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MONTHYEARML0716501222007-08-0303 August 2007 Relief Request No. BV3-PT-1 Regarding Hydrostatic Pressue Testing (TAC Nos. MD2936) and MD2937) Project stage: Other 2007-08-03
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Category:Letter
MONTHYEARML24025A0922024-01-25025 January 2024 Requalification Program Inspection L-23-267, Submittal of Discharge Monitoring Report (Npdes), Permit No. PA00256152023-12-18018 December 2023 Submittal of Discharge Monitoring Report (Npdes), Permit No. PA0025615 IR 05000334/20230112023-12-0404 December 2023 Age-Related Degradation Inspection Report 05000334/2023011 and 05000412/2023011 L-23-229, Request for Additional Information Regarding the Spring 2023 Generic Letter 95-05 Voltage-Based Alternate Repair Criteria and Steam Generator F-Star Reports2023-11-29029 November 2023 Request for Additional Information Regarding the Spring 2023 Generic Letter 95-05 Voltage-Based Alternate Repair Criteria and Steam Generator F-Star Reports IR 05000334/20233012023-11-27027 November 2023 Initial Operator Licensing Examination Report 05000334/2023301 L-23-247, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-11-17017 November 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 IR 05000334/20230032023-11-0606 November 2023 Integrated Inspection Report 05000334/2023003 and 05000412/2023003 L-23-227, Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Third Quarter 20232023-10-20020 October 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Third Quarter 2023 ML23279A0612023-10-0505 October 2023 Paragon Energy Solutions LLC, Part 21 Final Report Re Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23198A3592023-10-0202 October 2023 Issuance of Amendment Nos. 322 and 212 Analytical Methodology to the Core Operating Limits Report for a Full Spectrum Loss of Coolant Accident (EPID L-2022-LLA-0129) - Nonproprietary IR 05000334/20234022023-09-29029 September 2023 Security Baseline Inspection Report 05000334/2023402 and 05000412/2023402 (Cover Letter Only) ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure IR 05000334/20234012023-09-21021 September 2023 Cybersecurity Inspection Report 05000334/2023401 and 05000412/2023401 (Cover Letter Only) ML23263A0192023-09-20020 September 2023 Operator Licensing Examination Approval ML23243A9272023-09-19019 September 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23249A1842023-09-18018 September 2023 Authorization and Safety Evaluation for Alternative Request No. 2-TYP-4-RV-06 L-23-208, Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA00256152023-09-14014 September 2023 Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA0025615 L-23-167, Twenty-Third Refueling Outage Inservice Inspection Summary Report2023-09-13013 September 2023 Twenty-Third Refueling Outage Inservice Inspection Summary Report L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments IR 05000334/20230052023-08-31031 August 2023 Updated Inspection Plan for Beaver Valley Power Station Units 1 and 2 (Report 05000334/2023005 and 05000412/2023005) L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual ML23129A1722023-08-25025 August 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2; Davis Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 IR 05000334/20230022023-08-0909 August 2023 Integrated Inspection Report 05000334/2023002 and 05000412/2023002 ML23219A0592023-08-0707 August 2023 Steam Generator Inspection Reports - Spring 2023 Spring Refueling Outrage L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-179, Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA00256152023-07-18018 July 2023 Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA0025615 ML23188A0982023-07-17017 July 2023 Correction to the Safety Evaluation Issued Related to Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time ML23188A0672023-07-10010 July 2023 Project Manager Assignment L-23-165, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-06-26026 June 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-139, Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report2023-06-13013 June 2023 Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report ML23157A1072023-06-0707 June 2023 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000334/2023011 and 05000412/2023011 ML23143A0272023-05-23023 May 2023 Licensed Operator Positive Fitness-For-Duty Test