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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 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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 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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, 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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 PowerStation FirstEnergyNuclear OperatingCompany P.O. Box 4 Shippingport,PA 15077 PaulA. Harden 724-682-5234 Site Vice President Fax: 724-643-8069 September 14,2011 L-1 1-275 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 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Reply to Request for Additional Information Regarding 10 CFR 50.55a Requests VRR3 and VRR4 (TAC Nos. ME5749, ME5750, ME5752)
By letter dated February 21, 2011, FirstEnergy Nuclear Operating Company (FENOC) submitted 10 CFR 50.55a request VRR3 for authorization of a proposed alternative to the frequency of position verification testing specified in Paragraph ISTC-3700 of the American Society of Mechanical Engineers Operation and Maintenance Code (ASME OM Code). The request applies to testing of certain solenoid-operated valve assemblies during the Beaver Valley Power Station, Unit No. 1 (BVPS-1) fourth inservice testing (IST) program interval and for the BVPS-2 third IST program interval. By letter dated February 21, 2011, FENOC submitted 10 CFR 50.55a request VRR4 for authorization of a proposed alternative to the frequency of testing specified in Appendix I, Paragraph 1-1 320(a) of the ASME OM Code for pressurizer safety valve assemblies during the BVPS-2 third IST program interval.
The Nuclear Regulatory Commission (NRC) staff requested additional information to complete its review of 10 CFR 50.55a requests VRR3 and VRR4 in a letter dated August 22, 2011. FENOC's response to the NRC staff request for additional information is attached to this letter.
Beaver Valley Power Station, Unit Nos. 1 and 2 L-1 1-275 Page 2 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 330-315-6810.
Sincerel Paul A. Harden
Attachment:
Reply to Request for Additional Information Regarding 10 CFR 50.55a Requests VRR3 and VRR4 cc: NRC Region I Administrator NRC Resident Inspector NRR Project Manager Director BRP/DEP Site BRP/DEP Representative
ATTACHMENT L-1 1-275 Reply to Request for Additional Information Regarding 10 CFR 50.55a Requests VRR3 and VRR4 Page 1 of 3 By letter dated August 22, 2011 the Nuclear Regulatory Commission requested additional information to complete the review of 10 CFR 50.55a requests VRR3 and VRR4. Each request for information is shown below in bold text and is followed by the FENOC response.
Request VRR3:
- 1. For the valves subject to exercise testing, describe:
- i. the exercise test method; ii. the parameters that are measured or observed; and iii. the criteria for evaluating the results.
RESPONSE
The affected Beaver Valley Power Station, Unit No. 1 (BVPS-1) solenoid operated valves (SOVs) associated with the containment hydrogen analyzers are stroke timed open and closed one at a time on a quarterly frequency. The opening stroke time for each valve is measured from the time the control switch is placed in the open position until the red indicating light is the only indicating light remaining illuminated. The closing stroke time for each valve is measured from the time the control switch is placed in the closed position until the green indicating light is the only indicating light remaining illuminated. The stroke times are compared to a 2.0 second limiting stroke time established in accordance with Paragraph ISTC-5152(c) of the American Society of Mechanical Engineers Operations and Maintenance Code (ASME OM Code), 2001 Edition thru 2003 Addenda. If the stroke time is within the 2.0 second limiting stroke time, then the valve is considered to have passed and is operating acceptably.
The affected Beaver Valley Power Station Unit No. 2 (BVPS-2) SOVs associated with containment hydrogen analyzers are ganged in sets of two valves per control switch.
Two operators time the valves so that pre-conditioning is avoided by not cycling the valves more than once. For each valve, the opening stroke time is measured from the time the common control switch is placed in the open position until the red indicating light is the only indicating light remaining illuminated. For each valve, the closing stroke time is measured from the time the common control switch is placed in the closed position until the green indicating light is the only indicating light remaining illuminated.
The valves are stroke time tested quarterly.
