|
---|
Category:Letter type:L
MONTHYEARL-23-267, Submittal of Discharge Monitoring Report (Npdes), Permit No. PA00256152023-12-18018 December 2023 Submittal of Discharge Monitoring Report (Npdes), Permit No. PA0025615 L-23-229, Request for Additional Information Regarding the Spring 2023 Generic Letter 95-05 Voltage-Based Alternate Repair Criteria and Steam Generator F-Star Reports2023-11-29029 November 2023 Request for Additional Information Regarding the Spring 2023 Generic Letter 95-05 Voltage-Based Alternate Repair Criteria and Steam Generator F-Star Reports L-23-247, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-11-17017 November 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-227, Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Third Quarter 20232023-10-20020 October 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Third Quarter 2023 L-23-208, Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA00256152023-09-14014 September 2023 Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA0025615 L-23-167, Twenty-Third Refueling Outage Inservice Inspection Summary Report2023-09-13013 September 2023 Twenty-Third Refueling Outage Inservice Inspection Summary Report L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-179, Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA00256152023-07-18018 July 2023 Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA0025615 L-23-165, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-06-26026 June 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-139, Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report2023-06-13013 June 2023 Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report L-23-055, Submittal of the Updated Final Safety Analysis Report, Revision 342023-05-23023 May 2023 Submittal of the Updated Final Safety Analysis Report, Revision 34 L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report L-23-137, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-05-18018 May 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-125, Cycle 24 Core Operating Limits Report2023-05-17017 May 2023 Cycle 24 Core Operating Limits Report L-23-132, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-10010 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations L-23-129, Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations2023-05-0505 May 2023 Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations L-23-115, Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological2023-04-27027 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological L-23-126, Discharge Monitoring Report (Npdes), Permit No. PA00256152023-04-22022 April 2023 Discharge Monitoring Report (Npdes), Permit No. PA0025615 L-23-053, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-04-14014 April 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-058, 180-Day Steam Generator Tube Inspection Report2023-03-27027 March 2023 180-Day Steam Generator Tube Inspection Report L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage L-23-036, Report of Facility Changes, Tests and Experiments2023-03-13013 March 2023 Report of Facility Changes, Tests and Experiments L-23-086, Response to Request for Additional Information for Emergency License Amendment Request for Technical Specification 3.5.2 Regarding One-Time Action for Valve Leak Repair2023-03-0404 March 2023 Response to Request for Additional Information for Emergency License Amendment Request for Technical Specification 3.5.2 Regarding One-Time Action for Valve Leak Repair L-23-087, Supplement to Emergency License Amendment Request for Technical Specification 3.5.2 Regarding One-Time Action for Valve Leak Repair (L-2023-LLA-0027)2023-03-0404 March 2023 Supplement to Emergency License Amendment Request for Technical Specification 3.5.2 Regarding One-Time Action for Valve Leak Repair (L-2023-LLA-0027) L-23-073, Emergency License Amendment Request for Technical Specification 3.5.2 Regarding One-Time Action for Valve Leak Repair2023-03-0101 March 2023 Emergency License Amendment Request for Technical Specification 3.5.2 Regarding One-Time Action for Valve Leak Repair L-23-016, Twenty-Eighth Refueling Outage Inservice Inspection Summary Report2023-02-21021 February 2023 Twenty-Eighth Refueling Outage Inservice Inspection Summary Report L-23-064, Discharge Monitoring Report, (NPDES) Permit No. PA00256152023-02-21021 February 2023 Discharge Monitoring Report, (NPDES) Permit No. PA0025615 L-23-057, Energy Harbor Nuclear Corp Retrospective Premium Guarantee2023-02-20020 February 2023 Energy Harbor Nuclear Corp Retrospective Premium Guarantee L-22-193, Request for Exemption from Specific Provisions in 10 CFR 50 Appendix H2023-02-14014 February 2023 Request for Exemption from Specific Provisions in 10 CFR 50 Appendix H L-22-286, Supplement to Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time2023-02-14014 February 2023 Supplement to Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time L-23-032, Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Second Half of 20222023-01-23023 January 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Second Half of 2022 L-22-281, Discharge Monitoring Report (NPDES) Permit No. PA00256152022-12-16016 December 2022 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-22-246, Response to Request for Additional Information Regarding a Request to Consolidate Fuel Decay Time Technical Specifications to New LCO2022-12-0707 December 2022 Response to Request for Additional Information Regarding a Request to Consolidate Fuel Decay Time Technical Specifications to New LCO L-22-217, Submittal of Discharge Monitoring Report (NPDES) Permit No. PA00256152022-11-21021 November 2022 Submittal of Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-22-226, Emergency Preparedness Plan2022-11-0404 November 2022 Emergency Preparedness Plan L-22-222, Cycle 29-1 Core Operating Limits Report2022-10-31031 October 2022 Cycle 29-1 Core Operating Limits Report L-22-228, Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2022-10-26026 October 2022 Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-22-200, Response to Request for Additional Information Regarding a 180-Day Steam Generator Tube Inspection Report Fall 2021 Refueling Outage2022-10-21021 October 2022 Response to Request for Additional Information Regarding a 180-Day Steam Generator Tube Inspection Report Fall 2021 Refueling Outage L-22-232, Withdrawal of a License Amendment Request Associated with Fire Protection Program Changes2022-10-21021 October 2022 Withdrawal of a License Amendment Request Associated with Fire Protection Program Changes L-22-238, Submittal of Discharge Monitoring Report (NPDES) Permit No. PA00256152022-10-20020 October 2022 Submittal of Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-22-227, Revised August 2022 Outfall 003 & 004 NPDES Discharge Monitoring Report (Dmr), Revised Daily Effluent Monitoring Report Forms for Outfalls 003 & 004 and Corrective Action Letter from Eurofins2022-10-0303 October 2022 Revised August 2022 Outfall 003 & 004 NPDES Discharge Monitoring Report (Dmr), Revised Daily Effluent Monitoring Report Forms for Outfalls 003 & 004 and Corrective Action Letter from Eurofins L-22-219, Submittal of Discharge Monitoring Report (NPDES) Permit No. PA00256152022-09-26026 September 2022 Submittal of Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-22-204, Submittal of Evacuation Time Estimates2022-09-0707 September 2022 Submittal of Evacuation Time Estimates L-22-137, Request for Fire Protection Program Changes2022-09-0606 September 2022 Request for Fire Protection Program Changes L-21-238, License Amendment Request for Addition of Analytical Methodology to the Core Operating Limits Report for a Full Spectrum Loss of Coolant Accident2022-08-31031 August 2022 License Amendment Request for Addition of Analytical Methodology to the Core Operating Limits Report for a Full Spectrum Loss of Coolant Accident L-22-188, Response to Request for Additional Information Regarding Steam Generator Inspection Report- Fall 2021 Refueling Outage2022-08-22022 August 2022 Response to Request for Additional Information Regarding Steam Generator Inspection Report- Fall 2021 Refueling Outage L-22-191, Spent Fuel Storage Cask Registration2022-08-17017 August 2022 Spent Fuel Storage Cask Registration 2023-09-14
[Table view] |
Text
FENOC Beaver Valley Power Station NP.O. Box 4 FirstEnergyNuclear OperatingCompany Shippingport,PA 15077 PaulA. Harden 724-682-5234 Site Vice President Fax: 724-643-8069 February 25, 2011 L-1 1-023 10 CFR 50.55a Attention: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 10 CFR 50.55a Request (VRR5) Regarding Turbine Driven Auxiliary Feedwater Valve Test Frequency In accordance with 10 CFR 50.55a, FirstEnergy Nuclear Operating Company (FENOC) requests Nuclear Regulatory Commission (NRC) approval of proposed alternatives for the Beaver Valley Power Station (BVPS), Unit No.1 fourth interval Inservice Testing Program for Pumps and Valves (IST Program) and the BVPS, Unit No. 2 third interval IST Program. The proposed alternative is associated with full-stroke open exercise tests of turbine driven auxiliary feedwater pump discharge valves.
In support of the spring 2012 refueling outage, FENOC requests approval of the proposed requests by March 14, 2012.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Thomas A. Lentz, Manager - Fleet Licensing, at 330-761-6071.
Sincereli Paul A. Harden
Enclosure:
10 CRF 50.55a Request Number: VRR5, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)
Beaver Valley Power Station, Unit Nos. 1 and 2 L-11-023 Page 2 cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative
10CFR 50.55a Request Number: VRR5 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)
Page 1 of 3
--Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety--
1.0 ASME Code Components Affected
1FW-33, Turbine-Driven Auxiliary Feedwater Pump (TDAFWP) Discharge Check Valve (Class 3, Category C) 2FWE*FCV122, TDAFWP Discharge Check and Recirculating Valve (Class 3, Category B/C) 2.0 Applicable Code Edition and Addenda American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM)
Code-2001, with Addenda through OMb-2003.
3.0 Applicable Code Requirement ISTC-3510, "Exercising Test Frequency," states in part: "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months..."
