L-07-066, Response to Request for Additional Information Regarding May 11, 2007 Proposed Alternatives and Relief Requests

Response to Request for Additional Information Regarding May 11, 2007 Proposed Alternatives and Relief Requests

ML073340079
Person / Time
Site:	Beaver Valley
Issue date:	09/24/2007
From:	Sena P FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-07-066, L-07-125, TAC MD5595, TAC MD5600, TAC MD5602, TAC MD5603
Download: ML073340079 (10)

Text

FE NC FirstEnergy Nuclear Operating Company Peter P. Sena III 724-682-5234 Site Vice President Fax.- 724-643-8069 September 24, 2007 L-07-125 U. S., Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Vil1ey Power Station, Unit No. 2 Docket No. 50-412, License No. NPF-73 Response to Request for Additional Information Regarding May 11, 2007 Proposed Alternatives and Relief Requests (TAC Nos. MD5595, MD5600, MD5602, and MD5603)

By letter dated May 11, 2007 (Letter Number L-07-066), FirstEnergy Nuclear Operating Company (FENOC) submitted nine 10 CFR 50.55a requests associated with pump testing requirements, and one 10 CFR 50.55a request associated with valve test requirements. In order to complete its review of proposed alternatives and relief requests, the NRC staff requested additional information by letter dated August 22, 2007. The attachment to this letter includes FENOC's response to the NRC request.

Based upon further evaluation it has been determined that proposed alternative PRR1, submitted with the May 11, 2007 letter, is not required. Accordingly, FENOC hereby withdraws the proposed alternative identified as Pump Relief Request 1 (PRR1).

• Additionally, FENOC has determined that the proposed alternative in Relief Request PRR9 should be modified. FENOC hereby modifies Relief Request PRR9 by withdrawing the request for relief under 10 CFR 50.55a(a)(3)(ii), and requesting relief instead under 10 CFR 50.55a(a)(3)(i). The modified Relief Request PRR9 is provided as part of the attached response to request for additional information number 6.

/1.47

Beaver Valley Power Station, Unit No. 2 Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests

.L-07-125 Page 2 There are no regulatory commitments contained in this letter. If there are any questions, or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -

FENOC Fleet Licensing, at (330) 761-6071.

Sincerely, Peter P. Sena III

Attachment:

Response to August 22, 2007 Request for Additional Information c:

Ms. N. S. Morgan, NRR Project Manager Mr. D. L. Werkheiser, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. J. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

Attachment to Letter L-07-125 Beaver Valley Power Station, Unit No. 2 Response to August 22, 2007 Request for Additional ]Information By letter dated May 11, 2007, Agency-wide Documents Access and Management System (ADAMS) accession number ML071370347, FirstEnergy Nuclear Operating Company (FENOC, licensee) requested approval of ten proposed alternatives and relief requests associated with the inservice testing (IST) program third 10-year interval update for the Beaver Valley Power Station, Unit No. 2 (BVPS-2).

The Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has the following requests for information (shown in bold type). Each request for information is followed by the FENOCresponse.

Relief Request PRR1:

1. The licensee stated, "Lieu of double frequency test requirements specified in ISTB-6200(a) an evaluation and analysis shall be performed per the guidelines provided in ISTJB-6200(c)." ISTB-6200(c) specifically states, "In cases where the pump's test parameters are within either the alert or required action ranges....., a new set of reference values may be established." Therefore, the use of ISTB-6200(c) is applicable to both alert and required action ranges. Please clarify the need for Relief Request PRR1.

RESPONSE: FENOC has determined that Relief Request PRR1 is not needed since ISTB-6200(c) from the 2001 Edition through 2003 Addenda of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code allows an analysis to be performed. Therefore, FENOC hereby withdraws Relief Request PRR1.

Relief Request PRR6:

2. NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," Revision 1, Section 5.5.2, "Use of Tank Level to Calculate Flow Rate for Positive Displacement Pumps" is the basis for the proposed alternative in the relief request. However, the relief request does not indicate if the diesel fuel oil transfer pumps are positive displacement pumps. Are the diesel fuel oil transfer pumps positive displacement' pumps? Please provide another basis for the proposed alternative in the relief request, if the pumps are not positive displacement pumps.

