L-08-316, License Renewal Application Amendment No. 26 (TAC Nos. MD6593 and MD6594), Revisions

License Renewal Application Amendment No. 26 (TAC Nos. MD6593 and MD6594), Revisions

ML082800180
Person / Time
Site:	Beaver Valley
Issue date:	10/02/2008
From:	Brosi R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-316, TAC MD6593, TAC MD6594
Download: ML082800180 (7)

Text

FENOC Beaver Valley Power Station P.O. Box 4 Shippingport,PA 15077 FirstEnergyNuclear Operating Company Roy K. Brosi 724-682-5234 Director,Site Performance Improvement Fax: 724-643-8069 October 2, 2008 L-08-316 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 License Renewal Application Amendment No. 26 (TAC Nos. MD6593 and MD6594)

The referenced letter provided the FirstEnergy Nuclear Operating Company (FENOC)

License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS).

During the U.S. Nuclear Regulatory Commission (NRC) Region I Inspection Procedure IP-71002 License Renewal Inspection held the weeks of June 23 and July 14, 2008, FENOC identified necessary revisions to the BVPS LRA following questioning by the NRC Inspection Team. The Enclosure provides Amendment No. 26 to the BVPS LRA.

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.

Sincerely, y Kri Roy K. Brosi A0"Nt5~

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-316 Page 2

Reference:

FENOC Letter L-07-113, "License Renewal Application," August 27, 2007.

Enclosure:

Amendment No. 26 to the BVPS License Renewal Application cc: Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator Mr. J. E. Richmond, NRC Region I DRS/EB1 cc: w/o 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

ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-316 Amendment No. 26 to the BVPS License Renewal Application Page 1 of 5 License Renewal Application Sections Affected Table A.4-1 Table A.5-1 B.2.20 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-out and added text underlined.

Enclosure L-08-316 Page 2 of 5 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.4-1 Page A.4-4 & 5 Item Number 10 LRA Table A.4-1, "Unit I License Renewal Commitments," Item Number 10 regarding the Fuel Oil Chemistry Program, requires revision to include additional clarification about a program enhancement to perform periodic ultrasonic testing (UT) thickness measurement of accessible above-ground fuel oil tank bottoms to ensure that significant degradation is not occurring (see the revision to LRA Section B.2.20 in this Enclosure). The commitment change below shows changes made in Amendment 23 as incorporated. Item Number 10 in LRA Table A.4-1 is revised to read:

Item Implementation Related LRA No. Commitment Schedule Source Section No.!

Comments 10 Enhance the Fuel Oil Chemistry Program January 29, 2016 LRA and A.1.20 to: LRA B.2.20

• Revise the implementing procedure for Amendment sampling and testing the diesel-driven 23 fire pump fuel oil storage tank (Unit I only) to include a test for particulate and accumulated water in addition to the test for sediment and water;

• Generate a new implementing procedure for sampling and testing the security diesel generator fuel oil day tank (Common) for accumulated water, particulate contamination, and sediment / water; and,

• Revise implementing procedures to perform UT thickness measurements of accessible above-groundfuel oil tank bottoms at the same frequency as tank cleaning and inspections to ensure that significant degradationis not occurring.For inaccessible tank bottoms, determine tank bottom thickness using an appropriateNDE technique if inspectionsindicate the presence of significant corrosion.

Enclosure L-08-316 Page 3 of 5 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.5-1 Page A.5-5 Item Number 11 LRA Table A.5-1, "Unit 2 License Renewal Commitments," Item Number 11 regarding the Fuel Oil Chemistry Program, requires revision to include additional clarification about a program enhancement to perform periodic ultrasonic testing (UT) thickness measurement of accessible above-ground fuel oil tank bottoms to ensure that significant degradation is not occurring (see the revision to LRA Section B.2.20 in this Enclosure). The commitment change below shows changes made in Amendment 23 as incorporated. Item Number 11 in LRA Table A.5-1 is revised to read:

Item Commitment mImplementation See Source Related Section LRA No.!

No. ComtetSchedule Cmet Comments 11 Enhance the Fuel Oil Chemistry Program May 27, 2027 LRA and A.1.20 to: LRA B.2.20

• Revise the implementing procedure for Amendment sampling and testing the diesel-driven 23 fire pump fuel oil storage tank (Unit 1 only) to include a test for particulate and accumulated water in addition to the test for sediment and water;

" Generate a new implementing procedure for sampling and testing the security diesel generator fuel oil day tank (Common) for accumulated water, particulate contamination, and sediment / water; and,

• Revise implementing procedures to perform UT thickness measurements of accessible above-groundfuel oil tank bottoms at the same frequency as tank cleaning and inspections to ensure that significant degradationis not occurring.Forinaccessible tank bottoms, determine tank bottom thickness using an appropriateNDE technique if inspections indicate the presence of significant corrosion.

Enclosure L-08-316 Page 4 of 5 Affected Paragraph Affected LRA Section LRA Page No. and Sentence B.2.20 B.2.55 - 56 "Detection of Aging Effects" under "Exceptions to NUREG-1 801" &

"Detection of Aging Effects" under "Enhancements" LRA Section B.2.20 requires revision because FENOC has added an exception to the Fuel Oil Chemistry Program (B.2.20). Exception is taken to performing UT on buried or inaccessible fuel oil tanks. If visual inspection of the internal surface of these tanks indicates significant loss of material, use of an alternate Non-Destructive Examination (NDE) technique to confirm no loss of intended function will be evaluated. Also, additional clarification has been added to the program enhancement for the NUREG-1 801 element "Detection of Aging Effects." The changes below show changes made in Amendment 23 as incorporated. Section B.2.20 is revised to read:

Exceptions to NUREG-1801

• Detection of Aging Effects NUREG-1801 states that an ultrasonic thickness measurement of tank bottom surfaces ensures that siQnificantdegradationis not occurring.FENOC takes an exception to this element of the program, because ultrasonic (UT) measurement techniques may not be used to determine tank bottom thickness for tanks whose external bottom surfaces are not normally accessible. Pitting corrosion could potentially result in an irregularinternaltank bottom surface. Meaningful results for tank bottom thickness measurements using UT require access to the unpitted surface of the tank. Access to the bottom external surface of buried fuel oil tanks and to the Unit 1 emergency diesel generatorengine-mounted day tanks is impractical.Forthese tanks, FENOC will perform an appropriateNDE technique to determine tank wall thickness if periodic visual inspections identify siqnificant corrosion.

Enclosure L-08-316 Page 5 of 5 Enhancements Detection of Aging Effects The two program enhancements described under the Parameters Monitored /

Inspected program element are necessary for consistency with this program element.

Revise implementing procedures to perform UT thickness measurements of accessible above-ground fuel oil tank bottoms at the same frequency as tank cleaning and inspections to ensure that significant degradationis not occurring.

Forinaccessible tank bottoms, determine tank bottom thickness using an appropriateNDE technique if inspections indicate the presence of significant corrosion.