L-23-055, Submittal of the Updated Final Safety Analysis Report, Revision 342023-05-23023 May 2023 Submittal of the Updated Final Safety Analysis Report, Revision 34 ML23102A1472023-05-22022 May 2023 Issuance of Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23135A7872023-05-19019 May 2023 Summary of Conference Calls Regarding the Spring 2023 Steam Generator Tube Inspections L-23-137, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-05-18018 May 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 L-23-125, Cycle 24 Core Operating Limits Report2023-05-17017 May 2023 Cycle 24 Core Operating Limits Report ML23124A3882023-05-16016 May 2023 Summary of Regulatory Audit in Support of License Amendment Request to Revise Technical Specification 5.6.3, Core Operating Limits Reports (COLR) and TS 4.2.1 Fuel Assemblies ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) L-23-132, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-10010 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations IR 05000334/20230012023-05-0808 May 2023 Integrated Inspection Report 05000334/2023001 and 05000412/2023001 L-23-129, Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations2023-05-0505 May 2023 Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations ML23118A3812023-04-28028 April 2023 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations L-23-115, Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological2023-04-27027 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological L-23-126, Discharge Monitoring Report (Npdes), Permit No. PA00256152023-04-22022 April 2023 Discharge Monitoring Report (Npdes), Permit No. PA0025615 CP-202300181, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-20020 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML23107A2502023-04-18018 April 2023 Requalification Program Inspection 2024-01-25
[Table view] Category:Safety Evaluation
MONTHYEARML23198A3592023-10-0202 October 2023 Issuance of Amendment Nos. 322 and 212 Analytical Methodology to the Core Operating Limits Report for a Full Spectrum Loss of Coolant Accident (EPID L-2022-LLA-0129) - Nonproprietary ML23237B4282023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 2, Draft Conforming License Amendments ML23237B4302023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0000) (Public) ML23249A1842023-09-18018 September 2023 Authorization and Safety Evaluation for Alternative Request No. 2-TYP-4-RV-06 ML23188A0982023-07-17017 July 2023 Correction to the Safety Evaluation Issued Related to Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time ML23102A1472023-05-22022 May 2023 Issuance of Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time ML23019A0032023-03-16016 March 2023 Issuance of Amendment Nos. 320 and 210 Adoption of Technical Specifications Task Force (Tstf) Traveler Tstf-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control ML23062A5212023-03-0606 March 2023 Issuance of Amendment No. 319 Revise Technical Specification (TS) 3.5.2, ECCS Operating, Limiting Condition for Operation (LCO) 3.5.2, ML22277A8142022-10-0707 October 2022 Correction of Errors in Safety Evaluation Associated with License Amendment Nos. 315 and 205 Regarding Changes to the Emergency Preparedness Plan ML22210A0102022-09-16016 September 2022 Energy Harbor Fleet- Issuance of Amendments Regarding Adoption of TSTF 554, Revise Reactor Coolant Leakage Requirements ML22222A0862022-09-0101 September 2022 Issuance of Amendment Nos. 317 and 208 Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation ML22235A7672022-09-0101 September 2022 Correction of Errors in Safety Evaluation Associated with License Amendment Nos. 315 and 205 Regarding Changes to the Emergency Preparedness Plan ML22202A4642022-06-29029 June 2022 Emergency Plan Safety Evaluation ML22140A2092022-06-28028 June 2022 Issuance of Amendment No. 207 Correct TS 3.1.7 Change Made by TSTF-547 ML22095A2352022-05-10010 May 2022 Issuance of Amendment Nos. 316 and 206 Revise Technical Specification 5.6.3, Core Operating Limits Report (COLR) ML21286A7822022-05-0606 May 2022 Issuance of Amendment Nos. 315 and 205 Regarding Changes to the Emergency Plan ML22077A1342022-05-0202 May 2022 Issuance of Amendment Nos. 314 and 204 Revise Technical Specifications to Adopt TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ML22082A2532022-03-29029 March 2022 Correction Letter - Issuance of Authorization of Proposed