RESPONSE: The BVPS-2 Diesel Fuel Oil Transfer Pumps are not positive displacement pumps. They are vertical line-shaft pumps mounted above the Diesel Fuel Oil Storage Tanks. Although the proposed alternative does not meet NUREG-1482, Rev. 1, Section

.5.5.2, "Use of Tank Level to Calculate Flow Rate for Positive Displacement Pumps," the

Beaver Valley Power Station, Unit No. 2 Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests L-07-125 Attachment, Page 2 of 8" same test methodology is applied. Calculating the Diesel Fuel Oil Transfer Pump flow rate by measuring the level change in the Diesel Generator Fuel Oil Day Tank over time provides an acceptable level of quality and safety since the accuracy of the calculated flow rate is consistent with the level of accuracy required by Table ISTB-3500-1 (plus or minus 2 percent) for flow rate measuring instruments, the record includes the method used to reduce the data as required by ISTB-3550, and the method provides reasonable assurance of operational readiness..

A similar relief request was previously approved for the BVPS-2 Second Ten-Year Inservice Test Interval. The NRC letter authorizing this similar alternative is referenced under the heading "Precedents" in Relief Request PRR6 forwarded with the May 11, 2007 FENOC letter.

Relief Request PRR8: -

3. In the last paragraph of the American Society of Mechanical Engineers (ASME) Code Components Affected Section, the licensee stated, "This Request for Relief may also be applied to any pump in the Inservice Test (IST) Program scope should a vibration reading of <0.05 in/sec be obtained as a new reference value subsequent to repair or replacement and for pumps that demonstrate a vibration reading of <0.05 in/sec for new comprehensive tests." NUREG/CP-152, "Smooth-Running Pumps," Session 4, Pages 4-32, July 1996, states, "If licensees intend to submit alternative requests to use minimum reference values, the requests should be pump specific and include justification as to how the current inservice testing methodology will detect pump degradation.". The NRC staff's position is to review relief requests on a case-by-case basis for a specific requirement of the Code. Generic relief for all pumps cannot be authorized. Generic changes to Code requirements can be achieved through the ASME Code for Operation and Maintenance of Nuclear Power Plants Committee. Therefore, please revise the relief request to delete the last paragraph from the ASME Code Component(s) Affected Section. Also, future relief requests may be submitted to NRC, if historical data of the pump shows that the reference value of vibration is less than 0.05 in/sec.

RESPONSE: Relief Request PRR8 is hereby revised bydeleting the last paragraph from the "Component(s) Affected" section, and changing the words "all pumps in the BVPS Unit No.

2 Inservice Test Program" in the second paragraph of the "Proposed Alternative and Basis for Use" section to read "pumps listed above."

Beaver Valley Power Station, Unit No. 2" Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests L-07-125 Attachment, Page 3 of 8.

4. The relief request does not address pump operating speed. Pump operating speed is a critical component in the vibration acceptance criteria. Please provide operating speed of each pump listed in the relief request.,

RESPONSE: The pump operating speed for each pump listed in the "Components Affected" section of Relief Request PRR8 is provided in the table below.

Pump Description Speed 2CHS*P21A Charging Pumps 4850 rpm 2CHS*P21B.

2CHS*P21C 2CHS*P22A Boric Acid Transfer Pumps 3505 rpm 2CHS*P22B 2RHS*P21A "A" Residual Heat Removal 1769 rpm Pump 2QSS*P24A "A" Chemical Injection Pump 1170 rpm 2FWE*P23A Motor Driven Auxiliary 3546 rpm 2FWE*P23B Feedwater Pumps

-2SWS*P21B "B" Service Water Pump 885 rpm 2EGF*P21A Diesel Generator Fuel Oil 1745 rpm 2EGF*P21B Transfer Pumps 2EGF*P21C 2EGF*P21D Relief Request PRR9:

5. The licensee stated, "Since suction pressure is typically a small value, it has minimal impact on pump differential pressure." Please provide the typical service water pump suction pressure, discharge pressure, and pressure instrument accuracy.

RESPONSE: A typical Service Water Pump suction pressure is approximately 11 pounds per square inch gauge pressure (psig) based on a normal river elevation (665 to 666 feet above sea level) above the pump suction impeller elevation (640 feet 7 inches above sea level). River elevation is read from an installed level recorder which has a, loop. accuracy of plus or minus 1.8 percent of full scale (transmitter accuracy is plus or minus 1.5 percent of full scale and recorder accuracy is plus or minus 1.0 percent of full scale). A pump curve is used since the Service Water Pump flow rate and discharge pressure vary for each pump due to seasonal conditions. A typical discharge pressure for pump 2SWS*P21A is between 80 and 96 psig (110 and 126 psig when corrected for elevation differences).using the installed pressure indicator, which has an instrument accuracy of plus or minus 0.5 percent of full scale. A typical discharge pressure for pump. 2SWS*P21B is between 77 and.95 psig (106 and 124 psig when corrected for elevation differences) using the installed pressure indicator, which has an instrument accuracy of plus or minus 0.5 percent of full scale. A typical discharge pressure for pump 2SWS*P21C is between 78 and 95 psig (108 and 125 psig when corrected for elevation differences) using the installed pressure indicator, which has an instrument accuracy of plus or minus 0.5 percent of full scale.

