ML093140250

NUREG-1929 V1 & V2 Supp 1, Safety Evaluation Report Related to the License Renewal of Beaver Valley Power Station, Units 1 & 2.

ML093140250
Person / Time
Site:	Beaver Valley
Issue date:	10/31/2009
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-1929, Vol. 1, Suppl 1, NUREG-1929, Vol. 2, Suppl 1
Download: ML093140250 (48)

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~U.S.NRC

• U.S.NRC United States United States Nuclear.

NuclearRegulatory Regulatory Commission Commission Vois. 11and NUREG-1929, Vols.

NUREG-1929, Supplement and 22 Supplement 11 ProtectingPeople Protecting People and andthe theEnvironment Environment Safety Evaluation Safety Evaluation Report Report Related to the License Related License Renewal Renewal of of Beaver Valley Power Station, Beaver Units 1 and 2 Docket Nos. 50-334 and 50-412 50-412 FirstEnergy Nuclear Operating Company Office of Office of Nuclear Nuclear Reactor Reactor Regulation Regulation

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~U.S.NRC

• U.S.NRC United States Commission States Nuclear Regulatory Commission NUREG-1929, Vols. 1 and 2 NUREG-1929, Supplement 1 Supplement Protecting Protecting People People and the Environment Safety EvaluationEvaluation Report Related to the License Renewal Renewal of Beaver Valley Beaver Power Station, Units 1 and 2 Docket Nos. 50-334 and 50-412 50-412 FirstEnergy Nuclear FirstEnergy Nuclear Operating Operating Company Company Manuscript Manuscript Completed: October 2009 Date Published: October October 2009 Office Office of Nuclear Nuclear Reactor Regulation Regulation

ABSTRACT ABSTRACT This document is a supplemental supplemental safety evaluation evaluation report (SSER) for the technical technical review of the the Beaver Valley Power Station (BVPS), Units 1 and 2, license renewal application application (LRA) as filed Nuclear Operating by FirstEnergy Nuclear Operating Company (FENOC or the applicant).

applicant). By letter dated August 27,2007, 27, 2007, FENOC application to the United States FENOC submitted its application Nuclear Regulatory States (US) Nuclear Commission (NRC) for renewal of the BVPS, Units 1 and 2, operating licenses licenses (Facility Operating License Operating License Numbers DPR-66 and NPF-73, respectively) for a period of 20 years beyond the current operating operating license. The NRC staff issued a safety evaluation evaluation report (SER), dated June 8, 2009, which summarizes summarizes the results of its safety review of the renewal application for renewal application compliance compliance with the requirements requirements of Title 10, Part 54, of the Code of Federal FederalRegulations, Regulations, (10 (10 CFR Part 54), "Requirements for Renewal of Operating Operating Licenses for Nuclear Power Plants."

This SSER only provides changes to the June 2009 SER. -

provides changes This SSER documents documents the NRCNRC staffs evaluation evaluation of information information provided by the applicant applicant on supplemental supplemental volumetric examinations examinations of the BVPS, Units 1 and 2 containment containment liners. The The applicant provided additional information regarding examinations of the Units 1 and 2 regarding examinations containment liners as a result of discussion discussion during the Advisory Committee Committee of Reactor Safeguards meeting Safeguards meeting held in July 2009 and by letters letters dated July 28, 2009, September September 2, 2009, September 4, 2009, September 8,2009, 4,2009, 8, 2009, and September 14, 2009.

iii III

TABLE OF CONTENTS CONTENTS A bs tra c t ...............................................................................

Abstract ....... ............................... .........................  ; ........................................................... iii ii Abbreviations Abbreviations .................................................................

........................................... ..................................................................................... vii 1 Introduction and G eneral Discussion General Discussion .............................................................................

........................... ...................................................... 1-1

........ 1-1 2 Structures Systems System s and Components Com ponents ............... ........................................................................

.......................................................................... 2-1 3 Aging Management Management Results .............................................

.................................................................................................... 3-1 3.0.3 Aging Management Management Programs ..................................................

............................................................................... 3-1 3-1 3.0.3.2 3.0.3.2 AMPs Consistent Consistent with the GALL Report with Exceptions or Enhancements Enhancements ....... ....... 3-1 Tim e Limited 4 Time Lim ited Aging Ag ing A nalysis ....................................................................................................

Analysis ............................................................................. ........... .... 4-1 4-1 Review by the Advisory Committee 5 Review Committee on Reactor Safeguards .................................... 5-1 Safeguards ..................................................

6 C o n c lu s io n ................................................................................................................

Conclusion ............. ........-.........................................

- 6- 1

............... 6-1

....................................

Appendices Appendices Appendix Appendix A: CommitmentsCommitments for License Renewal. Renewal ...............................

