L-08-181, Reply to Request for Additional Information for the Review of the License Renewal Application and License Renewal Application, Amendment No. 10

Reply to Request for Additional Information for the Review of the License Renewal Application and License Renewal Application, Amendment No. 10

ML081620356
Person / Time
Site:	Beaver Valley
Issue date:	06/06/2008
From:	Sena P FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-181, TAC MD6593, TAC MD6594
Download: ML081620356 (14)

Text

FENOC FirstEnergy Nuclear Operating Company PeterP. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 June 6, 2008 L-08-181 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) and License Renewal Application Amendment No. 10 Reference 1 provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS). Reference 2 requested additional information from FENOC regarding BVPS license renewal aging management programs in Sections B.2.13 and B.2.39 of the BVPS LRA.

The Attachment provides the FENOC reply to the U.S. Nuclear Regulatory Commission request for additional information. The Enclosure provides Amendment No. 10 to the BVPS License Renewal Application.

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 June * ,2008.

Sirely Peter P. Sena Ill

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-181 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 30, 2008.

Attachment:

Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.13 and B.2.39

Enclosure:

Amendment No. 10 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-08-181 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.13 and B.2.39 Page 1 of 7 Section B.2.39 Question RAI B.2.39-1 Beaver Valley Power Station (BVPS) license renewal application (LRA) does not discuss the issue of aging of coatings or has any aging management program (AMP) to manage the aging of coatings. The generic aging lessons learned (GALL) Report recommends such a program. Please justify why an aging management program for coatings is not needed at BVPS. The failure of coatings could result in aging effects for the steel shell in containment. The failure of coatings could also result in the failure of safety systems to perform their intended functions (for instance, safety injection).

RESPONSE RAI B.2.39-1 The NUREG-1801 Protective Coating Monitoring and Maintenance Program uses inspections to monitor and maintain coatings inside containment to prevent clogging of post-accident safety system strainers, and to minimize loss of material due to corrosion.

Coatings are applied to concrete and steel surfaces within the Beaver Valley Power Station (BVPS) Containment Structures to provide protection to the underlying material, and are considered to be an integral part of the structure or component on which they are applied. Inspections of the underlying structure or component include verification of coating integrity.

BVPS did not credit coatings with mitigation of any aging effects; the base material was evaluated as if it were exposed directly to the ambient environment. No aging-related failure mechanisms were identified for coatings. Coatings do not perform any 10 CFR 54.4(a)(1) or (a)(3) intended functions (such as corrosion protection) in this context.

Additionally, coatings were not included within the scope of License Renewal as component commodities whose failure could prevent accomplishment of a safety-related function under 10 CFR 54.4(a)(2). Therefore, coatings were not considered as a separate subcomponent of these surfaces.

Generic NRC communications have been issued that address the potential for degradation of the Emergency Core Cooling System due to accumulation of debris (including coatings) in the containment sump. The BVPS responses to these documents address the potential for coating failure based on qualification and proximity

Attachment L-08-181 Page 2 of 7 to a high energy line break. Available industry and plant-specific operating experience does not provide evidence that the potential effects on the containment sumps change with coating age.

The potential for containment sump blockage due to debris is an event-driven concern that is addressed by the plants' current licensing basis. Aging of coatings does not affect the assumptions used in the evaluation of potential sump blockage. Coatings do not perform or support any of the intended functions listed in 10 CFR 54.4. Therefore, management of aging for containment coatings as a separate subcomponent is not required for compliance with 10 CFR 54.4, and a program corresponding to NUREG-1801 XI.S8, "Protective Coating Monitoring and Maintenance Program," is not credited in the BVPS License Renewal Application (LRA).

Question RAI B.2.39-2 In the BVPS LRA, AMP B.2.39, "Structures Monitoring Program," is not clear as to how it satisfies the GALL Report program element "Parameters Monitoredllnspected." BVPS enhancement for this program element does not include the frequency of periodic sampling of groundwater for pH, chloride, and sulfate concentrations. Please, provide the time frame of your "periodic" sampling, and the results for the last two samplings of groundwater.

