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EPID:L-2020-LLR-0050, 10 CFR 50.55a Request Number 2-TYP-4-RV-06, Hardship for Hot Leg Nozzle Inspections (Approved, Closed) |
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MONTHYEARML20093G6512020-04-0202 April 2020 Email Beaver Valley Unit 2 - Request for Additional Information - Snubber RR Project stage: RAI L-20-118, CFR 50.55a Request Number SRR-1, Revision 0, Snubber Testing2020-04-0303 April 2020 CFR 50.55a Request Number SRR-1, Revision 0, Snubber Testing Project stage: Request L-20-125, Response to Request for Additional Information Regarding 10 CFR 50.55a Request Number SRR-1, Rev. 0, Snubber Testing2020-04-0303 April 2020 Response to Request for Additional Information Regarding 10 CFR 50.55a Request Number SRR-1, Rev. 0, Snubber Testing Project stage: Response to RAI L-20-117, 10 CFR 50.55a Request Number 2-TYP-4-RV-06, Hardship for Hot Leg Nozzle Inspections2020-04-0303 April 2020 10 CFR 50.55a Request Number 2-TYP-4-RV-06, Hardship for Hot Leg Nozzle Inspections Project stage: Request ML20095J0992020-04-0404 April 2020 Email Beaver Valley Power Station, Unit 2 - Verbal Relief for Snubbers - Delivered 4/4/2020 at 4:00 P.M Project stage: Other ML20223A0142020-08-20020 August 2020 Issuance of Relief Request SSR-1, Revision 0, from the Requirements of the ASME Code (EPID L-2020-LLR-0050 (COVID-19)) Project stage: Approval 2020-04-03
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Category:Code Relief or Alternative
MONTHYEARML23249A1842023-09-18018 September 2023 Authorization and Safety Evaluation for Alternative Request No. 2-TYP-4-RV-06 ML22082A2532022-03-29029 March 2022 Correction Letter - Issuance of Authorization of Proposed Alternative to Use ASME OM Code Case OMN-27 ML22012A2972022-01-21021 January 2022 Proposed Alternative to Use ASME OM Code Case OMN-27 L-20-256, Request to Use Provision in Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2020-09-28028 September 2020 Request to Use Provision in Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI ML20223A0142020-08-20020 August 2020 Issuance of Relief Request SSR-1, Revision 0, from the Requirements of the ASME Code (EPID L-2020-LLR-0050 (COVID-19)) ML20206K8652020-08-0707 August 2020 Relief Requests 2-TYP-4-RV-06 and 2-TYP-4-RV-07 from the Requirements of the ASME Code (EPID L-2020-LLR-0053 and EPID L-2020-LLR-0054 (COVID-19)) ML20145A0002020-06-0303 June 2020 Relief from the Requirements of the ASME Code for Requests VRR6 and VRR5 (EPID L-2020-LLR-0049 and EPID L-2020-LLR-0051 (COVID-19)) ML20100N3222020-04-0909 April 2020 Verbal Relief for Penetration Evaluation and Hot Leg Nozzles - Delivered 4/9/2020 at 10:00 Am ML20099B2572020-04-0808 April 2020 Verbal Relief Unit 2 CIV ML20098F3012020-04-0707 April 2020 Verbal Relief for Appendix I Safety Relief Valves ML20095J2192020-04-0404 April 2020 Email Beaver Valley Power Station, Unit 2 - Verbal Relief for MOVs - Delivered 4/4/2020 at 4:00 Pm ML20095J0992020-04-0404 April 2020 Email Beaver Valley Power Station, Unit 2 - Verbal Relief for Snubbers - Delivered 4/4/2020 at 4:00 P.M L-20-117, 10 CFR 50.55a Request Number 2-TYP-4-RV-06, Hardship for Hot Leg Nozzle Inspections2020-04-0303 April 2020 10 CFR 50.55a Request Number 2-TYP-4-RV-06, Hardship for Hot Leg Nozzle Inspections L-20-118, CFR 50.55a Request Number SRR-1, Revision 0, Snubber Testing2020-04-0303 April 2020 CFR 50.55a Request Number SRR-1, Revision 0, Snubber Testing L-20-060, CFR 50.55a Request Number: VRR4, Revision 0, Containment Isolation Valve Test Frequency2020-04-0202 April 2020 CFR 50.55a Request