ML080790538

RAI for the Review of the Beaver Valley Power Station, Units 1 & 2, LRA

ML080790538
Person / Time
Site:	Beaver Valley
Issue date:	04/01/2008
From:	Kent Howard NRC/NRR/ADRO/DLR
To:	Sena P FirstEnergy Nuclear Operating Co
HOWARD, K
References
TAC MD6593, TAC MD6594
Download: ML080790538 (11)

Text

April 01, 2008 Mr. Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-BV-SEB-1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

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)

Dear Mr. Sena:

By letter dated August 27, 2007, FirstEnergy Nuclear Operating Company submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Beaver Valley Power Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. Cliff Custer of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2989 or by e-mail at klh1@nrc.gov.

Sincerely,

\RA\

Kent L. Howard, Sr., Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: See next page

April 01, 2008 Mr. Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-BV-SEB-1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

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)

Dear Mr. Sena:

By letter dated August 27, 2007, FirstEnergy Nuclear Operating Company submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Beaver Valley Power Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. Cliff Custer of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2989 or by e-mail at klh1@nrc.gov.

Sincerely,

\RA\

Kent L. Howard, Sr., Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Accession No.: ML080790538 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR

NAME IKing KHoward RFranovich DATE 3/31/08 4/01/08 4/01/08 OFFICIAL RECORD COPY REQUEST FOR ADDITIONAL INFORMATION (RAI)

BEAVER VALLEY LICENSE RENEWAL APPLICATION 4.7.1 Piping Subsurface Indications (Unit 1 only)

RAI 4.7.1-1 Section 4.7.1 of the license renewal application (LRA) does not provide information regarding the inspection history and results of the subject weld on the reactor coolant system (RCS) loop C cold leg nor degradation mechanism of the indication. The staff needs this information to complete its evaluation. (a) Discuss the inspection history and results (characterization) of the indication on the RCS loop C cold leg between the elbow and a section of straight pipe since the discovery in 1996. (b) Discuss future inspection frequency of the subject indication. (c) Clarify the exact location of the subject indication, e.g., in the weld that joins the elbow and pipe, on the elbow, or on the pipe. (d) Discuss the degradation mechanism of the indication.

RAI 4.7.1-2 The applicant stated that the subject pipe is made of cast austenitic stainless steel (CASS) piping. However, it is not clear to the staff the material specification of the elbow and subject weld. It is also not clear the indication characterization. (a) Confirm that the elbow is made of CASS also. (b) Discuss the material specification of the weld that joins the elbow and the pipe.

(c) Provide the indication size and characterization. (d) The staff notes that ultrasonic testing of CASS material cannot be performed to meet the requirements of Appendix VIII to the ASME Code,Section XI. Therefore, discuss the reliability and accuracy of the detection and characterization of the subject indication.

RAI 4.7.1-3 In Section 4.7.1, the applicant stated that the fully aged fracture toughness properties of the CASS straight pipe were used in the flaw evaluation. However, the applicant did not state the CASS piping has limiting material properties as compared to the subject weld. Confirm that the fracture toughness properties of the CASS piping are more limiting than the fracture toughness properties of the weld at the end of 60 years.

RAI 4.7.1-4 In Section 4.7.1, third paragraph, the applicant stated that it postulated an initial flaw and considered the flaw growth based on imposed loading transients in the flaw evaluation without providing detailed information. (a) Discuss the initial flaw size assumed. (b) Discuss the flaw growth rate used and associated references. (c) The applicant stated that The cycle assumptions used in the analysis are conservative compared to the BVPS [Beaver Valley

Power Station] original design cycles Clarify whether the operating cycles used in flaw evaluation that was performed in 1996 exceed the projected operational cycles at the end of 60 years.

ENCLOSURE

RAI 4.7.1-5 Section 4.7.1 of the LRA does not contain sufficient information regarding the stress evaluations of the subject flaw for the staff to make a conclusion on the validity of the evaluations. (a)

Besides the indication on the cold leg, identify all Class 1 components that contain indications or flaws that have remained in service at BVPS, Units 1 and 2. (b) Discuss briefly the flaw evaluations (such as procedures and assumptions) performed for the affected components in accordance with the ASME Code,Section XI. (c) Discuss how the indications or flaws were accepted and reference the appropriate ASME Code requirements. (d) Provide indication/flaw characterization. (e) Discuss the analyses performed to accept the degraded components (other than the subject weld) for the extended period of operation.

RAI 4.7.1-6 In Section 4.7.1, the applicant referenced an NRC safety evaluation of the subject indication on the RCS loop C cold leg. However it is unclear to the staff which safety evaluation is being referenced. Confirm that May 1, 1996, is the date of the NRCs safety evaluation. If the date is correct, please provide a copy of the safety evaluation because the staff cannot find the reference (Reference 4.7-1) in the NRC database (ADAMS).

4.7.3 Leak Before Break RAI 4.7.3-1 Nickel-based Alloy 600/82/182 material in the pressurized-water reactor environment has been shown to be susceptible to primary stress corrosion cracking (PWSCC). This is an emerging issue. The applicant did not address this issue in Section 4.7.3 of the LRA. (a) Identify all Alloy 82/182 weld metal and Alloy 600 components used in the piping that have been approved for LBB. (b) If LBB piping contains Alloy 600/82/182 material, discuss any plans to mitigate these components (such as weld overlays or mechanical stress improvement) to reduce their susceptibility to PWSCC. (c) Discuss the inspection history of these components. (d) Discuss future inspection frequency of the Alloy 600/82/182 components and whether the inspection frequency will provide reasonable assurance that PWSCC will be detected early, should it occur in the LBB piping.

