L-09-139, Reply to Request for Additional Information on License Renewal Application Amendment No. 38

Reply to Request for Additional Information on License Renewal Application Amendment No. 38

ML091540012
Person / Time
Site:	Beaver Valley
Issue date:	06/01/2009
From:	Ostrowski K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-09-139, TAC MD6593, TAC MD6594
Download: ML091540012 (11)

Text

FENOCf Beaver Valley Power Station Shippin P.O. Box 4 Company FirstEnergyNuclear Operating Kevin L. Ostrowski 724-682-5234 Director, Site Operations Fax: 724-643-8069 June 1,2009 L-09-139 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. 38 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 B.2.3 and B.2.5 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. 38 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. 38 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 June /., 2009.

Sincerely, Kevin L. Ostrowski OK jNfl,4

Beaver Valley Power Station, Unit Nos. 1 and 2 L-09-139 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 7, 2009.

Attachment:

Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.3 and-B.2.5

Enclosure:

Amendment No. 38 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-09-139 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections B.2.3 and B.2.5 Page 1 of 6 Section B.2.3 Question RAI B.2.3-4

Background:

LRA Section B.2.3 states that American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code Section XI, Subsection IWE inspections have identified containment liner plate deficiencies such as paint flaking, chipping, blistering, and other minor damage. The application further stated that the inspections have been effective in identifying minor irregularities on the inside surface of the liner plate before significant corrosion damage occurred.

Issue:

In 2006, during a steam generator replacement, three locations of corrosion were discovered on the concrete side of the containment liner. These were attributed to degradation during initial construction, and the locations were either repaired or identified for future inspections. On April 23, 2009, during an IWE inspection, a paint blister was discovered, which upon further inspection revealed through-wall corrosion of the containment liner.

Request:

Explain how the recent plant-specific operating experience, both the 2006 and 2009 degradation, will be incorporated into the ASME Section XI, Subsection IWE AMP, and whether or not a plant-specific program is necessary to manage aging of the containment liner.

RESPONSE RAI B.2.3-4 A plant-specific program is not necessary. Modifications to the existing program and corrective actions are described below.

Following the liner corrosion discovered in 2006, the containment inspection procedures were modified to address the potential corrosion of the liner material utilizing a visual inspection approach. Both the Unit I and Unit 2 procedures were modified to include the following acceptance criteria:

Attachment L-09-139 Page 2 of 6

1. When paint or coatings are to be removed for further inspection, the paint or coatings shall be visually examined by a qualified VT-3 inspector prior to removal.

2. If the visual examination detects surface flaws on the liner or suspect areas on the liner plate that could potentially impact the leak tightness or structural integrity of the liner, then surface or volumetric examinations shall be performed to characterize the condition (i.e., depth, size, shape, orientation).

Two of the three degraded areas were removed and replaced with new plate material.

The third area was reinstalled upon restoration of the containment construction opening in 2006. The reinstalled area was inspected by ultrasonic testing (UT) during the current refueling outage (April/May 2009) to confirm that additional corrosion'is not occurring.

Wall thickness measurements were within the calibration tolerances of the installed (2006) condition.

In 2009, an approximately 1 inch by 3/8 inch defect area of through-wall corrosion was identified by visual observation of a paint blister and subsequent use of the actions in the modified procedure. The affected area containing the defect (identified in 2009) was replaced in accordance with IWE 3122.2. The defect was associated with the presence of a piece of wood embedded in the concrete directly behind the through-wall corrosion defect and is considered an event-based occurrence.

The next ASME Section XI, Subsection IWE program visual examinations of accessible containment liner surfaces are currently scheduled for Unit 1 refueling outage 1R21 (April 2012 at Unit 1) and Unit 2 refueling outage 2R1 5 (April/May 2011 at Unit 2).

Corrective actions for the degradation identified in 2009 include visual examinations of 100% of the accessible liner area in 1 R20 in October/November 2010 and 2R1 4 in October/November 2009 to confirm that additional through wall corrosion has not occurred. A UT inspection of the replaced area is scheduled during 1 R20 to confirm that no new unacceptable corrosion is occurring as a result of the replacement. These future actions are tracked in the corrective action program.

Additionally, supplemental volumetric examinations will be performed on the Unit I and Unit 2 containment liners prior to the period of extended operation. Seventy five (one foot square) sample locations at each unit will be examined. If no degradation is found, this sample size will provide 95% confidence that 95% of the liner is not degraded (using the methodology in chapter 4 of EPRI TR-107514). If degradation is identified, the degraded area(s) will be evaluated and follow-up examinations will be performed to ensure the continued reliability of the containment liner. A commitment to perform these supplemental examinations is provided in Appendix A of the LRA.