....................................................... A-1 A-1 A ppendix B:

Appendix B: C hronology ....................................

Chronology ..........................................................................................

......................................................... B -1 B-1 vV

ABBREVIATIONS ABBREVIATIONS ACRS Advisory Advisory Committee on Reactor Safeguards Safeguards AMP management program aging management program ASME Society of Mechanical American SOciety Mechanical Engineers Engineers BVPS Beaver Valley Power Station Station CFR Code of Federal Regulations Regulations FENOC FirstEnergy Nuclear Operating Company LRA renewal application license renewal NRC Regulatory Commission Nuclear Regulatory Commission RAI RAJ request for additional information additional information SC structures and components components SER safety evaluation report SSER supplemental safety evaluation report supplemental US US States United States UFSAR UFSAR updated final safety updated safety analysis report vii

SECTION 1 INTRODUCTION AND INTRODUCTION AND GENERAL GENERAL DISCUSSIONDISCUSSION Introduction 1.1 Introduction This document is a supplemental supplemental safety evaluation evaluation report (SSER) on the license license renewal application (LRA) application (LRA) for Beaver Valley Power Station (BVPS), Units 1 and 2, as filed by FirstEnergy Nuclear Operating Nuclear Operating Company (FENOC or the applicant).

applicant). By letter dated August 27, 2007, 27,2007, FENOC submitted its application FENOC application to the U.S. Nuclear Nuclear Regulatory Regulatory Commission (NRC) for renewal of the BVPS operating operating licenses for an additional 20 years. The NRC staff (the staff) issued a safety evaluation evaluation report (SER), dated June 8, 2009, which summarizes summarizes the results of its safety review of the renewal renewal application application for compliance requirements of Title 10, Part 54, of the compliance with the requirements the Code of Federal Regulations, Federal Regulations, (10 CFR Part 54), "Requirements for Renewal of Operating Renewal Operating Licenses for Nuclear Power Plants." This SSER supplementssupplements portions of Sections 1 and 3, and Appendices A and Appendices and B of the June 2009 SER.

In letters dated July 28,2009, In 28, 2009, September September 2, 2009, September 4,2009, 4, 2009, September September 8, 2009, and 8,2009, and September 14, 2009, the applicant provided September 14,2009, provided revisions to commitments commitments related to the aging aging management management program for the BVPS Units 1 and 2 containment containment liners, associated FENOC's associated with FENOC's renewal application. These letters renewal letters were were a result of discussions between between the NRC and the the applicant teleconferences held between applicant during teleconferences between July 24, 2009, and September September 3, 2009, concerning concerning the applicant's planned examinations examinations of the containment liners of Units containment Units 1 and 2.

1.6 Summary Summary of Proposed License Conditions Conditions The staff has added a proposed proposed license license condition that requires the applicant applicant to continue continue containment liner volumetric containment volumetric examinations examinations under the following conditions:

a) IfIf degradation degradation (greater than 10 percent percent of the nominal thickness thickness not attributable attributable to fabrication/erection identified in the non-random fabrication/erection practices) is identified non-random areas examined examined using ultrasonic testing (UT),

(UT), UT examinations shall be performed performed at additional non-random areas, to be selected based on this operating experience.

experience. Should additional degradation degradation be identified, identified, additional non-random non-random areas areas shall be UT examined until no further degradation (greater than 10 percent of the nominal degradation nominal thickness) is identified. All areas areas with degradation degradation shall be reexamined reexamined over at least least the next three successive inspection inspection periods to ensure that progression progression of the degradation is not occurring.

occurring.

1-1 1-1

degradation (greater than 10 b) If degradation 10 percent percent of the nominal thickness attributable to thickness not attributable fabrication/erection fabrication/erection practices) is identified in the random samples samples examined examined using UT, UT examinations shall be performed performed on additional additional random samples, to ensure a 95 percent confidence percent confidence that 95 percent of the unexamined accessible containment containment liner is not degraded. degradation is identified, the sample degraded. If additional degradation sample size for UT examinations examinations shall be further expanded expanded until the statistical sampling sampling has achieved achieved the 95 percent confidence confidence goal described previously. All areas areas with degradation degradation shall be reexamined over at least the next three successive inspection periods successive inspection periods to ensure that progression of of the degradation degradation is not occurring.

occurring.

1-2

SECTION 2 STRUCTURES SYSTEMS STRUCTURES SYSTEMS AND COMPONENTS AND COMPONENTS The staff does not have any changes changes or update to this section of the original SER (ML091600216)..