RESPONSE RAI B.2.39-2 License renewal future commitment Item Number 20 in LRA Table A.4-1 (Unit 1), and future commitment Item Number 22 in LRA Table A.5-1 (Unit 2), are revised to state that the Implementation Schedule for groundwater monitoring will begin five (5) years prior to entering the Unit 1 period of extended operation (2016) and the Unit 2 period of extended operation (2027), then continue on a five (5) year interval thereafter. This revision to the enhancement is being made even though BVPS groundwater is non-aggressive.

See Enclosure A to this letter for the revision to the BVPS LRA.

Groundwater evaluation prior to 2007 comprised soil and water sampling data for the Shippingport Nuclear Power Station construction phase obtained in 1954 adjacent to BVPS. Sampling for potable water quality (biological activity) was performed in 1976 and 1983, but did not include chemical analysis. More recently, water samples were taken at pre-existing site piezometers on June 25, 2003, and on January 17, 2007, for License Renewal Project information and use. The 2003 and 2007 sampling results data are shown in the table below.

Attachment L-08-181 Page 3 of 7 BVPS Chemical Analysis 1 of Groundwater Year & Results Chemical 1954 2003 2007 3 Parameter (soil & water) 2 (water) (water) pH 6.8 - 7.1 (water) 6.87 6.83 6.8 - 7.7 (soil)

Chlorides 0.0003% - "trace" (soil) 2 44.60 mg/I (44.6 ppm) 208 ppm Sulfates 0.005 - 0.020% (soil) 2 1.2 mg/I (1.2 ppm) 187 ppm

1. An aggressive chemical environment where water might cause significant concrete degradation is defined as: [Electric Power Research Institute (EPRI) Report 1002950, "Aging Effects for Structures and Structural Components (Structural Tools)," Rev. 1, Section 5.3.3.2]

• Acidic solutions with pH < 5.5

" Chloride solutions > 500 ppm

• Sulfate solutions > 1,500 ppm

2. The tests made on these soils show nothing of a chemical nature which would be deleterious to buried concrete or steel. The pH reactions are all substantially neutral, indicating absence of acid or alkali. The total soluble salts are in no case higher than 200 parts per million (.02%).

3. Two samples were taken and higher impact values are listed; chlorides value is from sample taken adjacent to roadway during wintertime (de-icing salts are used on roadways); yard sample results showed 18.9 ppm chlorides (second sample values were pH = 7.12, chlorides = 18.9 ppm, sulfates = 177 ppm).

Question RAI B.2.39-3 BVPS LRA, AMP B.2.39, "Structures Monitoring Program," does not include the 2006 inspection results. Please provide:

a. 2006 inspection results, and how these compare with the 1996 baseline inspection, and the 2001 inspection results.

b. The location, size, and depth of the reappear corroded steel found in 2001 inspection, which was painted as a result of the 1996 baseline inspection.

What was the condition found in 2006 inspection? Was any other corrective action taken to ensure its capability to maintain its design function for the end of period of extended operation?

RESPONSE RAI B.2.39-3

a. Similar to the 2001 inspection report, the 2006 maintenance rule structural inspection (performed in 2007) reported that some minor concrete cracks were

Attachment L-08-1 81 Page 4 of 7 noted. The cracks were narrow and shallow, and presented no structural integrity problems. Some exterior surfaces of concrete structures evidenced pop-outs and spalls. These conditions were not detrimental and no repair or patching was necessary. No exposed reinforcing steel was noted. Areas of peeling or cracked paint were observed. Some areas had been painted since the baseline inspection.

Other areas were noted for future painting. Some calcium deposits and water stains were noted, however no active wall leaks were observed. Deposits and stains noted in the baseline inspection that were cleaned had not reappeared.

The 2006 report also states that:

"Inthe majority of cases little or no change was noted from the previous observations. Some conditions such as corrosion or minor cracking were no longer present due to maintenance cleaning and painting activities. Other conditions noted in the baseline inspection or first five-year inspection had been repaired or corrected. In these cases the repairs were found to be performing well. In a few cases where painting was performed on corroded steel (component supports) the rust is beginning to reappear. In all such cases the area was located in a damp or wet environment or the underlying steel was not thoroughly cleaned of rust. In no case was the corrosion considered detrimental to the component."