The existing BVPS ASME Section XI, Subsection IWE program is in accordance with the requirements of ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWE with the limitations and modifications required by the Code of Federal Regulations in 10 CFR 50.55a.

Attachmenf L-09-139 r Page 3 of 6 Question RAI B.2.3-5

Background:

During a presentation to the ACRS sub-committee, on February 4, 2009, the applicant stated that their ASME Section XI, Subsection IWE Program'had been enhanced in response to the degradation discovered in 2006.

Issue:

The applicant has not discussed the relationship, if any between an enhanced IWE Program and an augmented IWE Program.

Request:

Explain how the IWE Program was enhanced, with a focus on how the enhancements relate to the ASME code required augmented inspections. The explanation should be in sufficient detail to allow for a one to one comparison between an enhanced IWE Program and the augmented inspections required by ASME Section XI, Subsection IWE.

RESPONSE RAI B.2.3-5 The program was not enhanced to achieve GALL consistency as described in NUREG-1 800. The procedures used by the program were modified, as described below, to identify additional actions to be followed in the event suspect surfaces were identified by the IWE visual inspection.

In 2006, the containment inspection procedures of the existing IWE program for both units were modified to address the potential corrosion of the liner material utilizing a visual inspection approach. The procedure modifications were the outcome of corrective actions from the 2006 occurrence. At Beaver Valley, these procedures satisfy ASME XI, Subsection IWE General Visual Examination requirements for examination of Class MC (Metal Containment) surfaces. Both the Unit 1 and Unit 2 procedures were modified to include the following acceptance criteria:

1.. When paint or coatings are to be removed for further inspection, the paint or coatings shall be visually examined by a qualified. VT-3 inspector prior to removal.

2. If the visual examination detects surface flaws on the liner or suspect areas on the liner plate that could potentially impact the leak tightness or structural integrity of the liner, then surface or volumetric examinations shall be performed to characterize the condition (i.e., depth, size, shape, orientation).

Following the discovery of the corrosion on the concrete side of the liner plate in 2006, two of the three degraded areas were removed and replaced with new plate material.

The third area was acceptable for continued use and was left in place. As part of the

Attachment L-09-139 Page 4 of 6 corrective actions from the discovery, this area is monitored with subsequent examinations. The area is defined on the interior surface of the liner plate to allow examination from the surfaces inside the Containment Building. A baseline UT thickness measurement was performed in 2006. In May 2009, in accordance with this corrective action, UT measurements were taken of the third area. Wall thickness measurements were within the calibration tolerances of the installed (2006) condition.

These corrective actions from 2006 are not characterized as ASME Xl, Subsection IWE augmented examinations. The degradation was discovered outside of scheduled ASME Xl, Subsection IWE examinations.

In April 2009, during the performance of the ASME Xl, Subsection IWE containment liner interior visual examination, a suspect area was discovered which exhibited blistered paint and protruding corrosion product. The area was cleaned, which revealed a through-wall hole approximately 1" by 3/8". Wood debris was found within the concrete, directly adjacent to the hole. Laboratory analysis concluded that the wood debris most likely promoted the corrosion. The affected area was replaced and pressure tested to ensure leak tightness.

The next ASME Section XI, Subsection IWE program visual examinations of accessible containment liner surfaces are currently scheduled for Unit 1 refueling outage 1 R21 (April 2012 at Unit 1) and Unit 2 refueling outage 2R15 (April/May 2011 at Unit 2).

Corrective actions for the degradation identified in 2009 include visual examinations of 100% of the accessible liner area in 1R20 in October/November 2010 and 2R1 4 in October/November 2009 to confirm that additional through wall corrosion has not occurred. A UT inspection of the replaced area is scheduled during 1R20 to confirm that no new unacceptable corrosion is occurring as a result of the replacement. These future actions are tracked in the corrective action program.

Additionally, supplemental volumetric examinations will be performed on the Unit 1 and Unit 2 containment liners prior to the period of extended operation. Seventy five (one foot square) sample locations at each unit will be examined. If no degradation is found, this sample size will provide 95% confidence that 95% of the liner is not degraded (using the methodology in chapter 4 of EPRI TR-1 07514). If degradation is identified, the degraded area(s) will be evaluated and follow-up examinations will be performed to ensure the continued reliability of the containment liner. A commitment to perform these supplemental examinations is provided in Appendix A of the LRA.

