ML080601020

RAI for the Review of the Beaver Valley Power Station, Units 1 & 2, LRA

ML080601020
Person / Time
Site:	Beaver Valley
Issue date:	03/05/2008
From:	Kent Howard NRC/NRR/ADRO/DLR
To:	Sena P FirstEnergy Nuclear Operating Co
HOWARD, KENT, NRR/ADRO/RPB2, 415-2989
References
TAC MD6593, TAC MD6594
Download: ML080601020 (10)

Text

March 5, 2008 Mr. Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-BV-SEB-1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MD6593 AND MD6594)

Dear Mr. Sena:

By letter dated August 27, 2007, FirstEnergy Nuclear Operating Company submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Beaver Valley Power Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. Cliff Custer of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2989 or by e-mail at klh1@nrc.gov. Sincerely, /RA/ Kent L. Howard, Sr. Project Manager Reactor Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

As requested cc w/encl: See next page

ML080601020 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME SFigueroa (ESayoc for) KHoward RFranovich DATE 03/03/08 03/05/08 03/05/08

BEAVER VALLEY POWER STATION (BVPS), UNITS 1 AND 2 LICENSE RENEWAL APPLICATION (LRA) REQUEST FOR ADDITIONAL INFORMATION (RAI) SECTION 2.1

Section 2.1 RAI 2.1-1 10 CFR 54.4(a)(1)(iii) requires that plant systems, structure, and component (SSC) within the scope of license renewal (LR) include safety-related SSCs, which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49(b)(1)) to ensure "the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable."

During the scoping and screening methodology audit, performed at the facility December 3-6, 2007, the staff noted the definitions of "safety-related" used to identify SSCs within the scope of LR as contained in the License Renewal Application (LRA). The LR scoping procedures and the text of the plant classification document agree with the definition contained in 10 CFR Part 54.4(a)(1)(iii). However, the form/procedure used to initially populate the equipment data base, and subsequently relied upon to identify safety-related SSCs, refers only to 10 CFR Part 100. Units 1 and 2 have been approved for use of the alternate source term and, therefore, 10 CFR 50.67(b)(2) is applicable. This issue applies to BVPS Units 1 and 2.

The staff requests that the applicant provide a written evaluation that addresses the impact, if any, of (1) the use of a differing definition of "safety-related," and of (2) not having explicitly considered in its scoping methodology for BVPS those structures, systems, or components that are relied upon to ensure "the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines in 10 CFR 50.34(a)(1),10 CFR 50.67(b)(2), or 10 CFR 100.11 of this chapter, as applicable," consistent with the CLB.

RAI 2.1-2 The LRA states that the application was developed in accordance with the guidance of NEI 95-10, Revision 6, which the NRC has endorsed via Regulatory Guide 1.188. NEI 95-10 contains a definition of "equivalent anchor", which includes a combination of restraints or supports such that the nonsafety-related piping and associated structures and components attached to safety-related SSCs are included in scope up to a boundary point that encompasses of at least two supports in each of three orthogonal directions. Equivalent anchors are one method used to define the portion of nonsafety-related pipe, attached to safety-related SSCs, to be included within the scope of LR in accordance with 10 CFR 54.4(a)(2).

During the NRC scoping and screening methodology audit, performed at the facility December 3-6, 2007, the applicant indicated that equivalent anchors had been used to identify portions of nonsafety-related pipe to be included within the scope of LR. However, the applicant indicated that in certain cases, combinations of less than two restraints or supports in each of the three orthogonal directions had been used as equivalent anchors to determine the portions of nonsafety-related pipe, attached to safety-related SSCs, to be included within the scope of LR. This issue applies to BVPS Units 1 and 2.

The staff requests that the applicant provide a written evaluation to address your review of this issue. Indicate if the review concludes that use of the scoping methodology precluded the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your current licensing basis (CLB), and therefore should have been considered within the scope of LR. Describe any additional scoping evaluations to be performed to address the 10 CFR 54.4(a)(2) criteria.

As part of your response, please address the extent of condition (the number and location of equivalent anchors which contained less than two supports in each of the three orthogonal directions). List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.

RAI 2.1-3 The Beaver Valley Power Station (BVPS) LRA states that the limits of the NRC Office of Inspection and Enforcement Bulletin (IEB) 79-14, Seismic Analyses for As-built Safety-Related Piping Systems, evaluations as shown on isometric or other controlled engineering drawings,were used to identify the portions of nonsafety-related piping, attached to safety-related SSCs, to be included within the scope of LR in accordance with the requirements of 10 CFR 54.4(a)(2).

