L-08-190, Reply to Request for Additional Information for the Review, License Renewal Application and License Renewal Application Amendment No. 12

Reply to Request for Additional Information for the Review, License Renewal Application and License Renewal Application Amendment No. 12

ML081640097
Person / Time
Site:	Beaver Valley
Issue date:	06/09/2008
From:	Sena P FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-190, TAC MD6593, TAC MD6594
Download: ML081640097 (9)

Text

FENOC FirstEnergyNuclear OperatingCompany Peter P. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 June 9, 2008 L-08-190 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. 12 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 the BVPS license renewal integrated plant assessment in Sections B.2.6 and 3.3.2 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. 12 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 4*, 2008.

Sinc ely, Peter P. Sena Ill c1/0

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-190 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)," May 8, 2008.

Attachment:

Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.6 and 3.3.2

Enclosure:

Amendment No. 12 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-08-190 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.6 and 3.3.2 Page 1 of 3 Section B.2.6 Question RAI B.2.6-3 In the BVPS LRA, there are many AMR line items which reference VII.I-4 of GALL.

However, no items could be found which reference V1I.l-5 of GALL; even though the two share the same component, material, and environment descriptions. The exclusion of item VII.l-5 leads to the assumption that the associated aging effect, "Loss of preload/thermal effects, gasket creep, and self-loosening" for the component, material, and environment combination are not experienced at BVPS.

Similarly, VIII.H-4 of GALL is referenced in the BVPS LRA and VIII.H-5 of GALL is not. Please provide your technical basis for these exclusions and why, specifically, the associated aging effect is not expected to be experienced at BVPS.

RESPONSE RAI B.2.6-3 Electric Power Research Institute (EPRI) 1010639, Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, was consulted for the aging management review methodologies for FENOC license renewal. Based on the guidance provided by EPRI 1010639, FirstEnergy Nuclear Operating Company (FENOC) did not identify loss of preload as an applicable aging effect. Therefore, the NUREG-1801, "Generic Lessons Learned (GALL) Report," line items associated with this aging effect do not appear in the Beaver Valley Power Station (BVPS) License Renewal Application (LRA). However, as stated in LRA Section B.2.6, the Bolting Integrity Program includes periodic inspection for indication of loss of preload (i.e.,

leakage), and preventive measures to preclude or minimize loss of preload during the installation process.

EPRI 1010639, Appendix F, Bolted Closures, Section 3.1, Loss of Pre-Load, states:

"Pre-loadis the tension force developed in a fastener when it is tightened againsta joint. The pre-load in a bolt is often less than expected and decrease of the pre-load may be attributedto, but not limited to, one or more of the following effects: embedment, cyclic load embedment, gasket.

creep, thermal effects (e.g., yield stress effect, modulus of elasticity effect, and stress relaxation), and self-loosening. ... These effects are typically addressed upon installationand subsequent maintenance of the joint."

Attachment L-08-190 Page 2 of 3

"... the loss of pre-load in a mechanicaljoint can only result in leakage, not failure of thatjoint. This leakage does not impact the pressure boundary such that the component's intended function is not accomplished. It is noted that in ASME Section III (NX-2121), gaskets, seals, and O-rings are not considered to perform a pressure retaining function and therefore, these parts are typically not considered to support a component intended function. It follows that the loss of pre-load from the above mechanisms does not result in loss of mechanical closure or loss of pressure boundary integrity. Therefore, loss of pre-load is not an applicableaging effect."

Because loss of preload in a mechanical joint results in leakage, and the effects that contribute to loss of preload are addressed upon installation and subsequent maintenance of the joint, FENOC manages loss of preload through leakage monitoring and proper installation and maintenance of the components in accordance with industry standards.

Table 3.3.2-7 Question RAI 3.3.2-7-1 In the BVPS LRA, Item 55 of Table 3.3.2-7, "Heat exchanger (Tube-diesel cooling water)," includes footnote H-aging effect not in NUREG-1801 (Chapter VII) for this component, material and environment combination. The aging management program (AMP) designated by BVPS to manage this item is B.2.15 - External Surfaces Monitoring, with the aging effect listed as "Reduction of Heat Transfer".

Although the diesel generator jacket water radiator fins are clearly identified as being within the scope of the program, it is not clear whether or not the heat exchanger tubes are included. Because of this, it is not apparent how this AMP is able to manage the detection of aging effects element of the GALL for Item 55 of Table 3.3.2-7. Please elaborate on the scope and detection of aging effects for this AMP as it relates to Item 55 of Table 3.3.2-7.

RESPONSE RAI 3.3.2-7-1 BVPS LRA Sections A. 1.15 and B.2.15, "External Surfaces Monitoring Program," are revised to state that inspection is required of radiators (fins and tubes) associated with diesel engines and diesel-driven equipment for build-up of dust, dirt and debris.

BVPS LRA Sections A.1. 15 and B.2.15 previously stated that inspection is required of the Emergency Response Facility (ERF) diesel generator jacket water radiator fins for build-up of dust, dirt and debris, referring to Table 3.3.2-17, "Auxiliary Systems -

Attachment L-08-1 90 Page 3 of 3 Emergency Response Facility Substation System - Summary of Aging Management Evaluation," row 32. However, as shown in LRA Table 3.3.2-7, "Auxiliary Systems -

Compressed Air System - Summary of Aging Management Evaluation," the diesel in the Unit 2 Compressed Air System also credits the program, but the inspection requirement was not specifically stated in the program descriptions in LRA Appendices A and B.

