ML120270298

Relief Request VRR3 Regarding Solenoid Operated Valve Remote Position Verification Frequency

ML120270298
Person / Time
Site:	Beaver Valley
Issue date:	02/07/2012
From:	George Wilson Plant Licensing Branch 1
To:	Harden P FirstEnergy Nuclear Operating Co
Morgan N, NRR/DORL, 415-1016
References
TAC ME5749, TAC ME5750
Download: ML120270298 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 February 7, 2012 Mr. Paul A. Harden Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - RELIEF REQUEST VRR3 REGARDING SOLENOID OPERATED VALVE REMOTE POSITION VERIFICATION FREQUENCY (TAC NOS. ME5749 AND ME5750)

Dear Mr. Harden:

By letter dated February 21, 2011, as supplemented by letter dated September 14, 2011, FirstEnergy Nuclear Operating Company (the licensee) submitted Relief Request VRR3 to the Nuclear Regulatory Commission (NRC) for relief from Paragraph ISTC-3700 of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) requirements at Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i),

the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.

The NRC staff has reviewed the licensee's proposed alternative to use a test frequency, in accordance with 10 CFR Part 50, Appendix J, Option B, to perform position verification testing of the 24 solenoid-operated valves listed in the enclosed safety evaluation and concludes that the proposed alternative in Relief Request VRR3 provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative for the remainder of the BVPS-1 fourth 10-year inservice testing (1ST) interval and the BVPS-2 third 10-year 1ST interval.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable.

P. Harden -2 If you have any questions, please contact the Beaver Valley Project Manager, Nadiyah Morgan.

at (301) 415-1016.

Sincerely.

~d George Wilson. Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST VRR3 REGARDING SOLENOID-OPERATED VALVES FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412

1.0 INTRODUCTION

By letter dated February 21,2011 (Agencywide Document Access and Management System (ADAMS) Accession No. ML110550162), as supplemented by letter dated September 14, 2011 (ADAMS Accession No. ML11262A045), FirstEnergy Nuclear Operating Company (the licensee) requested relief from the requirements of Paragraph ISTC-3700 of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) for an alternative test frequency to perform position verification testing of several solenoid-operated valves (SOV) at Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i),

the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

10 CFR 50.55a(f), "Inservice testing requirements," requires, in part, that ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii). Paragraph (a)(3) of 10 CFR 50.55a states that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. 10 CFR 50.55a allows the NRC to authorize alternatives to ASME OM Code requirements upon making necessary findings. The NRC staff reviewed and evaluated the licensee's request pursuant to 10 CFR 50.55a(a)(3)(i}.

Enclosure

-2

3.0 TECHNICAL EVALUATION

3.1 Licensee's Relief Request System/Component Affected Class 2, Category A valves:

SOV-1 HY-102A1 A Hydrogen Analyzer Containment Dome Inlet Flow Sample SOV-1 HY-102A2 A Hydrogen Analyzer Containment Dome Inlet Flow Sample SOV-1HY-10281 8 Hydrogen Analyzer Containment Dome Inlet Flow Sample SOV-1 HY-10282 8 Hydrogen Analyzer Containment Dome Inlet Flow Sample SOV-1 HY-103A1 A Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample SOV-1 HY-1 03A2 A Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample SOV-1 HY-1 0381 8 Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample SOV-1 HY-10382 8 Hydrogen Analyzer Pressurizer Cubicle Inlet Flow Sample SOV-1 HY-104A 1 A Hydrogen Analyzer Flow Sample Discharge SOV-1 HY-104A2 A Hydrogen Analyzer Flow Sample Discharge SOV-1HY-10481 8 Hydrogen Analyzer Flow Sample Discharge SOV-1 HY-10482 8 Hydrogen Analyzer Flow Sample Discharge 2HCS*SOV133A Hydrogen Analyzer A Outlet Inside Containment Isolation 2HCS*SOV1338 Hydrogen Analyzer 8 Outlet Inside Containment Isolation 2HCS*SOV134A Hydrogen Analyzer A Outlet Outside Containment Isolation 2HCS*SOV1348 Hydrogen Analyzer 8 Outlet Outside Containment Isolation 2HCS*SOV135A Hydrogen Analyzer 8 Inlet Inside Containment Isolation 2HCS*SOV1358 Hydrogen Analyzer B Inlet Outside Containment Isolation 2HCS*SOV136A Hydrogen Analyzer A Inlet Inside Containment Isolation 2HCS*SOV136B Hydrogen Analyzer A Inlet Outside Containment Isolation 2HCS*SOV114A Containment Isolation to Hydrogen Recombiner 21A 2HCS*SOV114B Containment Isolation to Hydrogen Recombiner 21 8 2HCS*SOV115A 8ackup Containment Isolation to Hydrogen Recombiner 21A 2HCS*SOV1158 8ackup Containment Isolation to Hydrogen Recombiner 218 Applicable Code Requirements The 2001 Edition of the ASME OM Code with Addenda through OMb-2003 is the Code of Record for 8VPS-1 and 2 10-year 1ST program intervals.

- 3 ISTC-3700, Position Verification Testing, states, in part that, "Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated." ISTC-3700 also states that, "Where local observation is not possible, other indications shall be used for verification of valve operation."

ISTC-5152(b), Stroke Test Acceptance Criteria, states that, "Valves with reference stroke times of less than or equal to 10 sec shall exhibit no more than +/-50% change in stroke time when compared to the reference value."

