L-08-377, Supplemental Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 34

Supplemental Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 34

ML090220216
Person / Time
Site:	Beaver Valley
Issue date:	01/19/2009
From:	Ostrowski K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-377, TAC MD6593, TAC MD6594
Download: ML090220216 (18)

Text

FENOC  %%P.O.

Beaver Valley Power Station Box 4 FirstEnergyNuclear OperatingCompany Shippingport, PA 15077 Kevin L. Ostrowski 724-682-5234 Director,Site Operations Fax: 724-643-8069 January 19, 2009 L-08-377 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 Supplemental 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. 34 The Reference provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS). Due to recent site operating experience with Boral neutron absorber blistering, FENOC is crediting the existing plant-specific Boral Surveillance Program for aging management in the LRA.

This letter provides the associated changes to the LRA.

The Attachment provides the reason for crediting the Boral Surveillance Program. The Enclosure provides Amendment No. 34 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 January __, 2009.

Sincerely, Kevin L. Ostrowski

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-377 Page 2

Reference:

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

Attachment:

Supplemental Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application

Enclosure:

Amendment No. 34 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-08-377 Supplemental Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application Page 1 of 1 Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable.

Following submittal of the License Renewal Application, inspection of Boral coupons under the existing site Boral Surveillance Program identified that the coupons exhibited numerous blisters. In region 1 fuel storage racks, blisters can displace water from the flux traps between storage cells and challenge dimensional assumptions used in the criticality analysis.

Due to the results of this inspection, FENOC will credit the existing Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. Specifically, the Boral Surveillance Program will confirm the effectiveness of the Water Chemistry Program in managing loss of material of the Boral's aluminum cladding, and will manage the aging effect of blistering.

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-08-377 Amendment No. 34 to the BVPS License Renewal Application Page 1 of 15 License Renewal Application Sections Affected 3.3.2.2.6 Table 3.3.1-13 3.5.2.1.14 Table 3.5.2-14 3.5, Note 515 A.1.43 Table B.1-1 Table B.1-2 Table B.1-3 B.2.43 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 hined-e u and added text underlined.

Enclosure L-08-377 Page 2 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section 3.3.2.2.6 3.3-50 New paragraph Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FirstEnergy Nuclear Operating Company (FENOC) will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. A sixth paragraph is added to section 3.3.2.2.6:

Additionally, blistering of Boral coupons has recently been identified at BVPS Unit 1.

While the neutron absorptionproperties of Boral are not affected by blistering, severe blistering could have the potential to challenge dimensionalassumptions of water flux traps in the region 1 fuel storage criticalityanalysis. Therefore, blistering is considered an aging effect requiring management. The Boral Surveillance Program (Section B. 2.43) will confirm the effectiveness of the Water Chemistry Programrelated to managing the aging effect of loss of materialof the Boral's aluminum cladding in the Unit I Spent Fuel Pool, and will manage blistering of the Boral sheets in the Unit 1 Spent Fuel Pool

Enclosure L-08-377 Page 3 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.3-1 3.3-66 Item 3.3.1-13, Discussion column Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. The discussion column of item 3.3.1-13 in Table 3.3-1 is revised to read:

Consistent with NUREG-1 801, with exception.

Unit 1 has Boral neutron-absorbing sheets in Spent Fuel Pool storage racks; Unit 2 does not.

Reduction of neutron-absorbingcapacity for Boral does not need aging management.

However, the aging effect of loss of material will be managedby the Water Chemistry (B.2.42) Program. The Boral Surveillance Program (B.2.43) will confirm the effectiveness of the Water Chemistry Programin managing loss of materialof the Boral's aluminum cladding and will manage blistering.

Further evaluation is documented in Section 3.3.2.2.6.

Enclosure L-08-377 Page 4 of 15 Affected Paragraph Affected LRA Section LRA Paqe No. and Sentence Section 3.5.2.1.14 3.5-17 "Aging Effects Requiring Management," new bullet Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. Section 3.5.2.1.14 is revised to read:

Aging Effects Requiring Management The following aging effects associated with Fuel Building components require management.

" Blistering

• Cracking 0 Loss of material

Enclosure L-08-377 Page 5 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.5.2-14 3.5-124 New Rows Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. Two new rows are added to Table 3.5.2-14 as follows:

Aging Effect NUREG-Row Component Intended Material Environment Requiring1801 Table Notes No. Type Function Management Program Volume 2 Item Item New Spent fuel rack Exposed to Boral Surveillance VII.A2-5 3E neutron SHD, SSR Boral treated water Loss of Material (B.2.43) 3.3.1-13 5 absorbers te(

New Spent fuel rack Exposed to Boral Surveillance VII.A2-5 3E neutron SHD, SSR Boral treated water Blistering (B.2.43) 3.3.1-13 5 absorbers te(

Enclosure L-08-377 Page 6 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section 3.5 Notes 3.5-231 Note 515 Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. Note 515 in Section 3.5 is modified to read:

The listed AMP is a plant-specific AMP for this item. The BVPS plant-specific AMR concluded Boraldoes not require aging management for the period of extended operation for its neutron absorbing function; however, aging management for blistering and for loss of materialof its aluminum constituent is required.Management of blistering is compared to row VII.A2-5 because it has the potential to challenge assumptions used in the criticalityanalysis for region 1 fuel storage.

