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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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-FENOC Beaver Valley Power Station P.O.:Box 4 FirstEnergyNuclear OperatingCompany Shippingport,PA 15077 PaulA. Harden 724-682-5234 Site Vice President Fax: 724-643-8069 February 21, 2011 L-1 1-021 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 Proposed 10 CFR 50.55a Request VRR4 Regarding Pressurizer Safety Valve Test Frequency In accordance with 10 CFR 50.55a, FirstEnergy Nuclear Operating Company (FENOC) requests Nuclear Regulatory Commission (NRC) approval of a proposed alternative for the Beaver Valley Power Station, Unit No. 2 (BVPS-2) third interval Inservice Testing Program for Pumps and Valves (IST Program).
Testing of pressurizer safety valve assemblies included in the BVPS-2 IST Program is currently performed in accordance with the frequency described in Appendix I, Paragraph 1-1320(a) of the ASME OM Code-2001 Edition, "Code for Operation and Maintenance of Nuclear Power Plants," with Addenda through OMb-2003. Enclosed is a proposed alternative to perform testing of these pressurizer safety valve assemblies at the test frequency specified in ASME OM Code Case OMN-17.
In support of the fall 2012 refueling outage, FENOC requests approval of the proposed requests by May 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.
Since ly, Paul A. Harden Ao4 7
Beaver Valley Power Station, Unit No. 2 L-1 1-021 Page 2
Enclosure:
10 CFR 50.55a Request Number: VRR4, 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: VRR4 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
Page 1 of 3
--Alternative Provides Acceptable Level of Quality and Safety--
1.0 ASME Code Components Affected
The following Class 1, Category C, valves:
2RCS*RV551A, Pressurizer Safety Valve 2RCS*RV551 B, Pressurizer Safety Valve 2RCS*RV551C, Pressurizer Safety Valve 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 Appendix I, Paragraph 1-1320, "Test Frequencies, Class I PressureRelief Valves," of the ASME OM Code-2001 Edition, subparagraph (a), "5-Year Test Interval," states that:
Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval. This 20% shall consist of valves that have not been tested during the current 5-year interval, if they exist. The test interval for any individual valve shall not exceed 5 years.
4.0 Reason for Request Beaver Valley Power Station Unit No. 2 (BVPS-2) has three (3) pressurizer safety valves installed to protect the reactor coolant system from overpressure. Since BVPS-2 operates on an 18-month fuel cycle, one valve can be tested each refueling outage such that each valve is tested over a 4.5 year period. In order to avoid outage delays due to valve testing, a pressurizer safety valve is replaced during each refueling outage with a spare valve that has been tested. The removed valve is refurbished and tested for installation during the following refueling outage. In order to ensure the spare replacement valve does not exceed the five-year test interval limit from test to test, it must be tested within six months prior to installation.
ASME OM Code Case OMN-1 7, "Alternate Rules for Testing ASME Class I Pressure Relief/Safety Valves" allows a six-year test interval plus an additional six months grace period coinciding with a refueling outage in order to accommodate extended shutdown periods. Extending the maximum test interval to six years with a six month grace period would allow BVPS-2 to continue to rotate in a spare pressurizer safety valve without the need to test the spare valve within six months of installation.
Beaver Valley Power Station, Unit No. 2, 10 CFR 50.55a Request VRR4 Page 2 of 3 5.0 Proposed Alternative and Basis for Use Proposed Alternative As an alternative to the ASME OM Code-2001 Edition, Appendix I, Paragraph 1-1320(a) test interval of at least once every five years, FENOC proposes to test pressurizer safety valves at least once every six years plus a six month grace period, if required, in accordance with the periodicity and other requirements of ASME OM Code Case OMN-17. Code Case OMN-17 provisions will not be applied to a valve until the valve is disassembled and inspected as described in the following paragraph.