(ML091600216) 2-1

SECTION 3 AGING MANAGEMENT REVIEW AGING MANAGEMENT REVIEW RESULTS RESULTS 3.0.3 Aging Management 3.0.3 Management Programs Programs 3.0.3.2 AMPs Consistent Consistent with the GALL GALL Report with Exceptions Exceptions or Enhancements Enhancements 3.0.3.2.2 ASME Code Section XI, Subsection Subsection IWE Program Program Summary of Technical Information in the Application. In LRA Section 8.2.3, Technical Information B.2.3, the applicant applicant described the existing ASME Code Code Section XI, XI, Subsection IWE Program as consistent, with an exception, with GALL AMP XI.S1 "ASME Code Section XI, Subsection IWE." IWE." This program program is implemented through plant procedures, which provide implemented provide for lSIISI of Class MC and metallic metallic liners of Class CC components.

Class Section 50.55a of 10 CFR specifies the use of the examination requirements Section SO.SSa requirements in the ASME Code, Section XI,Section XI, Subsection IWE, IWE, for steel liners of concrete concrete containments and other containment containment components. The applicant applicant stated that itit has implemented implemented ASME Code Section XI, XI, Subsection Subsection IWE, 1992 Edition with the 1992 1992 Addenda, and will use the ASME ASME Code edition consistent consistent with the provisions of 10 50.55a, during the period of extended 10 CFR SO.SSa, extended operation.

Staff Evaluation.

Evaluation. In the LRA, the applicant applicant stated that ASME Code Section XI, Subsection IWE XI, Subsection IWE is an existing program that is consistent, with exception, with GALL AMP XI.S1. XI.S1.

During the audit, the staff interviewed the applicant's technical staff and audited the applicant's applicant's ASME Code Code Section Subsection IWE Section XI, Subsection IWE Program onsite basis documentsdocuments to confirm the the applicant's claim of consistency consistency with GALL AMP XI.S1.

XI.S 1. In addition, the staff reviewed the the exception and its justification justification to determine whether the AMP, with the exception, remains remains adequate to manage manage the aging effects for which itit is credited.

The applicant's ASME Code Section XI, Subsection IWE Program XI, Subsection Program takes exception exception to the scope scope of program, parameters monitored program, parameters monitored or inspected, inspected, detection detection of aging effect, monitoring monitoring and trending, acceptance acceptance criteria, and corrective action program elements in that it did not use the the ASME Code Section XI, Subsection Subsection IWE, 2001 edition, with the 2002 through 2003 Addenda. In the LRA, the applicant applicant stated that its use of the ASME Code 1992 1992 edition through the 1992 1992 Addenda Addenda complies with 10 CFR 50.55a SO.SSa which requires use of the Code in effect effect 12 months prior 12 months prior to the start of the inspection interval.

inspection interval. The applicant further applicant further committed that it will use the ASME ASME Code edition consistent with the provisions of 10 10 CFR SO.SSa 50.55a during the period period of extended operation. The staff issued generic generic RAI B.2-2, 8.2-2, by letter letter dated June June 5, S, 2008, requesting the requesting that the applicant clarify which edition of the ASME Code Section applicant Section XI will be credited for those AMPs that that credit the ASME Code Section XI, during the period of extended extended operation. The staffs review of of RAI B.2-2 8.2-2 is documented documented in SER Section 3.0.3.2.1.

3.0.3.2.1.

The staff reviewed the exception described in LRA Section 8.2.3 exception described B.2.3 and additional information information provided provided by the applicant in its response response to RAI 8.2-2B.2-2 dated July 21, 21, 2008. The staff finds that 3-1

the exception exception to the use of the ASME Code Section XI, Xl, Subsection Subsection IWE, 1992 Edition with 1992 1992 Addenda is within the limitations and modifications applicant's modifications required by 10 CFR 50.55a. The applicant's assurance assurance of the use of subsequent subsequent editions and addenda addenda of ASME Code Section XI,Section XI, Subsection Subsection IWE, as required by 10 CFR 50.55a ensures that the applicant's applicant's IWE program will be consistent with GALLGALL AMP XI.S1 during the period of extendedextended operation.

operation. Based on its review, the staff finds the applicant's applicant's exceptions exceptions to the use of the IWE program acceptable.

acceptable.

Operatingq Experience. The staff also reviewed the operating experience, including samples Operating samples of condition reports, and interviewed the applicant's technical staff to confirm that the plant-specific plant-specific operating experience did not reveal any degradation operating experience degradation not bounded by industry experience.

However, during its review audit, the staff noted noted that aa temporary temporary construction construction opening opening was was created in 2006 for the Unit 1 SG and reactor head replacements. Inspections Inspections during RFO 17 (2006) revealed revealed degradation degradation from the inaccessible inaccessible side of the steel liner, for which the applicant applicant could not identify a root-cause root-cause from observations in field or from lab analysis. To ensure the the essential essential leak-tight condition of the containment, the staff identified identified three issues where additional clarifications and justifications clarifications justifications were needed needed to complete the review.

