ML23052A129

Report of Facility Changes, Tests and Experiments

ML23052A129
Person / Time
Site:	Beaver Valley
Issue date:	02/21/2023
From:	Blair B Energy Harbor Nuclear Corp
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML23052A129 (1)

Text

energy Energy Harbor Nuclear Corp.

harbo r Beaver Valley Power Station P. 0. Box 4 Shippingport, PA 15077 Barry N. Blair 724-682-5234 Site Vice President, Beaver Valley Nuclear February 21, 2023 L-23-035 10 CFR 50.59(d)(2)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001

SUBJECT:

Beaver Valley Power Station, Unit No. 2 Docket No. 50-412, License No. NPF-73 Report of Facility Changes. Tests and Experiments In accordance with 10 CFR 50.59(d)(2), the Energy Harbor Nuclear Corp. hereby submits the attached Report of Facility Changes, Tests and Experiments for the Beaver Valley Power Station, Unit No. 2 (BVPS-2). This report reflects the implemented changes, tests and experiments that were evaluated pursuant to 10 CFR 50.59 during the period of February 1, 2021 through January 31, 2023.

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, Manager - Fleet Licensing, at 330-696-7208.

Attachment:

Beaver Valley Power Station, Unit 2, Report of Facility Changes, Tests, and Experiments cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

Attachment L-23-035 Beaver Valley Power Station, Unit 2, Report of Facility Changes, Tests, and Experiments Page 1 of 3

Title:

Remove Licensing Requirement Surveillance 3.3.9.6 for BVPS-2 Reheat Stop and Intercept Valve Inspections and update the BVPS-2 Updated Final Safety Analysis Report, Section 3.5.1.3.4 Activity

Description:

This proposed change eliminates the BVPS-2 Licensing Requirement Surveillance (LRS) 3.3.9.6, reheat stop valves (RSV) and intercept valves (IV) inspection interval requirement, from the Licensing Requirement Manual (LRM) and the statement mentioning that the 60-month inspection interval was assumed in the calculation to determine the turbine missile ejection probability from BVPS-2 Updated Final Safety Analysis Report (UFSAR),

Section 3.5.1.3.4.

Summary of Evaluation:

The turbine missile analyses developed by Westinghouse, the BVPS-1 and 2 turbine vendor, for the original BB-281 model rotors, did implicitly assume that the RSV and IV valve inspection interval was an input to missile probability generation. As a result, it was acknowledged in the BVPS-2 original safety evaluation report (ADAMS Accession No. ML20138J942). The requirement was also included in BVPS-2 Technical Specification (TS), Section 3.3.4 as a result of TS Amendment 53 (ADAMS Accession No. ML003772557) and mentioned in the corresponding safety evaluation. These original analyses were based upon Westinghouse Commercial Atomic Power (WCAP)-11525 (July 1987) or its predecessor documents.

A review of these calculations and their references, which include two Westinghouse WCAPs (11525 and14732), do not reveal an actual use of the inspection intervals. In addition, previous generic Westinghouse turbine missile reports submitted to the NRC in 1987 and a more specific calculation for BVPS submitted in 1992 do not reveal any use of the specified inspection intervals. In all cases, the RSV and IV testing (stroking) intervals are discussed as the input. The 18-month testing (stroking) interval for the RSV and IV will remain as an input to the turbine missile analysis. Furthermore, the failure of the valves that would lead to the turbine overspeed events described involve mechanisms, which include valve sticking, fluid line clogs and so on, that would be identified by the periodic testing as opposed to the valve inspections.

Attachment L-23-035 Page 2 of 3 The Westinghouse BB-281 low pressure (LP) turbines for which the above analyses and reviews were performed were replaced at both units (in 2012 and 2013) by Siemens BB-281 13.9M2 turbines. As a result, the BVPS-2 turbine missile analysis was updated based upon WCAP-16501, dated March 2006 and Siemens report CT-27472, Revision 2, dated August 2011. These reports indicated that the major overspeed event, intermediate overspeed, for which the RSVs and IVs were considered a probable input was not a significant contributor to overall turbine missile probability. The greater contributor, destructive overspeed, depends upon the LP turbine rotor disc (attaching the blades to the shaft) inspections. The RSV and IV failures are not an input to that dominating event.