Alternative to Use ASME OM Code Case OMN-27 ML22012A2972022-01-21021 January 2022 Proposed Alternative to Use ASME OM Code Case OMN-27 ML21197A0092021-11-0101 November 2021 Issuance of Amendment Nos. 313 and 203 Reactor Coolant System, Pressure and Temperature Limits Report ML21214A2752021-10-15015 October 2021 Issuance of Amendment Nos. 312 and 202 Atmospheric Dump Valves ML21153A1762021-06-30030 June 2021 Issuance of Amendment No. 201 Revision of Technical Specifications Related to Steam Generator Tube Inspection, and Repair Methods ML21075A1132021-04-16016 April 2021 Issuance of Amendment Nos. 311, 200, and 302 to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff, Into the Technical Specifications ML21070A0002021-03-22022 March 2021 Issuance of Amendment 310, Revise Technical Specification 5.5.5.1, Unit 1 SG Program, to Defer Spring 2021 Refueling Outage Steam Generator Inspections to Fall 2022 Refueling Outage ML20346A0222021-03-10010 March 2021 Issuance of Amendment Nos. 309 and 199 to Change Technical Specifications to Implement New Surveillance Methods for the Heat Flux Hot Channel Factor ML20335A0522021-02-18018 February 2021 Issuance of Amendment Nos. 308 and 198 to Modify Certified Fuel Handler Related Technical Specifications for Permanently Defueled Condition ML20345A2362021-01-28028 January 2021 Issuance of Amendment Nos. 307 and 197 to Add Containment Sump Technical Specifications to Address GSI-191 Issues ML20335A0232020-12-28028 December 2020 Issuance of Amendment Nos. 306 and 196 to Remove License Conditions B and C Related to the Irradiated Fuel Management Plans ML20285A2662020-10-21021 October 2020 Correction to Safety Evaluation for Amendment Nos. 305 and 195 Issued September 23, 2020, Modify Primary and Secondary Coolant Activity Technical Specifications ML20279A4402020-10-0808 October 2020 Energy Harbor Fleet-Beaver Valley Power Station; Davis-Besse Nuclear Power Station, and Perry Nuclear Power Plant - Request to Use a Provision of a Later Edition of the ASME Engineers Boiler and Pressure Vessel Code, Section XI ML20213A7312020-09-23023 September 2020 Issuance of Amendment Nos. 305 and 195 to Modify Primary and Secondary Coolant Activity Technical Specifications ML20223A0142020-08-20020 August 2020 Issuance of Relief Request SSR-1, Revision 0, from the Requirements of the ASME Code (EPID L-2020-LLR-0050 (COVID-19)) ML20206K8652020-08-0707 August 2020 Relief Requests 2-TYP-4-RV-06 and 2-TYP-4-RV-07 from the Requirements of the ASME Code (EPID L-2020-LLR-0053 and EPID L-2020-LLR-0054 (COVID-19)) ML20153A0142020-07-16016 July 2020 Relief from the Requirements of the American Society of Mechanical Engineers Code Regarding Request VRR4 (EPID L-2020-LLR-0052 (COVID-19)) ML20145A0002020-06-0303 June 2020 Relief from the Requirements of the ASME Code for Requests VRR6 and VRR5 (EPID L-2020-LLR-0049 and EPID L-2020-LLR-0051 (COVID-19)) ML20080J7892020-04-28028 April 2020 Relief Requests 2 TYP-3-B3.110-1, 2-TYP-3-C2.21-1, 2-TYP-3-C1.30-1, and 2-TYP-3-RA-1 Regarding Weld Examination Coverage for the Third Inservice Inspection Interval ML20079F8162020-03-26026 March 2020 Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 Regarding Weld Examination Coverage for the Fourth Inservice Inspection Interval ML19336A0282019-12-18018 December 2019 Safety Evaluation Irradiated Fuel Management Plans ML19305B1312019-12-0202 December 2019 Firstenergy Nuclear Operating Company - Enclosure 6, Non-Proprietary Safety Evaluation, Direct and Indirect Transfer of Licenses and Draft Conforming Amendments for Beaver Valley Units 1 and 2, Davis-Besse Unit 1, and Perry Unit 1 ML19275E2942019-10-16016 October 2019 Issuance of Relief Request Proposed Alternative to Reactor Vessel Nozzle Weld Examination Frequency Requirements in Lieu of Specific ASME Code Requirements ML19028A0302019-04-11011 April 2019 FENOC - Beaver Valley Power Station, Unit 1 & 2; Davis-Besse Nuclear Power Station Unit 1; and Perry Nuclear Power Plant Unit 1 - Approval of Certified Fuel Handler Training and Retraining Program ML18348B2062019-02-25025 February 2019 Issuance of Amendment No. 193 Revise Steam Generator Technical Specifications ML18249A1692018-09-0707 September 2018 Seismic Hazard Mitigation Strategies Assessment (CAC Nos. MF7800 and MF7801; EPID L-2016-JLD-0006) ML18227A7332018-08-27027 August 2018 Request for Relief from the Requirements of the ASME Code ML18205A2922018-08-10010 