L-08-149, Reply to Request for Additional Information for the Review of the Beaver Valley Power Station, Units 1 and 2, License Renewal Application
| ML081280490 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/05/2008 |
| From: | Sena P FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-08-149, TAC MD6593, TAC MD6594 | |
| Download: ML081280490 (7) | |
Text
FENOC FirstEnergy Nuclear Operating Company Peter P. Sena H/I 724-682-5234 Site Vice President Fax: 724-643-8069 May 5, 2008 L-08-149 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 the Review of the Beaver Valley Power Station, Units 1 and 2, License Renewal Application (TAC Nos. MD6593 and MD6594)
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 BVPS license renewal aging management programs in Sections B.2.8, B.2.30, and B.2.31 of the BVPS License Renewal Application.
The Attachment provides the FENOC reply to the U.S. Nuclear Regulatory Commission request for additional information.
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 May J
,2008.
Sincerely, Peter P. Sena III
Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-149 Page 2
References:
- 1.
FENOC Letter L-07-113, "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 3, 2008.
Attachment:
Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.8, B.2.30, and B.2.31.
cc:
Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc:
w/o Attachment 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-08-149 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.8, B.2.30, and B.2.31 Page 1 of 5 Question RAI B.2.8-1 There are two parts to operating experience. Standard Review Plan (SRP)
Section A.1.2.3.10-1 states that operating experience with existing programs should be discussed. SRP Section A.1.2.3.10-2 states that an applicant may have to commit to providing operating experience in the future to confirm their effectiveness.
A number of SRP sections discuss operating experience with buried components. For instance, SRP Section 3.4.3.2.5-2 states that the buried piping and tanks inspection program relies on industry practice, frequency of pipe excavation, and operating experience to manage the effects of loss of material from general corrosion, pitting, crevice corrosion, and MIC. The reviewer reviews the applicant's program, including inspection frequency and operating experience with buried components, to assess the effectiveness of the buried piping and tanks inspection program in ensuring that corrosion is not occurring and that the component's intended function will be maintained during the period of extended operation.
Have you had any major replacements of buried piping at Beaver Valley Power Station (BVPS)? Provide the details, such as original piping material, replacement piping material, coating type, and approximate date replaced.
RESPONSE RAI B.2.8-1 Major replacements of buried piping at BV/PS have occurred due to corrosion. The 6-inch carbon steel Unit 1 River Water piping from the 24-inch River Water headers to the emergency diesel generators was replaced in 1995 with Allegheny-Ludlum AL6XN stainless steel. This piping supplies cooling water to both trains of the Unit 1 emergency diesel generators. The carbon steel piping was experiencing degradation due to microbiologically-influenced corrosion (MIC). The replacement AL6XN piping is corrosion resistant and is not coated.
The east and west cement-lined gray cast iron fire protection headers from the Intake Structure to the yard loop were replaced in 2002 with cement-lined ductile iron piping.
The gray cast iron piping was experiencing graphitic corrosion. The ductile iron piping is bituminous coated and wrapped with a polyethylene sheet.
Attachment L-08-149 Page 2 of 5 The 6-inch carbon steel piping from the Unit 2 Service Water System supply and return headers to the Control Room chillers was replaced in 2002 with Allegheny-Ludlum AL6XN stainless steel. The piping was experiencing pitting and general corrosion, resulting in a reduced wall thickness. The replacement AL6XN piping is corrosion resistant and is not coated.
Based on the specific operating experience for buried pipe at the BVPS site, there is high confidence that implementation of the BVPS Buried Piping and Tanks Inspection Program will provide reasonable assurance that the aging effects will be managed so that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Question RAI B.2.30-1 The generic aging lessons learned (GALL) report states in Section IX.B that:
"Tanks, in deference to piping and piping components, are large reservoirs used as hold-up volumes for liquids or gases. Tanks may have an internal liquid space and/or vapor space and may also be situated in proximity to soils or concrete on the exterior surface.
Tanks are treated in GALL '05 as a separate commodity due to the potential need for a different aging management regime for piping.
The following is one example of aging management for tanks in GALL '05. Steel tanks with bottoms in a soil or concrete environment have general corrosion as the aging effect for the interface between soil or concrete and the bottom of the tank.
Degradation of the tank bottoms in these aboveground steel tanks can be managed by the GALL AMP XI.M29, Aboveground Steel Tanks."
How do you manage the effects of aging for aboveground tanks that are located outside in addition to the volumetric inspection that is part of the One-Time Inspection (OTI) Program? What materials are used to construct the aboveground tanks? What is your operating history with aboveground tanks?
RESPONSE RAI B.2.30-1 The One-Time Inspection Program is the only aging management program assigned to manage the potential for aging of the external bottom surfaces of tanks mounted on concrete foundations at BVPS.
Attachment L-08-149 Page 3 of 5 BVPS has five (5) aboveground tanks within the scope of License Renewal that are located outside and are mounted on concrete foundations. These tanks are summarized in Table B.2.30-1, below.