Beaver Valley Power Station, Unit No. 2 Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests L-07-125 Attachment, Page 4 of 8

6. Explain why replacing river level recorder and transmitter with level indication calibrated to 0.5% is considered a hardship or unusual difficulty. Are there any temporary flow instruments that have the accuracy required for the comprehensive test?

RESPONSE: To achieve a loop accuracy of 0.5 percent would require replacing the 1.0 percent accurate transmitter and the 1.5 percent accurate recorder with a 0.35 percent or more accurate transmitter and a 0.35 percent or more accurate recorder in order to give an overall loop accuracy of 0.5 percent. Although this may be burdensome, FENOC has determined that the proposed alternative in Relief Request PRR9 should be modified. FENOC hereby modifies Relief Request PRR9 by withdrawing the request for relief under 10 CFR 50.55a(a)(3)(ii), requesting relief instead under 10 CFR 50.55a(a)(3)(i), revising the proposed alternative by using a more accurate pump discharge pressure gauge to meet the intent of ASME OM Code instrumentation calibration requirements, and correcting typographical errors. Modified Rqlief Request PRR9 is presented below and is annotated by underline/strike-through to show the modifications. The availability of more accurate temporary flow and pressure instruments was not investigated further, since the proposed alternative below incorporates the use of a temporary test pressure gauge and provides an acceptable level of quality and safety.

PUMP RELIEF REQUEST 9 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

Proposed Alternative In Accordance with 100CFR5O.55a(a)(3)(i)

On the basis that coFpRrliaR*8 With the Code rlequirremeRt Would reslt in hardship A nd unu'Suial difficult" Witheout a omspernsating iroese in the level of quality and safety.

On the basis that the proposed alternative provides an acceptable level of quality and safety ASME Code Component(s)

Affected:

Component/System Function:

Applicable Code Edition and Addenda:

Applicable Code Requirement(s):

2SWS*P21A, Service Water Pump (Class 3) 2SWS*P21 B, Service Water Pump (Class 3) 2SWS*P21C, Service Water Pump (Class 3)

The Service Water Pumps operate continuously during normal plant operation to provide cooling water for heat removal from power plant auxiliary subsystems. During post accident conditions they provide the heat sink to the following components: at least two recirculation spray.

coolers, one charging pump lube oil cooler, one control room air-conditioning refrigerant condenser or one control room air-conditioning unit, one emergency diesel generator cooling system heat exchanger, and one safeguards area air-conditioning unit.

ASME OM Code-2001, with Addenda through OMb-2003.

ISTB-3510(a), "Data Collection; General Accuracy", states:

"Instrument accuracy shall be within the limits of Table ISTB-3500-1. If the parameter is determined by analytical methods instead of measurement, then the determination shall meet the parameter accuracy requirement of Table ISTB-3500-1. For individual analog

BeaverValley Power Station, Unit No. 2 Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests L-07-125 Attachunent, Page 5 of 8 instruments, the required accuracy is percent of full scale. For digital instruments, the required accuracy is over the calibrated range. For a combination of instruments, the required accuracy is loop accuracy."

Table IST_,-3500-1, "Required Instrument Accuracy"' requires pressure instruments to be calibrated to at least 0.5 percent when used during the Comprehensive Pump test.,

Reason for Request

The Beaver Valley Power Station Unit No. 2 Service Water Pumps are vertical line-shaft pumps that receive their suction from a pit that communicates with the Ohio river. Differential pressure is calculated using local Pump Discharge Pressure Indicators [2SWS-PI101A, B and C] and the calculated suction pressure using river water elevation from Ohio River Level Recorder [LR-1CW-1 01] (local). The transmitter associated with level recorder [LR-1CW-101] is calibrated to 1.5

,percent of full scale and the recorder is calibrated to 1.0 percent of full scale resulting in a loop accuracy of 1.8 percent of full scale. The overall loop accuracy exceeds the maximum 0.5 percent required by Table ISTC-3510-1 when performing a Comprehensive or Preservice test. ReplaGing leVel recorder [LR !CW 101] with level indication alibrfated to 0.5 percent is Ronsidered a hardship or u6nusual difficultI without a comTpensatin icesin the level quality orF safoty sinco the iRstalled-intumn accuracy is adequate to det8ermn Pu.mp e perational readinesrs.

