L-06-035, Supplemental Information - EPU Implementation Plan & Power Ascension Testing: License Amendment Request Nos. 302 and 173

Supplemental Information - EPU Implementation Plan & Power Ascension Testing: License Amendment Request Nos. 302 and 173

ML060750572
Person / Time
Site:	Beaver Valley
Issue date:	03/10/2006
From:	Lash J FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-06-035, TAC MC4645, TAC MC4646
Download: ML060750572 (14)

Text

FENOC FirstEnergy Nuclear Operating Company Jantes H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 March 10, 2006 L-06-035 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. I and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Supplemental Information - E]PU Implementation Plan & Power Ascension Testing: License Amendment Request Nos. 302 and 173 (Unit No. 1 TAC No. MC4645IUnit No. 2 TAC No. MC4646)

On October 4, 2004, FirstEnergy Nuclear Operating Company (FENOC) submitted License Amendment Request (LAR) Nos. 302 and 173 by letter L-04-125 (Reference 1).

This submittal requested an Extended Power Uprate (EPU) for Beaver Valley Power Station (BVPS) Unit Nos. I and 2.

Attachments 1 and 2 of this submittal provide supplemental information that pertains to the EPU LAR.

• Attachment 1 contains the updated EPU implementation plan & power ascension testing program projected for BVPS-I & BVPS-2.

• Attachment 2 contains updated information to correct core damage frequency (CDF) values provided previously in FENOC Letter No. L-06-018 (Reference 2).

The additional information provided by this transmittal has no impact on either the proposed Technical Specification changes or the no significant hazards consideration transmitted by Refierence 1.

The regulatory commitments contained in this submittal are listed in Attachment 3. Also provided in Attachment 3 are revisions to previous commitments relative to the schedule for completion of the modifications associated with the main feedwater valve internals and main steam / feedwater flow transmitters for BVPS-2. If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager -

FENOC Fleet Licensing, at (330) 315-7243.

-Aoa

Beaver Valley Power Station, Unit Nos. l and 2 Supplemental Information - EPU Implementation Plan & Power Ascension Testing:

License Amendment Request Nos. 302 and 173 L-06-035 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 10, 2006.

Sincerely, es H. Lash Attachments:

1. EPU Implementation Plan & Power Ascension Testing for BVPS-I & BVPS-2

2. BVPS-1 CDF Results: Revised Table 1

3. List of Revised Commitments

References:

1. FENOC Letter L-04-125, License Amendment Request Nos. 302 and 173, dated October 4, 2004.

2. FENOC Letter L-06-018, Supplemental Response in Support of License Amendment Request Nos. 302 and 173.

c: Mr. T. G. Colburn, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

Attachment 1 of L-06-035 EPU Implementation Plan & Power Ascension Testing for BVPS-1 & BVPS-2 The extended power uprate (EPU) implementation plan projected for BVPS-1 and BVPS-2 consists of a staged implementation of EPU to the fully uprated reactor power level of 2900 Megawatts thermal (MWt) from the current reactor power level of 2689 MWt. Following NRC review and approval of the EPU LARs and issuance of the EPU License Amendments, the implementation of safety-related equipment modifications and Technical Specification changes are required to support implementation of the EPU License Amendments.

The key plant modifications required to support the EPU License Amendments for BVPS-1 and BVPS-2 are scheduled to be implemented as follows:

Plant Modifications Required to Projected Schedule Implement EPU License Amendments BVPS-1 BVPS-2 BVPS-1 Steam Generator Replacement 1R17, Spring N/A 2006 Charging Pump rotating assemblies Completed 2R12, On-Line replacement Cycle 13 Overpower delta Temperature / Completed NA Overtemperature delta Temperature (OPDT/OTDT) Instrumentation change to incorporate lead-lag filters Instrumentation Setpoint and Scaling 1R17, Spring 2R12, Fall changes 2006 and On- 2006 Line - Cycle 18

• Modify Main Feedwater Control Valve 1RI 7, Spring Prior to power Internals (Valve Trim Replacements) 2006 (prior to increase >

power increase) 2770MWt*

(approximately 103%)

• Main Steam (MS) and Main Feedwater 1R1 7, Spring Prior to power (FW) Flow Transmitter Replacements 2006 (prior to increase >

power increase) 2770MWt*

(approximately 103%)

• NOTE: The main feedwater valve trims and main steam / feedwater flow transmitters for BV/PS-2 have been evaluated and sufficient margin exists in the existing trim size and transmitter ranges to support operation at a power increase of 2770MWt (approximately 103%). As a result, a revision to previous commitment dates identified in the EPU LAR, Attachment D of FENOC letter L-04-125 (Reference 1) is necessary relative to the due date for completion of the main feedwater valve trims and main steam / feedwater flow transmitters for BVPS-2 (previously identified as required to be completed "prior to power level increase").

