ML20133J622

Forwards RAI to Complete Review of Licensee 960628 Submittal Re Request for Relief from ASME Code,Section XI Requirements for Plant,Unit 1

ML20133J622
Person / Time
Site:	Perry
Issue date:	01/15/1997
From:	Hopkins J NRC (Affiliation Not Assigned)
To:	Myers L ENTERGY OPERATIONS, INC.
References
TAC-M95898, NUDOCS 9701210079
Download: ML20133J622 (6)

Text

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. . JCaldwell, RIII GMarcus l Mr. Lew W. Myers GGrant, RIII Vice President Nuclear - Perry Centerior Service Company P. 0.' Box 97, A200 Perry, OH 44081

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - INSERVICE INSPECTION PROGRAM, PERRY NUCLEAR POWER PLANT, UNIT NO. 1 (TAC NO. M95898) l

Dear Mr. Myers:

i

By letter dated June 28, 1996,-you submitted requests for relief from the American Society of Mechanical Engineers Code, Section XI requirements for the Perry Nuclear Power Plant, Unit No.1. The NRC staff has performed an initial review of your stbmittal, and needs additional information to complete its review.

Please respond to the enclosed request for additional information-(RAI) within 30 days of receiving this letter. In addition, to expedite the review process, please send a copy of your response to our contractor, Idaho National Engineering Laboratory, at the following address:

Michael T. Anderson INEL Research Center 2151 North Boulevard l PO Box 1625 Idaho Falls, Idaho 83415-2209 ,

Sincerely, Original signed by:

Jon B. Hopkins, Sr. Project Manager ,

, Project Directorate III-3 l Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Doc'ket No. 50-440 ,

Enclosure:

RAI r cc w/sncl: See next page j hl c -

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l DOCUMENT NAME: G:\ PERRY \lSI.RAI ,

.g c To receive a copy o' f this document, Indicate in the box: l "C" = Copy without enclosures""E" = Copy with enclosures "N" = No copy I- 0FFICE- PD33-LA l~ PD33-PM lE l NAME EBarnhill F/V - JHopkins Ak

, DATE 01/ C/97 0FFICIAL RECORD COPY 01//f/97 //l

( hh 170b66 9701210079 970115 PDR ADOCK 05000440 P PDit

January 15, 1997 Distribution w/ enc 1:

, Docket File OGC PUBLIC GBagchi PD3-3 Reading JRoe ACRS EAdensam (EGAl)

JCaldwell, RIII GMarcus Mr. Lew W. Myers GGrant, RIII Vice President Nuclear - Perry Centerior Service Company P. O. Box 97, A200 Perry, OH 44081 i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - INSERVICE INSPECTION PROGRAM, PERRY NUCLEAR POWER PLANT, UNIT N0. 1 (TAC NO. M95898) 4

Dear Mr. Myers:

1 By letter dated June 28, 1996, you submitted requests for relief from the American Society of Mechanical Engineers Code, Section XI requirements for the l

Perry Nuclear Power Plant, Unit No. 1. The NRC staff has performed an initial l

! review of your submittal, and needs additional information to complete its j l review.

i l Please respond to the enclosed request for additional information (RAI) within 30 days of receiving this letter. In addition, to expedite the review I J process, please send a copy of your response to our contractor, Idaho National Engineering Laboratory, at the following address:

Michael T. Anderson INEL Research Center

, 2151 North Boulevard

PO Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, Original signed by:

4 Jon B. Hopkins, Sr. Project Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

RAI cc w/ encl: See next page DOCUMENT NAME: G:\ PERRY \ISI.RAI To receive a copy of this document, indcote in the box:

• C" = Copy without enclosures "E" = Copy wrth enclosures "N" = No copy l0FFICE PD33-LA l PD33-PM lE lNAME EBarnhill E/V JHopkins N, lDATE 01/S/97 01//f/97 //l 0FFICIAL RECORD COPY

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.pwauq p  % UNITED STATES i , g j f

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-0001

, 4 4 . . . . . ,o January 15, 1997 Mr. Lew W. Myers Vice President Nuclear - Perry Centerior Service Company P. O. Box 97, A200 i

Perry, OH 44081

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - INSERVICE INSPECTION PROGRAM,

PERF.Y NUCLEAR POWER PLANT, UNIT NO. 1 (TAC N0. M95898)

Dear Mr. Myers:

By letter dated June 28, 1996, you submitted requests for relief from the American Society of Mechanical Engineers Code, Section XI requirements for the l Perry Nuclear Power Plant, Unit No. 1. The NRC staff has performed an initial review of your submittal, and needs additional information to complete its review.