BVPS LRA, Tables 3.3.2-7 and 3.3.2-17, each contain two rows which independently provide the external surface aging management review results for a "reduction of heat transfer" aging effect for the heat exchanger aluminum fins and copper alloy tubes of the Unit 2 diesel-driven air compressor jacket water radiator and the ERF diesel generator jacket water radiator, respectively. These rows credit the External Surfaces Monitoring Program for managing this aging effect. Although they were evaluated as two components in the aging management review tables, the fins and tubes are part of the same assembly that performs the intended function of "heat transfer". The fin and tube assembly can be seen externally, and will be inspected for build-up of dust, dirt, and debris that would affect its intended function.

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

ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-190 Amendment No. 12 to the BVPS License Renewal Application Page 1 of 4 Sections Affected Section A.1.15 Section B.2.15 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 or at the start of the affected section, as applicable. 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-08-190 Page 2 of 4 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section A.1.15 Page A.1-7 st Paragraph, 3 rd Sentence BVPS LRA Section A. 1.15, "External Surfaces Monitoring Program," states that inspection is required of the Emergency Response Facility (ERF) diesel generator jacket water radiator fins for build-up of dust, dirt and debris, but does not address the radiator tubes. Additionally, the diesel in the Unit 2 Compressed Air System also credits the program, but the inspection requirement was not specifically stated in the program description. LRA Section A.1.15 is revised to read:

The External Surfaces Monitoring Programis based on system inspections and walkdowns. This program consists of periodicinspections to monitor the external surfaces of in-scope steel components and other metal components for material degradationand leakage, and periodicinspection of in-scope elastomer components for hardening,loss of strength or cracking through physical manipulation. The program will also require inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris. The program will also rqie.. ction of the Emergen*y Responso Faeiliy 6'ERF) diesel generao 'Jacketateiriradiat-or-fins for buil up oe dust, dirt and debris. Additionally, the program is credited with managing aging effects of internal surfaces, for situations in which materialand environment combinations are the same for internaland external surfaces such that external surface condition is representativeof internal surface condition.

Enclosure L-08-190 Page 3 of 4 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section B.2.15 Page B.2-39 2 nd Paragraph, 3 rd Sentence BVPS LRA Section B.2.15, "External Surfaces Monitoring Program," states that inspection is required of the Emergency Response Facility (ERF) diesel generator jacket water radiator fins for build-up of dust, dirt and debris, but does not address the radiator tubes. Additionally, the diesel in the Unit 2 Compressed Air System also credits the program, but the inspection requirement was not specifically stated in the program description. LRA Section B.2.15 is revised to read:

The External Surfaces Monitoring Programis based on system inspections and walkdowns. This program will consist of periodicinspections to monitor the external surfaces of in-scope steel components and other metal components for materialdegradationand leakage, and periodic inspection of in-scope elastomer components for hardening,loss of strength or cracking through physical manipulation. The program will also require inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris. The program will also ruIr, n.... tion of the Emorgc*. .y Response Faciliy (E-RF) dieseol gnctoict 14phor radiator fine for-build up oe dust, dirt and deb.,s. Additionally, the program is credited with managing aging effects of internal surfaces, for situations in which materialand environment combinations are the same for internaland external surfaces such that external surface condition is representativeof internalsurface condition.

Section B.2.15 Pages B.2-39&-40 Last Paragraph, 3 rd Sentence BVPS LRA Section B.2.15, under the headings "Aging Management Program Elements," "Scope of Program," states that inspection is required of the Emergency Response Facility (ERF) diesel generator jacket water radiator fins for build-up of dust, dirt and debris, but does not address the radiator tubes.

Additionally, the diesel in the Unit 2 Compressed Air System also credits the program, but the inspection requirement was not specifically stated in the program description. LRA Section B.2.15, page B.2-39, last paragraph, 3 rd sentence is revised to read:

The program will also require inspection of radiators(fins and tubes) associated with diesel engines and diesel-driven equipment for build-up of dust, dirt and debris.Th pregran* ,; also mqui,

,r;n fi;n of the ERF= diesel nerator Jacket water radiator-fins for build up of dust, dirt and debris.

Enclosure L-08-190 Page 4 of 4 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section B.2.15 Page B.2-40 2 nd Paragraph, 3 rd Sub-bullet BVPS LRA Section B.2.15, under the headings "Aging Management Program Elements," "Scope of Program," states that visual inspection is required of the Emergency Response Facility (ERF) diesel generator jacket water radiator fins for build-up of dust, dirt and debris, but does not address the radiator tubes.

Additionally, the diesel in the Unit 2 Compressed Air System also credits the program, but the inspection requirement was not specifically stated in the program description. LRA Section B.2.15, page B.2-40, 2n paragraph, 3 rd sub-bullet is revised to read:

Visual inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris. Visual inpection o, the ERE= diesel generFator Jacket water-radiator fins for build up of dust, dirt an debris. The E-RF-dieselgen orator jacket water radiator-is a coilfin typc heat exchanger-whec the fins arc exposed to an air outdoor environment. The applicable aging effect is reduction of heat transferdue to build-up of dust, dirt and debris.

Section B.2.15 Page B.2-41 1 st Paragraph, 3 rd Sentence BVPS LRA Section B.2.15, under the headings "Aging Management Program Elements," "Detection of Aging Effects," states that inspection is required of the Emergency Response Facility (ERF) diesel generator jacket water radiator fins for build-up of dust, dirt and debris, but does not address the radiator tubes.

Additionally, the diesel in the Unit 2 Compressed Air System also credits the program, but the inspection requirement was not specifically stated in the program description. LRA Section B.2.15, page B.2-41, 1 st paragraph, 3 rd sentence is revised to read:

The program will also require inspection of radiators(fins and tubes) associated with diesel engines and diesel-driven equipment for build-up of dust, dirt and debris. The program will also req.ir.. periodic inpection of the ERF diesel generator jacket water radhiatorfi~n.S ifor build up of dust, dirt and debris.