Although the RSV and IV disassembly and inspection were originally included as a commitment in the BVPS-2 Final Safety Analysis Report (FSAR), Amendment 8 and discussed in the BVPS-2 safety evaluation report for the BVPS-2 original license and FSAR, as well as the safety evaluation for TS Amendment 53, the reasons for its inclusion no longer apply. The overall regulatory requirement of meeting 10 CFR 50 Appendix A General Design Criterion (GDC) 4 with respect to internal plant missiles, as described in NRC Regulation Guide 1.115, Rev. 0 with regards to the probability threshold, is met without reference to such RSV and IV inspections.

The BVPS-2 Technical Specification, Section 3.3.4 and the inspection provisions were moved to the BVPS Licensing Requirements Manual (LRM) by TS Amendment 115 (ADAMS Accession No. ML003729909), which subjects them to review under 10 CFR 50.59.

Based on the analyses performed and reviews conducted, it is concluded that the RSV and IV inspection intervals listed in LRS 3.3.9.6 are not significant inputs to the turbine missile overspeed analysis inspection interval.

The turbine missile ejection accident remains the same; therefore, all UFSAR described plant responses and analyses remain in effect. No new accidents are introduced because the plant equipment and response remain the same.

The proposed BVPS-2 LRS 3.3.9.6, turbine low pressure RSV and IV inspection interval elimination does not meet any of the 10 CFR 50.59(c)(2) criteria; therefore, a license amendment is not required.

Attachment L-23-035 Page 3 of 3

Title:

Evaluate the PIPESTRESS software for use at BVPS-2 Activity

Description:

This activity will add the PIPESTRESS program as an alternative analytical tool. The PIPESTRESS software is capable of performing piping analysis to the American National Standards Institute (ANSI) B31.1 and American Society of Mechanical Engineers (ASME) Ill Codes and is endorsed by the NRC for use on the Westinghouse AP1000 and Advanced Power Reactor 1400 (APR1400) projects as noted in references NUREG-1793 Volume 1 (Accession No. ML043450344) and APR1400 Chapter 3 (Accession No. ML18215A242).

This activity also adds PC-PREPS to the list of computer programs used in seismic Category I piping design. During the mid-1990's migration to a personal computer (PC) environment, the PC-PREPS software was developed to replace STRUDL-SW and provide additional analytical features.

This activity updates the BVPS-2 UFSAR, Sections 3.7B.3 and Appendix 3A, with regard to the Stone & Webster Engineering software.

Summary of Evaluation:

The PIPESTRESS software has been reviewed and found acceptable for use on the AP1000 and APR1400 projects, as noted in reference NUREG-1793 Volume 1 (Accession No. ML043450344) and APR1400 Chapter 3 (Accession No. ML18215A242). The software code was specifically approved as applied to its use on ASME Code Class 1, 2, and 3 piping.

Therefore, in accordance with 10 CFR 50.59 this change in software is not considered a change in evaluation methods that requires NRC approval.

PC-PREPS was developed from STRUDL-SW and added the ability to analyze welds, local tube steel stresses, anchor bolts, and surface mounted base plates in accordance with American Institute of Steel Construction (AISC), American Welding Society (AWS) and ASME criteria. PC-PREPS is a quality assurance (QA) Category I structural analysis computer code qualified in accordance with the Stone & Webster QA Program. PC-PREPS has been used for other Stone & Webster projects that have been reviewed and accepted by the NRC for pipe support and structural analysis. Therefore, in accordance with 10 CFR 50.59 this change in software is not considered a change in evaluation methods that requires NRC approval.

The application of PIPESTRESS or PC-PREPS software does not meet any of the 10 CFR 50.59(c)(2) criteria; therefore, a license amendment is not required.