L-08-146, Reply to Request for Additional Information for Review, License Renewal Application and License Renewal Application Amendment No. 7

Reply to Request for Additional Information for Review, License Renewal Application and License Renewal Application Amendment No. 7

ML081230618
Person / Time
Site:	Beaver Valley
Issue date:	04/30/2008
From:	Sena P FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-146, TAC MD6593, TAC MD6594
Download: ML081230618 (8)

Text

FENOC FirstEnergy NuclearOperatingCompany PeterP. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 April 30, 2008 L-08-146 10 CFR 54 ATTN: 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 Reply to Request for Additional Information for Review of the Beaver Valley Power Station, Units 1 and 2, License Renewal Application (TAC Nos. MD6593 and MD6594),

and License Renewal Application Amendment No. 7 Reference 1 provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application for the Beaver Valley Power Station (BVPS). Reference 2 requested additional information regarding Section 4.7.5 of the BVPS License Renewal Application.

The Attachment provides the FENOC reply to the U.S. Nuclear Regulatory Commission (NRC) request for additional information (RAI). The Enclosure provides Amendment No. 7 to the BVPS License Renewal Application based on changes resulting from the FENOC reply to the NRC RAI.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 30 , 2008.

Sincerely, Peter P. Sena IIlI

Beaver Valley Power Station, Unit Nos, 1 and 2 L-08-146 Page 2

References:

1. FENOC Letter L-07-1 13, "License Renewal Application," August 27, 2007.

2. NRC Letter, "Request for Additional Information for the Review of the Beaver Valley Power Station, Units 1 and 2, License Renewal'Application (TAC Nos.

MD6593 and MD6594)," April 1, 2008.

Attachment:

Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Section 4.7.5

Enclosure:

Amendment No. 7 to the BVPS License Renewal Application cc: Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc: w/o Attachment or Enclosure Dr. S. S. Lee, NRC DLR Acting Director Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRC DORL Project Manager Mr. D. J. Allard, PA BRP/DEP Director Mr. L. E. Ryan, PA BRP/DEP

ATTACHMENT L-08-146 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Unitsdl and 2, License Renewal Application, Section 4.7.5 Page 1 of 4 Question RAI 4.7.5-1 The applicant did not list the number and type of safety significant structures and piping which have experienced, or may experience, significant settlement, and are therefore included in the Settlement Monitoring Program. The applicant did not state which structures will be monitored to the end of the period of extended operation. This is relevant information for writing the safety evaluation.

For each structure included in the Settlement Monitoring Program, indicate if the structure is being monitored and if it will be monitored to the end of the period of extended operation.

RESPONSE RAI 4.7.5-1 Structures that are currently being monitored by the Beaver Valley Power Station (BVPS) Settlement Monitoring Program will be monitored to the end of the period of extended operation or until the settlement of the structure has been determined to be stable as defined by the Settlement Monitoring Program.

The BVPS Settlement Monitoring Program is applicable only to Unit 2. As documented in the Unit 2 Updated Final Safety Analysis Report (UFSAR), Section 2.5.4.13, the settlement of each Unit 2 Category I structure was monitored during construction, and will be monitored throughout the life of the plant until the settlement of a particular structure has been determined to be stable as defined by the Settlement Monitoring Program (BVPS License Renewal Application (LRA), Section B.2.37). For such structures, settlement monitoring is then discontinued.

A settlement marker location is considered stable if, over a reasonable time frame (2 to 3 years, or 730 to 1095 days), a trend can be established that shows the marker has maintained a "fixed" elevation within a tolerance range of plus or minus 0.125 inch (plus or minus 1/8th inch).

Unit 2 safety related structures have been determined to be "stable" with the exception of:

1. " Refueling Water Storage Tank Pad and Shield Wall

2. Safeguards Area Building

3. Valve Pit

Attachment L-08-146 Page 2 of 4 These three Unit 2 structures have not yet maintained a "fixed" elevation, and, therefore, continue to be monitored in accordance with the Settlement Monitoring Program.

Question RAI 4.7.5-2 This RAI addresses specifically which safety related piping systems will be monitored for differential settlement. For each system, the RAI requests that the applicant provide the projected differential settlements for the monitored piping systems, and the maximum projected stresses and allowable stresses, to verify that a margin will be available at the end of the period of extended operation.

Provide a list of the safety-related piping systems that are subject to differential structure settlement of the attached structures. For each piping system provide the following:

A. The projected 40-year and 60-year differential settlement of the anchor points.

B. The highest projected stresses for 40-years and 60-years of operation, and the corresponding allowable stress.

RESPONSE RAI 4.7.5-2 There are no safety-related piping systems monitored for differential settlement. As documented in the Unit 2 UFSAR, Section 2.5.4.13, differential settlements along buried safety-related piping that extends from the, structures out into the yard and differential settlements of piping that spans the shake spaces between the closely spaced main plant area structures are not monitored as part of the settlement monitoring program.

/

As presented in LRA Section 4.7.5, "Settlement of Structures (Unit 2 only)," the Settlement Monitoring Program provides the requirements to measure the settlement of Unit 2 structures at selected locations. If the settlement of a structure exceeds that anticipated, a review of the current analysis (as it relates to the integrity of the structure and the maintenance of settlement assumptions in the associated piping stress analyses) is required.

