ML023160394
| ML023160394 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/12/2002 |
| From: | Richard Laufer NRC/NRR/DLPM/LPD1 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| Collins D S, NRR/DLPM, 415-1427 | |
| References | |
| TAC MB5558 | |
| Download: ML023160394 (9) | |
Text
November 12, 2002 Mr. Mark B. Bezilla Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT 1 - EVALUATION OF INSERVICE TESTING RELIEF REQUEST (TAC NO. MB5558)
Dear Mr. Bezilla:
By letter dated July 8, 2002, FirstEnergy Nuclear Operating Company (FENOC) submitted Pump Relief Request No. 6 (PRR6), and proposed an alternative, to certain inservice testing requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for the boric acid transfer pumps at Beaver Valley Power Station, Unit 1. In PRR6, FENOC requests relief from the ASME OM Standard, Part 6, Paragraph 5.2 and Table 2 requirements. As an alternative to the requirements, FENOC proposes to test quarterly through a fixed resistance non-instrumented minimum flow recirculation line, and test at a refueling frequency while on-line or during refueling outages at full flow through a larger recirculation line, using a portable flow meter.
The Nuclear Regulatory Commission (NRC) staff has completed its review of this relief request and the proposed alternative. As described in the enclosed safety evaluation, the NRC staff has authorized PRR6 for the remainder of the third interval pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), on the basis that the proposed alternative provides an acceptable level of quality and safety.
If you have any questions regarding this evaluation, please contact the Beaver Valley Project Manager, Daniel Collins, at (301) 415-1427.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-334
Enclosure:
Safety Evaluation cc w/encl: See next page
November 12, 2002 Mr. Mark B. Bezilla Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT 1 - EVALUATION OF INSERVICE TESTING RELIEF REQUEST (TAC NO. MB5558)
Dear Mr. Bezilla:
By letter dated July 8, 2002, FirstEnergy Nuclear Operating Company (FENOC) submitted Pump Relief Request No. 6 (PRR6), and proposed an alternative, to certain inservice testing requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for the boric acid transfer pumps at Beaver Valley Power Station, Unit 1. In PRR6, FENOC requests relief from the ASME OM Standard, Part 6, Paragraph 5.2 and Table 2 requirements. As an alternative to the requirements, FENOC proposes to test quarterly through a fixed resistance non-instrumented minimum flow recirculation line, and test at a refueling frequency while on-line or during refueling outages at full flow through a larger recirculation line, using a portable flow meter.
The Nuclear Regulatory Commission (NRC) staff has completed its review of this relief request and the proposed alternative. As described in the enclosed safety evaluation, the NRC staff has authorized PRR6 for the remainder of the third interval pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), on the basis that the proposed alternative provides an acceptable level of quality and safety.
If you have any questions regarding this evaluation, please contact the Beaver Valley Project Manager, Daniel Collins, at (301) 415-1427.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-334
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC MOBrien DTerao ACRS MOprendek, RGN-I PDI-1 Reading SRichards DCollins GHill (2)
WKPoertner RLaufer OGC TBergman, EDO, RGN-I DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML023160394.wpd ACCESSION NO. ML023160394
- see previous concurrence OFFICE PDI-1/PM PDI-1/LA EMEB**
OGC**
PDI-1/SC NAME DCollins MOBrien DTerao SUttal RLaufer DATE 11/8/02 11/8/02 10/15/02 10/24/02 11/8/02 OFFICIAL RECORD COPY
Beaver Valley Power Station, Units 1 and 2 Mary OReilly, Attorney FirstEnergy Nuclear Operating Company FirstEnergy Corporation 76 South Main Street Akron, OH 44308 FirstEnergy Nuclear Operating Company Regulatory Affairs/Performance Improvement Larry R. Freeland, Manager Beaver Valley Power Station Post Office Box 4, BV-A Shippingport, PA 15077 Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305 Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.
Harrisburg, PA 17110-9364 Ohio EPA-DERR ATTN: Zack A. Clayton Post Office Box 1049 Columbus, OH 43266-0149 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 J. H. Lash, Plant Manager (BV-IPAB)
FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077 Rich Janati, Chief Division of Nuclear Safety Bureau of Radiation Protection Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P O Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 298 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station ATTN: M. P. Pearson, Director Services and Projects (BV-IPAB)
Post Office Box 4 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mr. B. F. Sepelak Post Office Box 4, BV-A Shippingport, PA 15077
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING A REQUEST FOR RELIEF FROM INSERVICE TESTING OF BORIC ACID TRANSFER PUMPS PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNIT NO. 1 DOCKET NO. 50-334
1.0 INTRODUCTION
By letter dated July 8, 2002, FirstEnergy Nuclear Operating Company (FENOC) submitted Pump Relief Request No. 6 (PRR6) that proposed an alternative to certain inservice testing (IST) requirements of Section XI of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code (ASME Code) for the boric acid transfer pumps at Beaver Valley Power Station, Unit 1 (BVPS-1). In PRR6, FENOC requests relief from the ASME OM Standard, Part 6, Paragraph 5.2 and Table 2 requirements. As an alternative to the requirements, FENOC proposes to test quarterly through a fixed resistance non-instrumented minimum flow recirculation line, and test at a refueling frequency while on-line or during refueling outages at full flow through a larger recirculation line, using a portable flow meter.