Attachment 3 contains the revised commitment due dates for completion of these modifications for BVPS-2.

Based on the above projected implementation schedules, the BVPS-1 EPU License Amendment will be implemented on-line during Cycle 18 (following refueling outage 1R1 7) within 120 days of issuance of the amendment. The BVPS-2 EPU License

Attachment 1 of L-06-035 Page 2 of 10 Amendment will be implemented during the BVPS-2 refueling outage 2R12, prior to the first entry into Mode 4. BVPS-1 and BVFPS-2 will continue to operate at the current reactor power level of 2689 MWt until the balance of plant (BOP) equipment modifications that are needed to support operation at higher power levels are implemented, as identified in the EPU LAR (Reference 1).

The phased implementation approach to the fully uprated reactor power level (2900 Mwt) will occur in two (2) stages. The 1st stage will increase Rated Thermal Power (RTP) to 2770 Muvt, approximately 3%above the current RTP of 2689 MWt. The 1st stage power ascension will be implemented in one power ascension step of 3%. The 2nd stage will increase the core RPT to 2900 Mwt. (approximately an additional 5%

above the initial 3% power increase). This 2nd stage power ascension will be implemented in tNo steps of 2.5% each. Each stage will be implemented as the required modifications are completed which enable the units to produce the increased electrical output. The phased approach will provide a firm foundation for establishing the plant response at each power level incremental increase and establish operating experience prior to reaching the extended power level of 2900MWt.

The power ascension testing program was initially described in the EPU LAR submittal, L-04-025, Enclosure 2 Chapter 13 (Reference 1) and Attachment D of the Supplemental Response submittal L-05-026 (Reference 2). Additional information was also provided in responses to Request for Information (RAI) Questions N.7 and N.1 3 (FENOC submittal letter L-05-078 - Reference 3). The information relative to the EPU implementation plan and power ascension testing plan and plateaus identified in this submittal supersedes, in part, the information previously provided in the above referenced submittals.

The following summarizes the projected power ascension and testing approach for each unit.

BVPS- 1:

The BVPS-1 Containment Conversion (CC), Best Estimate LOCA (BELOCA), and the Replacement Steam Generator (RSG) License Amendments will be implemented during refueling outage I RI 7 at the current licensed Rated Thermal Power (RTP) level of 2689 MWt. The Extended Power Uprate (EPJ) power ascension will occur following I R17.

Figure 1 provides a profile of the projected power ascension and testing plateaus for BVPS-1.

The 1st stage will be implemented on-line during Cycle 18 (following 1R17) by increasing RTP to 2770 MWt.

The 2nd stage will be implemented in a subsequent operating cycle (following 1R18) to increase the RTP to the uprated reactor power level of 2900 MWt. This implementation will be completed in two steps of approximately 2.5% each.

The test plan will include provisions for recording and analyzing data at each power incremental increase to confirm that response is as expected and acceptance criteria are met. The power ascension testing program requires that plant data be recorded at approximately 2550 MWt (95% of 2689 MWt) and at 2689 MWt during power ascension following 1R17. This data will be used as a "baseline" to predict operating values at 2770 MWt. The baseline data will also take into consideration the changes as a result of

Attachment 1 of L-06-035 Page 3 of 10 the RSG. The 1st stage of power ascension will be conducted in a controlled manner, monitoring required parameters to expected ranges and acceptance criteria. Various parameters will be assigned levels of significance, to aid in determining the appropriate response if a parameter differs from expectations. The test plan will be approved and implemented prior to power ascension.

Similar actions will be taken during the 2nd stage of power ascension. Data recorded at the power level of 2770 MWt will be used to predict expected values during power ascension to 2900 MWt. Power will be increased to 2830 MWt and held while data is taken to assure that the unit is safe for power ascension to 2900 MWt. As was done for the 1st stage, the power ascension will be monitored at each step to confirm that the values are as predicted and meet acceptance criteria.

Table 1 shows the BVPS-1 tests performed at each power level increment based on the EPU LAR (Reference 1)Chapter 13 Test Abstracts.