Overall, the 2006 inspection report concluded that plant structures were in good condition and performing well. The inspection found no conditions requiring immediate maintenance or repair. Conditions noted were minor in nature and did not affect the structural integrity of any of the structures reviewed. Many of the observed conditions were noted for further review during the next programmatic inspection. Conditions noted inthe 2001 and 1996 inspections that were revisited showed that, in most cases, little or no change was noted from the previous observations.

b. As identified in response to item "a", in some cases corroded steel on component supports that was painted as a result of the 1996 baseline or 2001 inspections had corrosion reappear. Environment or preparation was the cause attributed to the recurring rust, because, in all cases, the corroded components were located in damp or wet environments, or the underlying steel was not thoroughly cleaned of rust.

None of this minor corrosion was considered to be detrimental to the component function, and no quantitative data regarding the extent or depth of corrosion was reported.

Since little change was evident from the 1996 and 2001 structural inspections, and the conditions identified were considered minor in nature, the scheduled programmatic maintenance rule structural inspections provide reasonable assurance that the effects of aging will be managed such that the structural integrity of plant

Attachment L-08-181 Page 5 of 7 systems, structures, and components will be maintained during the period of extended operation.

Question RAI B.2.39-4 In the BVPS LRA, AMP B.2.39, "Structures Monitoring Program," is not clear in how it satisfies the GALL Report program element "Parameters Monitored/Inspected." Specifically, the GALL Report program element suggested ACI 349.3R-96 and ANSI/ASCE 11-90 for an acceptable basis for selection of parameters to be monitored.

On page B.2.109 of the LRA, under operating experience element, the applicant stated, "The Structures Monitoring Program inspection of floors was found to be sufficient to identify and repair any cracks large enough to allow water seepage."

Please, explain when does a crack become large enough and which industry codes, standards, and guidelines form the basis for this program element?

RESPONSE RAI B.2.39-4 The BVPS Structures Monitoring Program does not directly cite ACI 349.3R-96 or ANSI/ASCE 11-90 as the basis for selection of parameters to be monitored. The structural parameters monitored under the current BVPS Maintenance Rule structural inspection program were identified in 1996 using the guidance existing at that time; primarily NEI 96-03 (Rev. D), "Industry Guidelines for Monitoring the Condition of Structures at Nuclear Power Plants," and Westinghouse Owner's Group (WOG), "Life Cycle Management Aging Assessment Field Guide." The fundamental attributes of structural deficiency types and documentation are consistent between the BVPS Structures Monitoring Program and ACI 349.3R-96, which NEI 96-03 references. Also, use is made of tools, such as crack comparators to record crack widths; as described by ACI 349.3R-96, Section 3.5.1, "Visual Inspection:"

"Documentationof inspection results should include a general description of observed surface conditions, location/size of any significant discontinuities,noted effects of environmental exposure, and presence of degradation. Sketches, photographs,videotapes, and other means should be used to supplement text descriptions. It is recommended that a calibrationstandardsuch as a ruleror crack comparatorbe placed on any structureprior to photography or videotaping, to serve as a scaling factor for interpretationof the image. In the event that additionaltesting is needed, any limitations on use should be noted."

Attachment L-08-1 81 Page 6 of 7 The referenced LRA statement (LRA, Section B.2.39, "Operating Experience," page B.2-1 09) regarding cracks large enough to allow water seepage]was based upon a plant assessment performed for NRC Information Notice (IN)2003-08, "Potential Flooding Through Unsealed Concrete Floor Cracks." The assessment concluded that the Structures Monitoring Program requires inspection for water infiltration. The Program requires that inspectors look for the presence of water or evidence of previous water infiltration, such as stains or crystalline deposits. Using this evidence, inspectors can identify cracks that could permit water infiltration through the floor, but a size criteria is not applied. Documentation of the crack and size of the crack can then be used for potential crack growth comparison in future inspections.

Section B.2.13 Question RAI B.2.13-1 In the BVPS LRA, AMP B.2.13, "Electrical Wooden Poles/Structures Inspection Program [Unit 2 Only]," it is not clear as to how it satisfies the GALL Report program element "parameter monitored/inspected." Please clarify the parameters of electrical wooden poles/structures that need inspection for aging effects and aging effects mechanisms affecting the ability of the wooden poles to perform their intended function. How will the buried part of the wooden pole be monitored/inspected?

