ML110610205

Beaver Valley, Units 1 & 2, 10 CFR 50.55a Request (VRR5) Regarding Turbine Driven Auxiliary Feedwater Valve Test Frequency

ML110610205
Person / Time
Site:	Beaver Valley
Issue date:	02/25/2011
From:	Harden P A FirstEnergy Nuclear Generation Corp
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-11-023
Download: ML110610205 (5)

Text

FENOCBeaver Valley Power Station P.O. Box 4 FirstEnergy Nuclear Operating CompanyShippingport, PA 15077 Paul A. Harden724-682-5234 Site Vice PresidentFax: 724-643-8069 February 25, 2011 L-11-023 10 CFR 50.55a Attention: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 10 CFR 50.55a Request (VRR5) Regarding Turbine Driven Auxiliary Feedwater Valve Test Frequency In accordance with 10 CFR 50.55a, FirstEnergy Nuclear Operating Company (FENOC) requests Nuclear Regulatory Commission (NRC) approval of proposed alternatives for the Beaver Valley Power Station (BVPS), Unit No.1 fourth interval Inservice Testing Program for Pumps and Valves (IST Program) and the BVPS, Unit No. 2 third interval 1ST Program. The proposed alternative is associated with full-stroke open exercise tests of turbine driven auxiliary feedwater pump discharge valves.

In support of the spring 2012 refueling outage, FENOC requests approval of the proposed requests by March 14, 2012.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Thomas A. Lentz, Manager - Fleet Licensing, at 330-761-6071.

Paul A. Harden

Enclosure:

10 CRF 50.55a Request Number: VRR5, Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)

Beaver Valley Power Station, Unit Nos. 1 and 2 L-11-023 Page 2 cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

10CFR 50.55a Request Number: VRR5 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)

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--Hardship or Unusual Difficulty without Compensating In crease in Level of Quality or Safety--

1.0 ASME Code Components Affected

1FW-33, Turbine-Driven Auxiliary Feedwater Pump (TDAFWP) Discharge Check Valve (Class 3, Category C) 2FWE*FCV122, TDAFWP Discharge Check and Recirculating Valve (Class 3, Category B/C)

2.0 Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Operations an d Maintenance (OM)

Code-2001, with Addenda through OMb-2003. 3.0 Applicable Code Requirement ISTC-3510, "Exercising Test Frequency," states in part: "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months-"

4.0 Reason for Request

2FWE*FCV122 is a three-way automatic recircul ation control valve t hat acts as both a manual automatic flow control valve in one direction and a check valve in the other direction. 1FW-33 is a check valve onl

y. Both 2FWE*FCV122 and 1FW-33 are normally closed during plant operation and ar e required to open in order to allow auxiliary feedwater flow to the steam generators (SGs) during an accident. The relatively cold auxiliary feedwater is drawn from a demineralized water storage tank, which is not routinely treated for pH or oxygen control.

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 SG s 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 direct ion on a three-month frequency results in hardship:

Beaver Valley Power Station, Unit Nos. 1 and 2 10 CFR 50.55a Request Number: VRR5

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a) The introduction of relatively cold aux iliary 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 t he 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 rela tively cold water coul d 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 nece ssary to reduce reactor power to 97 percent or less, which places additi onal burden on plant operators. c) The TDAFW pumps receive their suct ion from a demineralized water storage tank. The water in these demineralized water storage tanks is not routinely treated for pH or oxygen c ontrol, 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.

5.0 Proposed

Alternative and Basis for Use Per ISTC-3522(c), "Category C Check Valves," "If exercising is not practicable during operation at power and cold shutdown, it s hall be performed during refueling outages."

Because it has been considered not practic able to perform during operation at power and cold shutdown, the quarte rly 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 le vel no greater than 97 percent.

Although testing during power operation has been determined to be acceptable, FENOC desires to test the pump and associat ed 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-st roke exercises of valves 1FW-33 and 2FWE*FCV122 in the open direction when auxiliar y 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 Beaver Valley Power Stat ion, Unit Nos. 1 and 2 Inservice Testing 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. Te sting these check valves during power operation at the nominal quarterly frequency required by ISTC-3510 would result in the hardship described above, without a compensating increase in the level of quality and safety.

Beaver Valley Power Station, Unit Nos. 1 and 2 10 CFR 50.55a Request Number: VRR5

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6.0 Duration

of Proposed Alternative The proposed alternatives identified in this relief request shall be utilized during the remainder of the BVPS Unit No. 1 fourth 10-Year Inservice Test Interval, which began on September 20, 2007 and the BVPS Unit No. 2 th ird 10-Year Inservice Test Interval, which began on Nove mber 18, 2007. 7.0 References Westinghouse Report, Beaver Valley Units 1 and 2 Transient Analysis of at Power Auxiliary Feedwater Functional Test, LT R-PCSA-10-5, dated S eptember 2, 2010.