L-08-376, Supplemental Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 32
| ML083590223 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/19/2008 |
| From: | Sena P FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-08-376, TAC MD3593, TAC MD3594 | |
| Download: ML083590223 (8) | |
Text
BFENOC eaver Valley Power Station FENOCP.O.
Box 4
~Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Peter P. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 December 19, 2008 L-08-376 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 I
BV-2 Docket No.,,50-412, License No. NPF-73 Supplemental Information for the Review of the ýBeaver Valley Power Station Units 1 and 2'License Renewal.Application (TAC Nos. MD659'3.: and MD6594) and License Renewal Application Amendment No. 32 The Reference provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS). The attached supplemental information related to LRA Section 3.1.2.2 provides additional detail. In addition, a typographical error in Table A.5-1 of the LRA is corrected. This letter provides the supplemental information and Amendment No. 32 to the LRA.
The Attachment provides the supplemental information. The Enclosure provides Amendment No. 32 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 December I?
, 2008.
Sit rely Peter P. Sena III C)8n
Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-376 Page 2
References:
FENOC Letter L-07-113, "License Renewal Application," August 27, 2007.
Attachment:
Supplemental Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Section 3.1.2.2
Enclosures:
Amendment No. 32 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-08-376 Supplemental Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Section 3.1.2.2 Page 1 of 2 Section 3.1.2.2.2.4 FENOC is providing clarification on how the additional inspection procedures for the BVPS Unit 2 steam generator shell-to-transition cone welds address the NRC's ultrasonic testing, non-destructive evaluation recommendations in NRC Information Notice (IN) 90-04.
CLARIFICATION 3.1.2.2.2.4 Augmented examinations of the Unit 2 steam generator upper shell to transition girth welds were performed using ultrasonic testing (UT) methods in response to NRC IN 90-04, with no degradation identified. In order to distinguish innocuous reflectors from cracks, qualified NDE level II or III inspectors used 0 degree straight beam and 45 and 60 degree shear wave angles, at gain settings ranging from a minimum of +6 dB to as much as +20 dB above a reference level established using side-drilled holes in the calibration block. The steam generators at BVPS Unit 2 are the original generators installed intact, with factory welds at the upper shell to transition cone. The physical configuration of the welds (ground flush both inside and outside) was such that there were no surface ripples or other geometric features associated with the welds that would produce UT reflectors.
Section 3.1.2.2.14 FENOC did not clarify in LRA Section 3.1.2.2.14 whether loss of material due to flow-accelerated corrosion (FAC) is anticipated to occur in the steam generator (SG) feedrings or supports, or if it is, whether the progression of FAC in the components would only occur at an extremely slow growth rate. FENOC is providing additional justification for crediting the One-Time Inspection Program as the aging management basis in lieu of proposing to use a periodic condition monitoring program for aging management of loss of material due to FAC.
CLARIFICATION 3.1.2.2.14 Erosion/corrosion or Flow-Accelerated Corrosion (FAC) is not expected to occur in the Beaver Valley Power Station (BVPS) Unit 1 or BVPS Unit 2 steam generator feedwater
Attachment L-08-376 Page 2 of 2 rings, based on previous inspections. FENOC assigned the One-time Inspection program to confirm that degradation is not occurring.
Loss of material of the feedwater rings is represented by three rows in LRA Table.
3.1.2-3 (rows 178, 179, and 180), with three aging management programs (AMPs) assigned.
" The Steam Generator Tube Integrity program manages loss of material due to general, pitting, and crevice corrosion. Table 3.1.2-3, row number 179 is aligned to NUREG-1801 (GALL) row IV.D1-9 (RP-16).
" The Water Chemistry program is credited with mitigating the effects of aging through controlling feedwater chemistry. Table 3.1.2-3, row number 180, is also aligned to GALL row IV.D1-9 (RP-16).
- The One-Time Inspection program verifies that loss of material due to FAC is not occurring. Table 3.1.2-3, row number 178 is aligned to GALL row IV.D1-26 (R-51).
GALL row IV.D1-26 (R-51) specifies a plant-specific AMP for aging management and references NRC Information Notice (IN) 91-19, "'Steam Generator Feedwater Distribution Piping Damage." IN 91-19 identified a potential concern resulting from degradation of feedwater distribution piping due to thermal stress, cracking, erosion and corrosion.
In response to IN 91-19, results of inspections of the BVPS Unit 1 feedwater rings in all three steam generators (conducted during the Unit 1 eighth refueling outage) were reviewed. The results were:
" No damage to the feedwater rings or supports were noted.
Feedwater ring wall thickness readings had been taken in a prior outage. FAC effects in the feedwater ring itself were negligible.
" BVPS Unit 2 feedwater ring inspections were deemed to be unnecessary at the time because of the similarity of design between the Units.
