ML113130428

Relief Request VRR5 Regarding Turbine Driven Auxiliary Feedwater Valve Test Frequency for the 10-Year Inservice Testing Program Interval (TAC Nos. ME5781 and ME5782)

ML113130428
Person / Time
Site:	Beaver Valley
Issue date:	11/22/2011
From:	Nancy Salgado Plant Licensing Branch 1
To:	Harden P FirstEnergy Nuclear Operating Co
Morgan Nadiyah, NRR/Dorl, 415-1016
References
TAC ME5781, TAC ME5782
Download: ML113130428 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 22, 2011 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 VRR5 REGARDING TURBINE DRIVEN AUXILIARY FEEDWATERVALVE TEST FREQUENCY FOR THE 10-YEAR INSERVICE TESTING PROGRAM INTERVAL (TAC NOS. ME5781 AND ME5782)

Dear Mr. Harden:

By letter dated February 25, 2011, FirstEnergy Nuclear Operating Company (the licensee) requested authorization of a proposed alternative to the inservice testing (1ST) programs at Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) for the remainder of the BVPS-1 fourth 10-year 1ST program interval and the BVPS-2 third 10-year 1ST program interval.

Specifically, the licensee requested to use an alternative test interval rather than the required interval per the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) for turbine driven auxiliary feedwater pump (TDAFWP) discharge check valve, 1FW-33 at BVPS-1 and TDAFWP discharge check and recirculating valve, 2FWE*FCV122 at BVPS-2.

The Nuclear Regulatory Commission (NRC) staff has concluded that the proposed alternative in Relief Request VRR5 provides reasonable assurance that TDAFWP valves, 1FW-33 and 2FWE*FCV122, are operationally ready. Therefore, pursuant to Section 50.55a(a}(3}(ii) of Part 50 of Title 10 of the Code of Federal Regulations, the NRC staff authorizes the proposed alternative for the remainder of the BVPS-1 fourth 1O-year lSI interval and the BVPS-2 third 10 year lSI interval, which ends September 19,2017, and November 17, 2017, respectively.

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, l\Iadiyah Morgan, at (301) 415-1016.

Sincerely, OLQ~~,-

a,~~?~ L. Salgado, 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 REGARDING ALTERNATIVE TO THE INSERVICE TESTING PROGRAM 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 25,2011 (Agencywide Document Access and Management System (ADAMS) Accession No. ML110610205), FirstEnergy Nuclear Operating Company (the licensee) requested authorization of a proposed alternative to the inservice testing (1ST) programs at Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) for the remainder of the BVPS-1 fourth 10-year 1ST program interval and the BVPS-2 third 10-year 1ST program interval. Specifically, the licensee requested to use an alternative test interval rather than the required interval per the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for turbine driven auxiliary feedwater pump (TDAFWP) discharge check valve, 1FW-33 at BVPS-1 and TDAFWP discharge check and recirculating valve, 2FWE*FCV122 at BVPS-2.

2.0 REGULATORY EVALUATION

Section 50.55a(f) of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR), "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)(1i). 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)(ii).

Enclosure

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3.0 TECHNICAL EVALUATION

3.1 System/Component Affected 1FW-33 TDAFWP Discharge Check Valve (Class 3, Category C) 2FWE*FCV122 TDAFWP Discharge Check and Recirculating Valve (Class 3, Category B/C) 3.2 Applicable Code Requirements The applicable ASME OM Code edition and addenda for BVPS-1 and 2 is the 2001 Edition through the 2003 Addenda.

ISTC-3510, "Exercising Test Frequency, "states in part that, "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3

[months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3560, ISTC-5221, and ISTC-5222. Power-operated relief valves shall be exercise tested once per fuel cycle."]

[ISTC-3522(c), "Category C Check Valves," states that, "If exercising is not practicable during operation at power and cold shutdowns, it shall be performed during refueling outages."]

3.3 Licensee's Proposed Alternative 2FWE*FCV122 is a three-way automatic recirculation control valve that acts as both a manual automatic flow control valve in one direction and a check valve in the other direction. 1FW-33 is only a check valve. Both 2FWE*FCV122 and 1FW-33 are normally closed during plant operation and are required to open in order to allow auxiliary feedwater flow to the steam generators (SGs) during an accident.

In accordance with ISTC-5221, "Valve Obturator Movement," and NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," Revision 1, Section 4.1.3, "Full Flow Testing of Check Valves," a full-stroke exercise in the open direction may be achieved by passing the maximum required accident condition flow through the valve. A full-stroke open exercise of these check valves can only be performed when auxiliary feedwater flow is aligned to the SGs during the full flow (comprehensive pump) test of the TDAFWP. The TDAFWP full flow test can only be performed in Modes 1, 2, or 3 because steam from any of the three SGs is required to drive the pump.

The following information describes why aligning auxiliary feedwater flow to the SGs in order to perform a full-stroke exercise test in the open direction on three-month frequency results in a hardship:

-3 a) The introduction of relatively cold auxiliary feedwater into the SGs produces a potential for thermal shock to both the main feed piping (thermal sleeves) and the secondary side of the SGs. Although the thermal sleeves and SGs are designed for thermal shock, exposure to such events should be minimized in order to ensure the benefits of plant life extension are realized.

b) Feeding the SGs with a large volume of relatively cold water could also result in a large level transient in the SGs and could cause a reactor trip.