ISTC-5152(c) states that, "Valves that stroke in less than 2 sec may be exempted from ISTC 5152(b). In such cases the maximum limiting stroke time shall be 2 sec."

In summary, the licensee notes the following in its February 21, 2011 and September 14, 2011, submittal:

Licensee's Basis for Request The valves listed Section 3.1 are category A containment isolation valves and are required by BVPS 1ST programs to be seat leakage tested in accordance with 10 CFR Part 50, Appendix J, Option B (Type C leak test). Due to the design of the valves, position verification testing is performed in conjunction with the Type C test. Each of the listed valves is an SOY 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.

The subject valves are seat leakage tested using local leakage rate test equipment, as part of the Appendix J, Type C, Leak Test Program at BVPS. As part of the leakage rate test, the position verification test is also performed. This method involves attempting to pressurize the containment penetration volume to approximately 45 pounds per square inch gauge (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 that 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 of whether the containment penetration is due for Type C leakage testing or not. In order to perform the 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 operations and test personnel time and dose savings, since the test would be performed with the leakage test and would not be performed as frequently.

-4

Licensee's Proposed Alternative and Basis for Use

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 3.1 be performed in conjunction with the Type C seat leakage test at the frequency specified by 10 CFR Part 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 Part 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 Part 50, Appendix J, Option B.

In addition to position verification testing and seat leakage testing, the BVPS-1 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 time established in accordance with paragraph ISTC-5152(c) of ASME OM Code. If the stroke time is within the 2.0 second limiting time, then the valve is considered to have passed and is operating acceptably.

The 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. These valves are stroke time tested quarterly. The stroke times are compared to a 2.0 second limiting time established in accordance with ISTC-5152(c). If the stroke time is within the 2.0 second limiting time, then the valve is considered to have passed and is operating acceptably.

The BVPS-2 SOVs associated with the containment hydrogen recombiners are not required to be stroke time tested.

The hydrogen analyzer valves are normally closed and must remain closed for isolation of BVPS-1 containment penetration numbers 109-44, 95-64,109-49,95-69,109-52 and 95-72, and 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-2WOO-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

- 5 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 Part 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 [the seat leakage test frequency of a valve] 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.

Over the past five refueling outages at BVPS-1 and 2, the associated valves have always passed both the position verification test and the Type C leakage rate test. Valve performance data is recorded into a database and trended by the 1ST 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.

Additionally, all of the SOVs that are required to be stroke timed tested with their stroke times measured and compared to the ASME OM Code acceptance criteria of less than 20 seconds are exercised on a quarterly test frequency. For the past 5 years, no quarterly, stroke time failures have been noted.

Valve exercise testing each quarter and position verification and seat leakage testing in accordance with frequency specified by 10 CFR Part 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 milliRem for both units is expected with the implementation of this alternative. 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 Part 50, Appendix J, Option B. This frequency of testing and the provisions of this alternative request will demonstrate an acceptable level of quality and safety, since the alternative provides reasonable assurance of valve operational readiness.

3.2 NRC Staff's Evaluation The 24 SOVs are Category A containment isolation valves with leakage rate test requirements as specified in 10 CFR Part 50, Appendix J. As required by BVPS-1 and 2 Technical Specification 5.5.12, the licensee has implemented a containment leakage rate testing program

- 6 in accordance with 10 CFR Part 50, Appendix J, Option B. This places the SOVs into a performance-based program, based on the leakage testing requirements.

The licensee has proposed an alternative test in lieu of the requirements found in 2001 Edition of the ASME OM Code, Section ISTC-3700, for the SOVs. Specifically, the licensee's proposal is to functionally test and verify that valve operation is accurately indicated on the schedule of 10 CFR Part 50, Appendix J, Option B seat leakage testing rather than the 2-year frequency, specified by ASME OM Code. This proposal synchronizes the position indication verification test requirements of ISTC-3700 with the leakage rate test requirements of 10 CFR Part 50, Appendix J, Option B. Both tests will be performed together on an Option B, performance based schedule.

In order for the seat leakage test frequency of a valve to be extended, the individual containment isolation valve must first successfully pass two consecutive as-found seat leakage tests at the code-required, 2-year frequency before it can be placed on an extended test frequency. Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended to every third refueling outage, not to exceed 60 months. Any position indication verification test failure would require the component to return to the initial interval of every refueling outage or 2 years until good performance was once again established.

Performance data, compiled from the 1ST programs for the 24 SOVs, show that the valves have not experienced any leakage rate or position verification failures over the past five test cycles.

Additionally, no quarterly, stroke-time failures for the valves subject to exercising have been detected. Also, maintaining the current 2-year position verification test interval would result in additional personnel radiation exposure without an increase in the level of quality and safety.

Therefore, based on the past performance of the SOVs and the quarterly valve stroking for the valves subject to exercising, coupled with a 10 CFR Part 50, Appendix J, Option B performance based program to test for leakage and verify valve position indication, the NRC staff finds that the proposed alternative test provides an acceptable level of quality and safety and is acceptable.

4.0 CONCLUSION

As set forth above, the NRC staff concludes that the proposed alternative in Relief Request VRR3 provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative for the remainder of the BVPS-1 fourth 1O-year 1ST interval and the BVPS-2 third 10-year 1ST interval.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable.

Principal Contributor: J. Billerbeck Date: February 7, 2012

P. Harden -2 If you have any questions, please contact the Beaver Valley Project Manager, Nadiyah Morgan, at (301) 415-1016.

Sincerely, Iral George Wilson, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

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