L-08-310, Reply to Request for Additional Information for the Review of License Renewal Application and License Renewal Application Amendment No. 27
| ML082810100 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/03/2008 |
| From: | Sena P FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-08-310, TAC MD6593, TAC MD6594 | |
| Download: ML082810100 (12) | |
Text
Beaver Valley Power Station FENOC Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Peter P. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 October 3, 2008 L-08-31 0 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. 27 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 Sections 3.2.2.3.2, 3.3, 3.5 and B.2.17 of the BVPS LRA. This letter provides the FENOC reply to the U.S. Nuclear Regulatory Commission (NRC) request for additional information (RAI). This letter also provides Amendment No. 27 to the BVPS LRA based on changes resulting from the FENOC reply to the NRC.
The Attachment provides the FENOC reply to the NRC request for additional information. The Enclosure provides Amendment No. 27 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 October *.,
2008.
7/
Sincerely Peter P. Sena III
Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-31 0 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,"
September 3, 2008.
Attachment:
Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections 3.2.2.3.2, 3.3, 3.5 and B.2.17
Enclosure:
Amendment No. 27 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 Mr. B. E. Holian, NRC DLR 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-08-31 0 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections 3.2.2.3.2, 3.3, 3.5 and B.2.17 Page 1 of 5 Section 3.2.2.3.2 Question 3.2.2.3.2-1 In LRA Table 3.2.2-2, aging management review lines 25 and 36 describe that for reduction of heat transfer, the Water Chemistry Program will be used.
The staff noted that the One-Time Inspection Program is not identified to verify the effectiveness of the Water Chemistry Program in ensuring that the aging effect is being managed.
Explain how verification of the Water Chemistry Program is accomplished to ensure that the aging effect is managed.
RESPONSE RAI 3.2.2.3.2-1 Table 3.2.2-2 lines 25 and 36 address management of reduction of heat transfer for the Residual Heat Removal System heat exchangers. Confirmation of the effectiveness of the Water Chemistry Program is provided by operation of the system during plant cooldowns. Reduction of heat transfer capability would be evident during system operation.
NUREG-1801, "Generic Aging Lessons Learned (GALL) Report,"Section V.D1, "Emergency Core Cooling System (Pressurized Water Reactors)," addresses the emergency core cooling systems for PWRs, including the Residual Heat Removal System. However,Section V.D1 does not recommend confirmation of the Water Chemistry Program effectiveness for aging management of stainless steel components.
NUREG-1801 V.D1-30 and V.D1-31 address loss of material and cracking of stainless steel in treated borated water environments. Both V.D1-30 and V.D1-31 recommend management of these aging effects using the Water Chemistry Program alone, without confirmation by the One-Time Inspection Program. NUREG-1 801 does not address
"'Reduction of heat transfer" for treated borated water environments.
Attachment L-08-3 10 Page 2 of 5 Section 3.3 Question 3.3-A In license renewal application (LRA) Tables 3.3.2-1, 3.3.2-2, 3.3.2-11 and 3.3.2-12, the applicant has credited the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program, to manage the aging effects of cracking and reduction of heat transfer of stainless steel, aluminum, and copper alloy <15% Zn moisture separators and heat exchangers. The applicant has described this program in LRA Section B.2.22 and stated that it is consistent with the generic aging lessons learned (GALL) aging management program (AMP)
XI.M38. However, the GALL AMP XI.M38 is credited for managing the aging effect of loss of material due to corrosion for steel components only.
(a) Please justify how this program will manage the aging effect of reduction of heat transfer or provide a plant-specific program.
(b) Please justify how this program will manage the aging effect of cracking of moisture separator or provide a plant-specific program.
RESPONSE RAI 3.3-A
- a. Reduction of heat transfer for selected components will be managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program by visual inspection for accumulation of dirt and debris on heat transfer surfaces. "Fouling" is associated with both loss of material and reduction of heat transfer. Fouling is specifically included in the XI.M38 program Monitoring and Trending and Acceptance Criteria elements. The material of construction of heat transfer surfaces is not relevant to inspection for buildup of dirt and debris (fouling) that could impede heat transfer. Therefore, FENOC considers inspections for fouling that could lead to reduction of heat transfer to be consistent with the recommendations of NUREG-1801 XI.M38.
- b. The moisture separators that are potentially susceptible to cracking in LRA Table 3.3.2-12 are associated with the Unit 1 Emergency Diesel Generator Air Start system.