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, requires that the IST of certain ASME Code, Class 1, 2, and 3, pumps and valves be performed in accordance with Section XI of the ASME Code and applicable addenda, except where proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a(a)(3)(i) or (a)(3)(ii), or relief has been requested and granted pursuant to 10 CFR 50.55a(f)(6)(i). In proposing alternatives or requesting relief, the applicant must demonstrate that: (1) the proposed alternative provides an acceptable level of quality and safety; (2) compliance would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for its facility. Nuclear Regulatory Commission (NRC) guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants.
2.0 BACKGROUND
By letter dated July 8, 2002, FENOC submitted a request for relief (PRR6) from, and proposed an alternative to, certain IST requirements of ASME Code,Section XI, for the boric acid transfer pumps at BVPS-1. Specifically, the licensees Relief Request, PRR6, seeks relief from the pump testing requirements of OM-6, Paragraph 5.2 and Table 2. As an alternative to the requirements, FENOC proposes to test quarterly through a fixed resistance non-instrumented minimum flow recirculation line, and test at a refueling frequency while on-line or during refueling outages at full flow through a larger recirculation line, using a portable flow meter.
3.0 CODE REQUIREMENTS The boric acid transfer pumps at BVPS-1 are required to be tested in accordance with the ASME OM Standard, Part 6, Paragraph 5.2 and Table 2. More specifically, these portions of the OM standard require pump flow rate and differential pressure to be measured and recorded at specified pump running conditions.
4.0 LICENSEES BASIS FOR RELIEF The licensee states:
Testing the Boric Acid Transfer pumps using the emergency boration flow path is impractical during power operation because it would inject water with higher concentration of boric acid into the RCS which would result in a reactivity transient and subsequent reactor shutdown. Therefore, the code-required quarterly testing is performed using an alternate test loop.... During normal plant operations, the pumps are tested quarterly through [RO-1CH-ORBA-1(2)], the restricting orifices in the minimum flow fixed resistance recirculation lines. Because of the restricting orifices, the flow is assumed to be fixed at its reference value. Delta-P and vibration are then measured and compared to the acceptance criteria. Position 9 of GL 89-04 states that In cases where flow can only be established through a non-instrumented minimum flow path during quarterly pump testing and a path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions, the staff has determined that the increased interval is an acceptable alternative to the code requirements, provided that pump differential pressure, flow rate, and bearing vibration measurements are taken during this testing and that quarterly testing also measuring at least pump differential pressure and vibration is continued.
Therefore, in accordance with Position 9 of the GL 89-04, the pumps have also been tested through their full flow recirculation flow paths through [HCV-1CH-110(105)], at a refueling frequency. For the full-flow recirculation test, the flow is measured using a portable ultrasonic flow meter that has been wet flow calibrated to within the +- 2%
accuracy required by ASME. In order to install the flow meters, however, the insulation on the piping must be removed and the heat trace elements must be moved away from where the transducers and tracks will be installed. Moving the heat trace elements places stresses on them, which increases the probability of failure of the heat trace elements. The heat tracing on the boric acid piping is needed to support system operability. Therefore, it is also impractical to test the pumps at a cold shutdown frequency.
A review of plant test results has shown that this combination of quarterly and refueling frequency testing is capable of assessing pump performance and detecting degradation.
The use of the portable ultrasonic flow meter and full-flow recirculation flow path was considered for the quarterly test. It was determined, however, that use of the full-flow recirculation line was impractical for quarterly testing. Testing quarterly using the temporary ultrasonic flow meter would lead to the increased probability of failure of the heat trace elements and to increased dose for the laborers who remove/re-install the insulation and the technicians who install the flow meters. In addition, additional calibrated flow instrumentation would have to be purchased to ensure the availability of the equipment. Permanently installing the flow meters would require a design change to the plant and the purchase of additional flow instrumentation. Performing the full-flow test quarterly and during cold shutdowns would not enhance our ability to assess the operability of the pumps enough to justify the increased cost or a system design change.