Typical Ohio River elevation is between 665 and 666-7 feet resulting in a small variance between calculated suction pressure when determined by the calculational method provided by the procedure.,

However, it should be noted that during the spring, river elevations may be higher due to rain. This condition is evaluated with the test results to ensure operational readiness of the-pumps.

Proposed Alternative and Basis for Use:

Existi*g level instrumentatio w.ill be used when determieRng dIiff[-Felica PF8666IF UUHFI~y ;rumFRPiiuRi6iVu A-1210- W-viw-PRA teuti~g, with a calibrated loop accurFacy of 1.80 percent fuAll scale, in lieu1 G ran r*n nvicf+n lnc+r, mmn+

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,r'r requ1irement for pressureinsrmettin as specified in Table ISTGO 3500 1. Since suctionR pressure is typically a small value, it has minimnal impact on pump diffeFRetial peressure.

FENOC proposes to use the installed Ohio River Level Recorder LR-1CW-1 01 with a loop accuracy of 1.8 percent (to determine pump Service Water Pump suction pressure), and a 0 to 200 psicq, 0.1 percent or better accurate test pressure gauge (to determine Service Water Pump discharge pressure). These instrument readings are used to determine Service Water Pump differential pressure.

Differential pressure (delta-p) for the Service Water Pumps is determined by taking the difference between the pump discharge pressure (corrected for elevation back to the pump impeller) minus the river elevation (corrected for elevation back to the pump impeller and

Beaver Valley Power Station, Unit No. 2-Response to NRC RAI Dated August 22, 2007 Regarding May 11 2007 Proposed Alternatives and Relief Requests, L-07-125 Attachunent, Page 6 of 8 Proposed Alternative converted to pressure).

and Basis for Use:

Suction pressure for Service Water Pumps 2SWS*P21A, B and C is, (Continued) determined by converting a river elevation reading measured by level recorder LR-1CW-101 to a calculated pressure. This level recorder has a full scale range from 648 feet to 705 feet (river elevation above sea level). Normal river elevation is 665 to 666 feet which provides for a typical suction pressure of approximately 11 psig (based on the suction impeller being at elevation 640 feet 7 inches above sea level).

The loop accuracy for level recorder LR-1 CW-1 01 is 1.8 percent.

The suction pressure reading over the range of the installed level recorder LR-1CW-101 is accurate to within 0.45 psig. This accuracy is obtained by taking the full scale range of 57 feet, converting it to a pressure f(57 feet) / (2.31 feet/psig) = 25 psigl, and multiplying it by 1.8 percent accuracy. The ASME OM Code would require this suction.

S.pressure reading to be accurate within 0.1 psig (25 psig x 0.5 percent accuracy).

Discharge pressure for Service Water Pumps 2SWS*P21A, B and C is to be obtained from a temporary test pressure gauge with a full scale range of 0 to 200 psig. The ASME OM Code would require this discharge pressure reading to be accurate within 1 psig (200 psig x 0.5 percent).

In order to compensate for the 1.8 percent suction pressure loop accuracy, a 0.1 percent accurate temporary test pressure gauge will be used. This temporary test pressure gauge (to be used in place of the installed 0 to 160 psig, 0.5 percent accurate discharge pressure indicators 2SWS-PI-101A, B and C) will provide a discharge pressure reading over the range of the instrument with an accuracy of 0.2 psig (200 psig x 0.1 percent). Adding this to the installed 1.8 percent accurate suction pressure instrument reading yields an accuracy of 0.65 psig (0.45 psig plus 0.2 psig) for the combination of instruments.

When the Table ISTB-3500-1 required instrument accuracy of plus or minus 0.5 percent is applied to the river water level reading, the suction pressure reading over the range of the instrument is required to be accurate within 0.1 psig (25 psig x 0.5 percent). When the Table ISTB-3500-1 required instrument accuracy of plus or minus 0.5 percent is applied to the pump discharge pressure reading, the reading is required to be accurate to within 1 psig (200 psig x 0.5 percent). Adding these required instrument accuracies together would yield an overall worst case (allowed) error of 1.1 psig (0.1 psig plus 1 psig).

