ML041660343

Evaluation of Inservice Testing (IST) Proposed Revisions 1J and 2H to Pump Relief Request No. 7

ML041660343
Person / Time
Site:	Beaver Valley
Issue date:	07/02/2004
From:	Richard Laufer NRC/NRR/DLPM/LPD1
To:	Pearce L FirstEnergy Nuclear Operating Co
Harold J, NRR/DLPM, 415-1421
References
TAC MC2317, TAC MC2318
Download: ML041660343 (8)

Text

July 2, 2004 Mr. L. William Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - EVALUATION OF INSERVICE TESTING (IST) PROPOSED REVISIONS 1J AND 2H TO PUMP RELIEF REQUEST NO. 7 (TAC NOS. MC2317 AND MC2318)

Dear Mr. Pearce:

By letter dated March 12, 2004, FirstEnergy Nuclear Operating Company (the licensee) submitted a relief request for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(a)(3)(ii). The March 12, 2004, letter was superceded by letter dated March 26, 2004, in which the licensee requested essentially the same relief in accordance with 10 CFR 50.55a(f)(5)(iii). Specifically, the licensee requested relief from the testing requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, which references the OM-6 Standard, as it applies to the testing of the residual heat removal (RHR) pumps for BVPS-1 and 2. The requirements include that IST shall be run on each pump nominally every 3 months. The licensee requested approval to use an alternative testing method that would require testing every cold shutdown and during refueling outages but not more frequently than once every 92 days. The licensees basis for this request is that the OM-6 Standard requirements, as stated above, are impractical.

The Nuclear Regulatory Commission (NRC) staff has completed its review of the licensees relief request and the proposed alternative. As described in the enclosed safety evaluation, the NRC staff has found that the OM-6 Standard requirements, as stated above, are impractical.

Therefore, the NRC staff has authorized Revision 1J to Pump Relief Request No. 7 for BVPS-1 for the third 10-year IST interval, and Revision 2H to Pump Relief Request No. 7 for BVPS-2 for the second 10-year IST interval, pursuant to 10 CFR 50.55a(f)(6)(i), on the basis that the proposed alternative provides reasonable assurance that the RHR pumps are operationally ready and on the basis that the granting of relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

L. Pearce If you have any questions, please contact the BVPS-1 and 2 Project Manager, Mr. Timothy G.

Colburn, at (301) 415-1402.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

Safety Evaluation cc w/encl: See next page

ML041660343 OFFICE PDI-1/PM PDI-1/LA EMEB OGC PDI-1/SC NAME TColburn MOBrien DTerao GLongo RLaufer DATE 06/17/04 06/17/04 06/24/04 06/28/04 07/01/04 Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Mary OReilly, Attorney Rich Janati, Chief FirstEnergy Nuclear Operating Company Division of Nuclear Safety FirstEnergy Corporation Bureau of Radiation Protection 76 South Main Street Department of Environmental Protection Akron, OH 44308 Rachel Carson State Office Building P.O. Box 8469 FirstEnergy Nuclear Operating Company Harrisburg, PA 17105-8469 Regulatory Affairs/Performance Improvement Mayor of the Borough of Shippingport Larry R. Freeland, Manager P O Box 3 Beaver Valley Power Station Shippingport, PA 15077 Post Office Box 4, BV-A Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Commissioner James R. Lewis 475 Allendale Road West Virginia Division of Labor King of Prussia, PA 19406 749-B, Building No. 6 Capitol Complex Resident Inspector Charleston, WV 25305 U.S. Nuclear Regulatory Commission Post Office Box 298 Director, Utilities Department Shippingport, PA 15077 Public Utilities Commission 180 East Broad Street FirstEnergy Nuclear Operating Company Columbus, OH 43266-0573 Beaver Valley Power Station ATTN: R. G. Mende, Director Director, Pennsylvania Emergency Work Management (BV-IPAB)

Management Agency Post Office Box 4 2605 Interstate Dr. Shippingport, PA 15077 Harrisburg, PA 17110-9364 FirstEnergy Nuclear Operating Company Ohio EPA-DERR Beaver Valley Power Station ATTN: Zack A. Clayton Mr. B. F. Sepelak Post Office Box 1049 Post Office Box 4, BV-A Columbus, OH 43266-0149 Shippingport, PA 15077 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

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE TESTING (IST) - PUMP RELIEF REQUEST NO. 7 - REVISIONS 1J AND 2H BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 (BVPS-1 AND 2)

FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NUMBERS 50-334 AND 50-412

1.0 INTRODUCTION

By letter dated March 12, 2004, FirstEnergy Nuclear Operating Company (FENOC, the licensee) submitted a relief request for BVPS-1 and 2 in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(a)(3)(ii). The March 12, 2004, letter was superceded by letter dated March 26, 2004, in which the licensee requested essentially the same relief in accordance with 10 CFR 50.55a(f)(5)(iii). Specifically, the licensee requested relief for residual heat removal (RHR) pumps 1-RH-P-1A/1B and 2RHS*P21A/P21B from the requirements in the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, which references the ASME OM-6 Standard for inservive testing (IST) of pumps. Specifically, the licensee requested relief from the ASME OM-6 Standard, Paragraph 5.1, Frequency of Inservice Tests, that requires an IST shall be run on each pump, nominally every 3 months.