These corrective actions are not characterized as ASME XI, Subsection IWE augmented examinations. The affected area has been replaced.

The existing BVPS ASME Section Xl, Subsection IWE program is in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWE, within the limitations and modifications required by the Code of Federal Regulations in 10 CFR 50.55a.

Attachment L-09-139 Page 5 of 6 Section B.2.5 Question RAI B.2.5-1

Background:

During a steam generator replacement in 2006, three areas of corrosion were identified on the concrete side of the containment liner. In response to previous license renewal RAIs, the applicant explained that when visual examinations detect indications of degradation, surface or volumetric examinations will be performed on suspect areas of the liner plate.

Issue:

On April 23, 2009, during an IWE inspection, a paint blister was discovered, which upon further inspection revealed through-wall corrosion of the containment liner.

During the applicant's inspection of the corrosion, a piece of wood was discovered in the concrete behind the containment liner, which the applicant has indicated may have led to degradation of the containment concrete.

Request:

Explain whether or not the concrete or rebar, located behind the through-wall flaw, were degraded. Also explain how the recent plant-specific operating experience will be incorporated into the ASME Section Xl, Subsection IWL AMP, and whether or not a plant-specific program is necessary to manage aging of the containment concrete.

RESPONSE RAI B.2.5-1 The concrete exposed during the removal of the wood and replacement of the flawed liner section was not degraded. No structural rebar was exposed. No enhancement to the ASME Section XI, Subsection IWL program is needed, and no plant-specific program is needed to manage aging of the containment concrete.

The concrete behind the liner defect contained a small void associated with the volume of embedded wood. Some concrete immediately around the wood was removed to support removal of the embedded wood, and the area was repaired with grout prior to replacement of the liner section. The concrete behind the through-wall flaw was not degraded. No structural rebar was exposed during the removal of the wood and replacement of the affected section of the liner.

A section of vertical rebar (with visible corrosion adjacent to the location of the wood) was encountered during removal of the wood and concrete for the repair associated with the liner corrosion. Based on the location and orientation of the steel rebar encountered, the rebar was determined to be an extra, non-structural member of the

Attachment L-09-1 39 Page 6 of 6 containment concrete structure used in forming the rebar skeleton prior to and during the concrete pour.

No structural rebar was exposed during the 2009 liner repair. During the 2006 steam generator replacement project, the structural rebar within the (approximately 23 ft x 21 ft) construction dpening was exposed. Within the expanse of rebar exposed by the concrete removal, corrosion was noted on only one small section approximately nine inches in length. This observation provides reasonable assurance that the structural rebar is in good condition.

The BVPS ASME Section Xl, Subsection IWL program is in accordance with ASME Boiler and Pressure Vessel Code, Section Xl, Subsection IWL, within the limitations and modifications required by the Code of Federal Regulations in 10 CFR 50.55a. No enhancement to the ASME Section Xl, Subsection IWL program is needed, and no plant-specific program is needed.

ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-09-139 Amendment No. 38 to the BVPS License Renewal Application Page 1 of 3 License Renewal Application 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 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-09-139 Page 2 of 3 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.4-1 Page A.4-9 New Item No. 32 LRA Table A.4-1, "Unit I License Renewal Commitments," is amended to add new Item No. 32 regarding examination of the containment liner as follows:

Related LRA Item Commitment Section No./

Number Comments 32 Supplemental volumetric January29, None examinations will be performed on the 2016 Unit I containment liner prior to the Deriod of extended ooeration. Seventy five (one foot sauare) sample locations will be examined. If dearadationis identified, the deQraded area(s) will be evaluated and follow-up examinations will be Derformed to ensure the continuedreliabilityof the containmentliner.

Enclosure L-09-139 Page 3 of 3 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table A.5-1 Page A.5-10 New Item No. 33 LRA Table A.5-1, "Unit 2 License Renewal Commitments," is amended to add new Item No. 33 regarding examination of the containment liner as follows:

ImplementationRead Related LRAA Item temCommitment Ipeme Source Section No./

Number ComtetSchedule Cmet Comments 33 Supplemental volumetric May 27, 2027 FENOC None examinations will be performed on the Letter Unit 2 containment linerprior to the L-09-139 period of extended operation. Seventy five (one foot square)sample locations will be examined. If degradationis identified, the degraded area(s)will be evaluated and follow-up examinations will be performed to ensure the continued reliabilityof the containment liner.