ML042800320

RAI, Elimination of Response Time Testing

ML042800320
Person / Time
Site:	Beaver Valley
Issue date:	10/25/2004
From:	Colburn T NRC/NRR/DLPM/LPD1
To:	Pearce L FirstEnergy Nuclear Operating Co
Colburn T, NRR/DLPM, 415-1402
References
TAC MC3894
Download: ML042800320 (6)

Text

October 25, 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, UNIT NO. 2 (BVPS-2) - REQUEST FOR ADDITIONAL INFORMATION (RAI) - ELIMINATION OF RESPONSE TIME TESTING (TAC NO. MC3894)

Dear Mr. Pearce:

By letter dated July 23, 2004, FirstEnergy Nuclear Operating Company submitted a request to eliminate certain periodic pressure sensor and protection channel response-time tests from the BVPS-2 Technical Specification surveillance requirements. The Nuclear Regulatory Commission staff has determined that the information contained in the enclosed RAI will be needed for the staff to complete its review. These questions were previously e-mailed to your staff on September 28, 2004, in draft form, for discussion during a September 29, 2004, conference call.

As discussed with your staff, we request your response within 45 days of receipt of this letter. If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-412

Enclosure:

RAI cc w/encl: See next page

ML042800320 *Input received. No substantive changes made.

OFFICE PDI-1/PM EEIB/SC PDI-1/SC NAME TColburn EMarinos* RLaufer DATE 10/20/04 09/22/04 10/21/04 REQUEST FOR ADDITIONAL INFORMATION (RAI)

BEAVER VALLEY POWER STATION, UNIT NO. 2 (BVPS-2)

ELIMINATION OF PERIODIC PRESSURE SENSOR AND PROTECTION CHANNEL RESPONSE-TIME TESTS DOCKET NO. 50-412 By letter dated July 23, 2004, FirstEnergy Nuclear Operating Company (the licensee) requested an amendment to the BVPS - 2 Technical Specifications (TSs) to allow the elimination of certain periodic pressure sensor and protection channel response-time tests. The Nuclear Regulatory Commission (NRC) staff has determined that the additional information below is needed to complete its review of the licensees application.

1. Note 1 in Table 1 stated: Allocated sensor response times for the ITT Barton 752, 763 (763A) and 764 pressure sensors specified in Table 1 are based on historical records (method 1) of acceptable response time testing (RTT) obtained from the BVPS-2 RTT program. The sensor response times for all sensors except the containment pressure sensors were obtained using the Analysis and Measurement Services (AMS) noise analysis method. The containment pressure sensor response times were obtained using a hydraulic RTT method. The historical response time data used as the bases for the allocated response times were the AMS sensor response time measurement tests performed on October 1998, August 2000, January 2002 and August 2003 and the containment pressure sensors hydraulic RTT performed between February 1995 and August 2003. The highest response time measured for the ITT Barton sensors were as follows: Barton 752 - 160 [milli-seconds (ms)]; Barton 763 (763A) - 370 ms; Barton 764

- 380 ms.

Since the most conservative value may not reflect the 95/95 confidence level if the number of total previous tests is small, please submit the actual values obtained in previous response time measurement tests.

2. On page 10 of Enclosure 1 of the submittal, it is stated: Some versions of 7300 cards installed (or planned to be installed) in BVPS Unit 2 are cards that have been re-designed since the original FEMA [failure effects and modes analysis] was performed for WCAP-14036-P-A (see Table 1, Note 3). These newer cards have been evaluated by Westinghouse for RTT elimination. The results of this evaluation for the newer NLP, NSA and NAL cards concluded that the differences in the re-designed cards are insignificant with respect to the conclusions of the original FEMA and that the FEMA and bounding response times documented in WCAP-14036-P-A, Revision 1 is applicable to these newer cards. A new FMEA was performed for the re-designed NRA cards. This FEMA was based on the original NRA FEMA methodology used for WCAP-14036-P-A, Revision 1. The Westinghouse evaluation concluded that the newer NRA cards meet the bounding response times listed in WCAP-14036-P-A, Revision 1".

ENCLOSURE

Please provide the new FEMA showing that the cards actually installed or planned for installation are bounded by the original FEMA, WCAP-14036, and the NRC staffs related Safety Evaluation.

Beaver Valley Power Station, Unit Nos. 1 and 2 Mary OReilly, Attorney Rich Janati, Chief FirstEnergy Nuclear Operating Company Division of Nuclear Safety FirstEnergy Corporation Bureau of Radiation Protection 76 South Main Street Deparment 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 Larry R. Freeland, Manager Shippingport Beaver Valley Power Station P O Box 3 Post Office Box 4, BV-A Shippingport, PA 15077 Shippingport, PA 15077 Regional Administrator, Region I Commissioner James R. Lewis U.S. Nuclear Regulatory Commission West Virginia Division of Labor 475 Allendale Road 749-B, Building No. 6 King of Prussia, PA 19406 Capitol Complex Charleston, WV 25305 Resident Inspector U.S. Nuclear Regulatory Commission Director, Utilities Department Post Office Box 298 Public Utilities Commission Shippingport, PA 15077 180 East Broad Street Columbus, OH 43266-0573 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Director, Pennsylvania Emergency ATTN: M. P. Pearson, Director Management Agency Services and Projects (BV-IPAB) 2605 Interstate Dr. Post Office Box 4 Harrisburg, PA 17110-9364 Shippingport, PA 15077 Ohio EPA-DERR FirstEnergy Nuclear Operating Company ATTN: Zack A. Clayton Beaver Valley Power Station Post Office Box 1049 Mr. B. F. Sepelak Columbus, OH 43266-0149 Post Office Box 4, BV-A 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