ML102740027

Request for Additional Information Regarding Revised Steam Generator Tube Inspection, F* Methodology License Amendment Request

ML102740027
Person / Time
Site:	Beaver Valley
Issue date:	10/01/2010
From:	Nadiyah Morgan Plant Licensing Branch 1
To:	Harden P FirstEnergy Nuclear Operating Co
References
TAC ME3498
Download: ML102740027 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 1, 2010 Mr. Paul A. Harden 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 REGARDING THE REVISED STEAM GENERATOR INSPECTION SCOPE USING F* METHODOLOGY LICENSE AMENDMENT REQUEST (TAC NO. ME3498)

Dear Mr. Harden:

By letter dated February 26, 2010, FirstEnergy Nuclear Operating Company (the licensee) submitted a license amendment request to revise the Technical Specifications by expanding the scope of the steam generator (SG) tubesheet inspections using the F* inspection methodology to the SG cold-leg tubesheet region at Beaver Valley Power Station, Unit NO.2.

The Nuclear Regulatory Commission (NRC) staff is reviewing the submittals and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). The NRC staff is requesting a response to the RAI within 60 days of receipt.

The NRC staff considers that timely responses to RAls help ensure sufficient time is available for NRC staff review and contribute toward the NRC goal of efficient and effective use of staff resources.

P. Harden -2 If you have any questions regarding this issue, please contact me at (301) 415-1016.

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:

RAI cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE F* INSPECTION METHODOLOGY LICENSE AMENDMENT REQUEST 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 February 26, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100630422), FirstEnergy Nuclear Operating Company (the licensee) submitted a license amendment request (LAR) to revise the Technical Specifications by expanding the scope of the steam generator (SG) tubesheet inspections using the F*

inspection methodology to the SG cold-leg tubesheet region at Beaver Valley Power Station, Unit NO.2 (BVPS-2). In order to complete the review, the Nuclear Regulatory Commission (NRC) staff needs the following additional information:

1. The paragraph at the bottom of page 7, of the Enclosure to the February 26, 2010, letter, seems to indicate that BVPS-2 had outages during the spring and fall of 2009 (i.e., 2R09

[spring 2009] and 2R14 [fall 2009]). Clarify the outage history listed in this paragraph.

2. The discussion on page 3 seems to indicate that a temperature differential (~T) of 471 degrees Fahrenheit (OF) was used with a differential pressure of 2650 pounds per square inch (psi) to calculate the F* value under faulted conditions. Section 2.1.5 of WCAP-16385 NP (ADAMS Accession No. ML051040084) indicates that a ~T of 460 OF (530 - 70) was used for calculating the F* value under faulted conditions. Confirm the ~ T used in the analysis for faulted conditions. In addition, confirm that the analysis is consistent with your design and licensing basis steam line break accident.

3. The licensee stated on page 6 that the BVPS-2 Technical Specification (TS) Section 5.5.5.2.d.5 requires 100 percent full-length inspection of each SG tube using a bobbin probe. The NRC staff notes that TS 5.5.5.2.d. does not specify which type of probe is to be used, but rather, indicates that the inspection shall be performed with the objective of detecting flaws that may satisfy the applicable tube repair criteria. Clarify the intent of your original statement. In addition, confirm that tubes at BVPS-2 are being inspected with probes capable of detecting flaws that may satisfy the applicable tube repair criteria.

Enclosure

-2

4. In Attachment 1 of the February 26, 2010, letter, TS 5.5.5.2.d.6 proposed adding a requirement for a 20 % minimum sample of the cold-leg tubes when the F* alternate repair criterion (ARC) are implemented on the cold-leg side of the tubesheet. The current TSs are largely performance-based and generally do not specify a sample size, except for ARC where the potential for cracking is known to exist and a 100 percent sample is specified (i.e.,

TS 5.5.5.2.d.5). In addition, it is not clear as to what the first sentence of TS 5.5.5.2.d.6 is implying. Since the inspection of the cold-leg tubesheets are already covered by other portions of your TSs, discuss your plans to delete this proposed paragraph.

5. Plants implementing other alternate repair criteria, such as H*, have committed to monitoring for slippage during each inspection of the SGs. Discuss your plans to commit to monitoring for tube slippage as part of the SG tube inspection program.

6. Recent changes to SG finite element models have resulted in other ARC analyses (i.e., H*)

showing a loss of contact pressure at the top of the tubesheet for up to as much as 4 inches in other SG designs. Discuss whether the information from the H* program (e.g., changes to coefficients of thermal expansion, probabilistic analyses, revised finite element models, non destructive examination uncertainty) would challenge the adequacy of the proposed inspection distance in the current LAR.

7. BVPS-2 is authorized to repair tubes by sleeving. Since some of the sleeve joints may be installed near the tube end, such that 3 inches of tubing is not present below the lower end of the lower sleeve joint, discuss your plans to modify your proposed TSs to not allow F* to be applied in tubing sleeved in this manner.

P. Harden -2 If you have any questions regarding this issue, please contact me at (301) 415-1016.

Sincerely, Ira!

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:

RAI cc w/encl: Distribution via Listserv DISTRIBUTION:

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• See email dated October 1, 2010

• • See memo d ae t d Septem t ber 1, 2010 OFFICE DORLILPLI-1/PM DORLILPLI-1/LA DCIICSGB/BC DORLILPLI-1/BC NAME NMorgan SUttle RTaylor NSalgado DATE 10/1/2010 10/1/2010* 9/112010** 1011/2010 OFFICIAL RECORD COpy