In RAI B.2.3-1, B.2.3-1, dated dated May 8, 2008, that staff requested requested that the applicant provide provide information information related to the minimum required thicknessthickness of the liner; discuss the possibility and severity of similar similar corrosion corrosion at other locations, including including Unit 2 containment; containment; and justify whether whether the the corrosion is active. Furthermore, the staff requested the applicant discuss discuss the use of the GALL Report which recommends recommends further evaluation evaluation of plant-specific plant-specific programs to manage this aging effect effect for inaccessible inaccessible areas, if corrosion is significant.

B.2.3-1, dated June 16, 2008, the applicant In its response to RAI B.2.3-1, applicant stated:

Analyses Analyses and evaluations evaluations of the Unit 1 containment containment liner corrosion in 2006 were performed for FENOC by several vendors that specialize performed specialize in these types of analyses and by the FirstEnergy FirstEnergy Beta Laboratory.

The Shaw Group, Inc., Inc., evaluated evaluated the condition containment liner condition of the Unit 1 containment regarding the extent of the degradation degradation and effects on intended function following following the discovery of the containment liner corrosion corrosion in 2006. The evaluation included included consideration of the impact of an additional 20 years of operation consideration operation as a result of license renewal on the recurring license recurring Integrated Leak Rate Test loading.

Integrated Leak In the Shaw Group's Group's report, design basis calculations developed for the calculations originally developed the BVPS Unit 1 containment liner were used to demonstrate demonstrate that the degraded conditions conditions found on the liner did not adversely adversely affect its mechanical/structural function as a leak-tight leak-tight membrane.

membrane. The thickness thickness of the remaining sound metal was determined adequate to maintain determined to be adequate maintain the design design safety function of the liner.

In addition, the capacity of the concrete structure to withstand concrete containment structure withstand Design Basis Accident loadings was not adversely adversely affected.

affected.

3-2 3-2

Of the three areas of corrosion identified, two were were replaced replaced with new plate plate material. The third area material. area showed minimal wall loss at the deepest deepest pit, and was left in place for further monitoring.

monitoring. In addition to initial "baseline" "baseline" ultrasonic thickness thickness measurements in accordance measurements accordance with Table IWE-2500-1, IWE-2500-1, examination examination category E-C, it was recommended recommended that the third area of degradation degradation be mapped on the inside inside of the containment containment liner for future UT examinations. ItIt was recommended recommended that this this area be examined examined for the next three inspection If no change in liner inspection periods. If thickness thickness was detected after three inspectioninspection periods, it was determined determined that the the area wouldwould require no additional inspections. Further engineering engineering evaluation evaluation was was recommended if the thickness changed.

recommended changed. FENOC has scheduled scheduled additional UT UT examinations as recommended examinations recommended by The Shaw Group, Inc., for the three inspection inspection periods following the 2006 RFO when the degradation periods degradation was discovered.

A material analysis was performed performed by the FirstEnergy Beta Beta Laboratory Laboratory on thethe corroded corroded steel liner areas areas and sample pieces of concrete concrete to aid in determining determining a cause cause of the corrosion. The following conclusions were drawn concerning concerning thethe corrosion corrosion activities:

• " The corrosion was general general pitting corrosion (wastage) with no evidence evidence of stress corrosion or microbiological microbiological attack. The metallographic metallographic work performed by Beta Labs found the pitting to be rounded in nature nature with no no crack like projections. The examination examination of the corrosion product trapped in the deep deep pits identified no unusual levels of elements that were not expected to be present. No preferential preferential corrosion attack was observed on the sample sample piece with the weld or on the welds around the Nelson Nelson studs studs welded to the liner plate. Some crevice corrosion corrosion was observed the observed in the cross section of the studs where the flash weld could trap contaminates.

• • The corrosion corrosion occurred occurred after welding and construction of the liner plate plate since the corrosion pitting was even even across the weld, the heat affected affected zone (HAZ) and both edges of the weld where weld prep would have have occurred.

occurred. No preferential preferential corrosion occurred at the weld or HAZ.

"* necessary elements The necessary elements for corrosion corrosion (oxygen and water) were presentpresent throughout the construction construction phase of Unit 1, from the fabrication fabrication and erection erection of the liner plate through the completion of concrete concrete pours for the the top of the containment containment structure. During this timeframe, water, in the form of the wetting methodology methodology used during the concrete concrete pour sequences sequences and weather (rain (rain and snow), could accumulate accumulate in areas between between the liner plate and the concrete concrete structure. Corrosion activities are likely to have have initiated during this construction construction period.