BVPS- 2:

The BVPS-2 Containment Conversion (CC) and BELOCA License Amendments will be implemented during refueling outage 2R12. The EPU power ascension will begin following 2R12 and will also be implemented as a phased approach in two stages.

Figure 2 provides a profile of the projected power ascension and testing plateaus for BVPS-2.

Prior to the BVP',-2 shutdown for 2R1 2, data will be recorded at the current reactor power level of 2689 MWt. This data will be used as a "baseline" to predict operating values at 2770 MWt (3%increase). During power ascension from the refueling outage 2R12, plant data will be recorded at approximately 2550 MWt (95% of 2689 MWt) and then at 2689 MWt. This data will be used to predict values at 2770 MWt during subsequent power ascension. Power will be increased in a controlled manner, and required parameters will be monitored. As stated above for BVPS-1, parameters are assigned levels of significance to aid in determining the appropriate response if a parameter differs from expectations and does not meet acceptance criteria. Upon reaching 2770 MWt, parameters will be monitored to confirm that the expectations and acceptance criteria have been met.

During a subsequent refueling outage, a new high pressure (HP) turbine rotor, similar to that installed in BVPS-1, will be installed in BVPS-2 to allow increasing power above 2770 MWt. Following return to power after the subsequent refueling outage, data will be recorded at 2770 MWt. Power will be increased to 2830 MWt and held while data is taken to assure that the unit is safe for further power ascension to 2900 MWt. As was done for the 1st stage, the power ascension will be monitored at each step to confirm that the values are as predicted and meet acceptance criteria.

Table 2 shows the BVPS-2 tests performed at each power level increment based on the EPU LAR (Reference 1) Chapter 13 Test Abstracts.

of L-06-035 Page 4 of 10

References:

1. FENOC Letter L-04-125, License Amendment Request Nos. 302 and 173, dated October 4, 2004.

2. FENOC Letter L-05-026, Supplemental Information Supporting License Amendment Request Nos. 302 and 173.

3. FENOC Letter L-05-078, Responses to a Request for Additional Information in Support of License Amendment Request Nos. 302 and 173.

of L-06-035 Page 5 of 10 Figure 1 - Power Ascension Profile & Testing Plateaus (BVPS-1)

(NOTE - Timelines Not Drawn To Scale) 110 105 100 0~

a 95 C-i)a) 0 90 (D

I 85 80 0

1R17 :

Cycle 18 1R1.8 Cycle 19 Refueling Refueling Outage (18 Mor ith Operating Cycle) Outage (18 Month Operat! tIng Cycle)

Attachment I of L-06-035 Page 6 of 10 TABLE 1 Extended Power Uprate Test Plan (BVPS-1)

Test! Modification To P r Rated Thermal Power (RTP) Level Test Description Por 0 2689 2770 2830 2900 Start-Up Adjustment to the Reactor Test Abstract 13-2 X X X X Control System Full Power Demonstration Test Test Abstract 13-3 X X Alignment of Nuclear Instrumentation Test Abstract 13-4 X X X X System .

Alignment of Process Temperature Test Abstract 13-5 Startup X X X X Instruments Thermal Power Calorimetric Test Abstract 13-6 X X X X Measurements . . -

Incore / Excore Detector Calibration Test Abstract 13-7 X X X for Axial Offset Measurement .

Measure of Core Parameters During Test Abstract 13-8 X X X Steady State Conditions Pressurizer Level Control Test Abstract 13-9 Startup X X X X System Vibration Testing for Test Abstract 13-10 X X X X Extended Power Uprate Reactor Coolant System Flow Test Abstract 13-11 X X Measurement Primary Sampling System Test Test Abstract 13-12 X X Turbine Plant Sampling System Test Abstract 13-13 X X Performance Test Containment Penetration Cooling Test Abstract 13-14 X X X X System Test Automatic Steam Generator Water Test Abstract 13-15 Startup X X X X Level Control Test of L-06-035 Page 7 of 10 TABLE 1 Extended Power Uprate Test Plan (BVPS-1)

Test / Modification Test Description Prior to Rated Thermal Pwer (RTP) Level 2689 2770 2830 2900 Turbine Plant Component Cooling Test Abstract 13-16 X X X X est TPerformance Test TsAtrt1 7XXX Cooling Tower Performance Test Test Abstract 13-17 X X X X Main Transformer Performance Test Test Abstract 13-18 X X X X Plant Communications Test Test Abstract 13-19 X X Plant Radiation Survey and Verification of Shielding Effectiveness Test Abstract 13-20 Containment Air Recirculation System Test Abstract 13-21 X X X X T est__ _ _ _ _ __ _ _ _ _ ___ _ _ _ _

