requests a one-time extension of the testing interval for the following four check valves at PNPP:

Table 1 Component ID Component Description Code Valve Class Category Feedwater Header A Outboard 1B21-F032A 1 C Isolation Check Valve Feedwater Header B Outboard 1B21-F032B 1 C Isolation Check Valve Feedwater Header A Containment 1N27-F559A 1 C Check Valve

Feedwater Header B Containment 1N27-F559B 1 C Check Valve 3.3 Reason for Request For VR-7, Revision 0, the licensee requested an alternative to allow a one-time extension of the testing interval for the valves listed in Table 1 of this safety evaluation (SE) at PNPP, during the spring of 2021 RFO. The licensee stated that it will resume the normal outage examination frequency at the next opportunity, currently expected to be the next RFO in spring 2023.

On March 13, 2020, the President of the United States declared a national emergency due to the spread and infectious nature of the Coronavirus-2019 (COVID-19) virus and resulting pandemic. To prevent the spread of COVID-19 and to protect the health and safety of plant personnel while maintaining responsibilities to support critical infrastructure, the licensee intends to reduce the amount of personnel on site, which will pose a hardship for completing the currently planned spring 2021 RFO work scope. With the current work scope and potential loss of personnel, the licensee may not be able to complete the RFO in a timely manner, which could affect critical infrastructure that is needed during this time. The licensee asserted that the testing of the specified check valves at PNPP, during the spring 2021 RFO would result in a hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(z)(2).

3.4 Proposed Alternative The licensee proposed a one-time extension of the exercise testing interval for the check valves listed in its request to the next RFO, scheduled for the spring of 2023. In particular, the licensee proposed to extend the check valve exercise testing interval required by ASME OM Code, Subsection ISTC, paragraphs ISTC-3510 and ISTC-3522(c), until the next RFO, scheduled for the spring of 2023.

The licensee stated that these check valves have a leak rate acceptance criterion of 200 gallons per minute (gpm) when they are tested at 1.1 Pa, where Pa is the limit for the peak containment pressure during a loss of coolant accident. The leakage tests performed on all four of these check valves from 2003 to the present have met the acceptance criterion. The licensee considered that this successful test history supported an extension of the exercise test interval for these check valves.

The licensee asserted that based on the check valves current acceptable performance, there is reasonable assurance that each check valve will be operationally ready to perform its safety function for the duration of this request.

3.5 NRC Staff Evaluation As incorporated by reference in 10 CFR 50.55a, ASME OM Code (2012 Edition),

Subsection ISTC, paragraphs ISTC-3510 and ISTC-3522(c), specify requirements for the exercising of check valves, including the testing intervals. In lieu of performing the check valve exercise testing required by the ASME OM Code during the spring 2021 RFO, the licensee requested a one-time extension of the testing interval for the specified check valves at PNPP to

the next RFO currently scheduled for spring of 2023. In its request, the licensee indicated that these four check valves have met the leak rate acceptance criterion for leakage tests performed from 2003 to the present.

In its , L-2021-LLR-0009, L-2021-LLR-0010, and L-2021-LLR-0011)|letter dated February 22, 2021]], the licensee provided a response to a request for additional information from the NRC staff regarding alternative request VR-7. In its response, the licensee indicated the results of the recent leak rate tests conducted to satisfy the exercise close tests for the four check valves. The licensee corrected a reference in its original submittal to the applicable subsection of the ASME OM Code for the subject check valves. The licensee clarified that the four check valves are ASME OM Code Category alternate current valves based on their self-actuating operation and seat leakage limitations.

The NRC staff reviewed the licensees characterization of the hardship posed by the occupational health and safety concerns associated with the pandemic-related issues pertaining to COVID-19. The licensee reported that to prevent the spread of COVID-19 and protect the health and safety of plant personnel, it intended to reduce the amount of personnel on-site during the spring 2021 outage activities. The check valve exercise testing requires specialized external resources such as qualified leak rate contractors to perform the tests and carpenters to erect scaffolding for access to the valves. These external personnel resources could introduce an additional potential to spread the virus, as their medical history could be unknown and exposure to the COVID-19 virus is possible during travel. The NRC staff considers that requiring the check valves listed in the licensees submittal to be exercised during the spring 2021 RFO with limited personnel resources represents a hardship or unusual difficulty without a compensating increase in the level of quality and safety Based on the information described above for the specific check valves at PNPP identified in the licensees submittal, the NRC staff finds that: (1) previous testing of these check valves indicates their acceptable historical performance; (2) no current concerns with the performance of the performance of these check valves have been identified; (3) periodic maintenance activities are not modified by this request; and (4) a hardship exists for the performance of team-oriented exercise testing of these check valves at this time that would be contrary to the health and safety of plant personnel.

Therefore, the NRC staff determined that the licensees proposed alternative for a one-time extension of the exercise testing interval for the four specified check valves at PNPP is acceptable in accordance with 10 CFR 50.55a(z)(2). The proposed alternative will provide reasonable assurance that the check valves listed in the licensees request will be operationally ready to perform their safety functions until the next RFO, scheduled for the spring of 2023.

4.0 CONCLUSION

As set forth above, the NRC staff finds that the proposed alternative described in VR-7, Revision 0, will provide reasonable assurance that the check valves at PNPP, listed in the licensees request are operationally ready to perform their safety functions until the spring 2023 RFO. The NRC staff finds that complying with certain requirements of the ASME OM Code would result in hardship without a compensating increase in the level of quality and safety.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC authorizes the use of proposed alternative VR-7, Revision 0, at PNPP, until the next scheduled RFO in the spring of 2023.

All other ASME Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable. If the licensee identifies a performance issue with any of these valves, the licensee will be expected to take action to implement the requirements of its technical specifications. This authorization will remain in effect until restart from the next RFO for PNPP, scheduled for the spring of 2023. The licensees testing plans for these check valves may be adjusted as appropriate by any subsequent NRC-authorized alternative requests.

Principal Contributor: N. Hansing T. Scarbrough Date: May 4, 2021

ML21123A289 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DEX/EMIB/BC NRR/DORL/LPL3/BC NAME SWall SRohrer ABuford NSalgado (RKuntz for)

DATE 05/04/2021 05/04/2021 04/30/2021 05/04/2021