Number: VRR4, Revision 0, Containment Isolation Valve Test Frequency L-20-116, CFR 50.55a Request Number VRR6, Revision 0, Motor-Operated Valve Test Frequency2020-04-0101 April 2020 CFR 50.55a Request Number VRR6, Revision 0, Motor-Operated Valve Test Frequency ML20079F8162020-03-26026 March 2020 Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 Regarding Weld Examination Coverage for the Fourth Inservice Inspection Interval ML19275E2942019-10-16016 October 2019 Issuance of Relief Request Proposed Alternative to Reactor Vessel Nozzle Weld Examination Frequency Requirements in Lieu of Specific ASME Code Requirements L-19-107, Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements2019-08-27027 August 2019 Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements ML19051A1082019-02-20020 February 2019 Request Alternative Examination Frequency for Reactor Vessel Nozzle to Safe-End Welds (Request 2-TYP-4-RV-05, Revision 0) ML18227A7332018-08-27027 August 2018 Request for Relief from the Requirements of the ASME Code ML18004A1222018-01-22022 January 2018 FENOC-Beaver Valley, Davis-Besse, and Perry - Alternative for the Use of ASME Code Case N-513-4 (CAC Nos. MG0120, MG0121, MG0122, and MG0123; EPID L-2017-LLR-0088) L-17-317, Request to Extend Certain Reactor Vessel Inspections from 10 to 20 Years (Request 1-TYP-4-BN-01)2017-11-15015 November 2017 Request to Extend Certain Reactor Vessel Inspections from 10 to 20 Years (Request 1-TYP-4-BN-01) L-17-308, 10 CFR 50.55a Request for Alternate Reactor Vessel Nozzle Flaw Depth Sizing Criteria (Request 2-TYP-4-RVSE-2)2017-10-25025 October 2017 10 CFR 50.55a Request for Alternate Reactor Vessel Nozzle Flaw Depth Sizing Criteria (Request 2-TYP-4-RVSE-2) ML17167A0672017-06-26026 June 2017 Requests for Alternatives and Requests for Relief Fourth 10-Year Inservice Test Program Interval (CAC Nos. MF8333-MF8356). Note: Correction Safety Evaluation See ML17255A526 ML17159A4422017-06-26026 June 2017 Requests for Alternatives and Requests for Relief Fifth 10-Year Inservice Testing Program Interval (CAC Nos. MF8332 Through MF8357). Note: Correction Safety Evaluation See ML17255A508 ML17047A6102017-03-0202 March 2017 Relief from the Requirements of the American Society of Mechanical Engineers Code ML17041A1852017-03-0202 March 2017 Relief from the Requirements of the ASME Code ML17048A0042017-03-0202 March 2017 Relief from the Requirements of the ASME Code ML16328A1252017-01-23023 January 2017 Relief from the Requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) (TAC No. MF7780 - MF7783) ML16190A1332016-12-27027 December 2016 Relief from the Requirements of the ASME Code ML16319A0572016-12-0101 December 2016 Acceptance of Requested Licensing Action Relief Request for Proposed Alternative to Perform As-Found Set-Pressure Test ML16257A6212016-11-21021 November 2016 Relief Request BV2-PZR-01, Regarding Alternative to Requirements for Components Connected to the Steam Side of the Pressurizer ML16228A4082016-10-21021 October 2016 Correction to Relief Request 2-TYP-3-RV-04, Revision 0, Regarding Repair Activities for Reactor Vessel Head Penetration Nozzles and Associated J-Groove Welds ML16147A3622016-06-17017 June 2016 Relief Request No. 2-TYP-3-RV-04, Revision 0, Regarding Repair Activities for Reactor Vessel Head Penetration Nozzles and Associated J-Groove Welds ML14363A4092015-01-28028 January 2015 Relief Request No. 1-TYP-4-RV-04 Regarding the Examination Requirements of Code Case N-729-1 ML1202702982012-02-0707 February 2012 Relief Request VRR3 Regarding Solenoid Operated Valve Remote Position Verification