BVPS-1 High Pressure Turbine Rotor Test Abstract 13-23 Startup Completed X Replacement Charging Pump Rotating Assembly Test Abstract 13-24 EPU Complete Replacement LAR Imp______

Charging Pump Re-Throttling Test Abstract 13-25 EPU Complete LAR Imp during 1R1 7 ____

BVPS-1 Fifth Point Heater Drain Test Abstract 13-26 Startup X X X X Control Valves Trim Replacement BVPS-1 Feedwater Control Valves Test Abstract 13-27 Startup X X X X Trim Change Instrument & Control Set Point and Test Abstract 13-30 Startup X X X X Re-scaling Changes of L-06-035 Page 8 of 10 Figure 2 - Power Ascension Profile & Testing Plateaus (BVPS-2)

(NOTE - Timelines Not Drawn To Scale) 110 105 in 0 100 a,

M 95 i-I- 90 01 L 85 80 0

Oct2006

• April2008 2R2 - Cycle 13 2R13 '

Refueling Cycle 14 (or subsequent outage)

Refueling Outage (18 Month Operating Cycle) Outage (18 Month Operating Cycle) of L-06-035 Page 9 of 10 TABLE 2 Extended Power Uprate Test Plan (BVPS-2)

Test / Modification Test Description Prior to Rated Thermal Power (RTP) Level TsIoiiainD i 2689 _2770 2830 2900 Start-Up Adjustment to the Reactor Test Abstract 13-2 X X X X Control System _________

Full Power Demonstration Test Test Abstract 13-3 X X Alignment of Nuclear Instrumentation Test Abstract 13-4 X X X X System_____

Alignment of Process Temperature Test Abstract 13-5 Startup X X X X Instruments _____

Thermal Power Calorimetric Test Abstract 13-6 X X X X Measurements TesAbtrat_3_6_____

Incore / Excore Detector Calibration for Test Abstract 13-7 X X X Axial Offset Measurement Measure of Core Parameters During Test Abstract 13-8 X X X Pressurizer Level Control Test Abstract 13-9 Startup X X X X System Vibration Testing for Extended Test Abstract 13-10 X X X X Power Uprate Reactor Coolant System Flow Test Abstract 13-11 X X Measurement Primary Sampling System Test Test Abstract 13-12 X X Turbine Plant Sampling System Test Abstract 13-13 X X Performance Test Containment Penetration Cooling Test Abstract 13-14 X X X X S ystem _T est I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

of L-06-035 Page 10 of 10 TABLE 2 Extended Power Uprate Test Plan (BVPS-2)

Test / Modification Test Description Prior to Rated Thermal Power (RTP i Level Tet/_______et _s___ 2689 2770 2830 2900 Automatic Steam Generator Water Test Abstract 13-15 StartuD X X X X Level Control Test Turbine Plant Component Cooling Test Test Abstract 13-16 X X X X Cooling Tower Performance Test Test Abstract 13-17 X X X X BVPS-2 Cooling Tower Fill Test Abstract 13-17 Startup X Replacem ent _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Main Transformer Performance Test Test Abstract 13-18 X X X X BVPS-2 Main Electrical Transformer Test Abstract 13-18 Startup X Cooler Replacement T A 1 Plant Communications Test Test Abstract 13-19 X Plant Radiation Survey and Verification Test Abstract 13-20 X X of Shielding Effectiveness Containment Air Recirculation System Test Abstract 13-21 X X X X T est__ _ _ _ _ _ _ _ _ _

BVPS-2 High Pressure Turbine Rotor Test Abstract 13-23 Needed for increase to above X Replacement 2770 MWt_____

Charging Pump Rotating Assembly Test Abstract 13-24 LAR Imp Replacement Complete Charging Pump Re-Throttling Test Abstract 13-25 LAR Imp 2R12 BVPS-2 Fourth Point Heater Drain Test Abstract 13-28 Startup X X X X Control Valves Replacement BVPS-2 2ndary Component Cool. Test Abstract 13-29 Startup X X X X Water Orifice Plate Removal Instrument & Control Set Point and Re- Test Abstract 13-30 Startup X X scaling Changes