The stroke times are compared to a 2.0 second limiting stroke time established in accordance with Paragraph ISTC-5152(c) of the ASME OM Code, 2001 Edition thru 2003 Addenda. If the stroke time is within the 2.0 second limiting stroke time, then the valve is considered to have passed and is operating acceptably.
Attachment L-1 1-275 Page 2 of 3 As discussed in Request VRR3, the affected BVPS-2 solenoid operated valves associated with the containment hydrogen recombiners are not required to be stroke time tested.
- 2. Have any evaluations been performed, such as probabilistic assessment risk
[sic] and expert panel review, to assess the change in aggregate risk associated with relaxing the interval for verification of obturator movement to as long as 60 months? If so, what were the results?
RESPONSE
No evaluations to assess changes in aggregate risk have been performed to support relaxing the two-year test interval for verifying SOV obturator movement. The valves are required by the Beaver Valley Power Station inservice test programs to be seat leakage tested in accordance with 10 CFR 50 Appendix J, Option B for Type C tests.
Option B requires testing at intervals based on the safety significance and historical performance of each valve. For over seven years the valves have not shown any position verification failures. This testing history supports the extended position verification frequency of up to five years under Option B. An evaluation to assess changes in aggregate risk was not performed because the proposed alternative is considered to be equally effective in demonstrating continuously acceptable valve performance, and there is no increase in the probability of a malfunction due solely to the change in testing frequency.
Request VRR4:
- 1. In Section 5.0, under Basis for Use, the licensee stated that the as-found set-pressure acceptance criteria for the BVPS-2 pressurizer safety valves is +1-3%
of nameplate set pressure. However, from reviewing Technical Specification 3.4.10.1, it appears that the acceptance criteria is more restrictive (i.e., 2467.6
+/- 2.3% psig). Explain this discrepancy. Does this affect the analysis of past operating history for the valves that the licensee presented as its "Basis for Use" to support the future use of Code Case OMN-17?
RESPONSE
There is no discrepancy because two different acceptance criteria were considered.
The pressurizer safety valves have a set-pressure of 2485 pounds per square inch gauge (psig). The Technical Specification as-found set-pressure acceptance criteria of plus 1.6 percent or minus 3 percent (that is, greater than or equal to 2410.5 psig and less than or equal to 2524.7 psig) is used to determine if the valves have passed or failed testing. The plus or minus 3 percent valve as-found set-pressure acceptance
Attachment L-1 1-275 Page 3 of 3 criteria of ASME OM Code, 2001 Edition, Appendix I, is used to determine if additional pressurizer safety valves are required to be tested for the purpose of sample expansion.
Pressurizer safety valve as-found set-pressure test results have been within the plus 1.6 percent or minus 3 percent Technical Specification range with the exception of valve 2RCS*RV551C (that lifted low in 1989) and valve 2RCS*RV551A (that lifted high in 2000). These as-found valve set-pressure test results demonstrate limited time related degradation or setpoint drift and demonstrate that it is acceptable to extend the test interval.
Both the Technical Specification plus 1.6 percent or minus 3 percent as-found valve set-pressure criteria as well as the plus or minus 3 percent ASME OM Code as-found valve set-pressure criteria were factored into the analysis of the test results for each valve (including the spare valves) over the past operating history. Therefore, the analysis of past operating history is not affected.
- 2. Will the licensee continue testing the removed valve prior to starting up after every refueling outage?
RESPONSE
Yes, FENOC will continue to test the removed valve prior to startup after every refueling outage. Paragraph 1-1320(b)(1) of ASME OM Code, Appendix I, indicates that for replacement of a partial complement of valves with a pre-tested valve, the valve removed shall be tested prior to resumption of electric power generation.
- 3. In the third paragraph, first sentence, under Basis for Use, the licensee refers to Code Case OMN-17 paragraphs (e) and (f). This appears to be a typographical error. Did you mean paragraphs (d) and (e)?
RESPONSE
Yes, the paragraphs referenced should be (d) and (e).