View source for L-11-021, Proposed 10 CFR 50.55a Request VRR4 Regarding Pressurizer Safety Valve Test Frequency

{{Adams
| number = ML110560014
| issue date = 02/21/2011
| title = Proposed 10 CFR 50.55a Request VRR4 Regarding Pressurizer Safety Valve Test Frequency
| author name = Harden P
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000412
| license number = NPF-073
| contact person = 
| case reference number = L-11-021
| document type = Letter type:L
| page count = 5
}}

=Text=
{{#Wiki_filter:-FENOC FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O.:Box 4 Shippingport, PA 15077 Paul A. Harden Site Vice President 724-682-5234 Fax: 724-643-8069 February 21, 2011 L-1 1-021 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 Proposed 10 CFR 50.55a Request VRR4 Regarding Pressurizer Safety Valve Test Frequency In accordance with 10 CFR 50.55a, FirstEnergy Nuclear Operating Company (FENOC)requests Nuclear Regulatory Commission (NRC) approval of a proposed alternative for the Beaver Valley Power Station, Unit No. 2 (BVPS-2) third interval Inservice Testing Program for Pumps and Valves (IST Program).Testing of pressurizer safety valve assemblies included in the BVPS-2 IST Program is currently performed in accordance with the frequency described in Appendix I, Paragraph 1-1320(a) of the ASME OM Code-2001 Edition, "Code for Operation and Maintenance of Nuclear Power Plants," with Addenda through OMb-2003.
Enclosed is a proposed alternative to perform testing of these pressurizer safety valve assemblies at the test frequency specified in ASME OM Code Case OMN-17.In support of the fall 2012 refueling outage, FENOC requests approval of the proposed requests by May 2012.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 330-761-6071.
Since ly, Paul A. Harden Ao4 7 Beaver Valley Power Station, Unit No. 2 L-1 1-021 Page 2 