Frequency ML1131304282011-11-22022 November 2011 Relief Request VRR5 Regarding Turbine Driven Auxiliary Feedwater Valve Test Frequency for the 10-Year Inservice Testing Program Interval ML1126404122011-09-20020 September 2011 Acceptance Review Results for VC Summer Relief Request (ME6879) ML1107705512011-04-26026 April 2011 Relief Request VRR2 Regarding the 10-Year Inservice Testing Program Interval ML1104705572011-02-25025 February 2011 Relief Request Regarding an Alternative Weld Repair Method for Reactor Vessel Head Penetrations J-Groove Welds ML1006807812010-03-12012 March 2010 Third 10-Year ISI Interval Relief Request (ME2608) L-08-362, Beaver, Units 1 and 2, Proposed Alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Paragraph IWA-5244 Examination Requirements2008-12-0202 December 2008 Beaver, Units 1 and 2, Proposed Alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Paragraph IWA-5244 Examination Requirements L-08-207, Proposed Alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Inspection Period Extension Requirement2008-09-24024 September 2008 Proposed Alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Inspection Period Extension Requirement L-08-069, Impractical American Society of Mechanical Engineers Code Section XI Weld Examination Requirements (Request Nos. 1-TYP-3-RA-1, 1-TYP-3-RA-2, 1-TYP-3-RA-3)2008-04-0909 April 2008 Impractical American Society of Mechanical Engineers Code Section XI Weld Examination Requirements (Request Nos. 1-TYP-3-RA-1, 1-TYP-3-RA-2, 1-TYP-3-RA-3) ML0720504882007-09-17017 September 2007 Relief Request No. BV1-PZR-01 Regarding Weld Overlay Repairs on Pressurizer Nozzle Welds ML0705905552007-04-30030 April 2007 Relief, Relief Request No. BV2-PZR-01 Regarding Weld Overlay Repairs on Pressurizer Nozzle Welds L-07-056, Requests Approval of Proposed Alternatives and Relief for Inservice Testing Program Ten-Year Update2007-03-28028 March 2007 Requests Approval of Proposed Alternatives and Relief for Inservice Testing Program Ten-Year Update ML0625801202006-10-0202 October 2006 (BVPS-1 and 2), Inservice Inspection (ISI) Program, Alternative Examination of Reactor Coolant Pipe Welds, Request for Relief No. BV3-RV-2 L-06-042, Proposed Alternative to American Society of Mechanical Engineers Code Section XI Examination Requirements2006-04-0707 April 2006 Proposed Alternative to American Society of Mechanical Engineers Code Section XI Examination Requirements 2023-09-18
[Table view] 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
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Text
Energy Harbor Nuclear Corp.
Beaver Valley Power Station P. O. Box 4 Shippingport, PA 15077 Rod L. Penfield 724-682-5234 Site Vice President, Beaver Valley Nuclear April 3, 2020 L-20-118 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Beaver Valley Power Station, Unit No. 2 Docket No. 50-412, License No. NPF-73 10 CFR 50.55a Request Number SRR-1, Revision 0, Snubber Testing In accordance with 10 CFR 50.55a(z)(2), Energy Harbor Nuclear Corp. hereby requests Nuclear Regulatory Commission (NRC) staff approval of request SSR-1, Revision 0, that proposes to cancel operational readiness testing of Beaver Valley Power Station, Unit No. 2 (BVPS-2) snubbers during the upcoming refueling outage.
Because of the hardship produced by the recent pandemic and the resulting national state of emergency, Energy Harbor Nuclear Corp. is requesting expedited NRC approval of this request. The proposed alternative would cancel the tests until the next refueling outage, which is within the current fourth 10-year inservice test interval.
