L-20-116, CFR 50.55a Request Number VRR6, Revision 0, Motor-Operated Valve Test Frequency
| ML20092K723 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/01/2020 |
| From: | Penfield R Energy Harbor Nuclear Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-20-116 | |
| Download: ML20092K723 (6) | |
Text
Energy Harbor Nuclear Corp.
Beaver Valley Power Station P. O. Box 4 Shippingport, PA 15077 April 1, 2020 L-20-116 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 10 CFR 50.55a Request Number VRR6, Revision 0, Motor-Operated Valve Test Frequency In accordance with 10 CFR 50.55a(z)(2), Energy Harbor Nuclear Corp. hereby requests Nuclear Regulatory Commission (NRC) approval of request VRR6, Revision 0, that proposes an alternative test frequency for certain motor-operated valves in the Beaver Valley Power Station, Unit No. 2 (BVPS-2) Inservice Testing Program for Pumps and Valves.
Because of the hardship produced by the recent pandemic and the resulting national state of emergency, Energy Harbor Nuclear Corp. is requesting expedited NRC approval of this request. The proposed alternative would defer the tests until the next refueling outage, which is within the current fourth 10-year inservice test interval.
To support the critical generation and startup of BVPS-2 from its scheduled spring 2020 refueling outage, Energy Harbor Nuclear Corp. requests approval of the proposed alternative by April 4, 2020.
The enclosed request identifies the affected components, applicable code requirements, and a description and basis for the proposed alternative.
There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager, Nuclear Licensing and Regulatory Affairs, at (330) 315-6808.
Sincerely, Rod L. Penfield Rod L. Penfield Site Vice President, Beaver Valley Nuclear 724-682-5234
Beaver Valley Power Station, Unit No. 2 L-20-116 Page 2
Enclosure:
Beaver Valley Power Station, Unit No. 2, 10 CFR 50.55a Request Number VRR6, Revision 0 cc:
NRC Region I Administrator NRC Resident Inspector NRR Project Manager Director BRP/DEP Site BRP/DEP Representative
Enclosure L-20-116 Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number VRR6, Revision 0 (3 Pages Follow)
Beaver Valley Power Station, Unit No. 2 10 CFR 50.55a Request Number VRR6, Revision 0 Page 1 of 3 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2)
--Hardship Without a Compensating Increase in Quality and Safety--
- 1. ASME Code Components Affected The affected components are the Beaver Valley Power Station, Unit No. 2 (BVPS-2) motor-operated valves (MOVs) listed below:
2CHS*MOV308A, Reactor coolant pump (RCP) 21A seal water injection isolation 2CHS*MOV308B, RCP 21B seal water injection isolation 2CHS*MOV308C, RCP 21C seal water injection isolation 2CHS*MOV378, RCP seal water return isolation 2CHS*MOV8130A, Charging pump suction isolation 2CHS*MOV8130B, Charging pump suction isolation 2SIS*MOV840, High head to cold leg injection isolation 2SIS*MOV841, High head to cold leg injection isolation 2SIS*MOV8890A, Low head safety injection pump 21A miniflow recirculation isolation 2QSS*MOV101B, Quench spray pump 21B discharge isolation 2CCP*MOV112B, RHR heat exchanger (B train) supply isolation 2CCP*MOV150-1, Primary component cooling header isolation outside containment 2CCP*MOV151-1, Primary component cooling header isolation outside containment 2SWS*MOV155-2, Containment air recirculation cooling coils supply header isolation 2SWS*MOV113D, Emergency diesel generator heat exchanger 21B service water header B cooling water inlet
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM)
Code - 2004 Edition, with Addenda through OMb-2006.
3. Applicable Code Requirements
ASME OM Code Case OMN-1 (ASME OMb Code-2006), Alternative Rules for Preservice and Inservice Testing of Active Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants, Paragraph 3.3.1, Inservice Test Interval, subparagraph (c) states, in part, that the maximum inservice test interval shall not exceed 10 years.
NOTE: ASME OM Code Case OMN-20, Inservice Test Frequency, allows the specified time period between tests to be extended by up to six months for test periods specified as greater than or equal to two years. This Code Case is applicable to the 2004 Edition of the ASME OM Code in accordance with
VRR6, Revision 0 Page 2 of 3 10 CFR 50.55a(a)(1)(iv) and 10 CFR 50.55a(b)(3)(x). Therefore, the MOVs tested in accordance with OMN-1 cannot exceed a test interval of ten years plus six months.