4.0 Reason for Request 2FWE*FCV122 is a three-way automatic recirculation control valve that acts as both a manual automatic flow control valve in one direction and a check valve in the other direction. 1FW-33 is a check valve only. Both 2FWE*FCV122 and 1FW-33 are normally closed during plant operation and are required to open in order to allow auxiliary feedwater flow to the steam generators (SGs) during an accident. The relatively cold auxiliary feedwater is drawn from a demineralized water storage tank, which is not routinely treated for pH or oxygen control.
In accordance with ISTC-5221, "Valve Obturator Movement," and NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," Revision 1, Section 4.1.3, "Full Flow Testing of Check Valves," a full-stroke exercise in the open direction may be achieved by passing the maximum required accident condition flow through the valve.
A full-stroke open exercise of these check valves can only be performed when auxiliary feedwater flow is aligned to the SGs during the full-flow (comprehensive pump) test of the TDAFWP. The TDAFWP full-flow test can only be performed in Modes 1, 2, or 3 because steam from any of the three SGs is required to drive the pump.
The following information describes why aligning auxiliary feedwater flow to the SGs in order to perform a full-stroke exercise test in the open direction on a three-month frequency results in hardship:
Beaver Valley Power Station, Unit Nos. 1 and 2 10 CFR 50.55a Request Number: VRR5 Page 2 of 3 a) The introduction of relatively cold auxiliary feedwater into the SGs produces a potential for thermal shock to both the main feed piping (thermal sleeves) and the secondary side of the SGs. Although the thermal sleeves and SGs are designed for thermal shock, exposure to such events should be minimized in order to ensure the benefits of plant life extension are realized.
b) Feeding the SGs with a large volume of relatively cold water could also result in a large level transient in the SGs and could cause a reactor trip. Therefore, in order to avoid a reactor trip, it is necessary to reduce reactor power to 97 percent or less, which places additional burden on plant operators.
c) The TDAFW pumps receive their suction from a demineralized water storage tank. The water in these demineralized water storage tanks is not routinely treated for pH or oxygen control, which could impact the corrosion rates in the secondary system. From a chemistry perspective, based on the lack of oxygen control in this water source, it is prudent to minimize the use of this water while in Modes 1, 2, or 3.
5.0 Proposed Alternative and Basis for Use Per ISTC-3522(c), "Category C Check Valves," "If exercising is not practicable during operation at power and cold shutdown, it shall be performed during refueling outages."
Because it has been considered not practicable to perform during operation at power and cold shutdown, the quarterly testing of valves 1FW-33 and 2FWE*FCV1 22 required by ISTC-3510 has, to date, only been performed at a refueling outage frequency, in Mode 3, during startup.
On the basis of an analysis performed by Westinghouse in September 2010, "Beaver Valley Units 1 and 2 Transient Analysis of at Power Auxiliary Feedwater Functional Test
- Final Report," performance of the test during power operation is now considered acceptable at an initial power level no greater than 97 percent.
Although testing during power operation has been determined to be acceptable, FENOC desires to test the pump and associated discharge check valve at the two-year frequency. As an alternative to the testing required at a nominal quarterly frequency by ISTC-351 0, FENOC proposes to perform full-stroke exercises of valves 1FW-33 and 2FWE*FCV122 in the open direction when auxiliary feedwater flow is aligned to the SGs during the full-flow (comprehensive pump) test of the TDAFWP, to be performed once every two years.
A review of the Beaver Valley Power Station, Unit Nos. 1 and 2 Inservice Testing Programs trending database indicated that over the past 10 years, these valves have consistently passed the full-stroke exercise test in the open direction. Testing at a refueling outage frequency has been adequate to demonstrate the continued reliability and acceptable operation of the valves. Testing these check valves during power operation at the nominal quarterly frequency required by ISTC-3510 would result in the hardship described above, without a compensating increase in the level of quality and safety.
Beaver Valley Power Station, Unit Nos. 1 and 2 10 CFR 50.55a Request Number: VRR5 Page 3 of 3 6.0 Duration of Proposed Alternative The proposed alternatives identified in this relief request shall be utilized during the remainder of the BVPS Unit No. 1 fourth 10-Year Inservice Test Interval, which began on September 20, 2007 and the BVPS Unit No. 2 third 10-Year Inservice Test Interval, which began on November 18, 2007.
7.0 References Westinghouse Report, Beaver Valley Units 1 and 2 Transient Analysis of at Power Auxiliary Feedwater Functional Test, LTR-PCSA-10-5, dated September 2, 2010.