ML12122A217

Proposed Alternative Regarding Motor Operated Valve Testing

ML12122A217
Person / Time
Site:	Beaver Valley
Issue date:	05/04/2012
From:	Meena Khanna Plant Licensing Branch 1
To:	Harden P FirstEnergy Nuclear Operating Co
References
TAC ME7684, TAC ME7685
Download: ML12122A217 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 4,2012 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 - PROPOSED ALTERNATIVE REGARDING MOTOR OPERATED VALVE TESTING (TAC NOS. ME7684 AND ME7685)

Dear Mr. Harden:

By letter dated December 2,2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113360483), FirstEnergy Nuclear Operating Company (FENOC, the licensee), submitted proposed alternative valve relief request VRR1, Revision 1, to the U.S.

Nuclear Regulatory Commission (NRC). The licensee requested authorization to use alternative rules, defined in American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) Code Case, OMN-1, 1 for preservice and in service testing of all motor-operated valve (MOV) assemblies in the MOV programs. These alternative rules will be used in lieu of the current MOV requirements described in the ASME OM Code for the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2. Request VRR1, Revision 1, is applicable to the fourth 1O-year inservice testing (1ST) program interval at BVPS, Unit 1 and the third 1O-year 1ST program interval at BVPS, Unit 2. Previously, the NRC had approved proposed alternative request VRR 1, Revision 0, for BVPS, by letters dated September 27,2007 (ADAMS Accession No. ML072420376, Unit 1), and February 14, 2008 (ADAMS Accession No. IVIL080140299, Unit 2). These previous approvals applied to an older version of OMN-1.

The NRC staff has completed its review of the proposed alternative as discussed in the enclosed safety evaluation. The NRC staff review concludes that the proposed alternative provides an acceptable level of quality and safety. Therefore, VRR 1, Revision 1, is authorized pursuant to 10 CFR 50.55a(a)(3)(i). This alternative allows the usage of the version of Code Case OMN-1, associated with the ASME OMb Code, 2006 Addenda, for all motor-operated valve assemblies included in the BVPS, Units 1 and 2, MOV programs, provided the conditions specified for Code Case OIVlN-1, in RG 1.192, Revision 0, are met.

This authorization of VRR1, Revision 1, is applicable for the remainder of the fourth 1ST interval for BVPS, Unit 1, which is scheduled to end on September 19,2017, and the third 1ST interval for BVPS, Unit 2, which is scheduled to end on November 17, 2017.

1. The OM Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants," version applicable to this request is associated with the AMSE OMb Code, 2006 Addenda.

P. Harden -2 If you have any questions, please contact the BVPS Project Manager, Mr. Peter J. Bamford, at 301-415-2833.

Sincerely,

'--YY\~

Meena Khanna, Chief Plant Licensing Branch 1-2 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 PROPOSED ALTERNATIVE REQUEST VRR1, REVISION 1 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FOURTH (UNIT 1) AND THIRD (UNIT 2) 10-YEAR INSERVICE TESTING INTERVAL FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NUMBERS SO-334 AND SO-412

1.0 INTRODUCTION

By letter dated December 2, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113360483), FirstEnergy Nuclear Operating Company (FENOC, the licensee), submitted proposed alternative valve relief request VRR1, Revision 1, to the U.S.

Nuclear Regulatory Commission (NRC). The licensee requested authorization to use alternative rules, defined in American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) Code Case, OMN-1, 1 for preservice and inservice testing of all motor-operated valve (MOV) assemblies in the MOV programs. These alternative rules will be used in lieu of the current MOV requirements described in the ASME OM Code for the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2. Request VRR1, Revision 1, is applicable to the fourth 10-year inservice testing (1ST) program interval at BVPS, Unit 1, and the third 10-year 1ST program interval at the BVPS, Unit 2. Previously, the NRC had approved proposed alternative request VRR1, Revision 0, for BVPS, by letters dated September 27,2007 (ADAMS Accession No. ML072420376, Unit 1), and February 14, 2008 (ADAMS Accession No. ML080140299, Unit 2). These previous approvals applied to an older version of OMN-1. The BVPS, Unit 1 fourth 10-year 1ST program interval commenced on September 20,2007, and is scheduled to end on September 19, 2017. The BVPS, Unit 2 third 10-year 1ST program interval commenced on November 18,2007, and is scheduled to end on November 17, 2017.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) SO.SSa(a)(3)(i), the licensee requested to use the version of ASME OM Code Case OMN-1 associated with the ASME OMb Code, 2006 Addenda, in lieu of meeting the test requirements of the ASME OM Code, proposing that the alternative provides an acceptable level of quality and safety for testing MOVs.