Request SSR-1 was discussed at a public pre-submittal meeting between Energy Harbor Nuclear Corp. and the NRC staff on March 31, 2020. To support the critical generation and startup of BVPS-2 from its scheduled spring 2020 refueling outage, Energy Harbor Nuclear Corp. requests approval of the proposed alternative by April 4, 2020.
The enclosed request identifies the affected components, applicable code requirements, and a description and basis for the proposed alternative.
There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager, Nuclear Licensing and Regulatory Affairs, at (330) 315-6808.
Sincerely, Rod L. Penfield
Beaver Valley Power Station, Unit No. 2 L-20-118 Page 2
Enclosure:
Beaver Valley Power Station, Unit No. 2, 10 CFR 50.55a Request Number SSR-1, Revision 0 cc: NRC Region I Administrator NRC Resident Inspector NRR Project Manager Director BRP/DEP Site BRP/DEP Representative
Enclosure L-20-118 Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number SSR-1, Revision 0 (5 Pages Follow)
Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number SSR-1, Revision 0 Page 1 of 5 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2)
--Hardship Without a Compensating Increase in Quality and Safety--
- 1. ASME Code Components Affected Dynamic restraints (snubbers) of the Beaver Valley Power Station Unit No. 2 (BVPS-2)
Snubber Testing Program as listed below:
Snubber Component Snubber Model Defined Test Component Service Life Number Plan Group Classification Expiration (DTPG) 2CCP-PSSP301 PSA-10 AB Safety-Related 10/5/2030 2EDG-PSSP042A PSA-3 DG Safety-Related 9/25/2030 2FWS-PSSP002A 30 72 56 RC1-SP FW Safety-Related 10/1/2038 2FWS-PSSP002B 30 72 56 RC1-SP FW Safety-Related 10/1/2038 2MSS-PSSP108A 30 72 16 RC1-S5 MS-H Safety-Significant 9/28/2038 2MSS-PSSP108B 30 72 16 RC1-S5 MS-H Safety-Significant 9/30/2038 2MSS-PSSP103 PSA-100 MS-P10Y Safety-Significant 10/15/2022 2MSS-PSSP456 PSA-1 MS-P10Y Safety-Related 10/28/2027 2MSS-PSSP151B PSA-10 MS-P6Y Safety-Significant 11/30/2021 2CHS-PSSP024 30 18 56 RF1 RBX-L Safety-Related 3/22/2034 2CHS-PSSP025 30 18 56 RF1 RBX-L Safety-Related 3/9/2034 2BDG-PSSP947 30 18 56 RF1 RBX-L Safety-Related 3/19/2034 2RCS-PSSP012A PSA-10 RBX-P Safety-Significant 4/12/2022*
2RCS-PSSP019X PSA-10 RBX-P Safety-Significant 10/21/2024 2RCS-PSSP891A PSA-3 RBX-P Safety-Significant 10/21/2024 2RCS-PSSP892A PSA-10 RBX-P Safety-Significant 10/1/2024 2SIS-PSSP208X PSA-1 RBX-P Safety-Related 2/18/2023*
2SIS-PSSP209A PSA-1 RBX-P Safety-Related 2/18/2023*
2RCS-SN21C12 12 X 6.25 S/G Safety-Related 8/14/2027 2RSS-PSSP579A 30 18 56 RF1 SFGD-H Safety-Related 9/28/2035 2RSS-PSSP579B 30 18 56 RF1 SFGD-H Safety-Related 9/28/2035 2SIS-PSSP449A PSA-1 SFGD-M Safety-Related 9/26/2027 2SIS-PSSP449B PSA-1 SFGD-M Safety-Related 9/26/2027 2SWS-PSSP754Y PSA-10 SFGD-M Safety-Related 10/11/2023*
- Section 5 contains additional detail regarding service life.
Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number SSR-1, Revision 0 Page 2 of 5
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM)
Code, 2004 Edition through the 2006 Addenda.
3. Applicable Code Requirements
ASME OM Code, Subsection ISTD 5200, Inservice Operational Readiness Testing, states in part that:
Snubbers shall be tested for operational readiness during each fuel cycle. Tests are required to be in accordance with a specified sampling plan.