RAI 4.7.3-2 In Section 4.7.1, the applicant stated that an indication on the RCS loop C cold leg between the elbow and a section of straight pipe was detected in 1996. The staff needs to clarify the location of this indication to make a proper evaluation. Discuss whether this indication is located on a segment of the pipe that has been approved for LBB. If it is, discuss whether the assumptions in the LBB analyses are still valid in light of the indication. Discuss whether the indication was fabrication or service induced. The NRC-approved LBB approach excludes piping with active degradation mechanism for LBB.

RAI 4.7.3-3 For the pressurizer surge line in Section 4.7.3.2, the applicant stated that a system temperature difference of about 360°F was experienced in the plant during heatup. The staff needs further information on this temperature difference to validate whether the safety margins are still met.

(a) Clarify whether the original LBB analysis has been evaluated with a 360°F temperature difference. (b) Clarify whether the cycle counts in Table 4.3-2 include this temperature transient in the LBB analysis.

RAI 4.7.3-4 In Section 4.7.3.2, the applicant stated that operating procedures have been revised to add precautions and limitations to prevent exceeding a 320°F system temperature difference. The revised LBB analysis for the surge line is based on a temperature difference of 320°F. The LBB analysis would be invalid if the temperature difference is greater than 320°F. Discuss whether the 320°F limitation has been exceeded since the implementation of the limit.

This information is needed for the staff to assess the adequacy of the precautions and limitations implemented by the applicant.

RAI 4.7.3-5 The applicant has an Aging Management Program B.2.41, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS), to manage CASS components. However, Section 4.7.3 of the LRA did not mention this aging management program (AMP) manage the LBB piping that are made of CASS. Discuss whether AMP B.2.41 will be used to monitor the CASS components in the LBB piping systems for thermal aging embrittlement.

RAI 4.7.3-6 By letter dated May 19, 2000, Christopher I. Grimes of the NRC forwarded Douglas J. Walters of Nuclear Energy Institute an evaluation of thermal aging embrittlement of CASS components (ADAMS Accession ML003717179). In the NRCs evaluation, the staff provided its positions on how to manage CASS components. For clarity of record, please discuss whether the CASS components in the LBB piping satisfy the staff positions in its evaluation dated May 19, 2000.

RAI 4.7.3-7 In Sections 4.7.3.1 and 4.7.3.2, the applicant stated that the LBB evaluation for the main coolant loop piping and pressurizer surge line continues to be justified at power uprate operating conditions for both units without providing details. (a) Discuss in detail how the LBB evaluations of these two piping systems are validated for uprate power conditions. (b) Clarify whether the LBB evaluation for the Unit 2 branch lines continues to be valid at power uprate operating conditions. Discuss the technical basis for the conclusion.

4.7.3-8 In Sections 4.7.3.1, 4.7.3.2, and 4.7.3.3, the applicant discussed fatigue crack growth analyses of the main coolant loop piping, surge line, and branch lines without details. Provide the bounding final fatigue crack size for each of the piping system and the corresponding pipe wall thickness. The information will assist the staff with an independent assessment of the structural integrity of the subject piping.

RAI 4.7.3-9 As part of the technical basis for the LBB, the applicant cited Reference 4.7-8, Westinghouse report WCAP-11923, Technical Justification for Elimination Large Primary Loop Pipe Rupture as the Structural Design Basis for Beaver Valley Unit 2 After Reduction of Snubbers, September 1988. The staff needs to verify information in this document for its evaluation. Please provide a copy of Westinghouse report WCAP-11923.

Letter to P. Sena from K. Howard, dated, April 01, 2008 DISTRIBUTION:

SUBJECT:

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)

HARD COPY:

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Beaver Valley Power Station, Units 1 and 2 cc:

Joseph J. Hagan Ohio EPA-DERR President and Chief Nuclear Officer ATTN: Zack A. Clayton FirstEnergy Nuclear Operating Company P.O. Box 1049 Mail Stop A-GO-19 Columbus, OH 43266-0149 76 South Main Street Akron, OH 44308 Peter P. Sena III Site Vice President James H. Lash FirstEnergy Nuclear Operating Company Senior Vice President of Operations Beaver Valley Power Station and Chief Operating Officer Mail Stop A-BV-SEB-1 FirstEnergy Nuclear Operating Company P.O. Box 4, Route 168 Mail Stop A-GO-14 Shippingport, PA 15077 76 South Main Street Akron, OH 44308 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Danny L. Pace Mail Stop A-GO-2 Senior Vice President, Fleet Engineering 76 South Main Street FirstEnergy Nuclear Operating Company Akron, OH 44308 Mail Stop A-GO-14 76 South Main Street Manager, Site Regulatory Compliance Akron, OH 44308 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Jeannie M. Rinckel Mail Stop A-BV-A Vice President, Fleet Oversight P.O. Box 4, Route 168 FirstEnergy Nuclear Operating Company Shippingport, PA 15077 Mail Stop A-GO-14 76 South Main Street Commissioner James R. Lewis Akron, OH 44308 West Virginia Division of Labor 749-B, Building No. 6 David W. Jenkins, Attorney Capitol Complex FirstEnergy Nuclear Operating Company Charleston, WV 25305 Mail Stop A-GO-15 76 South Main Street Director, Utilities Department Akron, OH 44308 Public Utilities Commission 180 East Broad Street Manager, Fleet Licensing Columbus, OH 43266-0573 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Director, Pennsylvania Emergency 76 South Main Street Management Agency Akron, OH 44308 2605 Interstate Drive Harrisburg, PA 17110-9364

Beaver Valley Power Station, Units 1 and 2 cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Julie Firestone Sierra Club FirstEnergy Nuclear Operating Company 433 Orlando Avenue Beaver Valley Power Station State College, PA 16803 P.O. Box 4, Route 168 Shippingport, PA 15077 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 Cliff Custer FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077 Mike Banko FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077