• • Access to these necessary necessary elements for corrosion activity became became significantly limited once the concrete structure structure was completed. Exposure Exposure to water sources sources all but ceased, and the concrete/steel interface was no concrete/steel interface no longer exposed to the atmosphere atmosphere for re-oxygenation.

3-3 3-3

• " The corrosion corrosion process consumes oxygen, and, once it is depleted, corrosion can not be sustained at a high rate due to the limited supply of corrosion between the concrete and the liner plate following fabrication.

oxygen between fabrication.

• • No corrosive agents or corrosion catalysts, such as chlorides, could be be identified on or in the steel liner plate. Additionally, no corrosion agents agents concrete were found in the pitted areas of the liner plate or in the concrete concentrations that would be of concern. However, it materials tested in concentrations considered that such materials must be considered materials may have existed in local areasareas and were removed during during the water hydrolazing process that was used used to remove the exterior exterior containment containment concrete.

• • Approximately Approximately 1 1%

% of the observable liner plate (portion removed for the the construction contained corroded construction opening) contained corroded areas and a much smaller smaller percentage of the rebar surface area had evidence percentage evidence of corrosion. So, itit is reasonable assume that the concrete did not contain corrosive reasonable to assume corrosive agents, and that corrosion corrosion elements (water and oxygen) were not present in in abundant abundant amounts. This finding would support the general conclusion that no general corrosion is active between the liner plate and the active in the area between the concrete.

• • The corrosion is localized localized for reasons that can not be determined determined with certainty. However, small breaks in the mill scale surface or other surface surface imperfections can provide the initiation sites for pitting (oxygen cell imperfections during the time of construction when oxygen and water corrosion) during water were were known to be present.

• • The concrete did contain small void areas areas at the concrete/steel concrete/steel interface.

These voids would most likely have filled with water during the These the construction phase. During the post-construction post-construction life of the liner, these locations could also serve accumulation point for any moisture serve as an accumulation moisture that containment liner enters the concrete structure. However, the area of the containment liner where concrete was found to have where the concrete have small voids at the steel/concrete steel/concrete interface had interface had no corrosion corrosion activity.

• Foreign material has been identified by other power plants that removed the liner plate from the inside inside of containment leaving leaving the concrete in place. The foreign debris was identifiable identifiable in these instances instances since the the corrosion product was available for analysis. At BVPS, little or no no corrosion product remained following the water hydrolazing, corrosion no hydrolazing, so no conclusions could be drawn conclusions drawn regarding the source source of the corrosion.

A vendor materials specialist was commissioned to perform perform a corrosion corrosion assessment assessment of the corroded steel liner, and stated stated that the primary primary source of of passivation of the steel used in fabrication passivation containment liner, studs and fabrication of the containment concrete itself. The passivity rebar is the concrete steel depends upon passivity of the steel upon the quality quality of concrete in contact with the steel and the intimate contact of the steel to the the concrete the containment steel liner, studs concluded that, where the containment concrete. The vendor concluded studs 3-4 3-4

,"", ~ t"" :"'" "

and rebar are in contact contact with the concrete concrete cover, the containment containment steel liner at BVPS Unit 1 would be in aa passivated passivated state and not subject to oxygen oxygen concentration concentration cell corrosion. The visual inspection inspection of the removed cutout and majority (over 99%) of the surfaces in contact rebar identified that the majority contact with the the concrete were passive concrete passive to an oxygen concentration concentration cell corrosion mechanism.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.3-1 acceptable because acceptable because the applicant has adequately explained explained that corrosion corrosion of the liner plate or rebar materials from the concrete side of the liner plate is passive passive because because there is no active mechanism mechanism for corrosion. The staff determined determined that the Shaw Group'sGroup's evaluation of the Unit 1 containment containment liner confirmed that the degraded degraded conditions found on the liner did not adversely adversely affect affect its mechanical and/or structural function as a leak-tight leak-tight membrane. Therefore, the staffs staff's concern concern described described in in RAI B.2.3-1 is resolved.

resolved.

In LRA Section B.2.3, the applicant applicant stated that following following RFO 17 (2006) for Unit 1, test procedures for the evaluation procedures evaluation of the containment liner liner plates were modified modified at both units. The The staff determined determined that additional additional information information was required to complete its its- review.

In RAI B.2.3-2, dated May 8, 2008, the staff requestedrequested that the applicant identify identify which test procedures or part of the procedures procedures were modified modified and compare them with previous previous procedures, as well as those required by ASME Code Section Xl, Subsection IWE. The XI, Subsection The applicant was also asked to explain whether the modified modified test procedures procedures help detect similar similar containment liner degradation degradation on the side that is in contact with the concrete concrete and; if not, how the the applicant will ensure that similar degradation, degradation, ifif any, is detected.