Please respond to the enclosed request for additional information (RAI) within 30 days of receiving this letter. In addition, to expedite the review process, please send a copy of your response to our contractor, Idaho National Engineering Laboratory, at the following address:

Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, M hi f

[JonB.Hopkins,Sr.ProjectManager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

RAI cc w/ enc 1: See next page

A----

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L. Myers Perry Nuclear Power Plant Centerior Service Company Unit Nos. I and 2 cc:

Mr. James W. Harris, Director Jay E. Silberg, Esq. Division of Power Generation Shaw, Pittman, Potts & Trowbridge Ohio Dept. of Industrial Relations 2300 N Street, N. W. P.O. Box 825

! Washington, D. C. 20037 Columbus, Ohio 43216 1

, Ms. Mary E. O'Reilly Mayor, Village of Perry l Centerior Energy Corporation 4203 Harper Street 300 Madison Avenue Perry, Ohio 44081 Toledo, Ohio 43652 Mayor, Village of North Perry Resident Inspector's Office North Perry Village Hall U. S. Nuclear Regulatory Commission 4778 Lockwood Road Parmly at Center Road North Perry Village, Ohio 44081 Perry, Ohio 44081 Attorney General Regional Administrator, Region III Department of Attorney General U. S. Nuclear Regulatory Commission 30 East Broad Street 801 Warrenville Road Columbus, Ohio 43216 Lisle, Illinois 60532-4531 Radiological Health Program Lake County Prosecutor Ohio Department of Health Lake County Administration Bldg. P.O. Box 118 105 Main Street Columbus, Ohio 43266-0118 Painesville, Ohio 44077 Ohio Environmental Protection Ms. Sue Hiatt Agency OCRE Interim Representative DERR--Compliance Unit 8275 Munson ATTN: Mr. Zack A. Clayton Mentor, Ohio 44060 P.O. Box 1049 Columbus, Ohio 43266-0149 Terry J. Lodge, Esq.

618 N. Michigan Street, Suite 105 Chairman Toledo, Ohio 43624 Perry Township Board of Trustees 3750 Center Rd., Box 65 Ashtabula County Prosecutor Perry, Ohio 44081 25 West Jefferson Street Jefferson, Ohio 44047 State of Ohio Public Utilities Commission Mr. James D. Kloosterman East Broad Street Regulatory Affairs Manager Columbus, Ohio 43266-0573 Cleveland Electric Illuminating Co.

Perry Nuclear Power Plant Mr. Richard D. Brandt, Plant Manager P. O. Box 97, A210 Cleveland Electric Illuminating Co.

Perry, Ohio 44081 Perry Nuclear Power Plant 4 P.O. Box 97, SB306 l Mr. James R. Williams Perry, Ohio 44081 l Chief of Staff Ohio Emergency Management Agency l

l 2855 West Dublin Granville Road Columbus, Ohio 43235-2206

1 B

REQUEST FOR ADDITIONAL INFORMATION PERRY NUCLEAR POWER PLANT

INSERVICE INSPECTION PROGRAM j 1. Scoce/ Status of Review I

The Nuclear Regulatory Commission (NRC) is responsible for the review and I

disposition of licensee requests relating to inservice inspection requirements contained in the Code of Federal Regulations (CFR) 10 CFR 50.55a, and Section XI of the American Society of Mechanical Engineers' (ASME) Boiler and Pressure Vessel Code. When submitting such l j

requests, licensees are required to provide both a regulatory basis (by citing the appropriate section of 10 CFR 50.55a) and a technical

)

discussion the request.supporting the request. This information is used in evaluating l

t The staff has reviewed the available information in the Perry Nuclear

" Power Plant, Unit 1, first 10-year interval inservice inspection (ISI) proposed alternatives to, and requests for relief from, ASME Code Section XI requirements.

j 2. Additional Information Reautred

' The staff has concluded that additional information and/or clarification is required to complete the evaluation. The licensee must state the specific paragraph of the Regulations (10 CFR 50.55a) under which the 2

request is submitted and provide supporting justification as discussed j below.

The Regulations provide that a licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(1) or 3

10 CFR 50.55a(a)(3)(ii). Under 10 CFR 50.55a(a)(3)(1), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in r terms of quality and safety. Under to 10 CFR 50.55a(a)(3)(ii), the il licensee must show that compliance with the original requirement results

' in a hardship or unusual difficulty without a compensating increase in the

' level of quality and safety. Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examinations, and

, development of sophisticated tooling that would result in only minimal increases in examination coverage.

A licensee may also request relief from ASME requirements. In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in 650.4,

! information to support that determination. When a licensee determines that an inservice inspection requirement is impractical, e.g., the system t

j Enclosure i

4

. would have to be redesigned or a component would have to be replaced to enable inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, l impose an alternative examination requirement.

The following information and/or clarification is required to complete the review of the ISI Program Plan:

A. Requests for Relief IR-028 and IR-029 were submitted without reference to an applicable section of the Code of Federal Regulations as discussed above. Without this reference, the requests cannot be evaluated. Provide the appropriate reference to the Code of Federal Regulations along with the documentation necessary to support the regulatory basis.

B. In Request for Relief IR-029, access to the subject welds is obstructed by jet impingement shields. However, the burden associated with removing the shields has not been adequately described. Are the jet impingement shields bolted or welded? Provide a more detailed description of the jet impingement shields and the burden associated with removing the shields.

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