In addition, testing during refueling outages diverts manpower from other refueling tasks. These tests must be scheduled at a time in the outage when the Boric Acid Tanks are not required to be part of the Technical Specification (TS) boration flow path and must be coordinated with power supply outages. Even though the actual performance of these tests may be completed in a relatively short time, the test set-up and restoration is approximately 8-10 hours for each pump. Removing the tests from the outage schedule would allow a greater focus on other safety related tasks without impacting the level of quality and safety of the Boric Acid Transfer Pumps. In addition, a PRA risk evaluation has determined that there is no increase in risk for the performance of this test, whether on-line or during refueling outages. Therefore, it is requested to perform the full-flow test on a refueling frequency while on-line, typically in the weeks just prior to the refueling outage. Overall, proper monitoring of pump performance will be maintained via quarterly testing and full flow testing on a refueling frequency.
5.0 PROPOSED ALTERNATIVE TESTING The licensee states:
In accordance with position 9 of GL 89-04, test quarterly through a fixed resistance minimum flow recirculation line: assuming flow to be constant and measuring delta-P in OST-7.1(2), Boric Acid Transfer Pump Operational Tests, and test at a refueling frequency while on-line in the weeks prior to a refueling outage or during refueling outages at full-flow through a larger recirculation line, using a portable ultrasonic flow meter in OST-7.13(14), Boric Acid Transfer Pump Full-flow Tests.
Separate vibration reference and acceptance criteria values will be used for the different test conditions of the recirculation and full flow tests.
6.0 EVALUATION The licensee proposes to implement an alternative to the flow rate determination and recording requirements of OM Standard, Part 6, Paragraph 5.2, Test Procedure, and Table 2, Inservice Test Parameters. The licensees alternative is to test quarterly through a fixed resistance minimum flow recirculation line (assuming flow to be constant and measuring delta-P) and test at a refueling frequency while on-line in the weeks prior to a refueling outage or during refueling outages at full flow through a larger recirculation line, using a portable ultrasonic flow meter.
Testing the boric acid transfer pumps on-line using the emergency boration flow path would inject water with a higher concentration of boric acid into the reactor coolant system which would result in a reactivity transient and subsequent reactor shutdown and is impractical to perform. Testing the boric acid transfer pumps at cold shutdown using the emergency boration flow path is impractical since it also would result in the addition of water with a higher concentration of boric acid and possibly impact the ability of the plant to restart, due to the time required to dilute the excess boron in preparation for startup.
The licensees proposed alternative is consistent with the NRC staffs Position 9, outlined in NRC GL 89-04, except for when the full-flow test is performed. In Position 9 of GL 89-04, the staff states, In cases where flow can only be established through a non-instrumented minimum-flow path during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test of the pump under full or substantial flow conditions, the staff has determined that the increased interval is an acceptable alternative to the code requirements provided that pump differential pressure, flow rate, and bearing vibration measurements are taken during testing and that quarterly testing also measuring at least pump differential pressure and vibration is continued.
Position 9 does not address on-line testing through a non-instrumented full-flow recirculation line. The full-flow recirculation line requires the installation of a portable ultrasonic flow meter to determine system flow rate. Installation of the portable flow meter requires removal of the piping insulation and movement of the heat trace elements away from where the transducers and tracks will be installed. Moving the heat trace elements places stresses on them, which increases the probability of failure of the heat trace elements. Permanently installing the flow meters would require a design change to the plant and the purchase of additional flow instrumentation. Quarterly testing through the full-flow recirculation line would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The staff concludes that testing the boric acid transfer pumps on-line through a non-instrumented full-flow recirculation line using a portable ultrasonic flow meter will adequately determine equipment condition without causing operational concerns, such as reactivity transients, or increase overall plant risk from a probabilistic risk assessment perspective.
Therefore, the NRC staff finds that the licensees proposed IST alternative to test the pumps (1) quarterly through a fixed-resistance minimum flow recirculation line measuring pump differential pressure and vibration and (2) on a refueling frequency (while on-line or during refueling outages) through a larger full-flow recirculation line, measuring pump differential pressure, flow rate (using a portable ultrasonic flow meter), and vibration, as described in relief request PRR6, provides an adequate method to assure operational readiness of the pumps and meets the intent of GL 89-04, Position 9. Furthermore, the NRC staff finds that the licensees proposed alternative to the ASME Code flow rate determination and recording requirements for the boric acid transfer pumps provides an acceptable level of quality and safety. Therefore, the proposed alternative testing is authorized for the remainder of the third interval pursuant to 10 CFR 50.55a(a)(3)(i).
7.0 CONCLUSION
The NRC staff evaluated the licensees submittal and finds that the proposed alternative to the Code flow rate determination and recording requirements for the boric acid transfer pumps provides an acceptable level of quality and safety. Therefore, the proposed alternative to the flow rate determination and recording requirements of OM-6, Paragraph 5.2, Test Procedure, and Table 2, Inservice Test Parameters, is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the remainder of the third interval.
Principal Contributors: W. K. Poertner D. Collins Date: November 12, 2002