In its response In response to RAI B.2.3-2, dateddated June 16, 2008, the applicant explained explained that the procedures procedures for Units Units 1 and 2 were modified modified to include two additional requirements in the containment containment inspection procedures, resulting resulting from the liner corrosion found in 2006: (1) when paint or coatings are removed for further inspection, the paint or coatings coatings shall be visually examined examined by a qualified VT-3 inspector prior to removal, removal, and (2) ifif the visual examination examination detects surface surface flaws flaws on the liner or suspect suspect areas on the liner plate that could potentially impact the leak tightness tightness or structural integrity of the liner, then surface surface or volumetric examinations shall be performed to to characterize the condition (i.e., depth, size, shape, orientation).

characterize orientation). The applicant further stated that examination requirements these additional examination requirements and the use of the FENOC Corrective Action Program provide reasonable Program reasonable assurance assurance that potential corrosion corrosion on the concrete side of the the containment liner plate will be identified containment identified and addressed.

addressed.

Based Based on its review, the staff finds the applicant's response response to RAI B.2.3-2 acceptable because acceptable because the applicant described the modifications applicant described modifications of the containment containment inspection procedures procedures that will identify additional additional areas areas of corrosion (if (if any). These procedures procedures will be incorporated incorporated as part of the ASME Code Xl, Subsection XI, Subsection IWE examinations. Therefore, the staff's concerns described described in RAI B.2.3-2 B.2.3-2 are resolved.

The staff reviewed the applicant's applicant's ASME Code Code Section Section XI,Xl, Subsection Subsection IWE Program. GALL AMP XI.S1 states that ASME Code Section Section Xl paragraph IWE-1240 XI paragraph IWE-1240 requires requires augmented augmented examinations containment surface areas examinations of containment areas that are subject to degradation. degradation. The staff determined determined that additional additional information was required to complete complete the review.

3-5 3-5

In RAI B.2.3-3, dated dated May May 8, 2008, the staff requested historically explain requested that the applicant historically explain what inspection findings under the BVPS ISI inspection lSI - IWE Program, including the 2006 findings of the liner degradation on the side in contact with concrete, have led to the need degradation need for augmented augmented inspections.

In its response to RAI B.2.3-3, dated June 16, 2008, the applicant stated that Units 1 and 2 do do not meet the criteria for ASME Code Code augmented augmented examinations examinations as defined in ASME Code Code Xl,XI, IWE-1240. There are no augmented IWE-1240. augmented examinations being performed on examination surface examination surface areas at Units 1 or 2 as defined in ASME Code Code Section Xl, XI, Subsection IWE-1 240.

IWE-1240. However, the the applicant further explained further explained that two of the three degraded areas degraded areas were removed removed and replaced with new plate material in 2006, following the discovery of corrosion on the concrete concrete side of the the liner plate. The third area was found acceptable acceptable from examination examination and laboratory laboratory analysis and was left in place. As part of the corrective actions from the discovery,discovery, this third area monitored area is monitored with additional additional examinations. FENOCFENOC has scheduled additional UT examinations examinations for the three three inspection periods following RFO 17 (2006), when the degradation inspection degradation was discovered. So far, these additional UT examinations examinations have identified identified no degradation.

Based Based on its review, the staff finds the applicant's response to RAI 8.2.3-3 B.2.3-3 acceptable because acceptable because the applicant applicant has verified that Units 1 and 2 do not meet the criteria criteria for ASME Code augmented examinations examinations as defined in ASME Code Section Section Xl, IWE-1240. Two of the three unacceptable XI, IWE-1240. unacceptable degraded degraded areas were removed and replaced with new plate material material following the discovery discovery of the corrosion corrosion on the concrete side of the liner plate during RFO 17 (2006), and the third area will have have been examined examined for three inspection inspection period period following RFO 17. 17. Therefore, the staffs staffs concerns concerns described in RAI B.2.3-3 are resolved.

On April 23, 2009, during a Unit 1 IWE inspection, inspection, a paint blister was discovered discovered on the the containment containment liner. Further investigation revealed through-wall investigation revealed through-wall corrosion of the containment containment liner.

In response to this operating experience, by letter dated dated May May 7, 2009, the staff issued RAI B.2.3-4, RAI B.2.3-5, and RAI B.2.5-1,B.2.5-1, requesting the applicant to explain how the recent recent plant-specific operating experience, as well as the 2006 degradation, degradation, would be incorporated incorporated intointo the ASME Section XI, Xl, Subsection Subsection IWE and Subsection IWL AMPs, and if the Subsection Subsection IWE IWE AMP has been enhanced enhanced by the applicant.