RESPONSE RAI B.2.13-1 The Electrical Wooden Poles / Structures Inspection Program will provide guidance for visual inspections, sounding, and boring, to detect degradation that jeopardizes pole integrity. Inspection guidance will be provided to assess parameters such as:

" pole leaning or tilt,

• physical or mechanical damage,

" insect damage or infestations (wood pole),

• change in original grade,

" shell, butt, or internal rot or decay (wood pole),

• ground-line or below grade degradation,

" failure or degradation of reinforced portions,

" broken or damaged electrical equipment,

• oxide formations in advanced stages,

Attachment L-08-181 Page 7 of 7

" delamination of steel plates, and

" cracking (fatigue, stress, toe) caused by vibrations or manufacturing defects.

The buried portion of the pole will be partially excavated for cleaning, inspection, and preservative treatment.

ENCLOSURE A Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-181 Amendment No. 10 to the BVPS License Renewal Application Page 1 of 5 Sections Affected Table A.4-1 Table A.5-1 The Enclosure identifies the correction by Affected License Renewal Application (LRA)

Section, 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-08-181 Page 2 of 5 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.4-1 Page A.4-7 & -8 Item Number 20 License renewal future commitment Item Number 20 in LRA Table A.4-1 does not provide a clear frequency for groundwater sampling. FENOC will implement groundwater monitoring five (5) years prior to entering the Unit I period of extended operation, then continue on a five (5) year interval thereafter. License renewal future commitment Item Number 20 in LRA Table A.4-1 is revised to read:

Item Component Implementation Related LRA Number Type Schedule Source Section No.!

Comments 20 Enhance the Structures Monitoring Programto: January29, 2016 LRA A. 1.39 o Include in program scope additionalstructuresand for all B.2.39 structuralcomponents identified as having aging effects enhancements requiring management for license renewal; except groundwater o Include inspection guidance in program implementing sampling (4 th procedures to detect significant cracking in concrete bullet).

surroundingthe anchors of vibrating equipment; Groundwater o Include a requirement in program proceduresto perform sampling will be opportunistic inspections of normally inaccessible below- implemented five grade concrete when excavation work uncovers a (5) years prior to significant depth; entering the period o Include a requirement in programprocedures to perform of extended periodicsampling of groundwaterfor pH, chloride operation,then concentration, and sulfate concentration;and, continue on a five o Include a requirement in program procedures to monitor (5) year interval elastomericmaterials used in seals and sealants, thereafter.

including compressiblejoints and seals, waterproofing

Enclosure L-08-181 Page 3 of 5 membranes, etc., associatedwith in-scope structures and structuralcomponents for cracking and change in material properties.

Enclosure L-08-181 Page 4 of 5 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.5-1 Page A.5-7 & -8 Item Number 22 License renewal future commitment Item Number 22 in LRA Table A.5-1 does not provide a clear frequency for groundwater sampling. FENOC will implement groundwater monitoring five (5) years prior to entering the Unit 2 period of extended operation, then continue on a five (5) year interval thereafter. License renewal future commitment Item Number 22 in LRA Table A.5-1 is revised to read:

Related LRA Item Implementation Number Component Type Schedule Source Section No.!

Comments 22 Enhance the Structures Monitoring Programto: May 27, 2027 LRA A. 1.39

• Include in program scope additionalstructures and for all B.2.39 structuralcomponents identified as having aging effects enhancements requiringmanagement for license renewal; except groundwater

" Include inspection guidance in program implementing sampling (4 th proceduresto detect significant cracking in concrete bullet).

surroundingthe anchors of vibrating equipment; Groundwater

• Include a requirementin programprocedures to perform sampling will be opportunisticinspections of normally inaccessible below- implemented five grade concrete when excavation work uncovers a (5) years priorto significant depth; entering the period

" Include a requirementin programprocedures to perform of extended periodic sampling of groundwaterfor pH, chloride operation, then concentration,and sulfate concentration;and, continue on a five

• Include a requirementin program procedures to monitor (5) year interval elastomeric materials used in seals and sealants, thereafter.

including compressiblejoints and seals, waterproofing.

Enclosure L-08-181 Page 5 of 5 membranes, etc., associatedwith in-scope structuresand structuralcomponents for cracking and change in material properties.