ML20149G738

Requests Addl Info Indentified in Encl to Complete Review of 10-yr Interval Inservice Insp Program.Info Requested within 60 Days of Ltr Receipt

ML20149G738
Person / Time
Site:	Perry
Issue date:	02/09/1988
From:	Colburn T Office of Nuclear Reactor Regulation
To:	Kaplin A CLEVELAND ELECTRIC ILLUMINATING CO.
References
TAC-61443, NUDOCS 8802180387
Download: ML20149G738 (8)

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February 9, 1988 o- .

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l Docket Nos. 50-440 DISTR;;B J";;0N:s

,Docaso Fues M ACRS(10)

NRC-& Local PDRs PDIII-3 Gray PDIII-3 r/f FLitton XPerkins CYCheng Mr. Alvin Kaplin, Vice President GHolahan WHazelton Nuclear Group PKreutzer The Cleveland Electric Illuminating TColburn Company OGC-WF1 10 Center Road EJordan Perry, Ohio 44081 JPartlow

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1, FIRST 10-YEAR INTERVAL INSERVICE i INSPECTION PROGRAM - REQUEST FOR ADDITIONAL INFORMATION (TAC # 61443) l l

We have received your March 31, 1987 letter containing the first 10-year i interval Inservice Inspection Program for the Perry Nuclear Power Plant, Unit No. 1. We have determined that we will need the additional information identified 1 in the enclosure to this letter in order for us to complete our review. Please provide your response to this request within 60 days of receipt of this letter.

This request for information affects fewer than 10 respondents, therefore, OMB l clearance is not required under Pub. L.96-511.

Sincerely, h/

Timothy G. Colburn, Project Manager l

Project Directorate III-3 Division of Reactor Projects

Enclosure:

As stated ,

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Office: L P III-3 St.-

PM/PDIII-3 fl PD/PDIII- -

Surname: P4 ter TColburn/tg KPerkins  !

Date: ;02/9 88 t

02/y/88 02/ 9 /88  ;

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Mr. Alvin Kaplan Perry Nuclear Power Plant The Cleveland Electric Unit 1 Illuminating Company cc:

Shaw, Pittman, Potts & Trowbridge Mr. James W. Harris, Director 2300 N Street, N.W. Division of Power Generation Washington, D.C. 20037 Ohio Department of Industrial Relations Donald H. Hauser, Esq. P.O. Box 825 The Cleveland Electric Columbus, Ohio 43216 Illuminating Company P.O. Box 5000 The Honorable Lawrence Logan Cleveland, Ohio 44101 Mayor, Village of Perry 4203 Harper Street Resident Inspector's Office Perry, Ohio 44081 U.S. Nuclear Regulatory Comission Pannly at Center Road The Honorable Robert V. Orosz Perry, Ohio 44081 Major, Village of North Perry North Perry Village Hall Regional Administrator, Region III 4778 Lockwood Road U.S. Nuclear Regulatory Comission North Perry Village, Ohio 44081 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attorney General Department of Attorney General Frank P. Weiss, Esq. 30 East Broad Street Assistant Prosecuting Attorney Columbus, Ohio 43216 105 Main Street Lake County Administration Center Radiological Health Program Painesville, Ohio 44077 Ohio Department of Health .

1224 Kinnear Road Ms. Sue Hiatt - Columbus, Ohio 43212 l OCRE Interim Representative j 8275 Hunson Ohio Environmental Protection i Mentor, Ohio 44060 Agency i 361 East Broad Street Terry J. Lodge, Esq. Columbus, Ohio 43266-0558 618 N. Michigan Street Suite 105 Mr. James R. Secor, Chainnan Toledo, Ohio 43624 Perry Township Board of Trustees Box 65 John G. Cardinal Esq. 4171 Main Street Prosecuting Attorney Perry, Ohio 44081 '

Ashtabula County Courthouse Jefferson, Ohio 44047 State of Ohio Public Utilities Comission Eileen M. Buzzelli 180 East Broad Street The Cleveland Electric Columbus, Ohio 43266-0573 Illuminating Company P. O. Box 97 E-210 Mr. Murray R. Edelman Perry, Ohio 44081 Centerior Energy 6200 Oaktree Bisd.

Independence. Ohio 44131

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l g ENCLOSURE 6

Reouest for Additional Information - First 10-Year Interval Inservice Insoection procram Plan

1. Scoce/ Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during the initial 120 month inspection interval shall comply with the requirements in the latest edition and addenda of the Code incorp' orated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in l subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein. The licensee, The Cleveland Electric Illuminating Company, has prepared the Inservice Inspection (ISI)

Program Plan to meet the requirements of the 1983 Edition, Sumer 1983 Addenda (83S83),of the ACME Code Section XI except that the extent of examination for Code Class 2 piping welds has been determined by ASME Code Case N-408, "Alternative Rules for Examination of Class 2 Piping,Section XI, Division 1."

