ML070780503

Confirmatory Action Letter-Beaver Valley Station, Unit 1

ML070780503
Person / Time
Site:	Beaver Valley
Issue date:	03/20/2007
From:	Dyer J E Office of Nuclear Reactor Regulation
To:	Lash J H FirstEnergy Nuclear Operating Co
Morgan N, NRR/DORL, 415-3650
References
TAC MD4132, NRR-07-011
Download: ML070780503 (6)

Text

March 20, 2007 CAL No. NRR-07-011Mr. James H. LashSite 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:

CONFIRMATORY ACTION LETTER - BEAVER VALLEY POWER STATION,UNIT NO. 1 (TAC NO. MD4132)

Dear Mr. Lash:

This letter confirms commitments by FirstEnergy Nuclear Operating Company (FENOC)regarding Alloy 82/182 butt welds in the pressurizer at Beaver Valley Power Station (BVPS),

Unit 1.

The discovery, in October 2006, of five circumferential indications in three dissimilar metal (DM)welds on the pressurizer at the Wolf Creek Generating Station (Wolf Creek) raised safetyconcerns based on the size and location of the indications. At Wolf Creek, three indicationswere in the pressurizer surge nozzle-to-safe end weld, and two separate indications were in thesafety and relief nozzle-to-safe end welds. These findings also indicated that significantconcerns might exist with the inspection schedules for addressing the pressurizer weldconcerns issued by the industry-sponsored Materials Reliability Program (MRP), in "PrimarySystem Piping Butt Weld Inspection and Evaluation Guideline (MRP-139)."The Nuclear Regulatory Commission (NRC) is concerned about the pressurizer surge nozzle-to-safe end weld indications, as this is the first time that multiple circumferential primarywater stress-corrosion cracking (PWSCC) indications have been identified in a weld. Thiscondition calls into question the degree of safety margin present in past structural integrityevaluations for flawed DM welds susceptible to PWSCC, since multiple stress-corrosioncracking flaws may grow independently and ultimately grow together, significantly reducing thetime from flaw initiation to leakage or rupture. The size of the relief nozzle-to-safe end flaw isalso of concern, as this flaw has a much larger aspect ratio than those assumed in theestimates used to establish the basis for completing the baseline inspections required by theindustry-sponsored MRP. Larger aspect ratios could result in achieving a critical flaw size andrupture before the onset of detectable leakage. The long-term resolution of this issue is expected to involve changes to the American Society ofMechanical Engineers Boiler and Pressure Vessel Code (ASME Code), and will involvechanges to the NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR),Part 50, Section 50.55a, "Codes and standards." The development of the NRC regulations,whether the rule adopts the ASME Code standards or defines separate requirements, will likely J. Lash benefit from additional operating experience, continuing assessments, and analysis beingconducted by the NRC and the MRP. Until NRC regulations are revised, it is necessary to establish a minimum set of enhancedreactor coolant system (RCS) DM butt weld inspection expectations for nickel-basedAlloy 82/182 pressurizer surge, spray, safety, and relief nozzle butt welds, including safe endwelds, to supplement existing inspection and other requirements of the ASME Code and NRCregulations. In addition, enhanced monitoring of RCS leakage is needed to promptly identifyany through-wall flaws in the pressurizer surge, spray, safety, or relief nozzle DM butt welds orsafe end DM butt welds to prevent additional degradation from occurring. The above actionsprovide reasonable assurance that there is no undue risk to the health and safety of the publicwhile the NRC regulations are revised. The NRC communicated the need for near-term enhancements to the industry through publicmeetings held on November 30, 2006, December 20, 2006, and February 2, 2007. Licenseessubmitted letters voluntarily committing to the enhanced inspection and leakage monitoringrequirements. After teleconferences with specific licensees held between February 12 throughFebruary 23, 2007, the licensees submitted supplemental commitment letters addressing theNRC staff's concerns regarding inspection, compensatory actions, and reporting.In your letter dated February 23, 2007, (Agencywide Documents Access & ManagementSystem (ADAMS) Accession Number ML070640092) you described actions you will take at BVPS, Unit 1 for the pressurizer dissimilar metal butt welds containing Alloy 82/182 material.

These commitments address: 1) completion schedules for inspection/mitigation of the welds; 2)

RCS leak monitoring frequency, action levels, and actions; 3) reporting requirements, and

4) reinspection frequencies. The NRC staff has reviewed these actions and commitments and agree the actions andcommitments are appropriate to address the potential of PWSCC of the applicable pressurizer dissimilar metal butt welds containing Alloy 82/182 material with clarification on one of the commitments as indicated in bold below regarding RCS leak monitoring and actions.*Once a 72-hour evaluation period "i.e. the period of sustained leakageincrease" is complete, and leak rate is still elevated, place the unit in Mode 3within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and perform bare metalvisual inspections of unmitigated pressurizer spray, safety and relief nozzle butt welds and safe-end butt welds containing Alloy 82/182 material. This clarification was discussed with and agreed upon by your staff during a telephonediscussion on March 19, 2007, between Greg Halnon, FENOC Fleet Regulatory Affairs Directorand Michele Evans, Director-Division of Component Integrity.Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:1)Notify me immediately if your understanding differs from that set forth above; 2)Notify me if for any reason you cannot complete the actions and commitments within the specified schedule and advise me in writing of your modified schedule in advance of the change; and J. Lash 3)Notify me in writing when you have completed the actions and commitments addressed in this Confirmatory Action Letter.Issuance of this Confirmatory Action Letter does not preclude issuance of an Order formalizingthe above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andyour response will be made available electronically for public inspection in the NRC PublicDocument Room or from the NRC's ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should notinclude any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.Sincerely,/RA/J. E. Dyer, Director Office of Nuclear Reactor RegulationDocket No. 50-334License No. DPR-66 cc: See next page

ML070780503OFFICECPNBDCILPL1-1/PMLPL1-1/LALPL1-1/BC (A)TECH EDDIRS/TANAMEKHoffmanESullivanNMorganSLittleDPickettHChangRPascarelliDATE3/20/073/20/073/19/073/19/073/19/07 2/28/073/20/07 OFFICECPNB/BCDRP/D RGN1DORL/DDCI/DAD:DESNRR/D NAMETChanDLewCHaneyMEvansJGrobeJDyer DATE 3/20/073/16/073/20/073/20/073/20/073/20/07 Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Gary R. LeidichPresident and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308Joseph J. HaganSenior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308Danny L. PaceSenior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308Jeannie M. RinckelVice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308David W. Jenkins, AttorneyFirstEnergy Corporation Mail Stop A-GO-18 76 South Main Street Akron, OH 44308Manager, Fleet LicensingFirstEnergy Nuclear Operating Company Mail Stop A-GHE-115 395 Ghent Road Akron, OH 44333Ohio EPA-DERRATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149Director, Fleet Regulatory AffairsFirstEnergy Nuclear Operating Company Mail Stop A-GHE-315 395 Ghent Road Akron, Ohio 44333Manager, Site Regulatory ComplianceFirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-A P.O. Box 4, Route 168 Shippingport, PA 15077Richard AndersonVice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Akron, Ohio 44308Commissioner James R. LewisWest Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305Director, Utilities DepartmentPublic Utilities Commission 180 East Broad Street Columbus, OH 43266-0573Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.

Harrisburg, PA 17110-9364 Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Dr. Judith JohnsrudEnvironmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803DirectorBureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469Mayor of the Borough of ShippingportP.O. Box 3 Shippingport, PA 15077Regional Administrator, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077