In its response to RAlsRAIs B.2.3-5 and B.2.5-1, B.2.5-1, dated June 1, 2009, the applicant stated that in in April 2009 during performance performance of an ASME Subsection IWE IWE containment containment liner plate examination examination a through wall hole with dimensions dimensions of 1 inch by 3/8 inch was discovered.

discovered. Wood debris was was found within the concrete adjacent to the hole. Laboratory analysis concluded that the wood analysis concluded debris most likely promoted promoted corrosion. The wood debris debris was removed. No structural rebar was was exposed during this process. The concrete behind the through wall liner plate flaw was repaired, and the affected affected area of the liner plate was replaced replaced and pressure pressure tested to ensure leak tightness.

The staff review of the reactor operating operating experience experience records records indicate that through-wall through-wall corrosion of the liner plate similar to that found in the BVPS containment containment has beenbeen previously detected in both PWR and BWR containments. Plants with previously detected through-wall through-wall corrosion include Brunswick Brunswick Units 2 (ambient pressure pressure containment),

containment), D. C. Cook Unit 2 (ambient pressure containment), and North Anna Unit 2 (sub-atmospheric containment). containment). BVPS, Units 1 and 2 containments were originally originally designed as sub-atmospheric sub-atmospheric but were converted to atmosphericatmospheric 3-6 3-6

2006. The root cause containments in 2006. cause of the the through-wall corrosion at at Brunswick Unit Unit 2, D.C. Cook Unit 2, D.C. 2, and North Anna Unit Unit 2 plants plants was was found to be construction construction imperfections imperfections and and foreign material trapped in the concrete againstagainst the liner. Therefore, Therefore, the staff believes believes that that the the occurrence of through wall corrosion at Beaver Valley is likely due to a foreign object (wood occurrence (wood debris) trapped in the concrete against the liner, especially especially since the wood debris had a pH value 3.7 and a moisture content of 13 percent. The additional visual and volumetric volumetric examinations that the applicant plans to perform, as described below, may provide provide additional insight about the potential corrosion mechanism. In In addition, the corrective actions carried out described below, by the applicant, also described below, have have restored the liner's liner's ability to perform its its intended function as a leak tight barrier.

The applicant also stated in in its response to RAI B.2.3-4 B.2.3-4 dated June 1, 2009, that a plant-specific plant-specific program to manage program manage aging of the containment containment liner or enhancement enhancement to the ASME SubsectionsSubsections IWE and IWL is not necessary necessary due to discovery of the through-wall hole in April 2009. However, the containment liner plate inspection procedures procedures for both Units 1 and 2 were modified following following the identification of degradation degradation in 2006 to include the following acceptanceacceptance criteria for the the containment liner plate:

containment

1. When paint or coatings are to be removed for further inspection,

1. inspection, the paint or coatings coatings shall be visually examined by a qualified qualified VT-3 VT -3 inspector prior to removal.

2. If the visual examination detects surface flaws on the liner or suspect areas on the liner If plate that could potentially potentially impact impact leak tightness or structural structural integrity of the liner, then surface or volumetric examinations performed to characterize examinations shall be performed characterize the condition condition (i.e.,

depth, size, shape, orientation).

In addition, in the June June 1, 2009, response to RAls RAIs B.2.3-4 8.2.3-4 and 8.2.3-5, B.2.3-5, the applicant applicant stated that corrective actions for the degradation the corrective degradation found in April 2009 include examination of include visual examination 100 percent percent of the accessible containment liner plate area of Unit 1 during 1 R20 refueling refueling outage in October/November October/November 2010 and Unit 2 refueling outage outage 2R14 in October/November October/November 2009. A volumetric examination examination of the small area of the Unit 1 liner plate replaced to remove the the discovered in April 2009 is also planned for the 1R20 refueling outage. Furthermore, in defect discovered in the June June 1, 2009, letter, the applicant applicant also committed committed to perform supplemental supplemental volumetric volumetric examinations of randomly examinations selected 75 (one square foot) locations randomly selected locations at both Units 1 and 2. If If no no degradation is found at these 75 sample degradation sample locations locations in each each unit, it will provide provide aa 95 percent percent confidence confidence that 95 percent of the containment degraded (using the containment liner plate is not degraded the methodology methodology of EPRI TR-107514).

TR-107514). These corrective actions These corrective characterized as ASME actions are not characterized ASME Section Xl, Subsection Section XI, Subsection IWE augmented examinations augmented examinations but rather rather as "supplemental volumetric volumetric examinations.""

examinations.