Enclosure L-08-377 Page 7 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section A.1.43 A.1-19 Section Number & New Section Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. The Section number of A. 1.43, "Appendix A. 1 References," is modified, and a new Section A.1.43 is inserted as follows:

A. 1.43 BORAL SURVEILLANCE PROGRAM (UNIT 1 ONLY)

The Boral Surveillance Programis an existing plant-specific condition monitoring program for which there is no comparable NUREG-1801 aging management program.

The program manages the neutron absorbingfunction of the BVPS Unit I High Density Spent Fuel Storage Racks by the removal and testing of sample Boral neutron absorber coupons. Coupon analysis is performed by a vendor, and recommendationsbased on the analysis are provided to FENOC.

The purpose of the program is to characterize certain propertiesof the Boral in the storageracks to assure its capability to fulfill its intended function, and to assure that assumptions made in the Fuel Pool criticality analysisremain valid. Because the test coupons are located and configured to ensure exposure to higher-than-averagelevels of gamma radiation,data gatheredby the program represent accelerateduse, and there is reasonableassurance that de-gradationwill be detected and corrective actions taken prior to a loss of intended function.

A.143 A. 1.44 APPENDIX A. I REFERENCES

Enclosure L-08-377 Page 8 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-1 B.1-7 New row Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. A new row is added to Table B.1-1:

Aging Management Program Title LRA Section Status Boral Surveillance (Unit I only) B.2.43 Existing

Enclosure L-08-377 Page 9 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-2 B.1-12 New row Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. A new row is added to Table B.1-2:

NUREG-1801 NUREG-1801 LRA Number Program BVPS Program Section NA Plant-specific Boral Surveillance (Unit 1 Only) B.2.43 Program

Enclosure L-08-377 Page 10 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-3 B.1-13 New row Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. A new row is added to Table B.1-3:

NUREG-1801 Comparison Programs Programs Consistent with with Exception(s)

Plant NUREG- Programs with to NUREG-Program Name Specific 1801 Enhancement(s) 1801 Boral Surveillance Yes (Unit I Only)

Enclosure L-08-377 Page 11 of 15 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Section B.2.43 B.2-120 New section Recent Beaver Valley Power Station operating experience indicates that the Boral neutron absorber material used in the Unit 1 Spent Fuel Pool may be susceptible to an aging effect requiring management that was not previously considered applicable. FENOC will credit the existing plant-specific BVPS Boral Surveillance Program for management of aging of Boral in the Unit 1 Spent Fuel Pool. A new section is added to Appendix B:

B.2.43 BORAL SURVEILLANCE (UNIT 1 ONLY)

ProaramDescription The Boral Surveillance Programis an existing plant-specific condition monitoring program for which there is no comparableNUREG-1801 aging management program.

The program manages the neutron absorbingfunction of the BVPS Unit I Hiqh Density Spent Fuel Storage Racks by the removal and testing of sample Boral neutron absorber coupons. Coupon analysis is performed by a vendor, and recommendationsbased on the analysis are provided to FENOC.

The purpose of the program is to characterizecertain propertiesof the Boral in the storage racks to assure its capability to fulfill its intended function, and to assure that assumptions made in the Fuel Pool criticality analysis remain valid. Because the test coupons are located and configured to ensure exposure to higher than average levels of gamma radiation,data gatheredby the program representaccelerateduse, and there is reasonableassurance that degradation will be detected and corrective actions taken priorto a loss of intended function.

Acing ManagementProgramElements The results of an evaluation of each of the 10 aging management program elements described in NUREG-1800 fReference 1.3-41, Appendix A. are provided as follows:

Scope of Pro-gram The scope of the program consists of the Boral neutron absorbingmaterial in the High Density Spent Fuel Storage Racks at BVPS Unit 1. The program applies only to BVPS Unit 1, because the BVPS Unit 2 Spent Fuel Storage Racks do not use Boral as a neutron absorber.

Enclosure L-08-377 Page 12 of 15

" PreventiveActions The program is a condition monitoring program that does not contain preventive actions.

" ParametersMonitored/ Inspected The program monitors changes in physical propertiesof the Boral by performing measurements on representativeBoral coupons. The coupons simulate as nearly as possible the actual in-service geometry, physical mounting, materials,and flow conditions of the Boral panels in the storage racks. The coupons are removed in accordance with a prescribedschedule. Upon removal, each coupon is inspected and tested to determine changes in physicalproperties of the Boral in the spent fuel pool. The measurements performed are:

0 Visual Observation and Photography 0 Neutron Attenuation 0 Dimensional Measurements (length, width, and thickness) 0 Weight and Specific Gravity The program provides for additional,optionalmeasurement parametersand actions, including radiography,destructive wet chemical analysis, re-insertionof tested coupons, and in-service inspection of the Boral panels themselves. These additionalactions provide options for confirming or further investigatingresults of coupon analysis.