FENOC used the Electric Power Research Institute (EPRI) 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools (Mechanical Tools)," as the primary aging effect reference for the determination that cracking is an aging effect requiring management for these components. The determination that cracking is a relevant aging effect for aluminum alloys is dependant upon the presence of zinc or magnesium above threshold levels within the aluminum alloy. LRA Note 310 (Assumes aluminum alloy contains greater than 12% zinc and/or 6% magnesium) is appended to Table 3.3.2-12 row 26 because FENOC was unable to confirm the alloying constituents of these cast aluminum components. However, levels of zinc and magnesium above these thresholds are not common in aluminum casting alloys,
Attachment L-08-31 0 Page 3 of 5 so the aging effect of cracking is not expected to occur. Therefore, FENOC revises LRA Table 3.3.2-12, Row 26 to assign the One-Time Inspection Program to confirm the absence of cracking in these moisture separators. The One-Time Inspection Program includes provisions for selection of an inspection technique appropriate to the aging effect of concern.
See the Enclosure to this letter for the revision to the BVPS LRA.
Section 3.5 Question 3.5-A In LRA Table 3.5.2-36, the applicant states in line 229 that for fire wraps, there is no aging effect requiring management. However, the applicant is proposing to use the Fire Protection Program. The applicant has referenced footnote 524 for this line item. Footnote 524 states that the Fire Protection (B.2.16) Program supplements aging effects management for fire barrier cable trays, conduits, ductwork and structural members.
Please clarify what you mean by "supplements aging effects management," when there is no aging effect requiring management.
RESPONSE RAI 3.5-A Inspection of the fire wrap supplements the aging effects management for the wrapped components.
There are no aging effects associated with fire wrap. However, aging effects have been identified for cable trays, conduits, ductwork and structural members that are protected by the fire wrap. The BVPS Fire Protection program verifies that the exposed surfaces of all fire-rated assemblies (including fire-wrapped ductwork, conduit, cable trays and support columns) within safety-related fire areas are in operable condition. Additionally, inspections verify that the exposed surfaces of fire wrap material have no mechanical damage, and the fire wrap material completely envelopes the wrapped item (cable tray, conduit, ductwork). These inspections supplement aging management of the wrapped components by ensuring proper protection and providing additional inspection opportunities for exposed surfaces of the wrapped components.
Attachment L-08-3 10 Page 4 of 5 Section B.2.17 Question B.2.17-2 Follow-up In RAI B2.17-2, since the frequency of inspections of fire hydrant gaskets of once every 18 months in the LRA is different than the recommended frequency of once every 12 months in the GALL AMP, the staff asked the applicant to justify why this was not an exception.
In its letter dated July 24, 2008, the applicant stated that although these gaskets perform no license renewal intended function, their condition is monitored by the Fire Water System Program and they are replaced as necessary. However, the frequency of inspection is still different than what the GALL AMP recommends and no justification was provided why this is not an exception.
Please provide justification why this is not an exception.
RESPONSE RAI B.2.17-2 Follow-up FENOC did not consider the difference in gasket inspection frequency to be an exception to NUREG-1801 because the gaskets are consumable items which are replaced on condition following inspections. As such, the gaskets are not subject to aging management review, and differences with program elements that address them were not considered exceptions.
Justification for the acceptability of the reviewer-identified difference from NUREG-1 801 is that site operating experience shows that the current monitoring frequency for these gaskets is sufficient to provide reasonable assurance that fire hydrants (hose stations) can perform their intended function and provide opportunities for degradation to be detected before a loss of intended function can occur.
Attachment L-08-3 10 Page 5 of 5 Question B.2.17-3 Follow-up In RAI B.2.17-3, since the fire hydrant hose hydraulic tests are performed at various frequencies different than the GALL AMP recommended frequency of once every 12 months, the staff asked the applicant to justify why this was not an exception.
In its letter dated July 24, 2008, the applicant responded that fire hoses are consumables, and are routinely tested, inspected, and replaced when necessary.
Criteria for inspection and replacement are based on accepted industry standards (e.g., NFPA-1962). Therefore, while these consumables are within the scope of license renewal, they do not require an aging management review. However, the frequency of hydraulic testing is still different than what the GALL AMP recommends and no justification was provided why this is not an exception.
Please provide justification why this is not an exception.
RESPONSE RAI B.2.17-3 follow-up FENOC did not consider the difference in fire hose hydrostatic test frequency to be an exception to NUREG-1801 because the hoses are consumable items which are replaced on condition following inspections. As such, the hoses are not subject to aging management review, and differences with program elements that address them were not considered exceptions.
Hoses that are stored outdoors or in unheated buildings are hydro-tested at least annually, as recommended by NUREG-1801 XI.M27. Hoses stored in heated buildings are not exposed to the same temperature extremes or temperature cycles as those that are stored outside, and are tested less frequently. Justification for the acceptability of this reviewer-identified difference from NUREG-1 801 is that site operating experience shows that the current testing frequency for fire hoses is sufficient to provide reasonable assurance that fire hydrants (hose stations) can perform their intended function and provide opportunities for degradation to be detected before a loss of intended function can occur. A search of corrective action database did not identify any instances of fire hose failure while in use for training, drills, or actual fire fighting.
ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-310 Amendment No. 27 to the BVPS License Renewal Application Page 1 of 5 License Renewal Application Sections Affected Table 3.3.2-12, Row 26 A.1.30 B.2.30 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 beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text fined-ou and added text underlined.
