ML090900193

Extension Request Approval Letter Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors,

ML090900193
Person / Time
Site:	Beaver Valley
Issue date:	03/31/2009
From:	Nadiyah Morgan Plant Licensing Branch 1
To:	Sena P FirstEnergy Nuclear Operating Co
morgan n
References
GL-04-002, TAC MC4666
Download: ML090900193 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 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 SUB~IECT: BEAVER VALLEY POWER STATION, UNIT NO.2 - EXTENSION REQUEST APPROVAL LETTER RE: GENERIC LETrER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED WATER REACTORS," (TAC NO. MC4666)

Dear Mr. Sena:

Generic Letter (GL) 2004-02 identified potential susceptibility of pressurized-water reactor recirculation sump screens to debris blockage during design-basis accidents requiring recirculation operation of emergency core cooling systems (ECCS) or containment spray systems (CSS), and on the potential for additional adverse effects due to debris blockage of flowpaths necessary for ECCS and CSS recirculation and containment drainage. The GL requested that all corrective activities be completed no later than December 31, 2007.

By letter dated December 20, 2007, you requested an extension for certain activities associated with your response to GL 2004-02. The Nuclear Regulatory Commission (NRC) staff evaluated the information provided in your letter and concluded that for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2), it was acceptable to extend the due date for completion of corrective actions until February 29, 2008.

By letter dated February 14, 2008, you requested an extension for certain sump blockage corrective actions associated with your response to GL 2004-02. The NRC staff evaluated the information provided in your letter and concluded that for BVPS-1, it was acceptable to extend the due date for completion of corrective actions until September 30, 2008, and for BVPS-2, it was acceptable to extend the due date for completion of corrective actions until March 31, 2009, or 60 days after NRC approval of a combined buffer change and containment overpressure credit license amendment request, whichever was sooner.

P.Sena -2 By letter dated August 28,2008, as supplemented by letter dated October 29,2008, you requested an extension for certain sump blockage corrective actions associated with your response to GL 2004-02. The NRC staff evaluated the information provided in your letters and concluded that for BVPS-1, it is acceptable to extend the due date for completion of GL 2004-02 corrective actions until startup, following the spring 2009 refueling outage, which commences in April 2009. The NRC staff evaluated the information provided in your letters and determined that for BVPS-2, it is acceptable to extend the due date for completion of corrective actions until startup following the fall 2009 refueling outage (2R 14).

Please contact me at 301-415-1016, if you have any questions on this matter.

Sincerely, Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-412

Enclosure:

As stated cc w/encl: Distribution via Listserv

EXTENSION REQUEST APPROVAL RELATED TO GENERIC LETTER 2004-02 CORRECTIVE ACTIONS FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NO.2 DOCKET NO. 50-412 By letter dated August 28, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082480045), as supplemented by letter dated October 29,2008 (ADAMS Accession No. ML083080094), FirstEnergy Nuclear Operating Company (licensee),

requested an extension to the corrective action due date of September 30, 2008, stated in Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2004-02, "Potentiallrnpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," (GL 2004-02), for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS 1 and 2). The stated intent of this extension was to allow additional time for completion of testing to be performed in order to identify the type and quantity of insulation required to be modified at BVPS- 2, and to finalize documentation for the supplemental response (including test reports and accompanying analyses) to GL 2004-02. The licensee requested an extension until startup following the fall 2009 refueling outage (RFO), which commences in October 2009, for BVPS-2.

The NRC staff has based its review of extension requests for the due date for completion of GL 2004-02 corrective actions on criteria stated in SECY-06-0078. Specifically, an extension may be granted if:

• the licensee has a plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties, and

• the licensee identifies mitigative measures to be put in place prior to December 31,2007, and adequately describes how these mitigative measures will minimize the risk of degraded emergency core cooling system (ECCS) and containment spray system (CSS) functions during the extension period, and

• for proposed extensions beyond several months, a licensee's request will more likely be accepted if the proposed mitigative measures include temporary physical improvements to the ECCS sump or materials inside containment to better ensure a high level of ECCS sump performance.

Enclosure

-2 With regard to the first extension criterion, the licensee has provided a plant-specific technical/experimental plan, with milestones and schedules, to complete the GL 2004-02 corrective actions, as described in their letters dated August 28 and October 29, 2008.

The licensee retested for debris and chemical effects in the fall of 2008, using the predicted precipitant loading in accordance with WCAP-16793 and a protocol that introduced debris in accordance with the March 28, 2008 NRC Reviewers Guide. The planned testing was performed such that post-accident containment pressure was credited in defining an acceptable debris loading. Other planned activities included updating evaluations, analysis, and documentation to reflect the new test results once testing is completed.

A follow-up supplemental response to GL 2004-02 including the results of BVPS-2 debris and chemical effects testing, results of downstream effects analyses (both in-vessel and ex-vessel),

and details of corrective actions will be submitted to the NRC by April 30, 2009. This regulatory commitment is established in lieu of the BVPS-2 regulatory commitment identified in the licensee's letter dated February 14, 2008 (ADAMS Accession No. ML080510246).

With regard to the second extension criterion, the NRC staff considers that, based on the information provided in the licensee's letter dated August 28, 2008, the modifications, mitigation measures, and compensatory measures in effect at BVPS-2, minimize the risk of degraded ECCS and CSS functions during the extension period and the NRC staff has not identified any issues with the BVPS-2 corrective action plan.

With regard to the third extension criterion, the significant modifications discussed in the licensee's August 28, 2008, letter; in particular, the installation of large replacement strainers at BVPS-1 and 2, satisfies this extension criterion. Additionally, the licensee's letter dated August 28,2008, provides plant risk evaluations for BVPS-1 and 2. The NRC staff has not reviewed the analysis in detail, but agrees with the licensee's conclusion that the impact on risk for the requested extension period for actions to address chemical effects beyond the December 31, 2007, implementation date specified in GL 2004-02 is low based on the mitigative measures identified in this document.

The NRC staff has not identified any issues with the BVPS-2 corrective action plan and expects the licensee to follow the outlined planned for BVPS-2 as described in their August 28, 2008, letter. The BVPS-2 retesting should identify the type and quantity of insulation required to be modified. Additional required corrective actions resulting from the BVPS-2 retesting, including insulation modifications will be implemented prior to startup following the fall 2009 refueling outage (2R14).

The NRC believes that the licensee has a reasonable plan for BVPS-2 that should result in the installation of final GL 2004-02 corrective actions that provide acceptable strainer function with adequate margin for uncertainties. Furthermore, the NRC staff has concluded that the licensee has put mitigation measures in place at BVPS-2 to adequately reduce risk for the approved extension period discussed below.

Based on the licensee having satisfactorily addressed the NRC GL 2004-02 due date extension criteria as discussed above, the NRC staff finds it is acceptable to extend the completion date for corrective actions resulting from the BVPS-2 retesting, including insulation modifications,

-3 until startup following the fall 2009 RFO. In addition, a follow-up supplemental response to GL 2004-02 including the results of BVPS-2 debris and chemical effects testing (that includes credit for post-accident containment pressure), results of downstream effects analyses (both in-vessel and ex-vessel), the effects on NPSH margins, and details of corrective actions, will be submitted to the NRC by April 30, 2009.

ML090900193 *See memo dated March 30, 2009

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