• Detection of Aginq Effects The pro-gram was approved by the NRC in the "Safety Evaluation by the Office of NuclearReactor Regulation Related to Amendment No. 178 to Facility Operating License No. DPR-66"(ADAMS Accession number ML003767816). Detection of aiging effects occurs through monitoring changes in physical properties of the Boral coupons. When the program was initiated,a total of 20 test coupons were installed in the Unit I fuel pool, with 10 coupons installedin each of 2 coupon trees. Coupons are removed for analysis according to a prescribedschedule.

The schedule is such that coupons will be removed through the period of extended operation.

After removal, three length measurements and three width measurements are taken and compared to correspondingpre-irradiationmeasurements. Five thickness measurements are taken and compared to correspondingpre-irradiationmeasurements. The coupons are examined visually for siqns of

Enclosure L-08-377 Page 13 of 15 degradation,including edge and comer defects, discoloration,and surface pitting.

The coupons are then dried carefully in three stages to avoid expansion of the water which has been absorbed and subsequent bulging of the coupon.

Neutron attenuationmeasurements are made relative to a standardsample.

Weight and specific gravity measurements are also taken.

• Monitoringand Trendin, The evaluation of the coupons provides information on the radiologicaleffects, thermal effects, and chemical effects of the spent fuel pool environment on the Boral panels. For the first several refueling cycles after installation,the coupon trees are surroundedby dischargedfuel assemblies having a high specific power priorto shutdown. This fuel storage configurationis intended to accelerateaging of the test coupons. Over the duration of the coupon testing program, the coupons will have accumulated more radiationdose than the expected lifetime dose for normal storage cells.

Because the test coupon data gatheredby the program represents accelerated use, there is reasonableassurancethat degradationwill be detected and corrective actions taken priorto a loss of intended function of the Boral panels themselves.

" Acceptance Criteria The most significant measurements taken are thickness (to monitor for swelling) and neutron attenuation (to confirm the concentration of Boron-lO in the Boral).

Acceptance criteria for these measurements are as follows:

A decrease of no more than 5% in Boron-lO content as determined by neutron attenuation.

An increase in thickness at any point should not exceed 10% of the initial thickness at that point.

Changes in excess of eitherof these two criteriarequire investigation and engineeringevaluation to identify whether further testing or corrective actions may be necessary.

Enclosure L-08-377 Page 14 of 15 The remaining measurementparametersserve a supportingrole and should be examined for early indicationsof the potentialonset of Boral degradationthat would suggest a need for further attention. These include:

• Visual or photographicevidence of unusual surface pitting, corrosion or edge deterioration

• Unaccountableweight loss in excess of the measurement accuracy

• The existence of areasof reduced boron density should an optional neutron radiographbe taken

" CorrectiveActions This element is discussed in Section B. 1.3.

" Confirmation Process This element is discussed in Section B. 1.3.

" Administrative Controls This element is discussed in Section B. 1.3.

• OperatingExperience The program administersthe removal and testing of sample Boral neutron absorbercoupons. Coupon analysisis performed by a vendor, and recommendations based on the analysis are provided to FENOC. The results of Boral coupon analysis are recordedin inspection reports. Recommended items for evaluation from the reports have been documented in the BVPS Corrective Action Program.

To date, the most recent program inspection report was issued in 2007. Two Boral coupons were removed from the BVPS Unit 1 Spent Fuel Pool in June 2007 and shipped to Northeast Technology Corp (NETCO) for testing. The results of these tests are indicative of satisfactorymaterialperformance.

However, both coupons had numerous blisters in the Boral cladding. The previous inspection report, issued in 2002, identified a few small blisters on the coupons. Priorto that, no blisters were noted on the coupons. Because the blisters displace water from the flux trap of the Region I racks, they could potentially challenge dimensional assumptionsmade in the fuel pool criticality analysis. FENOC performed an evaluation of the blisters through the Corrective Action Program.FENOC will monitor future surveillance coupons for extent and progression of corrosion and blister growth. This action is consistent with recommendationsfrom NETCO and EPRI Report 1013721, "Handbookof

• 0 Enclosure L-08-377 Page 15 of 15 Neutron Absorber Materialsfor Spent Nuclear Fuel Transportationand Storage Applications."

Although the results of the coupon analysis warrantedfurther evaluation, the neutron attenuationand structuralintegrity of the coupons was determined to be unaffected. The operatingexperience for the program provides evidence that continued surveillance of the coupons will effectively manage aging effects such that there is no loss of intended function.

Enhancements None Conclusion Continued implementation of the Boral Surveillance Programprovides reasonable assurancethat the aging effects will be managedsuch 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.