Unit 2 safety-related structures that have not maintained a "fixed" elevation and, therefore, continue to be monitored in accordance with the Settlement Monitoring Program, are listed as follows:

1. Refueling Water Storage Tank Pad and Shield Wall

2. Safeguards Area Building

3. Valve Pit

Attachment L-08-146 Page 3 of 4 As presented in LRA Section 4.7.5, the Settlement Monitoring Program ensures that the current 40-year settlement assumptions in the Unit 2 pipe stress analyses are maintained for the period of extended operation.

Sixty-year differential settlement projections are not provided since the time-limited aging analyses (TLAAs) (differential settlement assumptions) associated with the subject Unit 2 piping stress analyses have been dispositioned in accordance with 10 CFR 54.21 (c)(1)(iii).

Question RAI 4.7.5-3 The applicant stated that settlement monitoring has been discontinued for a number of structures. This RAI requests which structures were discontinued, and the basis for discontinuing this monitoring. This information is needed to complete the staffs evaluation.

Provide a list of the structures that were initially in the Settlement Monitoring Program, and for which monitoring has been discontinued. Provide the basis for discontinuing the monitoring.

RESPONSE RAI 4.7.5-3 The Settlement Monitoring Program is applicable only to Unit 2. Within that program, a settlement marker location is considered stable if, over a reasonable time frame (2 to 3 years, or 730 to 1095 days), a trend can be established that shows the marker has maintained a "fixed" elevation within a tolerance range of plus or minus 0.125 inch (plus or minus 1/8th inch).

Unit 2 safety-related structures with settlement markers that were determined to be stable and, therefore, monitoring was discontinued, are listed as follows:

1. Auxiliary Building

2. Diesel Generator Building

3. Emergency Outfall Structure

4. Fuel and Decontamination Building

5. Primary Plant Demineralized Water Tank Pad and Enclosure

6. Reactor Containment Building

7. Control Room Extension (BV2 Control Room)

8. Service Building

9. Main Steam and Cable Vault

10. Intake Structure

Attachment L-08-146 Page 4 of 4 Question RAI 4.7.5-4 The applicant did not mention that there is fatigue associated with the buried piping, and yet refers to Unit 2 piping fatigue TLAAs. This RAI requests that the applicant provide any missing information on this subject, or else justify the statement regarding piping time-limited aging analysis (TLAA).

The last sentence of Section 4.7.5 states that the Unit 2 piping fatigue TLAAs have been dispositioned in accordance with 10 CFR 54.21 (c)(1)(iii). Identify the fatigue effects on the buried piping associated with piping settlement, and clarify how the piping fatigue TLAA for the buried piping was dispositioned.

RESPONSE RAI 4.7.5-4 The use of the term "fatigue" in LRA Sections 4.7.5, "Settlement of Structures (Unit 2 only) and A.3.6.3, "Settlement of Structures," was incorrect, as there is no fatigue associated with the buried piping. The term "stress" should have been used instead of the term "fatigue." Therefore, the last sentence of LRA Section 4.7.5 is revised to read:

"Therefore, the TLAAs associatedwith the Unit 2 piping stress analyses have been dispositionedin accordance with 10 CFR 54.21(c)(1)(iii)."

Accordingly, the last paragraph of LRA Section A.3.6.3 is revised to read:

"The Settlement Monitoring Programensures that the current 40-year settlement assumptions in the pipe stress analyses are maintainedfor the period of extended operation. Therefore, the TLAAs associated with the piping stress analyses have been dispositionedin accordance with 10 CFR 54.21(c)(1)(iii)."

See the revised LRA text in the Enclosure to this letter.

ENCLOSURE Beaver Valley Power Station (BVPS) Unit Nos. 1 and 2 Letter L-08-146 Amendment No. 7 to the BVPS License Renewal Application Page 1 of 2 Sections Affected 4.7.5 A.3.6.3 The Enclosure identifies the correction by Affected Section, License Renewal Application (LRA) Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the top of the affected page. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text lined-out and added text underlined.

Enclosure L-08-146 Page 2 of 2 Affected Paragraph LRA Affected Section LRA Page No. and Sentence Section 4.7.5 Page 4.7-8 3 rd Paragraph, Last Sentence The last sentence of LRA Section 4.7.5 incorrectly states that Unit 2 piping fatigue TLAAs have been dispositioned in accordance with 10 CFR 54.21 (c)(1)(iii). There is no fatigue associated with the buried piping. Therefore, the 3 rd paragraph on LRA page 4.7-8 is revised to read, "The Settlement Monitoring Program (Unit 2 only) ensures that the current 40-yearsettlement assumptionsin the Unit 2 pipe stress analyses are maintainedfor the period of extended operation. Therefore, the TLAAs associatedwith the Unit 2 piping stress analyses have been dispositionedin accordance with 10 CFR 54.2 1(c)(1). The .foe, the U.nit 2 piping fatigue TLAAs have been dispositioned in accoAr'daPncc wit1h 10 CER5-.1)((i)"

Section A.3.6.3 Page A.3-22 4 th Paragraph, Last Sentence The last sentence of LRA Section A.3.6.3 incorrectly states that Unit 2 piping fatigue TLAAs have been dispositioned in accordance-with 10 CFR 54.21(c)(1)(iii). There is no fatigue associated with the buried piping. Therefore, the 4 th paragraph on LRA page A.3-22 is revised to read, "The Settlement Monitoring Programensures that the current 40-year settlement assumptions in the pipe stress fatigue-analyses are maintainedfor the period of extended operation. Therefore, the TLAAs associatedwith the Pipingstress analyses have been dispositionedin accordance with 10 CFR 54.21(c)(1)(iii).

The rcfo*, the piping fatigue TLAAs have been dipoitioned in accordancewi 10 CEF? 42()()ii