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As required by 10 CFR 50.55a(g)(5), if the licensee determines that

• certain Code examination requirements are impractical and relief is requgsted,thelicenseeshallsubmitinformationtotheNuclear Regulatory Commission (NRC) to support that determination.

The staff has reviewed the available information in the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan, Revision 0, submitted March 31, 1987,

2. Additional Information Recuired Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program Plan:

A. Provide the staff with the Boundary Diagrams which define the ASME Code Class 1, Class 2, and Class 3 boundaries for the systems in the Perry Nuclear Power Plant, Unit 1, First 10-Year Interval ISI Program Plan.

B. It is stated in the ISI Program Plan that the Class 2 pump casing welds will be examined only when the pump is disassembled for repair or service. ine licensee is reninded that relief is required orior to the end of the first 10-year inspection interval if the pump casing welds do not receive the Code-required examination.

C. The staff notes that there are wcids scheduled for examination in the ISI Program Plan for which the licensee had previously requested relief during preservice inspection (PSI), but has not requested relief for ISI. Instead, the PSI relief requests are referenced in the ISI Program Plan for the first 10-year interval. Because requests for relief are not automatically granted for subsequent inspection intervals, the licensee must make a complete submittal of the requests for relief for each 10-year inspection interval to enable the staff to review the requests for relief against the updated Code requirements. If relief requests are required for the 2

t first 10-year inspection interval, the licensee should submit thea g

for staff review. When preparing requests for relief, the staff j s,uggests that the licensee follow the attached Appendix A, "inservice Inspection: Guidance for Preparing Requests for Relief ,

from Certain Code Requirements Pursuant to 10 CFR 50.55a(g)(5)."

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APPENDIX A l INSERVICE INSPECTION: GUIDANCE FOR PREPARING l REQUESTS FOR REllEF FROM CERTAIN CODE REQUIREMENTS  !

4 PURSUANTTO10CFR50.55a(g)(5)

A. Descriotion of Reauests for Relief The guidance in this enclosure is intended to illustrate the type and extent of information that is necessary for "request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code. The inservice inspection prograr,should identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of design, geometry, radiation considerations or materials of construction i of the components. The request for relief should provide the information requested in the following section of this appendix for the inspections and pressure tests identified above.

B. Reauest for Relief From Certain Insoection and Testina Reautrements Many requests for relief from testing requirements submitted by licensees have not been supported by adequate descriptive and detailed technical information. This detailed information is necessary to:

(1) document the impracticality of the ASME Code requirements within the limitations of design, geometry and materials of construction of l components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety. l A relief request submitted with a justification such as "impractical",

' inaccessible', or any other categorical basis, require additional information to permit an evaluation of that relief request. The objective of the guidance provided in this section is to illustrate the extent of the information that is required to make a proper evaluation l and to adequately document the basis for granting relief in the Safety Evaluation . Subsequent requests for additional infomation and delays in completing the review can be considerably reduced if this information is provided initially in the licensee's submittal. ,

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For each relief request submitted, the following information should be included:

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State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination.)

2. State the time period for which the requested relief is needed.

3. An itemized list of the specific component (s) and the examination requirement for which relief is requested.

4. The number nf items associated with the requested relief.

5. The ASME Code Class, Examination Category, and Item Number (s).

6. An identification of the specific ASME Code requirement that has been determined to be impractical.

7. The information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting relief. If the Code-required examination cannot be performed because of a limitation or obstruction, describe or provide drawings showing the specific limitation or obstru. tion, and provide an estimate of the percentage of the Code-required examir.ation that can be completed on the individual components requiring relief.

8. An identification of the alternative examinations that are proposed:

(a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements of Section XI.

9. State when the proposed alternative examinations will be implemented and performed.

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10. A description and justification of any changes expected in the

' overall level of plant safety by performing the proposed alternative ,

If gxamination in lieu of the examination required by Section XI.

it is not possible to perform alternate examinations, discuss the .,

impact on the overall level of plant quality and safety. ,

Technical justification or data must be submitted to support the relief request. Opinions without substantiation that a change will not affect the quality level are unsatisfactory. If the relief is requested for inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request. A relief request is not required for tests prescribed in Section XI that do not apply to your facility. A statement of "N/A" (not applicable) or "none" will suffice.

C. Reouest for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examinations prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination must be performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.

Some of the radiation considerations will only be known at the time of the test. However, from experience at operating facilities, the licensee generally is aware of those areas where relief will be necessary and should submit as a minimum, the following information with the request for relief:

1. The total estimated man-res exposure involved in the examination.

2. The radiation levels at the test area.

3. Flushing or shielding capabilities which might reduce radiation levels.

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