ML062070010

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Request for Additional Information - Relief Request BV2-PZR-01, Alternative to Repair Requirements
ML062070010
Person / Time
Site: Beaver Valley
Issue date: 07/26/2006
From: Colburn T
Plant Licensing Branch III-2
To: Lash J
FirstEnergy Nuclear Operating Co
Colburn T, NRR/DORL/LPLI-1, 415-1402
References
BV2-PZR-01, TAC MD1206
Download: ML062070010 (6)


Text

July 26, 2006 Mr. James H. Lash Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NO. 2 - REQUEST FOR ADDITIONAL INFORMATION (RAI) - RELIEF REQUEST BV2-PZR-01, ALTERNATIVE TO REPAIR REQUIREMENTS (TAC NO. MD1206)

Dear Mr. Lash:

The Nuclear Regulatory Commission (NRC) staff has evaluated your March 31, 2006, subject request for relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, to perform an alternative weld overlay repair and approval to use the Electric Power Research Institute Performance Demonstration Initiative alternative. The NRC staff requires the additional information contained in the enclosed RAI in order to complete its review. As discussed with and agreed to by your staff, we request you respond within 2 weeks of the date of this letter, in order for the NRC staff to complete its review per your requested schedule.

If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-412

Enclosure:

RAI cc w/encl: See next page

July 26, 2006 Mr. James H. Lash Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NO. 2 - REQUEST FOR ADDITIONAL INFORMATION (RAI) - RELIEF REQUEST BV2-PZR-01, ALTERNATIVE TO REPAIR REQUIREMENTS (TAC NO. MD1206)

Dear Mr. Lash:

The Nuclear Regulatory Commission (NRC) staff has evaluated your March 31, 2006, subject request for relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, to perform an alternative weld overlay repair and approval to use the Electric Power Research Institute Performance Demonstration Initiative alternative. The NRC staff requires the additional information contained in the enclosed RAI in order to complete its review. As discussed with and agreed to by your staff, we request you respond within 2 weeks of the date of this letter, in order for the NRC staff to complete its review per your requested schedule.

If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-412

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION:

PUBLIC LPLI-1 R/F RidsNrrDorlLpla RidsNrrPMTColburn RidsOgc Rp RidsNrrCfeb RidsNrrLASLittle RidsAcrsAcnwMailCenter RBellamy, RI RidsNrrDpr TSteingass ACCESSION NO. ML062070010 *Input received. No substantive changes made.

OFFICE LPLI-1/PM LPLI-1/LA CFEB/BC LPLI-1/BC NAME TColburn SLittle KGruss* RLaufer DATE 07/26/06 07/26/06 06/14/06 07/26/06 OFFICIAL RECORD COPY

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. BV2-PZR-01 BEAVER VALLEY POWER STATION, UNIT NO. 2 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-412

1. In the licensees submittal dated March 31, 2006, the licensee states that a preemptive full structural weld overlay is proposed for each Alloy 82/182 nozzle-to-safe end weld.

Please indicate what types of nondestructive examination (NDE) will be performed prior to the full structural weld overlay installation. If pre-welding NDE is not to be performed, please confirm that in all cases, a full structural overlay will be installed and discuss the justification for not performing the NDE prior to welding.

2. Please discuss the repair strategy as a result of NDE. That is, if a flaw is detected in the weld by the NDE prior to weld overlay, confirm that a full-structural weld overlay is applied, and confirm that the weld overlay thickness calculation is based on the worst case flaw.
3. Please discuss whether flaw evaluations and shrinkage stress effects analyses required under Code Case N-504-2(g), Items 1, 2, and 3, will be performed. If the evaluations are to be performed after startup, please provide technical justification why it is acceptable to place these welded components into service without completing the analyses.
4. On page 12 of your submittal, you indicate that the weld overlay area may exceed 100 in2 in some cases. The staff has not approved overlay areas exceeding 300 in2 without a weld specific analysis. Since all the Beaver Valley Power Station design configurations are known, please provide your best estimate of the surface areas for all the full structural overlay configurations listed in your March 31, 2006, submittal. Part of your discussion should include similarities between your plant and those listed in your precedents section of the submittal and why the resultant overlay will not prevent the component from performing its design function.
5. Please verify that NDE will be performed after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from the time the welded component has achieved ambient temperature per Code Case -638-1.
6. On page 3 of your submittal, Figure 1: Generic Pressurizer Nozzle Configuration, provides a bounding representation of the configurations which you are going to be depositing a full structural overlay. Please discuss if the NDE requirement under 4.0(b)

Enclosure

of -638-1, ultrasonic examination of the 1.5T band on either side of the overlay, will be achieved. If this area requirement cannot be met, please discuss the achievable amount of area that will be successfully examined for each preemptive weld overlay weld design configuration you wish to apply. Secondly, clarify whether the ultrasonic test examination will be performed on the maximum extent achievable.

7. On page 9 of your submittal, you request that Code Case -416-2 be used as an alternative to the hydrostatic testing requirement under Code Case -504-2. Is Code Case -416-2 listed in your current Inservice Inspection Program Plan?

Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Gary R. Leidich James H. Lash President and Chief Nuclear Officer Site Vice President FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-SEB1 Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Joseph J. Hagan Senior Vice President of Operations Lew W. Myers and Chief Operating Officer Executive Vice President, Special Projects FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-SGRP Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Danny L. Pace Senior Vice President, Fleet Engineering Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-A Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Jeannie M. Rinckel Vice President, Fleet Oversight Commissioner James R. Lewis FirstEnergy Nuclear Operating Company West Virginia Division of Labor Mail Stop A-GO-14 749-B, Building No. 6 76 South Main Street Capitol Complex Akron, OH 44308 Charleston, WV 25305 David W. Jenkins, Attorney Director, Utilities Department FirstEnergy Corporation Public Utilities Commission Mail Stop A-GO-18 180 East Broad Street 76 South Main Street Columbus, OH 43266-0573 Akron, OH 44308 Director, Pennsylvania Emergency Manager, Fleet Licensing Management Agency FirstEnergy Nuclear Operating Company 2605 Interstate Dr.

Mail Stop A-GHE-107 Harrisburg, PA 17110-9364 395 Ghent Road Akron, OH 44333 Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077