August 2018 Correction of Errors in Safety Evaluation Associated with Relief Request 2-TYP-4-RV-02 ML18179A4672018-07-30030 July 2018 FENOC-Beaver Valley Power Station, Unit No. 1 and 2; Davis-Besse Nuclear Power Station, Unit 1, and Perry Nuclear Power Plant, Unit 1 - Issuance of Amendments Request to Adopt TSTF-529, Clarify Use and Application Rules ML18178A1122018-07-0202 July 2018 Relief Request No. 2-TYP-4-RV-02 Regarding the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case N-729-4 Examination Requirements ML18065A4032018-04-0505 April 2018 Correction of Errors in Safety Evaluation Associated with License Amendment Nos. 301 and 190 ML18073A1062018-03-28028 March 2018 Safety Evaluation of Proposed Alternatives 1-TYP-4-BA-01 and TYP-4-BN-01 Regarding the Fourth 10- Year Interval of the Inservice Inspection Program ML18075A0962018-03-27027 March 2018 Safety Evaluation of Proposed Alternative to Use ASME Code Cases N-695-1 and N-696-1 in Lieu of Certain Requirements of the ASME Code 2023-09-28
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August 3, 2007 Mr. Peter P. Sena III 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 NO. BV3-PT-1 REGARDING HYDROSTATIC PRESSURE TESTING (TAC NOS. MD2936 AND MD2937)
Dear Mr. Sena:
By letter dated September 1, 2006, FirstEnergy Nuclear Operating Company (the licensee),
requested approval of an alternative to the hydrostatic pressure testing of Class 1 pressure retaining piping and valves requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for Beaver Valley Power Station, Unit No. 1 (BVPS-1) third interval inservice inspection (ISI) program and Unit No. 2 (BVPS-2) second 10-year ISI program. The licensee plans to perform a system leakage test at a lower pressure than what is specified in ASME Code Case N-498-1. The RCS vents, drains, and instrument connections will be visually examined (VT-2) for evidence of past leakage and/or leakage, if any, during a system leakage test with each inboard isolation valve in its normal closed position.
The Nuclear Regulatory Commission (NRC) staff has concluded that compliance with the ISI Code of Record would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, and that the proposed alternative provides reasonable assurance of structural integrity. Therefore, pursuant to Section 50.55a(a)(3)(ii) of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR), the staff authorizes the ISI program alternative for the third 10-year ISI interval of BVPS-1 and the second 10-year interval of BVPS-2.
P. Sena All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA/
Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
As stated cc w/encl: See next page
ML071650122 *Input received. No substantive changes made.
OFFICE LPLI-1/PM LPLI-1/LA DCI/CSGB/BC OGC LPLI-1/BC NAME NMorgan SLittle AHiser
- ACuratola MKowal DATE 6/21/07 6/21/07 05/29/2007 7/26/07 8/03/07
Beaver Valley Power Station, Unit Nos. 1 and 2 cc:
Joseph J. Hagan Peter P. Sena III President and Chief Nuclear Officer Site Vice President FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-SEB1 Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 James H. Lash Senior Vice President of Operations Director, Fleet Regulatory Affairs and Chief Operating Officer FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GHE-315 Mail Stop A-GO-14 395 Ghent Road 76 South Main Street Akron, Ohio 44333 Akron, OH 44308 Manager, Site Regulatory Compliance Danny L. Pace FirstEnergy Nuclear Operating Company Senior Vice President, Fleet Engineering Beaver Valley Power Station FirstEnergy Nuclear Operating Company Mail Stop A-BV-A Mail Stop A-GO-14 P.O. Box 4, Route 168 76 South Main Street Shippingport, PA 15077 Akron, OH 44308 Richard Anderson Jeannie M. Rinckel Vice President, Nuclear Support Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Mail Stop A-GO-14 Akron, Ohio 44308 76 South Main Street Akron, OH 44308 Commissioner James R. Lewis West Virginia Division of Labor David W. Jenkins, Attorney 749-B, Building No. 6 FirstEnergy Corporation Capitol Complex Mail Stop A-GO-18 Charleston, WV 25305 76 South Main Street Akron, OH 44308 Director, Utilities Department Public Utilities Commission Manager, Fleet Licensing 180 East Broad Street FirstEnergy Nuclear Operating Company Columbus, OH 43266-0573 Mail Stop A-GHE-115 395 Ghent Road Director, Pennsylvania Emergency Akron, OH 44333 Management Agency 2605 Interstate Dr.