The staff requests that the applicant provide a discussion to specifically address how the information obtained in the walk-downs previously performed in support of IEB 79-14 was used to identify either a seismic anchor or an equivalent anchor, as defined in Appendix F of NEI 95-10, Revision 6, in order to determine the portion of the nonsafety-related pipe to be included within the scope of LR in accordance with 10 CFR 54.4(a)(2). This issue applies to BVPS, Units 1 and 2. The staff requests that the applicant provide a written evaluation to address the review of this issue. Indicate if the review concludes that use of the scoping methodology precluded the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your CLB, and therefore should have been considered within the scope of LR. Describe any additional scoping evaluations to be performed to address the 0 CFR 54.4(a)(2) criteria.

As part of your response, list any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.

RAI 2.1-4 The applicant identified certain components classified as "Q" (a BVPS term used to identify safety-related components) which are located within the nonsafety-related turbine building. However, the identified "Q" components were not included within the scope of LR in accordance with 10 CFR 54.4(a)(1). In addition, neither the turbine building nor the nonsafety-related SSCs in the vicinity of the "Q" components were included within the scope of LR in accordance with 10 CFR 54.4 (a)(1) or (a)(2) as applicable. This issue applies to BVPS, Units 1 and 2.

The staff requests that the applicant provide a written evaluation to address your review of this issue. Indicate if the review concludes that use of the scoping methodology precluded: (1) the identification of safety-related SSCs which should have included within the scope of LR in accordance with 10 CFR 54.4(a)(1), and (2) the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your CLB, and therefore should have been considered within the scope of LR in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations to be performed to address the 10 CFR 54.4(a)(1) and (a)(2) criteria.

As part of your response, list any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.

RAI 2.1-5 (A) A safety-related portion of the Unit 1 river water pipe, which consists of pipe and an elastic expansion joint, was included within the scope of LR in accordance with 10 CFR 54.4(a)(1). This portion of the river water pipe exits from the safety-related main steam cable vault pipe tunnel (included within the scope of LR in accordance with 10 CFR 54.4(a)(1)) and enters the nonsafety-related turbine building. However, neither the turbine building, nor the nonsafety-related SSCs located in the turbine building and in the vicinity of the river water pipe, have been included within the scope of LR in accordance with 10 CFR 54.4(a)(1) or (a)(2) as applicable. In addition, the river water pipe supports located the turbine building, which provide structural support to the safety-related river water pipe, were not included within the scope of LR.

(B) The turbine building is contiguous with the main steam cable vault pipe tunnel with no wall or door providing separation between the interiors of the two structures. The main steam cable vault pipe tunnel is safety-related and contains safety-related SSCs, all of which are included within the scope of LR in accordance with 10 CFR 54.4(a)(1). However, neither the turbine building, nor the nonsafety-related SSCs located in the turbine building and in the vicinity of the opening to the main steam cable vault pipe tunnel, have been included within the scope of LR in accordance with 10 CFR 54.4(a)(2).

(C) The turbine building is adjacent to the safety-related service building which was included within the scope of LR in accordance with 10 CFR 54.4(a)(1). However, the turbine building, although directly adjacent to a safety-related structure, has not been included within the scope

of LR in accordance with 10 CFR 54.4(a)(2). These issues apply to BVPS Units 1. The staff requests that the applicant provide a written evaluation to address your review of these issues.

Indicate if the review concludes that use of the scoping methodology precluded: (1) the identification of safety-related SSCs which should have included within the scope of LR in accordance with 10 CFR 54.4(a)(1), and (2) the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your CLB, and therefore should have been considered within the scope of LR in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations to be performed to address the 10 CFR 54.4(a)(1) and (a)(2) criteria.

As part of your response, list any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.

Letter to P. Sena from K. Howard, dated March 5, 2008 DISTRIBUTION

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MD6593 AND MD6594)

HARD COPY: DLR RF E-MAIL: PUBLIC SSmith (srs3) SDuraiswamy RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDlrRlrc RidsNrrDlrReba RidsNrrDlrRebb RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSbwb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter ------------- KHoward ESayoc PBuckberg NMorgan MModes, RI PCataldo, RI DWerkheiser, RI Beaver Valley Power Station, Units 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

David W. Jenkins, Attorney FirstEnergy Nuclear Operating Company 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 Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB-1 P.O. Box 4, Route 168 Shippingport, PA 15077 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 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 Drive Harrisburg, PA 17110-9364 Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Beaver Valley Power Station, Units 1 and 2 cc: 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 Cliff Custer FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077

Mike Banko FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077

Julie Firestone FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077