4. Reason for Request
BVPS-2 is scheduled to start its 21st refueling outage (2R21) on April 12, 2020. The MOVs listed in Section 1 of this request that are tested in accordance with ASME OM Code Case OMN-1 are near the end of their maximum 10-year test interval as specified in Paragraph 3.3.1(c), and are required to be tested during this refueling outage.
On March 13, 2020, the President of the United States declared a national emergency due to the spread and infectious nature of the Coronavirus-2019 (COVID-19) virus and resulting pandemic. The most recent guidance from the Centers for Disease Control and Prevention (CDC) includes recommendations for social distancing by maintaining approximately six feet from other personnel to limit the spread of the virus. On March 28, 2020, the Governor of Pennsylvania issued a Stay at Home order for Beaver County and the surrounding counties of Allegheny and Butler. Furthermore, on March 28, 2020, the Department of Homeland Security identified workers in the nuclear energy sector as essential critical infrastructure workers.
To prevent the spread of COVID-19 at BVPS, Energy Harbor Nuclear Corp. intends to reduce the amount of personnel on-site, which will pose a hardship for completing the currently planned 2R21 refueling outage work scope. Energy Harbor Nuclear Corp. is also contingency planning in case some of its workforce becomes unavailable due to the COVID-19 outbreak. With the current work scope and potential loss of personnel, there is the potential that the company may not be able to complete the refueling outage in a timely manner, which could negatively impact critical infrastructure that is needed during this time.
5. Proposed Alternative and Basis for Use
Energy Harbor Nuclear Corp. is requesting relief to extend the testing of the MOVs listed in Section 1 of this request to the next BVPS-2 refueling outage (2R22) in the fall of 2021.
If approved, the test extension interval would represent an additional 1.5 months from when the valves would need to be tested per Code requirements. The MOVs listed in Section 1 of this request were last tested during 2R15 in March of 2011 and have a 10-year test frequency per ASME OM Code Case OMN-1. Although ASME OM Code Case OMN-20 permits a grace period of up to 6 months, it is insufficient to extend the interval to 2R22 planned during the fall of 2021.
Furthermore, each of the MOVs has the following margin between valve operating requirements and the available actuator output capability to satisfy the acceptance criteria for MOV operational readiness, along with the probabilistic risk assessment (PRA) ranking and exercise testing frequency:
VRR6, Revision 0 Page 3 of 3 Margin (percent)
Valve Open (O) Shut (S) Safety Direction PRA Rank Exercise Frequency 2CHS*MOV308A 19.5 15.4 S
Low Cold Shutdown / Refueling 2CHS*MOV308B 19.5 15.3 S
Low Cold Shutdown / Refueling 2CHS*MOV308C 19.5 16.5 S
Low Cold Shutdown / Refueling 2CHS*MOV378 74.5 148.9 S
Medium Cold Shutdown / Refueling 2CHS*MOV8130A 78.5 28.5 S
Low Cold Shutdown / Refueling 2CHS*MOV8130B 172.3 51.9 S
Low Cold Shutdown / Refueling 2SIS*MOV840 13.7 11.5 O and S Low 18 Months 2SIS*MOV841 29.7 225.0 O and S Low 18 Months 2SIS*MOV8890A 196.5 51.0 O and S Medium Quarterly 2QSS*MOV101B 37.0 13.3 O and S Low 18 Months 2CCP*MOV112B 23.6 23.3 O
Medium Quarterly / Cold Shutdown 2CCP*MOV150-1 65.0 12.4 O and S Medium Refueling 2CCP*MOV151-1 73.6 10.3 O and S Medium Refueling 2SWS*MOV155-2 21.2 21.2 S
Low 18 Months 2SWS*MOV113D 40.1 16.2 O
Medium Quarterly The values above demonstrate that adequate margin exists between the operating requirements and the available actuator output capability to ensure the MOVs will be operationally ready.
Finally, the valves listed above are rising stem valves that will have their stems cleaned and lubricated in 2R21 except for the following butterfly valves:
- 2CCP*MOV112B
- 2CCP*MOV150-1
- 2CCP*MOV151-1
- 2SWS*MOV155-2 In conclusion, the following ensures that the proposed alternative to test these MOVs during 2R22 provides reasonable assurance that they remain operationally ready:
- The MOV actuator output margin to operating requirements from the most recent tests;
- They are exercised at least each refueling outage or 18 months;
- Except for four butterfly valves, the others are rising stem valves that will have stem lubrication maintenance during 2R21.
6. Duration of Proposed Alternative
This proposed alternative is requested for use during the fourth 10-year inservice test interval until the next refueling outage in the fall of 2021 (2R22). The fourth 10-year inservice test interval began on September 20, 2017 and ends on September 19, 2027.