Ohio EPA-DERR Harrisburg, PA 17110-9364 ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149
Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:
Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING THE INTERVAL INSERVICE INSPECTION PROGRAMS FOR RELIEF REQUEST NO. BV3-PT-1 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 September 1, 2006, Agencywide Document Access and Management System (ADAMS) accession number ML062490202, FirstEnergy Nuclear Operating Company (the licensee), requested approval of an alternative to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for Beaver Valley Power Station, Unit No. 1 (BVPS-1) third interval inservice inspection (ISI) program and Unit No. 2 (BVPS-2) second 10-year ISI program. In lieu of this requirement, the licensee proposed to perform a system leakage test in accordance with ASME Code Case N-498-1, Alternative Rules for 10-year System Hydrostatic Testing for Class 1, 2, 3 Systems, which requires that the boundary subject to test pressurization during the system leakage test extend to all Class 1 pressure boundary vents, drains, and instrument connections. However, the normal system alignment of valves in the Class 1 segment of the vents, drains, and instrument connections would exclude a small segment of the piping from attaining the required test pressure. In lieu of the 10-year system hydrostatic test for the reactor coolant system (RCS), the alternative pertains to performance of a system leakage test at a pressure less than the nominal operating pressure associated with 100% rated power and the visual examination of RCS vents, drains, and instrument connections with each inboard isolation valve in its normal closed position.
2.0 REGULATORY REQUIREMENTS Section 50.55a(g) of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR) requires that ISI of ASME Code Class 1, 2, and 3 components are performed in accordance with Section XI of the ASME Code and applicable addenda, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). According to 10 CFR Enclosure
50.55a(a)(3)(ii), alternatives to the requirements of paragraph 50.55a(g) may be used, when authorized by the Director of the Office of Nuclear Reactor Regulation, if an applicant demonstrates that the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that ISI of components and system pressure tests, conducted during the first 10-year interval and subsequent intervals, comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of Record for the third 10-year inspection interval of BVPS-1 and the second 10-year inspection interval of BVPS-2, is the 1989 Edition of the ASME Code,Section XI.
3.0 TECHNICAL EVALUATION
3.1 System/Component(s) Affected Class 1 reactor coolant pressure boundary vents, drains, and instrument connections less than 1 inch in diameter.
3.2 ASME Code Requirements Table IWB-2500-1, Category B-P, Item B15.51, requires hydrostatic testing of Class 1 pressure retaining piping once per Ten-year interval. Code Case N-498-1 (referenced in the BVPS Ten-Year Inservice Inspection Program) allows a system leakage test in lieu of the Ten-year hydrostatic testing. Note 2 of Table IWB-2500-1 and Paragraph (a)(2) of N-498-1 require that the test pressurization boundary extend to all Class 1 components.
Paragraph IWB-5221(a) states, The system leakage test shall be conducted at a test pressure not less than the nominal operating pressure associated with 100% rated power.
3.3 Licensees Basis for Request Normal reactor coolant pressure at 100% rated power is approximately 2235 pounds per square inch gauge (psig). The components and piping in the RCS vents, drains, and instrument connections less than 1-inch diameter are the portion of piping between the inboard and the outboard isolation valves including the valves, or between an isolation valve and a closure device such as a pipe cap, blind flange, or plug. This segment of piping will not be pressurized to the required test pressure during system leakage test with the inboard isolation valve closed in the normal plant operation. In order to test the segment, the test crew would have to change each valve position when the RCS is at 2235 psig and a temperature greater than 500 °F. Since most of the valves are inaccessible, temporary scaffolding has to be erected to reposition the valves. Alternatively, a test rig connected to a pipe segment, in place
of a blind flange or end cap, could be used during plant shutdown to pressurize the segments.