2.0 REGULATORY EVALUATION

2.1 Requirements Section 50.55a of 10 CFR Part 50, requires that IST of certain ASME Code, Class 1, 2, and 3 pumps and valves be performed at 120-month IST program intervals in accordance with the specified ASME Code and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Nuclear Regulatory Commission (NRC) pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of subsequent 120-month IST program intervals. In proposing alternatives or requesting relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for the facility. Section 50.55a authorizes the NRC to approve alternatives to and grant relief from ASME Code requirements upon making the necessary findings. NRC guidance in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Program, provides acceptable alternatives to the ASME Code requirements.

Further guidance is provided in GL 89-04, Supplement 1, and NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants.

The requirements of the ASME OM Code, OM-6 Standard, Paragraph 5.1, state that IST shall be run on each pump nominally every 3 months.

2.2 Licensees Basis for Relief from the Requirement of OM-6, Paragraph 5.1 (As Stated)

In accordance with 10 CFR 50.55a(f)(5)(iii), relief is requested on the basis that compliance with the Code test frequency requirement above is impractical.

The Residual Heat Removal (RHR) Pumps are in a standby condition during power operation, and are not required to be in service until the Reactor Coolant System (RCS) temperature is #350 [degrees] F and RCS pressure is #430 psig

[for BVPS-1 and #360 psig for BVPS-2]. Therefore, they are not exposed to operational wear except when the RCS is at low temperature and pressure and the RHR System is operating.

The RHR Pumps have a design pressure of 600 psig. They take suction from the RCS, pass flow through the RHR Heat Exchangers, and then discharge back to the RCS. The RHR System is considered to be a low pressure system that could be damaged if exposed to the normal operating RCS pressure of approximately 2235 psig. In order to prevent this, the RHR Inlet and Return Isolation Valves are interlocked with an output signal from the RCS pressure transmitters which prevent the valves from being opened when the RCS pressure exceeds 430 psig [for BVPS-1 and 360 psig for BVPS-2]. In addition, these valves are also maintained shut with their breakers de-energized and administratively controlled (caution tagged). Therefore, testing of the RHR Pumps during normal operation is not practicable.

In addition, the RHR Pumps are located inside Containment, and if tested at power, test personnel would have to make a Containment entry in order to properly monitor pump operation. However, the BVPS-1 [and -2] Containment is presently maintained subatmospheric as required by Technical Specifications.

This subatmospheric condition as well as high radiological dose rates at the pumps presents a hazardous working environment for station personnel and is considered inaccessible for quarterly surveillance testing.

Based on the above, compliance with the ASME XI Code test frequency requirement (quarterly) is impractical. Therefore, testing is only possible during a surveillance interval frequency of cold shutdown and refueling.

2.3 Licensees Proposed Alternative Testing (As Stated)

These pumps will be tested during cold shutdowns and refueling outages, not more often than once every 92 days, per 1OST-10.1 (Residual Heat Removal

Pumps Performance Test) [for BVPS-1 and per 2OST-10.1 and 2OST-10.2 (Residual Heat Removal Pumps Performance Test) for BVPS-2]. For a cold shutdown or refueling outage that extends longer than 3 months, the pumps will be tested every 3 months in accordance with OM-6, Paragraph 5.1.

3.0 TECHNICAL EVALUATION

The ASME OM-6 Standard, Paragraph 5.1, requires that IST be performed quarterly on each pump. The RHR pumps are low-pressure (600 psig design pressure) pumps which take suction from the RCS, pass flow through the RHR heat exchangers, and discharge back to the RCS.

The NRC staff notes that the RHR subsystem is isolated from the RCS before the RCS exceeds 500 psig by closing the inlet and return isolation valves and maintaining them shut with their breakers de-energized and administratively controlled (caution tagged). The RHR pumps sole suction source is the RCS. These RHR pumps are in a standby condition during power operation and are not exposed to operational wear except when the RCS is at low pressure and the RHR system is operating. Therefore, the proposed testing provides reasonable assurance that the RHR pumps are operationally ready. The RHR system is a low-pressure system that would rupture if exposed to the normal operating RCS pressure of approximately 2235 psig.

Also, the RHR motor-operated inlet and return isolation valves are interlocked with RCS pressure and cannot be opened when the RCS is at normal operating pressure. These pumps are inside containment and thus are inaccessible during power operation. Testing of the RHR pumps during normal operation is not practical. Therefore, compliance with the ASME Code test frequency requirement (quarterly) is impractical. A burden would be placed on the licensee because major plant and system modifications would be needed to allow quarterly testing of the RHR pumps according to the ASME Code requirements.

Based on the above information, the NRC staff finds that compliance with the ASME Code test frequency requirements is impractical and relief is granted pursuant to 10 CFR 50.55a(f)(6)(i).

4.0 CONCLUSION

Based on a review of the information provided by licensee, the NRC staff finds that compliance with the ASME Code test frequency requirements of OM-6 Standard, Paragraph 5.1, for the BVPS-1 and 2 RHR pumps is impractical, and grants relief pursuant to 10 CFR 50.55a(f)(6)(i) to the licensee for Revision 1J to Pump Relief Request No. 7 for BVPS-1 for the third 10-year IST interval, and for Revision 2H to Pump Relief Request No. 7 for BVPS-2 for the second 10-year IST interval, provided the licensee tests these pumps according to the ASME Code test method requirements during cold shutdown. The proposed testing provides reasonable assurance that the components are operationally ready.

The granting of relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Principal Contributors: J. Hardy T. Colburn Date: July 2, 2004