Therefore, in order to avoid a reactor trip, it is necessary to reduce reactor power to 97 percent or less, which places additional burden on plant operators.

c) The TDAFWPs receive their suction from a demineralized water storage tank. The water in these demineralized water storage tanks is not routinely treated for pH or oxygen control, which could impact the corrosion rates in the secondary system. From a chemistry perspective, based on the lack of oxygen control in this water source, it is prudent to minimize the use of this water while in Modes 1, 2, or 3.

Per ISTC-3522(c), "Category C Check Valves," "If exercising is not practicable during operation at power and cold shutdown, it shall be performed during refueling outages." Because it has been considered not practicable to perform during operation at power and cold shutdown, the quarterly testing of valves 1FW-33 and 2FWE*FCV122 required by ISTC-3510 has, to date, only been performed at a refueling outage frequency, in Mode 3, during startup.

On the basis of an analysis performed by Westinghouse in September 2010, "Beaver Valley Units 1 and 2 Transient Analysis of at Power Auxiliary Feedwater Functional Test - Final Report," performance of the test during power operation is now considered acceptable at an initial power level no greater than 97 percent.

Although testing during power operation has been determined to be acceptable, FENOC [the Iicensee1 desires to test the pump and associated discharge check valve at the two-year frequency. As an alternative to the testing required at a nominal quarterly frequency by ISTC-3510, FENOC proposes to perform full stroke exercises of valves 1FW-33 and 2FWE*FCV122 in the open direction when auxiliary feedwater flow is aligned to the SGs during the full-flow (comprehensive pump) test of the TDAFWP, to be performed once every two years.

A review of the (BVPS-1 and 21ST programs] trending database indicated that over the past 10 years, these valves have consistently passed the full-stroke exercise test in the open direction. Testing at a refueling outage frequency has been adequate to demonstrate the continued reliability and acceptable operation of the valves. Testing these check valves during power operation at the nominal quarterly frequency required by ISTC-3510 would result in the hardship

-4 described above, without a compensating increase in the level of quality and safety.

3.4 NRC Staff's Evaluation The licensee has proposed an alternative in lieu of the requirements found in 2001 Edition through 2003 Addenda of the ASME OM Code, Section ISTC-3510. Specifically, the licensee proposed to exercise check valve assemblies, 'I FW-33 and 2FWE*FCV122, in the open direction, at a refueling outage interval, instead of the nominal 3-month interval specified in ISTC-3510.

OM Code requirement ISTC-3510 requires that active Category A, Category B, and Category C check valves be exercised nominally every 3 months. Check valve exercise shall include open and close tests. These tests need only be performed at an interval that is practical to perform both tests. For valve tests deemed impractical to perform during normal operation, exercising shall be performed during cold shutdown or during refueling outages.

The licensee has been testing check valves, 1FW-33 and 2FWE*FCV122, at a refueling outage interval due to the impracticality of open testing of these valves at power. Nominal exercise testing every 3 months has been determined to be impractical due to the licensee noted summarized concerns. Examination of 10 years of 1ST program data indicates that these valves have conSistently passed operational testing at a refueling outage interval. However, a recent analysiS performed by Westinghouse determined that exercise testing of these the check valves, during normal operation, was acceptable. Although it was concluded by the Westinghouse analysis that testing is practical at normal operation, the licensee still has concerns with testing these valves at power. Testing at the nominal 3-month interval increases the potential for thermal shock of the main feed piping, escalates the possibility of upsetting the treated water chemistry balance, and increases the chances of a reactor trip. Based on the historical performance of check valves, 1FW-33 and 2FWE*FCV122, and the concerns of testing at power, exercise testing at the nominal 3-month interval represents a hardship or unusual difficulty without an jncrease in the level of quality and safety. Therefore, the NRC staff finds that the proposed alternative provides reasonable assurance that the valves are operationally ready.

4.0 CONCLUSION

Based on the above evaluation, the NRC staff has concluded that the proposed alternative in Relief Request VRR5 provides reasonable assurance that TDAFWP valves, 'I FW-33 and 2FWE*FCV122, are operationally ready. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the proposed alternative for the remainder of the BVPS-1 fourth 10-year lSI interval and the BVPS-2 third 10-year lSI interval, which ends September 19, 2017, and November 17, 2017, respectively.

- 5 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: M. Farnan Date: November 22, 2011

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

Sincerely, lraJ (J8oska for)

Nancy L. Salgado, 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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ADAMS Accession No.: ML113130428

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• See memo dated October 31 , 2011 ..

i OFFICE LPL1-1/PM LPL 1-1/LA DCI/CPTB/BC LPL 1-1/BC NSalgado NAME NMorgan SUttle AMcMurtray* (J Boska for)

,. ('II'">" 1"011 DATE 11/21/11 11/21/11 11/22/11 OFFICIAL RECORD COPY