==Enclosure:==

10 CFR 50.55a Request Number: VRR4, Proposed Alternative in Accordance with 10 CFR50.55a(a)(3)(i) cc: NRC Region I Administrator NRC Senior Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative 10 CFR 50.55a Request Number: VRR4 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
Page 1 of 3--Alternative Provides Acceptable Level of Quality and Safety--1.0 ASME Code Components Affected The following Class 1, Category C, valves: 2RCS*RV551A, Pressurizer Safety Valve 2RCS*RV551 B, Pressurizer Safety Valve 2RCS*RV551C, Pressurizer Safety Valve 2.0 Applicable Code Edition and Addenda American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM)Code-2001 Edition, with Addenda through OMb-2003 3.0 Applicable Code Requirement Appendix I, Paragraph 1-1320, "Test Frequencies, Class I Pressure Relief Valves," of the ASME OM Code-2001 Edition, subparagraph (a), "5-Year Test Interval," states that: Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation.
No maximum limit is specified for the number of valves to be tested within each interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval.
This 20% shall consist of valves that have not been tested during the current 5-year interval, if they exist. The test interval for any individual valve shall not exceed 5 years.4.0 Reason for Request Beaver Valley Power Station Unit No. 2 (BVPS-2) has three (3) pressurizer safety valves installed to protect the reactor coolant system from overpressure.
Since BVPS-2 operates on an 18-month fuel cycle, one valve can be tested each refueling outage such that each valve is tested over a 4.5 year period. In order to avoid outage delays due to valve testing, a pressurizer safety valve is replaced during each refueling outage with a spare valve that has been tested. The removed valve is refurbished and tested for installation during the following refueling outage. In order to ensure the spare replacement valve does not exceed the five-year test interval limit from test to test, it must be tested within six months prior to installation.
ASME OM Code Case OMN-1 7, "Alternate Rules for Testing ASME Class I Pressure Relief/Safety Valves" allows a six-year test interval plus an additional six months grace period coinciding with a refueling outage in order to accommodate extended shutdown periods. Extending the maximum test interval to six years with a six month grace period would allow BVPS-2 to continue to rotate in a spare pressurizer safety valve without the need to test the spare valve within six months of installation.
Beaver Valley Power Station, Unit No. 2, 10 CFR 50.55a Request VRR4 Page 2 of 3 5.0 Proposed Alternative and Basis for Use Proposed Alternative As an alternative to the ASME OM Code-2001 Edition, Appendix I, Paragraph 1-1320(a)test interval of at least once every five years, FENOC proposes to test pressurizer safety valves at least once every six years plus a six month grace period, if required, in accordance with the periodicity and other requirements of ASME OM Code Case OMN-17. Code Case OMN-17 provisions will not be applied to a valve until the valve is disassembled and inspected as described in the following paragraph.
Paragraph (d) of ASME OM Code Case OMN-17 requires disassembly and inspection of each valve after as-found set pressure testing is performed in order to verify that parts are free of defects resulting from time related degradation or service induced wear. Paragraph (e) of ASME OM Code Case OMN-17 requires each valve to be disassembled and inspected in accordance with Paragraph (d) prior to the start of the 72 month test interval.Basis for Use The longer test interval will eliminate the need for a valve test within six months of installation during each refueling outage. Eliminating the test will in turn remove the risk of any return shipping damage to the valve from the offsite testing facility and reduce wear on metal valve seats due to steam testing.The as-found set-pressure acceptance criteria is plus or minus three (3) percent of valve nameplate set pressure in accordance with Paragraph 1-1320(c)(1) of ASME OM Code-2001 Edition, Appendix I. Since 1989, eighteen (18) as-found set pressure tests have been performed for the four Crosby Model HB-86-BP pressurizer safety valves (including the spare valve). A summary of test results is shown in the table on page 3.These tests have been performed at an offsite test facility using saturated steam. The majority of the tests were performed after the valve was installed for three operating cycles. As-found tests were within plus or minus three (3) percent of the valve set pressure with the exception of valve 2RCS*RV551 C, which lifted low (minus 5.6 percent) in 1989 due to excessive seat leakage. Technical Specification Surveillance 3.4.10.1 requires that following testing, lift settings shall be within plus or minus one (1)percent. For 12 of the 18 tests, the valves were found within the as-left tolerance of plus or minus one (1) percent. These test results show limited time related degradation or set point drift and demonstrate that it is acceptable to extend the test interval from 4.5 years (three fuel cycles) to 6 years with a six-month grace period (four fuel cycles).When the proposed alternative is applied to a valve, the valve will be disassembled and inspected after as-found set pressure testing is performed in accordance with ASME OM Code Case OMN-17 paragraphs (e) and (f). The initial inspection and ongoing inspections will verify that valve parts are free of defects resulting from time related degradation or service induced wear. These inspections provide additional assurance that the pressurizer safety valves will perform their intended function.
Beaver Valley Power Station, Unit No. 2, 10 CFR 50.55a Request VRR4 Page 3 of 3 The ability to detect degradation and ensure the operational readiness of the pressurizer safety valves to perform their intended function is assured based on the valve test history and by performing the required inspection and testing initially and at the proposed alternative frequency.
Therefore, test and inspection of the valves in accordance with the proposed alternative demonstrates an acceptable level of quality and safety.Summary of Test Results BVPS-2 Pressurizer Safety Valves Outage 2RCS*RV551A 2RCS*RV551B 2RCS*RV551C Comments Year 2R01 / 1989 2486 psig 2346 psig B within 1%C lifted below 3%1 2R02 / 1990 2474 psig Within 1%2R03 / 1992 2435 psig Within 3%2R04 / 1993 2464 psig Within 1%2R05 / 1995 2485 psig Within 1%2R06 / 1996 2484 psig Within 1%CSD /1998 2513 psig Within 3%2R07 / 1999 2492 psig Within 1%2R08 / 2000 2548 psig Within 3%2R09 / 2002 2465 psig Within 1%2R10 /2003 2513 psig 2464 psig B within 3% and C within 1%2R1 1 / 2005 2449 psig Within 3%2R12 /2006 2491 psig Within 1%2R13 /2008 2483 psig 2466 psig Both within 1%2R14/2009 2479 psig Within 1%BVPS-2 Refueling Outage (2R)Cold Shut Down (CSD)2RCS*RV551B (B)2RCS*RV551C (C)Pounds per square inch gauge (psig)Setpoint = 2485 psig Plus or minus 3 percent = 2559.5 -2410.5 psig Plus or minus 1 percent = 2509.8 -2460.2 psig Note 1. Valve lifted due to seat leakage.6.0 Duration of Proposed Alternative The duration of the proposed alternative is the remainder of the BVPS-2 third 10-Year Inservice Test Interval.}}