The following evaluation documents the NRC's rationale for authorization of the proposed alternative.

1. The OM Code Case OMN*1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants; version applicable to this request is associated with the AMSE OMb Code, 2006 Addenda.

Enclosure

-2

2.0 REGULATORY EVALUATION

Paragraph 50.55a(f) of 10 CFR, "Inservice Testing Requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the appropriate ASME OM Code and applicable addenda. Paragraph 50.55a(a)(3) of 10 CFR specifies that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be used, when authorized by the NRC's Director of the Office of Nuclear Reactor Regulation, if the licensee demonstrates:

(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.

Regulatory Guide (RG) 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," March 2003, as specified in 10 CFR 50.55a(b), provides a standard approved for incorporation by reference into 10 CFR. This RG identifies the code cases that have been determined by the NRC to be acceptable alternatives to applicable parts of the OM Code.

OM Code cases not yet endorsed by the NRC may be implemented through the provisions of 10 CFR 50.55a(a)(3).

NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," Revision 1, provides a discussion of the applicable regulations for the 1ST of pumps and valves at nuclear power stations. While the NUREG, by itself, does not authorize alternatives to the ASME Code requirements, it provides information pertinent to requests for alternatives to the OM Code at commercial nuclear power plants.

ASME OM Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Active Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants," provides an alternative set of requirements, except for leakage rate testing, that may be used to assess the operational readiness of active electric MOV assemblies.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Alternative Request and Reason for Request According to the licensee, Revision 1 ofVRR1 for BVPS, Unit Nos. 1 and 2, specifies the version of Code Case OMN-1 to be implemented and provides a list that identifies affected MOV assemblies. In addition, wording is changed to make the text of VRR 1, Revision 1, consistent for BVPS, Unit Nos. 1 and 2, as compared with VRR1, Revision 0, and includes additional applicable code requirements. The licensee's submittal contains a detailed listing of the applicable code requirements.

According to the licensee, the reason for their request is as follows:

NUREG-1482, Revision 1, Section 4.2.5 states, in part:

... As an alternative to MOV stroke-time testing, ASME developed Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in LWR [Light Water Reactor] Power Plants,"

which provides periodic exercising and diagnostic testing for use in assessing the operational readiness of MOVs.... ,

- 3 The following Nuclear Regulatory Commission (NRC) staff recommendation is also provided in Section 4.2.5:

The NRC staff recommends that licensees implement ASME Code Cases OMN 1 .... as accepted by the NRC (with certain conditions) in the regulations or

[Regulatory Guide] RG 1.192, as alternatives to the stroke-time testing provisions in the ASME Code for applicable [power operated valves] POVs.

Section 4.2.5 provides a basis for the recommendation that states, in part:

RG 1.192 allows licensees with an applicable code of record to implement ASME Code Case OMN-1 (in accordance with the provisions in the regulatory guide) as an alternative to the Code provisions for MOV stroke-time testing, without submitting request for relief from their code of record .... Licensees with a code of record that is not applicable to the acceptance of these Code Cases may submit a request for relief to apply those Code Cases consistent with indicated conditions to provide an acceptable level of quality and safety.

The Code of record for BVPS, Unit No.1 (BVPS-1) fourth 10-year inservice test interval, and BVPS, Unit No.2 (BVPS-2) third 10-year test interval is the ASME OM Code 2001 Edition through OMb-2003 Addenda and the applicable Code for OMN 1, as stated in RG 1.192, was only reaffirmed through the OMa 1999 Addenda.

The licensee's proposed alternative and basis for use is restated as follows:

Implement Code Case OMN-1 from the ASME OMb Code, 2006 Addenda, in lieu of MOV stroke-time provisions specified in ISTC-5120, preservice testing provisions of ISTC-3100, reference value provisions of ISTC-3310, exercising test frequency provisions of ISTC-3510, and exercising provisions of ISTC-3520. Code Case OMN-1 has been determined by the NRC to provide an acceptable level of quality and safety when implemented in conjunction with the conditions imposed in RG 1.192. Also, implement the provisions specified in ISTC-3700 in conjunction with the MOV diagnostic test frequency (specified in the 1ST Program Valve Tables) in lieu of the ISTC-3700 frequency of once every two years.