The proposed alternative, using the 0.1 percent accurate test gauge in place of the installed discharge pressure indicator, will yield an effective differential pressure reading (considering both suction and discharge instrumentation together) that is more accurate than the plus or minus 0.5 percent instrument accuracy required by Table ISTB-3500-1 for Comprehensive pump testina.

Beaver Valley Power Station, Unit No. 2 Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests L-07-125 Attachment, Page 7 of 8 Proposed Alternative and Basis for Use:

(Continued)

Other activities are implemented at BVPS Unit No. 2, in addition to those required by the ASME OM Code, which enhances the ability to detect pump degradation. As part of the BVPS Unit No. 2 Predictive Maintenance Program, spectral analysis is also used to determine the mechanical condition of a pump. Spectral data can provide information to determine if misalignment, unbalance, resonance, looseness or a bearing problem is present. Through a review of the spectral data over a period of time, any change in condition of the pump may also be determined. Additionally, as part of the BVPS Unit No. 2 Preventive Maintenance Program, the pump motors are inspected, lubricated, and tested every 144 weeks. The pump and motor are completely overhauled every 516 weeks. Motor overhaul includes sending it to the vendor. This frequency is based on the expected condition of the pumps as a result of historical overhauls and was established to allow overhaul prior to the point of degradation

-'resulting in questionable operational readiness.

Using the provisions of this relief request as an alternative to the accuracy requirements of Table ISTB-3500-1, when performing Comprehensive or Preservice tests, provides an acceptable level of quality and safety.

The proposed alternative identified in this relief request shall be utilized during the Third Ten-Year Inservice Test Interval.

None ISTB-3510-1 (a), "Data Collection; General Accuracy" Table ISTB-3500-1, "Required Instrument Accuracy" NUREG-1482, Rev.1, Section 5.5.3, "Use of Tank or Bay Level to Calculate Differential Pressure".

Duration of Proposed Alternatives:

Precedents:

References:

Beaver Valley Power Station, Unit No. 2 Response to NRC RAI Dated August 22, 2007 Regarding May 11, 2007 Proposed Alternatives and Relief Requests.

L-07-125 Attachment, Page 8 of 8

7. Please provide a comparison of the Code required values and the proposed values, including the following information: (1) pressure instrument range, (2) referenced value range (established), and (3) effective and actual accuracies of instruments. Provide justification as to why the proposed alternative is acceptable.

RESPONSE: Based on the modified proposed alternative discussed in response to Request for Additional Information (RAI) 6, the comparison of Code required values and actual values for the proposed alternative are provided below.

Instrument Instrument Code Required Actual Accuracy Range Accuracy*

Suction Pressure Level Recorder 648 to 705 Feet

.0.1 psig 0.45 psig LR-1CW-101 Loop (0.5 percent)

(1.8 percent)

Discharge Pressure TestPressure Gauge 0 to 200 psig 1 psig 0.2 psig

" ' ________(0.5 percent)

(0.1 percent)

Combined Suction and Discharge Pressure 1.1 psig 0.65 psig.

Reading Effective Accuracy

• ASME OM Code Table ISTB-3500-1 requires instruments used to determine differential pressure readings during comprehensive pump testing to be accurate within plus or minus 0.5 percent..

Listed accuracies are calculated as described in modified Relief Request PRR9.

The proposed alternative would use the level recorder and test pressure gauge described above and in response to RAI 6 to provide a combined effective accuracy of 0.65 psig (0.45 plus 0.2 psig).

Pump curves are used to test Service Water Pumps 2SWS*P21A, B and C. Therefore, discharge pressure does not have an established reference value range for use during preservice and comprehensive testing. A typical discharge pressure for pump 2SWS*P21A is between 80 and 96 psig (110 and 126 psig when corrected for elevation). A typical discharge pressure for pump 2SWS*P21B is between 77 and 95 psig (106 and 124 psig when corrected for elevation). A typical discharge pressure for [2SWS*P21C] is between 78 and 95 psig (108 and.125 psig when corrected for elevation).

.The proposed alternative, using the 0.1 percent accurate test gauge in place of the installed,

• discharge pressure indicator, will yield an effective differential pressure reading (considering both suction and discharge instrumentation together) that is more accurate than the plus or minus 0.5 percent instrument accuracy required by Table ISTB-3500-1 for comprehensive, pump testing. Therefore, the proposed alternative provides adequate assurance of pump

.operational readiness, and provides an acceptable level of quality and safety.

.