Attachmont 2 of L-06-035 BVPS-1 CDF Results: Revised Table 1 BVPS-1 core damage frequency (CDF) results were provided in Table 1 of FENOC submittal letter L-06-018 dated February 14, 2006. While reviewing the fire sequences at BVPS-2, it was noted that the changes in the Human Error Probability (HEP) for operator action OPROB2 (from the pre-EPU value of 2.49E-02 to the post-EPU value of 2.71 E-02) was dominating the risk at BVPS-2 by contributing 6.02E-08 to the total delta Fire CDF value of 6.40E-08. This operator action (OPROB2) is to perform a feed and b'eed cooling, given that the operators previously failed to restore main feedwater. When this operator action was compared to the BVPS-1 values, it was noted that the pre-EPU HEP for OPROB2 inadvertently used the post-EPU HEP value of 1.68E-02, instead of the intended value of 1.53E-02. This resulted in no change to the delta Fire CDF for BVPS-1 due to failures of OPROB2. To correct for this, the BVPS-1 pre-EPU Sensitivity PRA model was re-quantified with the OPROB2 HEP set to 1.53E-02.

In addition, the BVPS-1 pre-EPU operator action HEP for OPROS2 (manually actuating Si following a small break LOCA and loss of both trains of SSPS) inadvertently used the pre-EPU HEP value for OPROS1 (same action without a LOCA). This HEP was corrected from 5.86E-03 (the pre-EPU HEP for OPROS1) to 7.01 E-03 in the BVPS-1 pre-EPU Sensitivity PRA model, and re-quantified.

The adjustments due to the corrections to the pre-EPU operator actions (OPROB2 and OPROS2) HEP slightly reduced the overall pre-EPU total CDF reported in FENOC submittal letters L-05-192 and L-06-018 from 2.26E-05 to 2.25E-05, and also reduced the Fire CDF from 4.66E-06 to 4.62E-06. Therefore, the revised BVPS-1 delta Fire CDF is now 3.89E-08, which compares more favorably with the BVPS-2 results of 6.38E-08. The results of the BVPS-1 re-quantification are provided below in the revised Table 1,with changes from those values reported previously in FENOC letter L-06-018 shown in bold type.

BVPS-1 Results (Pre-EPU OPROB2 &OPROS2 HEP Corrected)

Revised Table 1: BVPS-1 CDF Results BVPS-1 Risk Pre-EPU Sensitivity Revised Post-EPU Change In Risk Measures Model2 Model 1 (EPU -Sensitivity)

Total CDF (/year) 2.25E-05 2.29E-05 3.36E-07 Internal CDF (/year) 6.25E-06 6.55E-06 2.97E-07 External CDF (/year) 1.63E-05 1.63E-05 3.95E-08 Fire CDF (/year) 4.62E-06 4.66E-06 3.89E-08 Total LERF (/year) 4.37E-07 4.95E-07 5.83E-08 Note 1: Includes Replacement Steam Generator Tube Rupture Initiating Event Frequency

Attachment 3 of L-06-035 List of Revised Commitments The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS) Unit Nos. 1 and 2. The list also includes revised due dates for BVPS Unit No. 2 commitments identified in this document. Any other actions discussed in the submittal represent intended or planned actions by FENOC.

They are described only as information and are not regulatory commitments. Please notify Mr.

Gregory A. Dunn, Manager, Fleet Licensing at 330-315-7243 of any questions regarding this document or associated regulatory commitments.

Commitment Due Date BVPS-1 & 2:

1. The Power Ascension Test Plan will include The Power Ascension Test Plan will be provisions for recording and analyzing data at approved and implemented prior to each power incremental increase (as noted in power ascension for each unit.

Figures 1 and 2) to confirm that response is as expected and acceptance criteria are met.

BVPS-2:

2. Modify the main feedwater *Prior to BVPS-2 power increase flow control valve intemals. above 2770 MWt (approximately 103%)

3. Replace the main steam *Prior to BVPS-2 power increase flow and main feedwater above 2770 MWt (approximately flow transmitters. 103%)

• Note: These commitments were previously identified in Attachment D of FENOC Letter L-04-125, License Amendment Request Nos. 302 and 173, dated October 4, 2004.

The changes identified in this document affect only the due dates for completion of the modifications to the main feedwater valve internals and main steam / feedwater flow transmitters for BVPS-1 and BVPS-2 (previously identified as required to be completed "prior to power level increase")