Using the provisions of this relief request as an alternative to MOV stroke-time testing provisions of ISTC-5120, preservice testing provisions of ISTC-31 00, reference value provisions of ISTC-3310, exercising provisions of ISTC-3520, and position verification frequency provisions of ISTC-3700, provides an acceptable level of quality for the determination of valve operational readiness. Code Case OMN-1 from the ASME OMb Code, 2006 Addenda, should be considered acceptable for use with ASME OM Code-2001 through OMb-2003, as the Code of record.

3.2 NRC Staff Evaluation The NRC staff considered NUREG-1482, Revision 1, Section 4.2.5, "Alternatives to Stroke Testing," in its review of the licensee's proposed alternative. Section 4.2.5 states, in part, that as an alternative to MOV stroke-time testing, ASME developed Code Case OMN-1, may be used.

Code Case OMN-1 provides periodic exercising and diagnostic testing for use in assessing the operational readiness of MOVs. Further, Section 4.2.5 recommends that licensees implement

-4 ASME Code Case OMN-1 as an alternative to the MOV stroke-time testing, with certain conditions. As evidenced by the recommendation and basis provided in NUREG-1482, the NRC considers that the periodic exercising and diagnostic testing requirements in OMN-1 provide an improved method for assessing the operational readiness of MOVs.

Application of code cases is addressed in 10 CFR 50.55a(b)(6) through references to RG 1.192, which lists acceptable and conditionally acceptable code cases for implementation in 1ST programs. RG 1.192, Table 2, conditionally approves the use of Code Case OMN-1 and states that the code is applicable to the 2000 Addenda and earlier editions and addenda of the Code.

The NRC staff has reviewed Code Case OMN-1 in the 2006 Addenda of the ASME OM Code in preparation for the next revision to RG 1.192. Though not yet incorporated into RG 1.192, the staff plans to conditionally accept this Code Case, with the previous conditions noted for earlier versions of OMN-1 in RG 1.192, Revision O.

BVPS, Unit Nos. 1 and 2, had previously requested to use Code Case OMN-1 per alternative requestVRR1, Revision 0 (ADAMS Accession Nos. ML070890491, Unit 1, and ML071370347, Unit 2). As specified earlier in this safety evaluation, VRR1, Revision 0 was approved previously by the NRC staff. However, alternative request VRR 1, Revision 0 was applicable to the BVPS current Code of Record, which is the 2001 Edition through 2003 Addenda. Code Case OMN-1 was revised in the 2006 Addenda. The NRC staff considers the revised code case to be an improved version. The purpose of this alternative request is to use the improved version.

The NRC staff has reviewed Code Case OMN-1 in the 2006 Addenda of the ASME OM Code and determined that there are no Significant technical differences between the 2000 Addenda of the OM Code version that is currently approved in RG 1.192. The NRC staff considers the proposed alternative to be acceptable because Code Case OMN-1 provides a superior method than the stroke timing method required by the OM Code for assessing operational readiness of MOVs, provided the conditions in RG 1.192, Revision 0 are adopted. NUREG-1482, Revision 1, Section 4.2.5 contains a detailed rationale for this determination. The NRC staff has recommended that licensees implement Code Case OMN-1 , with the conditions specified in RG 1.192, as an alternative to the MOV stroke time and position verification testing provisions of the ASME Code, as reflected in NUREG-1482. The considerations of the NUREG review are applicable to BVPS, Units 1 and 2, and thus support the authorization of this request. Therefore, the NRC staff finds that the proposed alternative will provide an acceptable level of quality and safety.

4.0 CONCLUSION

On the basis of the review and evaluation of the licensee's submittals described above, the NRC staff concludes that the proposed alternative would provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the staff authorizes, as requested, the usage of the version of Code Case OMN-1 associated with the ASME OMb Code, 2006 Addenda, for all motor-operated valve assemblies included in the BVPS, Units 1 and 2, MOV programs, provided the conditions specified for Code Case OMN-1, in RG 1.192, Revision 0, are met.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable.

-5 Therefore, the NRC staff authorizes the alternative in request VRR1, Revision 1, for the remainder of the fourth 1ST interval for BVPS Unit 1, which is scheduled to end on September 19,2017, and the third 1ST interval for BVPS Unit 2, which is scheduled to end on November 17,2017.

Principal Contributors: M. Farnan P. Bamford Date: May 4,2012

P. Harden -2 If you have any questions, please contact the BVPS Project Manager, Mr. Peter J. Bamford, at 301-415-2833.

Sincerely,

/ra/

Meena Khanna, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

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