Enclosure L-08-31 0 Page 2 of 5 Affected Paragraph and Sentence Affected LRA Section LRA Page No.
Table 3.3.2-12 Page 3.3-366 Row 26 In request for additional information (RAI) 3.3-A, the U.S. Nuclear Regulatory Commission (NRC) asked FENOC to provide justification that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.22) will manage the aging effect of cracking of moisture separators, or to provide a plant-specific program. In response, FENOC stated that levels of zinc and magnesium above thresholds that would cause cracking are not common in aluminum casting alloys, so the aging effect of cracking is not expected to occur in these components. Therefore, the One-Time Inspection Program is assigned (in place of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program) to confirm the absence of cracking for these aluminum moisture separators. Table 3.3.2-12 is revised to read:
Aging Effect NUREG-AgngEfet Aging Management 1801 Table 1 Notes Row Component Intended Material Environment Requiring Program Voum 2
Item No.
Type Function Management Program Volume 2 Item Item 26 Moisture Leakage Aluminum Condensation Cracking One Time Inspection N/A N/A H,
Separator boundary (B.2.30) 310 (spatial)
!n..O..On, of Intr.na Piping and Ducting Gegp,2 l,
Enclosure L-08-31 0 Page 3 of 5 Affected Paragraph Affected LRA Section LRA Page No.
and Sentence Section A.1.30 Page A.1-13 3 rd Paragraph In RAI 3.3-A, the NRC asked FENOC to provide justification that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.22) will manage the aging effect of cracking of moisture separators, or to provide a plant-specific program. In response, FENOC stated that levels of zinc and magnesium above thresholds that would cause cracking are not common in aluminum casting alloys, so the aging effect of cracking is not expected to occur in these components. Therefore, the One-Time Inspection Program is assigned (in place of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program) to confirm the absence of cracking for these aluminum moisture separators. The third paragraph of Section A.1.30 is revised to read:
In addition to verifying program effectiveness, the program is used to verify less-of materal-s aging effects are not occurring in the following components:
S Steam Loss of material of the steam generator feedwater ring;-and7,
- Selected Loss of material of selected bottoms of tanks that sit on concrete pads (by volumetric examination)-. and,
- Cracking of aluminum alloy moisture separators associated with the Unit I Emergencv Diesel Generator Air Start System.
Enclosure L-08-31 0 Page 4 of 5 Affected Paragraph and Sentence Affected LRA Section LRA Page No.
Section B.2.30 Pages B.2 82 Program Description, 4 th Paragraph; Scope of Program, 2nd Paragraph; Detection of Aging Effects, 2 nd Paragraph; In RAI 3.3-A, the NRC asked FENOC to provide justification that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.22) will manage the aging effect of cracking of moisture separators, or to provide a plant-specific program. In response, FENOC stated that levels of zinc and magnesium above thresholds that would cause cracking are not common in aluminum casting alloys, so the aging effect of cracking is not expected to occur in these components. Therefore, the One-Time Inspection Program is assigned (in place of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program) to confirm the absence of cracking for these aluminum moisture separators. Section B.2.30 is revised to read:
Program Description In addition to verifying program effectiveness, the program is used to verify less-el mater-is aging effects are not occurring in the following components:
" Steam Loss of material of the steam generator feedwater ring;-ad-,
" Seleeted Loss of material of selected bottoms of tanks that sit on concrete pads (by volumetric examination)-. and,
" Cracking of aluminum alloy moisture separators associated with the Unit 1 Emergency Diesel Generator Air Start System.
I Enclosure L-08-31 0 Page 5 of 5 Scope of Program In addition to verifying program effectiveness, the program will be used to verify less of material is aging effects are not occurring in the following components:
" Several tanks that sit on concrete pads are in identified in the Aging Management Review Reports as having their external surface exposed to soil and credit this aging management program. The external bottom surfaces of these tanks will be inspected for loss of material (by volumetric examination) as part of the One-Time Inspection Program.
The Unit 1 and Unit 2 steam generator feedwater rings will be inspected for loss of material as part of the program.
" The aluminum alloy moisture separators associated with the Unit 1 Emergency Diesel Generator Air Start System are potentially susceptible to cracking. Levels of zinc and magnesium above thresholds are not common in aluminum casting alloys, so the aging effect of cracking is not expected to occur. The program will confirm the absence of cracking in these moisture separators.
Detection of Aging Effects In addition to inspecting a representative sample of the in-scope system and component population, the program will also inspect the following components to verify loss of material is aging effects are not occurring:
" Steam Loss of material of the steam generator feedwater ring; and,-
Seleoted Loss of material of selected bottoms of tanks that sit on concrete pads (by volumetric examination)7, and,
" Cracking of aluminum alloy moisture separators associated with the Unit I Emergency Diesel Generator Air Start System.