This would require excess man-hour for the test resulting in higher radiation exposure to personnel, which is inconsistent with as low as reasonably achievable (ALARA) radiation exposure goals. The test would not confirm leak-tightness of the removed closure device, such as a blind flange or an end cap. The radiation exposure to personnel in the evolution of pressurizing the segment of piping to the required test pressure, during the system leakage test, is estimated to be between 500 mrem (millirem) and 1500 mrem at BVPS-1, and between 100 mrem and 300 mrem at BVPS-2. Furthermore, the valve manipulation necessary to pressurize the isolated segments of vents, drains, and instrument connections and their return to normal closed position would impact the schedule for the outage. The licensee, therefore, considers that compliance with the requirement of Code Case N-498-1 to pressurize the downstream portion of the RCS vents, drains, and instrument connections less than 1 inch in diameter would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.4 Licensees Proposed Alternative In lieu of performing the 10-year system hydrostatic test, the licensee plans to perform a system leakage test at a lower pressure than what is specified in ASME Code Case N-498-1. The RCS vents, drains, and instrument connections will be visually examined (VT-2) for evidence of past leakage and/or leakage, if any, during a system leakage test with each inboard isolation valve in its normal closed position.
4.0 STAFF EVALUATION The Code of Record, 1989 Edition ASME Code,Section XI, Table IWB-2500-1, Category B-P, Item B15.51 requires hydrostatic testing of Class 1 pressure retaining piping once per 10-year interval. The licensee adopted Code Case N-498-1 in their 10-year ISI program which allows a system leakage test in lieu of the Code-required system hydrostatic test. The system leakage test is required to be performed at a test pressure not less than the nominal operating pressure of the RCS corresponding to 100% rated reactor power and must include all Class 1 components within the RCS boundary.
The licensee proposed an alternative to the requirement of Code Case N-498-1 for the RCS vents, drains, and instrument connections, which would isolate a segment of piping between the inboard and outboard isolation valves or the inboard isolation valve and a closure device such as a pipe cap, blind flange, or plug from being pressurized during a system leakage test. The line configuration, as outlined, provides double-isolation of the RCS. Under normal plant operating conditions, the subject pipe segments would see RCS temperature and pressure only if leakage through the inboard isolation valves occurs. In order for the licensee to perform the ASME Code-required test, it would be necessary to manually open the inboard valves to pressurize the pipe segments. Pressurization by this method would preclude the RCS double-valve isolation and may cause safety concerns for the personnel performing the examination.
Typical line/valve configurations are in close proximity of the RCS main run of pipes and thus, would require personnel entry into high radiation areas within the containment. In order to test the segment, the test crew would have to change each valve position when the RCS is at 2235 psig and a temperature greater than 500 °F. Since most of the valves are inaccessible, temporary scaffolding has to be erected to reposition the valves. Manual actuation (opening
and closing) of these valves is estimated to expose plant personnel to approximately between 500 mrem and 1500 mrem at BVPS-1, and between 100 mrem and 300 mrem at BVPS-2.
However, the licensee proposed a visual examination (VT-2) for leaks in the isolated portion of the subject segments of piping with the isolation valves in the normally closed position, which would indicate any evidence of past leakage during the operating cycle and any active leakage during the system leakage test if the inboard isolation valve leaks.
5.0 CONCLUSION
The NRC staff has concluded that to require the licensee to pressurize the subject piping segments in the RCS vents, drains, and instrument connections in accordance with Code Case N-498-1 during the system leakage test, would result in exposing personnel to high radiation, heat stress and will impact the schedule of the outage. Based on the NRC staffs evaluation, the licensees proposed alternative provides a reasonable assurance of operational readiness, structural integrity, and has shown that compliance with the code case requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the proposed alternative is authorized for the third 10-year ISI interval of BVPS-1 and the second 10-year ISI interval of BVPS-2.
All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including a third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: P. Patnaik Date: August 3, 2007