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10 CFR 50.55a Request VRR3 Regarding Solenoid Operated Valve Remote Position Verification Frequency
	ML110550162
Person / Time
Site:	Beaver Valley
Issue date:	02/21/2011
From:	Harden P; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-11-020
	Download: ML110550162 (18)
	v • d • e

FENOC Beaver Valley Power Station FENOCP.O.

Box 4 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Paul A. Harden 724-682-5234 Site Vice President Fax: 724-643-8069 February 21, 2011 L-11-020 10 CFR 50.55a ATTN: 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 VRR3 Regarding Solenoid Operated Valve Remote Position Verification 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.

Position verification testing of certain solenoid-operated valve assemblies included in the BVPS, Unit Nos. 1 and 2 IST Programs is currently performed in accordance with the frequency described in Paragraph ISTC-3700 of the American Society of Mechanical Engineers Operations and Maintenance Code-2001 Edition, with Addenda through OMb-2003. Enclosed is a proposed alternative to perform position verification testing of these solenoid-operated valve assemblies at the test frequency specified by 10 CFR 50 Appendix J, Option B for Type C valve leakage tests.

In support of the spring 2012 refueling outage, FENOC requests approval of the proposed requests by March 2012.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -

Fleet Licensing, at 330-761-6071.

Paul A. Harden

Beaver Valley Power Station, Unit Nos. 1 and 2 L-1 1-020 Page 2

Enclosure:

10 CFR 50.55a Request Number: VRR3, Proposed Alternative in Accordance with 10 CFR50.55a(a)(3)(i) cc:

NRC Region I Administrator NRC Senior Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

10 CFR 50.55a Request Number: VRR3 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

Page 1 of 16

-- Alternative Provides Acceptable Level of Quality and Safety--

1.0 ASME Code Components Affected

The following Class 2, Category A, valves:

SOV-1 HY-102A1, SOV-1 HY-1 02A2, SOV-1HY-102B1, SOV-1HY-102B2, SOV-1 HY-1 03A1, SOV-1 HY-1 03A2, SOV-1HY-103B1, SOV-1HY-103B2, SOV-1HY-104A1, SOY-1 HY-104A2, SOV-1HY-104B1, SOV-1 HY-1 04B2, 2HCS*SOV133A, 2HCS*SOV133B, 2HCS*SOV134A, 2HCS*SOV1 34B, 2HCS*SOV135A, 2HCS*SOV135B, 2HCS*SOV1 36A, 2HCS*SOV1 36B, 2HCS*SOV1 14A, 2HCS*SOV1 14B, 2HCS*SOV1 15A, 2HCS*SOV1 15B, A Hydrogen Analyzer Containment Dome Inlet Flow Sample A Hydrogen Analyzer Containment Dome Inlet Flow Sample B Hydrogen Analyzer Containment Dome Inlet Flow Sample B Hydrogen Analyzer Containment Dome Inlet Flow Sample A Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample A Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample B Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample B Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample A Hydrogen Analyzer Flow Sample Discharge A Hydrogen Analyzer B Hydrogen Analyzer B Hydrogen Analyzer Hydrogen Analyzer A Hydrogen Analyzer B Hydrogen Analyzer A Hydrogen Analyzer B Hydrogen Analyzer B Hydrogen Analyzer B Hydrogen Analyzer A Hydrogen Analyzer A Flow Sample Discharge Flow Sample Discharge Flow Sample Discharge Outlet Inside Containment Isolation Outlet Inside Containment Isolation Outlet Outside Containment Isolation Outlet Outside Containment Isolation Inlet Inside Containment Isolation Inlet Outside Containment Isolation Inlet Inside Containment Isolation Inlet Outside Containment Isolation Containment Isolation to Hydrogen Recombiner 21A Containment Isolation to Hydrogen Recombiner 21 B Backup Containment Isolation to Hydrogen Recombiner 21A Backup Containment Isolation to Hydrogen Recombiner 21B

Beaver Valley Power Station, Units 1 and 2 10 CFR 50.55a Request VRR3 Page 2 of 16 2.0

Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM)

Code-2001 Edition, with Addenda through OMb-2003.

3.0

Applicable Code Requirement

Paragraph ISTC-3700, "Position Indication Verification," of the ASME OM Code states in part that valves with remote position indicators shall be observed locally at least once every two years to verify that valve operation is accurately indicated.

4.0

Reason for Request

The valves listed in Section 1 are category A containment isolation valves and are required by Beaver Valley Power Station (BVPS) inservice test programs to be seat leakage tested in accordance with 10 CFR 50 Appendix J (Option B, Type C). Due to the design of the valves, position verification testing is performed in conjunction with the Type C leak test. Each of the listed valves is a solenoid operated valve (SOV) designed such that the position of the valve cannot be observed locally. The design of these valves is such that the coil position is internal to the valve body and is not observable in either the energized or de-energized state. In accordance with ISTC-3700, where local observation is not possible, other indications shall be used to verify valve position.

The required valves are seat leakage tested using local leakage rate test equipment as part of the Appendix J Type C Leak Test Program at BVPS, the leakage rate test also performs the position verification test. This method involves attempting to pressurize the containment penetration volume to approximately 45 psig for BVPS-1 and approximately 46 psig for BVPS-2 with the valve open as indicated by its remote position lights on the Control Room bench board. If the attempt to pressurize the containment penetration fails, the valve position is verified to be open. The valve is then closed using the control switch in the Control Room and the containment penetration volume is pressurized to approximately 45 psig for BVPS-1 and approximately 46 psig for BVPS-2. Being able to maintain pressure in the penetration while the valve is indicating closed by its remote position lights on the Control Room bench board verifies the valve is closed. This method satisfies the requirement for position verification testing and ensures that the remote indicating lights in the Control Room accurately reflect the local valve position in the field.

