ML082550315
| ML082550315 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/15/2008 |
| From: | Mark Kowal Plant Licensing Branch 1 |
| To: | Sena P FirstEnergy Nuclear Operating Co |
| Morgan N, NRR/DORL, 415-1016 | |
| References | |
| TAC MD7795, TAC MD7796 | |
| Download: ML082550315 (8) | |
Text
September 15, 2008 Mr. Peter P. Sena III 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 NOS. 1 AND 2 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7795 AND MD7796)
Dear Mr. Sena:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System Accession No. ML072910759). GL 2008-01 requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems comply with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations, GL 2008-01 required that each licensee submit the requested information within 9 months of the date of GL 2008-01. GL 2008-01 also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months of the date of GL 2008-01, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By "L-08-131, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated April 11, 2008]], FirstEnergy Nuclear Operating Company (FENOC, licensee) submitted a 3-month response to GL 2008-01 for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). The NRC staffs assessment of the response is contained in the enclosure.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for BVPS-1 and 2, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action, if implementation is consistent with the clarifications and associated requests discussed in the enclosure.
P. Sena If you have any questions regarding this letter, please feel free to contact Nadiyah S. Morgan at (301) 415-1016.
Sincerely,
/RA/
Mark Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
As stated cc w/encl: See next page
P. Sena If you have any questions regarding this letter, please feel free to contact Nadiyah S. Morgan at (301) 415-1016.
Sincerely,
/RA/
Mark Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
As stated cc w/encl: See next page Distribution:
PUBLIC RidsOgcRp LPLI-1 R/F RidsAcrsAcnw&mMailCenter RidsNrrDorlLplI-1 RidsRgn1MailCenter RidsNrrLASLittle DBeaulieu, DPR/PGCB RidsNrrPMNMorgan SSun, DSS/SRXB RidsNrrDorlDPR WLyon, DSS/SRXB ADAMS Accession Number: ML NRR-106 OFFICE LPLI-1/PM LPLI-1/LA PGCB:BC DSS/DD LPLI-1/BC NAME NMorgan SLittle MMurphy JWermeil MKowal DATE 09/15/08 09/11/08 09/15/08 09/15/08 09/15/08 OFFICIAL RECORD COPY
Beaver Valley Power Station, Unit Nos. 1 and 2 cc:
Joseph J. Hagan President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-15 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, Ohio 44308 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-A P.O. Box 4, Route 168 Shippingport, PA 15077 Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305 Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.
Harrisburg, PA 17110-9364
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 Ms. Carol OClaire Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin-Granville Road Columbus, OH 43235-2206 Mr. Dan Hill Chief, Radiological Health Program West Virginia Department of Health and Human Resources Capitol & Washington Streets 1 Davis Square Suite 200 Charleston, WV 25305-0360
Enclosure NUCLEAR REGULATORY COMMISSION STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412 1.0
Background
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System Accession No. ML072910759). GL 2008-01 requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL, (2) a description of all corrective actions that the licensee determined were necessary, and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations, GL 2008-01 required that each licensee submit the requested information within 9 months of the date of GL 2008-01. GL 2008-01 also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months of the date of GL 2008-01, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
2.0 Licensees Proposed Alternative Course of Action By "L-08-131, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated April 11, 2008]], FirstEnergy Nuclear Operating Company (licensee) submitted a 3-month response to GL 2008-01 for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). The licensee stated that the only GL 2008-01 reporting requirement that will not be completed by the required response time is in-field verification of some segments of piping within the GL subject systems. The verification cannot be completed because portions of the GL systems are inaccessible during power operation for the following reasons: (1) radiological dose due to entry into high radiation areas; (2) need to erect scaffolding (dose or adjacent equipment operability concerns); (3) prolonged containment entries during power operation; or (4) the need for removal of insulation from piping.
For BVPS-1, the licensee indicated that it plans to complete verifications of the accessible piping prior to the 9 month response. Any piping segments that require in-field verification, but have not received it prior to the 9-month GL response, will be in-field verified no later than restart from the next refueling outage that is planned for the spring of 2009.
For BVPS-2, the licensee stated that necessary in-field verifications on both the suction side piping and the discharge side piping would be completed during the April 2008 refueling outage except where issues such as those discussed in the first paragraph of Section 2.0 of this assessment prevent completion. Any piping segments that require in-field verification, but have not received it prior to the 9-month GL response, will be in-field verified no later than restart from the next refueling outage that is planned for the fall of 2009. The licensee provided the following commitments for completion of its GL response:
For BVPS-1: Any piping segments that require in-field verification, but have not received it prior to the 9-month GL response, will be in-field verified no later than restart from the next refueling outage that is planned for the spring of 2009.
For BVPS-2: Any piping segments that require in-field verification, but have not received it prior to the 9-month GL response, will be in-field verified no later than restart from the next refueling outage that is planned for the fall of 2009.
NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable at BVPS-1 and 2.
The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not explicitly state that its walkdowns and evaluations of accessible piping within the GL scope will be included in the response to be submitted by October 13, 2008.
Although the licensee committed to completing in-field piping verifications by no later than restart from the next refueling outage for BVPS-1 in the spring of 2009 and for BVPS-2 in the fall of 2009, it is not clear if that is the date the information will be submitted to the NRC.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the BVPS-1 and 2 refueling outages planned for the spring 2009 and fall 2009, respectively, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC no later than restart from the next refueling outages at BVPS-1 and 2, that are planned for the spring 2009 and fall 2009, respectively.
For each of the 2 submittals (9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide the following: (1) a description of the results of evaluations that were performed in response to the GL, (2) a description of all corrective actions that the licensee determined were necessary, and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suction piping, as well as, whether analysis development is needed to assess gas transport in the subject system piping as a function of system flow. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.