4. Reason for Request
Subsection ISTD 5200 requires snubbers to be tested for operational readiness during each fuel cycle. The number of snubbers to be tested is based on a sample test plan defined by article ISTD-5260, Testing Sample Plans. Within paragraph ISTD-5261, Sample Plans, there are two sample plans offered, the 10 percent (%) testing sample plan or the 37 testing sample plan. For the upcoming BVPS-2 refueling outage (2R21),
Energy Harbor Nuclear Corp. previously elected the 10% testing sample plan.
Energy Harbor Nuclear Corp. groups their BVPS-2 program snubbers into 11 DTPGs.
The 10% test plan requires 10% of each DTPG to be tested for operational readiness during each fuel cycle. The table in Section 1 of this request represents the population of snubbers scheduled to be tested under the snubber test plan for the 2R21 refueling outage.
On March 13, 2020, the President of the United States declared a national emergency due to the spread and infectious nature of the Coronavirus-2019 (COVID-19) and resulting pandemic. The most recent guidance from the Centers for Disease Control and Prevention (CDC) includes recommendations for social distancing by maintaining approximately six feet from other personnel to limit the spread of the virus. On March 28, 2020, the Governor of Pennsylvania issued a Stay at Home order for Beaver County and the surrounding counties of Allegheny and Butler. Furthermore, on March 28, 2020, the Department of Homeland Security identified workers in the nuclear energy sector as essential critical infrastructure workers.
To prevent the spread of COVID-19 at BVPS, and to protect the health and safety of plant personnel while maintaining responsibilities to support critical infrastructure, Energy Harbor Nuclear Corp. intends to reduce the amount of personnel on-site, which will pose a hardship for completing the currently planned 2R21 refueling outage work scope. Energy Harbor Nuclear Corp. is also contingency planning in case some of its workforce becomes unavailable due to the COVID-19 outbreak. With the current work scope and potential loss of personnel, there is the potential that the company may not be able to complete the refueling outage in a timely manner, which could negatively impact critical infrastructure that is needed during this time.
Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number SSR-1, Revision 0 Page 3 of 5 Because of the hardships caused by the COVID-19, Energy Harbor Nuclear Corp. is requesting that operational readiness testing of snubbers scheduled for the 2R21 refueling outage be canceled. The hardship caused by the current national emergency is twofold:
- 1. Implementation of the test plan described in this request requires the support of contract personnel assembled from various locations. These individuals are supplied from companies with unique experience and qualifications in the testing and assessing of dynamic restraints including the operation of contractor provided test equipment. Contract individuals previously scheduled for support of the 2R21 refueling outage are cancelling their scheduled outage support. Since replacement personnel are not readily available this is considered an emergent condition with less than two weeks before the start of the 2R21 refueling outage. Staffing of the outage with qualified individuals is a hardship without a known resolution.
- 2. The staff of BVPS-2 contains critical personnel who are necessary to complete 2R21 refueling outage activities, return the unit safely to service, and to maintain the unit operational to meet its power demands. Bringing contract personnel on site with unknown medical history and their potential exposure to COVID-19 increases the risks of infecting the BVPS-2 personnel with COVID-19. It is an extreme hardship for BVPS-2 to quarantine incoming contractors for sufficient durations to ensure they are free of COVID-19 symptoms or to conduct testing of contractors for COVID-19.
Without these safeguards, the BVPS-2 staff and surrounding community is at increased risk of contracting COVID-19 which has the potential of affecting the outage and future operation of the station.
5. Proposed Alternative and Basis for Use
As an alternative to Subsection ISTD-5200 of the OM Code, Energy Harbor Nuclear Corp. proposes to cancel the operational readiness testing of snubbers during the 2R21 refueling outage. Snubber testing to meet Subsection ISTD-5200 will resume during the next scheduled refueling outage 2R22.
The testing of snubbers in accordance with Subsection ISTD of the OM Code is a sampling test program that tests 10% of the snubbers in each of the DTPGs each refueling outage. To implement the 2R21 refueling outage test sample plan under the current conditions will result in undue hardship without providing a compensating increase to safety.