Based on these findings, FAC is not expected to occur in the BVPS feedwater rings.
However, to confirm the absence of aging effects, FENOC assigned the One-Time Inspection program to the feedwater rings in the BVPS LRA.
See the Enclosure to this letter for the revision to the BVPS LRA.
ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-376 Amendment No. 32 to the BVPS License Renewal Atplication Page 1 of 4 License Renewal Application Sections Affected Section 3.1.2.2.2.4 Section 3.1.2.2.14 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-08-376 Page 2 of 4 Affected Paragraph Affected LRA Section LRA Page No.
and Sentence Section 3.1.2.2.2.4 Page 3.1-7 3 rd Paragraph (on page 3.1-8)
FirstEnergy Nuclear Operating Company (FENOC) is providing additional clarification on how the additional inspection procedures for the BVPS Unit 2 steam generator shell-to-transition cone welds address the NRC's ultrasonic testing, non-destructive evaluation recommendations in NRC Information Notice (IN) 90-04. The third paragraph of Section 3.1.2.2.2.4 is revised to read:
The replacement steam generators in use at BVPS for Unit I are Model 54F generators; Unit 2 has Model 51 generators. Addietnal inspe.tion req..rements have been incorporated into the ASM4E SectionX XI nse '
.'i Inpton Subsections IW9, iWQ, and W'D Program (Section B.2.2) to detecGt general and pitting cGorrsion and the resulting co~fS~oiOn fatigue c-racking in the Unit 2 Mode!
51 steam generators. Augmented examinations of the Unit 2 steam generator upper shell to transition girth welds were performed using ultrasonic testing (UT) methods in response to NRC IN 90-04, with no degradation identified. In order to distinquish innocuous reflectors from cracks, gualified NDE level II or Ill inspectors used 0 degree straight beam and 45 and 60 degree shear wave angles, at gain settings ranging from a minimum of +6 dB to as much as +20 dB above a reference level established usinq side-drilled holes in the calibration block. The steam generators at BVPS Unit 2 are the original generators installed intact, with factory welds at the upper shell to transition cone. The physical confiquration of the welds (ground flush both inside and outside) was such that there were no surface ripples or other geometric features associated with the welds that would Droduce UT reflectors.
Enclosure L-08-376 Page 3 of 4 Affected Paragraph Affected LRA Section LRA Page No.
and Sentence Section 3.1.2.2.14 Page 3.1-12 2nd Paragraph (top of page 3.1-13)
FENOC is providing additional justification for crediting the One-Time Inspection Program as the aging management basis in lieu of proposing to use a periodic condition monitoring program for aging management of loss of material due to flow-accelerated corrosion (FAG). The second paragraph of Section 3.1.2.2.14 is revised to read:
BVPS uses the One Time inspection Program (Section B. 2.30) to manage los-s of mate"ia due to flow aGoclerated corrosion of the steam4 generator fgediodate, rings In response to IN 91-19, results of inspections of the BVPS Unitr I feedwater rings in all three steam generators (conducted durinq the Unit 1 eighth refueling outage) were reviewed. The results were:
- No damage to the feedwater rinqs or supports were noted.
- Feedwater rinq wall thickness readings had been taken in a prior outage.
FAC effects in the feedwater ring itself were negligible.
" BVPS Unit 2 feedwater rinq inspections were deemed to be unnecessary at the time because of the similarity of design between the Units.
Based on these findings, flow-accelerated corrosion is not expected to occur in the BVPS feedwater rings. However, to confirm the absence of aging effects, FENOC assigned the One-Time Inspection program to the feedwater rings in the BVPS LRA.
Enclosure L-08-376 Page 4 of 4 Affected Paragraph and Sentence Affected LRA Section LRA Page No.
Page A.5-9 Table A.5-1 Commitment No. 27 (as amended by FENOC Letters L-08-209 and L-08-212)
The original Commitment No. 27 in Table A.5-1 of the BVPS LRA was deleted in FENOC Letter L-08-209. A new Commitment No. 27 was added in FENOC Letter L-08-212. During a recent review a typographical error was discovered by FENOC in Commitment No. 27. Table A.5-1, Commitment No. 27 is amended to read as follows:
Related LRA Item Commitment Implementation Source Section No./
No.
ComtetSchedule Cmet Comments 27 With the exception of underground May 27, 2027 FENOC None GeoFlex fuel oil piping, prior to the period Letter of extended operation, FENOC will L-08-212 perform repetitive maintenance tasks to and replace, or to test and replace on condition, mechanical system elastomei FENOC polymer components that would otherwise Letter be subject to aging management review.
L-08-376 Subsequent frequencies of the repetitive tests/replacements will be based on manufacturer recommendations and applicable operating experience.