Paragraph (d) of ASME OM Code Case OMN-17 requires disassembly and inspection of each valve after as-found set pressure testing is performed in order to verify that parts are free of defects resulting from time related degradation or service induced wear. Paragraph (e) of ASME OM Code Case OMN-17 requires each valve to be disassembled and inspected in accordance with Paragraph (d) prior to the start of the 72 month test interval.
Basis for Use The longer test interval will eliminate the need for a valve test within six months of installation during each refueling outage. Eliminating the test will in turn remove the risk of any return shipping damage to the valve from the offsite testing facility and reduce wear on metal valve seats due to steam testing.
The as-found set-pressure acceptance criteria is plus or minus three (3) percent of valve nameplate set pressure in accordance with Paragraph 1-1320(c)(1) of ASME OM Code-2001 Edition, Appendix I. Since 1989, eighteen (18) as-found set pressure tests have been performed for the four Crosby Model HB-86-BP pressurizer safety valves (including the spare valve). A summary of test results is shown in the table on page 3.
These tests have been performed at an offsite test facility using saturated steam. The majority of the tests were performed after the valve was installed for three operating cycles. As-found tests were within plus or minus three (3) percent of the valve set pressure with the exception of valve 2RCS*RV551 C, which lifted low (minus 5.6 percent) in 1989 due to excessive seat leakage. Technical Specification Surveillance 3.4.10.1 requires that following testing, lift settings shall be within plus or minus one (1) percent. For 12 of the 18 tests, the valves were found within the as-left tolerance of plus or minus one (1) percent. These test results show limited time related degradation or set point drift and demonstrate that it is acceptable to extend the test interval from 4.5 years (three fuel cycles) to 6 years with a six-month grace period (four fuel cycles).
When the proposed alternative is applied to a valve, the valve will be disassembled and inspected after as-found set pressure testing is performed in accordance with ASME OM Code Case OMN-17 paragraphs (e) and (f). The initial inspection and ongoing inspections will verify that valve parts are free of defects resulting from time related degradation or service induced wear. These inspections provide additional assurance that the pressurizer safety valves will perform their intended function.
Beaver Valley Power Station, Unit No. 2, 10 CFR 50.55a Request VRR4 Page 3 of 3 The ability to detect degradation and ensure the operational readiness of the pressurizer safety valves to perform their intended function is assured based on the valve test history and by performing the required inspection and testing initially and at the proposed alternative frequency. Therefore, test and inspection of the valves in accordance with the proposed alternative demonstrates an acceptable level of quality and safety.
Summary of Test Results BVPS-2 Pressurizer Safety Valves Outage 2RCS*RV551A 2RCS*RV551B 2RCS*RV551C Comments Year 2R01 / 1989 2486 psig 2346 psig B within 1%
C lifted below 3%1 2R02 / 1990 2474 psig Within 1%
2R03 / 1992 2435 psig Within 3%
2R04 / 1993 2464 psig Within 1%
2R05 / 1995 2485 psig Within 1%
2R06 / 1996 2484 psig Within 1%
CSD /1998 2513 psig Within 3%
2R07 / 1999 2492 psig Within 1%
2R08 / 2000 2548 psig Within 3%
2R09 / 2002 2465 psig Within 1%
2R10 /2003 2513 psig 2464 psig B within 3% and C within 1%
2R1 1 / 2005 2449 psig Within 3%
2R12 /2006 2491 psig Within 1%
2R13 /2008 2483 psig 2466 psig Both within 1%
2R14/2009 2479 psig Within 1%
BVPS-2 Refueling Outage (2R) Pounds per square inch gauge (psig)
Cold Shut Down (CSD) Setpoint = 2485 psig 2RCS*RV551B (B) Plus or minus 3 percent = 2559.5 - 2410.5 psig 2RCS*RV551C (C) Plus or minus 1 percent = 2509.8 - 2460.2 psig Note 1. Valve lifted due to seat leakage.
6.0 Duration of Proposed Alternative The duration of the proposed alternative is the remainder of the BVPS-2 third 10-Year Inservice Test Interval.