Table B.2.30-1 BVPS Aboveground Tanks in License Renewal Scope Tank ID Tank name LR Drawing Material 1QS-TK-1 Refueling Water Storage Tank
-. 1-13-1 Stainless steel 2QSS-TK21 Refueling Water Storage Tank 2-13-2 Stainless steel 1WT-TK-11 ~
Turbine Plant Demineralized Water 1-22-1 Aluminum Storage Tank 1WT-TK-26 Demineralized Water Storage 1-32-7 Stainless steel Tank 2WTD-TK23 Demineralized Water Storage 2-32-1 Stainless steel Tank Each of these tanks includes one or more of the following design or construction features: an oil-sand bed, bitumastic coating, sloped foundations, caulking, and/or sealing fillets. These features are expected to preclude water from the bottom surfaces of the tanks that could result in aging effects. In the BVPS License Renewal Application, FENOC credits either the External Surfaces Monitoring Program or the Structures Monitoring; Program for managing the aging of the externally observable construction features (sloped foundations, caulking, and sealing fillets). However, since verification of the absence of water on the bottom surfaces of the tanks is impractical, these tanks are evaluated using the environment of "soil" for the external bottom surfaces. "Soil" was determined to approximate the worst conditions that could exist if water were not excluded. Loss of material was identified as a potential aging effect for the bottom surfaces of these tanks if the design and construction features failed to exclude water. The One-Time Inspection Program was assigned to verify that the aging effect is not occurring; should the aging effect be verified to be present, the program triggers additional actions that assure the intended function of the tanks will ýbe maintained during the period of extended operation. No additional program was assigned to manage the external bottom surfaces of the tanks, as the aging effect is expected to be precluded by design and construction features, and the purpose of the One-Time Inspection Program is to verify the absence of such effects.
The same aging management approach was used to address aging of the external bottom surfaces of the enclosure-protected Primary Plant Demineralized Water( Storage Tanks at both units (1WT-TK-10, shown on License Renewal (LR) Drawing 1-24-1, and 2FWE-TK210, shown on LR Drawing 2-24-3). The Unit 1 tank is fabricated of steel, and
Attachment L-08-149, Page 4 of 5 the Unit 2 tank is fabricated of stainless steel. Both tanks are mounted on concrete foundations with design and construction features to preclude the presence of water from the tank bottom surfaces. Additionally, these tanks are located within reinforced concrete structures that provide additional protection from the outside environment.
The One-Time Inspection Program is assigned to confirm the absence of aging effects from the external bottom surfaces of these tanks.
The NUREG-1801,Section XI.M29, "Aboveground Steel Tanks" program specifically addresses steel tanks, with an emphasis on coating inspection in elements 1 through 6.
The XI.M29 program also recommends thickness measurements of inaccessible locations, such as tank bottoms. Since most elements of the XI.M29 program deal with coatings, and would not be applicable to stainless steel and aluminum tanks, thickness measurements of the bottoms of tanks mounted on concrete foundations was incorporated into the One-Time Inspection program, and the program was credited for managing the aging of all in-scope tanks mounted on concrete foundations.
A review of operating experience associated with tank bottoms identified six (6) instances in which the actual or potential for tank bottom degradation was documented and evaluated. Five (5) of these instances involved either fuel oil or lubricating oil tanks, and none of the instances involved external bottom surfaces. A review of operating experience did not identify any instances of degradation of the tank bottoms thatare the subject of this question.
The implementation of the BVPS One-Time Inspection Program for managing the potential for aging of the external bottom surfacesof outside tanks mounted on concrete foundations will provide reasonable assurance that the aging effects will be managed so that the tanks within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Attachment L-08-149 Page 5 of 5 Question RAI B.2.31-1 The OTI of ASME Class 1 Small Bore Piping involves a volumetric examination of piping less than four inches normal pipe size. The staff concluded that if any socket welds are classified as high-safety significant as part of a risk informed in-service inspection program, special significance should be given to these welds as part of the OTI of ASME Class 1 Small Bore Piping Program. Have any small bore socket welds been classified as high-safety significant in the BVPS risk informed in-service inspection program? How will these socket welds be treated?
RESPONSE RAI B.2.31-1 There are six (6) Unit 1 and two (2) Unit 2 ASME Class 1 small bore piping segments containing socket welds that have been classified as high-safety significant (HSS) as part of the BVPS Risk-Informed InService Inspection Program. For each segment, a VT-2 examination at operating temperature and pressure is performed on a weld within the segment every refueling outage (every 18 months).
Table B.2.31-1, below, shows the HSS small bore piping segment numbers, safety classes, systems and descriptions of where in the system the segments are located.
Table B.2.31-1 BVPS High-Safety Significant Small Bore Piping Segments Bepaver Va lieUn t I_____
SEGMENT CLASS SYSTEM DESCRIPTION SIZE CH-102 1
CHEMICAL AND VOLUME CONTROL Seal Injection to RC Pumps 2"
CH-103 1
CHEMICAL AND VOLUME CONTROL Seal Injection to RC Pumps 2"
CH-104 1
CHEMICAL AND VOLUME CONTROL Seal Injection to RC Pumps 2"
SI-070A 1
SAFETY INJECTION Hot leg HHSI supply line 2"
SI-072A 1
SAFETY INJECTION Hot leg HHSI supply line 2"
SI-074A 1
SAFETY INJECTION Hot leg HHSI supply line
.2" Beaver Valley Unit 2__________
SEGMENT CLASS SYSTEM DESCRIPTION SIZE RCS-026 1
REACTOR COOLANT Lines to flow element 0.75" RCS-027 1
REACTOR COOLANT Lines to flow element 0.75",