Based on the BVPS-2 snubber test history, the elimination of refueling outage 2R21 snubber testing will not impact the ability of the untested snubbers to perform their intended safety function until refueling outage 2R22 when testing will resume. Since 2009, there have been approximately 211 tests of program snubbers with only one snubber test failure that occurred in 2014. That test failure occurred in the feedwater DPTG and was captured in the BVPS-2 corrective action program. The evaluation of that failure concluded that the snubber, even though not meeting the as-found test acceptance criteria, did activate during testing and was fully functional in the as-found
Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number SSR-1, Revision 0 Page 4 of 5 condition. The snubber population at BVPS-2 has been operating at a high level of performance for the past ten years and this performance provides reasonable assurance that a significant decline of performance between the 2R21 and 2R22 refueling outages is unlikely.
There have been no dynamic events or transients during operation since 2R20 that might affect snubber performance or place a need for added emphasis on a specific snubber or group of snubbers.
There is one recent internal operating experience that applies to a snubber included in Section 1 (2RCS-SN21C12). IRIS OE 475511 provide operating experience regarding the large bore snubbers at Beaver Valley Power Station, Unit No. 1, and BVPS-2. The piston seal integrity testing delinquency is being tracked via the corrective action process. An earlier Information Notice (IN 2015- 09) that described the impact of grease degradation due to inadequate service life monitoring has not been an issue at BVPS-2 as grease is regularly monitored and replaced in accordance with service life milestones.
There is one Title 10 Code of Federal Regulations, Part 21 notification with the potential of affecting snubbers within the 2R21 refueling outage sample test plan. This is in relation to a batch of hydraulic fluid that was supplied to several nuclear stations. The evaluation of the related notification for BVPS-2 determined the hydraulic fluid anomaly would not present a safety hazard as the hydraulic fluid was only used in a test machine and does not impact any installed snubbers at BVPS-2.
As evidenced by the BVPS-2 operational readiness test history during the past 10-years, the snubber population is well maintained within the examination, testing and service life monitoring program and is performing well in their environment and operating conditions. There are no planned changes to the snubber environments or operating conditions that would affect the snubbers differently than represented in past surveillance testing.
This request has no impact to the visual examination program (ISTD-4250) because implementation of Code Case OMN-13 provides for a ten-year visual examination interval. The ten-year visual examination interval includes the 2R22 refueling outage; therefore, visual examinations not performed in the 2R21 refueling outage may be completed in the 2R22 refueling outage.
This request does not impact the service life monitoring program. Within the provisions of ASME OM Code Subsection ISTD-6200, Service Life Evaluation, service life is evaluated each fuel cycle and may be increased or decreased, if warranted. Activities associated with service life monitoring scheduled for the 2R21 refueling outage may be evaluated by Energy Harbor Nuclear Corp. and where warranted and supported by technical data rescheduled for the 2R22 refueling outage. Snubbers denoted by an asterisk (*) in Section 1 are snubbers that require Service Life Maintenance to be performed during 2R21 to extend service life to the date listed. If maintenance is
Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number SSR-1, Revision 0 Page 5 of 5 unsuccessful, corrective actions will be performed as appropriate to ensure service life is not exceeded.
Based on the information provided above, snubber testing has demonstrated that the snubber population at BVPS-2 is reliable, and there have been no dynamic events or transients at BVPS-2 or recent operating experience that might affect snubber performance. Therefore, the proposed Subsection ISTD-5200 alternative to cancel snubber operational readiness testing during the 1R21 refueling outage and resume this testing during the 2R22 refueling outage provides reasonable assurance that the snubbers are operationally ready.
6. Duration of Proposed Alternative
The proposed alternative is requested for use during the BVPS-2 fourth 10-year inservice test interval. The proposed alternative would cancel operational readiness testing of the affected snubbers during refueling outage 2R21. Operational readiness testing of snubbers in accordance with Subsection ISTD-5200 would resume in the refueling outage 2R22.