L-13-331, 10 CFR 50.55a Request Number BV1-IWE-2-3

10 CFR 50.55a Request Number BV1-IWE-2-3

ML13281A477
Person / Time
Site:	Beaver Valley
Issue date:	10/07/2013
From:	Emily Larson FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-13-331
Download: ML13281A477 (3)

Text

Beaver Valley Power Station P.O. Box 4 RrstEnergy Nuclear Operating Company Shippingport, PA 15077 724-682-5234 Eric A. Larson Fax: 724-643-8069 Site Vice President October 7, 2013 L-13-331 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 10 CFR 50.55a Request Number BV1-IWE-2-3 In accordance with the provisions of 10 CFR 50.55a(a)(3)(i), the FirstEnergy Nuclear Operating Company (FENOC) hereby requests Nuclear Regulatory Commission (NRC) approval of a proposed alternative for implementation during the current Beaver Valley Power Station, Unit No.1 (BVPS-1), maintenance and refueling outage (fall2013) .

FENOC proposes a visual examination (VT-1) of the containment liner pressure boundary repair welds as an alternative to the detailed visual examination requirement of ASME Code Section XI, sub-article IWE-5240, during a required pressure test.

Details of the alternative are described in the enclosure.

There are no regulatory commitments contained in this submittal. FENOC requests approval of the proposed alternative by October 21, 2013 to support restart from the BVPS-1 fall 2013 maintenance and refueling outage. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.

Sincerely, ra £ Eric A. Larson

Enclosure:

10 CFR 50.55a Request Number BV1-IWE-2-3, Revision 0 cc: NRC Region I Administrator NRC Senior Resident Inspector NRC Project Manager Director BRP/DEP BRP/DEP Site Representative

10CFR 50.55a Request Number BV1-IWE-2-3, Revision 0 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

Page 1 of 2

--Alternative Provides Acceptable Level of Quality and Safety--

1.0 ASME Code Components Affected

The affected component for this request is the Beaver Valley Power Station, Unit No. 1 (BVPS-1), containment liner. The containment liner is not an American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) pressure vessel.

However, the containment liner is included in the BVPS-1 ASME Code Section XI lnservice Inspection (lSI) program and Section XI Repair/Replacement Program.

2.0 Applicable Code Addition and Addenda ASME Code Section XI, 2001 Edition, 2003 Addenda.

3.0 Applicable Code Requirements Article IWE-5000, "System Pressure Tests," sub-article IWE-5240, "Visual Examination,"

states:

During the pressure test required by IWE-5220, a detailed visual examination (IWE-231 0) shall be performed on areas affected by repair/replacement activities.

4.0 Reason for Request

During the fall 2013 maintenance and refueling outage for BVPS-1, a coatings examination of the painted internal surface of the containment liner plate identified a surface defect. Subsequent surface cleaning revealed the surface defect as a through-wall hole in the containment liner plate. The area of the through-wall hole was approximately 0.42 inches by 0.29 inches. Repairs include removing the degraded portion of the liner plate and welding a replacement plate in place. Following the repairs, a pneumatic leakage test is required in accordance with sub-article IWE-5221.

A local leak rate test is planned to be performed on the repaired area. The test requires the use of a test rig. The test rig will make the containment liner internal surface areas affected by the repair activities inaccessible for direct visual examination during the test.

The outside surface of the repair area is covered with concrete and is also inaccessible for direct visual examination.

Relief is requested from the direct visual examination requirement specified in sub-article IWE-5240 during the leakage test required by sub-article IWE-5221.

L-13-331 Enclosure Page 2 of 2 5.0 Proposed Alternative and Basis for Use In accordance with 10 CFR 50.55a(a)(3)(i), FENOC requests approval of an alternative to the detailed visual examination requirement of ASME Code Section XI, sub-article IWE-5240 during the pressure test. FENOC proposes to perform a visual examination (VT-1) of the affected containment liner internal surface area both prior to and following the local leak rate test.

Visual examination (VT-1) prior to the performance of the local leak rate testing provides assurance that the affected area has been properly prepared for testing and no abnormalities exist in the affected area. The local leak rate test will provide an accurate and direct method of assuring the leak-tight integrity of the repair welds. Post leak rate test visual examination (VT-1) provides assurance that the tested area is free of abnormalities that may be exposed by the local leak rate test.

The proposed visual examination (VT-1) of the affected area of the containment liner internal surface prior to and following the local leak rate test provides an adequate level of quality and safety. Required nondestructive examinations of the repair will provide additional assurance of the integrity of the repair welds.

6.0 Duration of Proposed Alternative The proposed alternative is requested in support of containment liner repairs made during the current outage and remainder of the current BVPS-1 inservice inspection interval ending March 31, 2018.