Position verification testing is required to be performed once every two years and is typically performed during a refueling outage, regardless if the containment penetration is due for Type C leakage testing or not. In order to perform Type C leakage testing, piping and valves associated with the individual valve being tested are drained, vented and aligned. Because the position verification test requires the Type C leakage test to be performed, the above actions are completed during each refueling outage.

Performing the position verification test at the same frequency as the Appendix J Type C leakage test, will result in dose and operations and test personnel time savings, since

Beaver Valley Power Station, Units 1 and 2 10 CFR 50.55a Request VRR3 Page 3 of 16 the test would be performed with the leakage test and would not be performed as frequently.

5.0 Proposed Alternative and Basis for Use Proposed Alternative As an alternative to the ISTC-3700 test interval of at least once every two years, it is proposed that the required position verification testing of the valves listed in Section 1.0 be performed in conjunction with the Type C seat leakage test at the frequency specified by 10 CFR 50 Appendix J, Option B for the Type C leakage test. This test interval may be adjusted to a frequency of testing commensurate with Option B of 10 CFR 50 Appendix J for Type C seat leakage testing based on valve seat leakage performance. If a valve fails a leak test representing an unacceptable remote position verification, the valve test frequency (including position verification testing) will be adjusted in accordance with 10 CFR 50 Appendix J, Option B.

Basis for Use The hydrogen analyzer valves are normally closed and must remain closed for isolation of BVPS Unit No. 1 (BVPS-1) containment penetration numbers 109-44, 95-64, 109-49, 95-69, 109-52 and 95-72, and BVPS Unit No. 2 (BVPS-2) containment penetration numbers 105b, 97b, 57c and 55c. Following an accident, they must be capable of opening to allow the hydrogen analyzers to obtain a sample from the containment dome.

The hydrogen recombiner valves 2HCS*SOV114A and 2HCS*SOV115A provide isolation of BVPS-2 containment penetration number 93. These valves are normally closed under Shift Manager Clearance #2BVP-CYC-014-1/2W-2W00-46-SM-002A, due to the associated hydrogen recombiner system being retired in place. Therefore, these SOVs are not required to be stroke timed. However, these valves may be opened following a severe beyond design bases accident to vent the containment atmosphere via the containment atmosphere purge blower.

The hydrogen recombiner valves 2HCS*SOV114B and 2HCS*SOV115B are normally closed and provide isolation of BVPS-2 containment penetration number 92. These valves are maintained in their safety position and are passive valves. Therefore, these SOVs are not required to be stroke timed.

Option B of 10 CFR 50 Appendix J permits the extension of Type C leakage testing to a frequency based on leakage-rate limits and historical valve performance. Valves whose leakage test results indicate good performance may have their seat leakage test frequency extended up to 60 months or three refueling outages (based on an 18-month fuel cycle). In order for a valve's seat leakage test frequency to be extended, the individual containment isolation valve must first successfully pass two consecutive as-found seat leakage tests before it can be placed on an extended seat leakage test frequency.

The valves listed in Section 1 that are required to be stroke timed tested are exercised on a quarterly test frequency with their stroke times measured and compared to ASME OM Code acceptance criteria of less than two seconds. Over the past five refueling

Beaver Valley Power Station, Units 1 and 2 10 CFR 50.55a Request VRR3 Page 4 of 16 outages at BVPS-1 and past five refueling outages at BVPS-2, the associated valves have passed the position verification test performed in conjunction with its Type C leakage test. The attached table provides each valve's history including stroke times, leakage rates, and remote position verifications. Valve performance data is recorded into a database and trended by the inservice testing coordinator. If the leak rate exceeds the allowable limit, the valves are repaired or replaced. Any maintenance performed on these valves that might affect position indication is followed by an applicable post-maintenance test including position verification testing regardless of the Type C test frequency.

Valve exercise testing each quarter and position verification and seat leakage testing in accordance with frequency specified by 10 CFR 50 Appendix J, Option B, provides an adequate assessment of valve health and therefore an acceptable level of quality and safety. A dose savings of approximately 55 mR for both units is expected with the implementation of this 10 CFR 50.55a request. Therefore, radiation exposure as well as Operations and test personnel time will be reduced by performing the position indication verification test at the same interval as the Appendix J seat leakage test.

The ability to detect degradation and to ensure the operational readiness of the subject valves to perform their intended functions is not jeopardized by performing the position verification testing at the same test frequency as specified in 10 CFR 50 Appendix J, Option B. This frequency of testing and the provisions of this 10 CFR 50.55a request will demonstrate an acceptable level of quality and safety, since the alternative provides reasonable assurance of valve operational readiness.

6.0 Duration of Proposed Alternatives The proposed alternative identified in this request shall be utilized during the remainder of the BVPS Unit No. 1 fourth 10-Year Inservice Test Interval and the remainder of the BVPS Unit No. 2 third 10-Year Inservice Test Interval.

Beaver Valley Power Station, Units 1 and 2 10 CFR 50.55a Request VRR3 Page 5 of 16 Valve History Rates and Remote Position Verifications Stroke Times. Leak Date or Stroke Open Stroke Shut Leak Leak Remote Valve Refueling Time Limit Time Limit Rate Rate Pos.

Outage Open (sec.)

Shut (sec.)

L-11-020, 10 CFR 50.55a Request VRR3 Regarding Solenoid Operated Valve Remote Position Verification Frequency