3-7 3-7

teleconferences held from July 24 through September During teleconferences September 3, 2009, th'ethe staff requested requested thethe applicant to clarify the supplementary applicant supplementary volumetric examination commitments described volumetric examination the described in the letter dated June 1, 2009. In subsequent letters dated July 28, 2009, September subsequent letters September 2, 2009, September 4, 4,2009, September 8,2009, 2009, September 8, 2009, and September 14, 2009, the applicant modified modified and expanded its previous commitments that will evaluate the condition of the containment liners at expanded Beaver Valley Units 1 and 2. These commitments are in addition to the visual examination Beaver examination of containment liner plate area that the applicant plans to perform 100 percent of the accessible containment perform in Unit 1 during 11R20 October/November 2010 and in Unit 2 during refueling R20 refueling outage in October/November refueling October/November 2009 as a part of the corrective action program. The new outage 2R14 in October/November outage commitments are to perform:

commitments

1. A supplemental volumetric examination supplemental volumetric minimum of 75 (one-foot square) examination (UT) of a minimum containment liner plate of both Unit 1 and 2 locations of the accessible portions of the containment completion of Unit selected randomly, with completion examinations over the next three refueling Unit 1 examinations refueling outages beginning in October October 2010. examinations will be completed prior to 2010, The Unit 2 examinations to entering the period of extended operation. If there are any failures in the first set of samples (minimum of 75), additional samples will be randomly selected selected such that, upon completion of the random sampling completion sampling plan, there is sufficient sufficient data to demonstrate demonstrate with a 95 95 percent confidence accessible portion of the containment confidence that 95 percent of the accessible containment liner is corrosion of concern experiencing localized pitting corrosion not experiencing greater than 10 concern with greater 10 percent loss loss of material. Any degradation degradation discovered addressed in the corrective action discovered will be addressed action process.

examination of a minimum of eight areas located in the

2. A supplemental volumetric examination the experience will be accessible areas of liner plate. Site specific and industry operating experience be locations that are susceptible to localized pitting corrosion. The used to determine locations The specific areas to be considered considered for selection include:

a. areas that have have been repainted more than once once

b. areas with irregular contour contour

c. an area 5 feet below the 2006 steam generatorgenerator replacement construction construction opening (Unit 1 only)

d. the area covering the final grade level containment is level where the concrete containment exposed to environment exposed environment was degradation of the liner was

e. an area adjacent to where the through-wall degradation discovered in April 2009 (Unit discovered (Unit 1 only) examination will commence on-line, within the current fuel cycle and will be The Unit 1 examination be refueling outage, not to exceed completed prior to the end of the 1R20 refueling completed exceed December 31, 31, completed prior to entering the period of extended examinations will be completed 2010. The Unit 2 examinations operation. Any degradation discovered will be addressed in the corrective degradation discovered corrective action process.

The following table provides the relevant past operating operating experience, proposed future experience, as well as proposed actions.

3-8 3-8

,ýUnit -Date Activity 1 May May 2006 Found three small areas areas of degraded degraded liner plate. Two areas removed removed and replaced.

replaced. Third area

............... found acceptable... S.LJccess.ful

_fou~d_a~~~pt~ble Successful integrated integrated leaka~e leakage rate test (ILRT) after rat~t~st(I~~n a~erJepair.

repair.. .. ___. _.....

. ._.

2 May May 2008 Successful Successful integrated leakage rate test (ILRT) integrated leakage 1 April 2009 inspection found aa 3/8 inch x 1 inch hole in liner plate which was removed and replaced.

IWE inspection 2 Complete 1100 October 2009 .'<;:0ITlRlete Q.qJ)er~~nt eX~!"1i~ation ofli~~r.pIClte percent visual examination of liner plate 1 October 2010 . Complete 100 percent visual examination October examination of liner plate. Perform Perform UT examination examination of the liner liner

._._._______ __.._ I:lI~t~ a~eCl r~pICl~~d.~url'!g,l\!>ril_?:Qq9.: .. .......__ ... _ ... _. ___ . __.. __ ._.. ___ _

1 December December ]Complete examination of 88 or more areas of liner plate, Complete volumetric examination plate. focused on areas most likely likely 2010 2010 .to experience degradation toexR~ri~nce d~JJ.~adation bas_ed_on based on past ().p~rati,!g~.~pe~i~n~~:

PClS.t operating experience.

22 April 20111 April20! Scheduled IWE Scheduled IWE program visual examination e~amination of liner plate 1 April 2012 Scheduled IWE program program visual examination of liner plate plate 1 January 2016 Complete volumetric examination examination of a minimum one-foot square areas.6flin~rplate.

minimum of 75 one-foot areas of liner plate, selected randomly, randomly. during the next three refueling refueling outages beginning beginning in October October2Q1p.21i0.

2 May 2027 May Complete volumetric examination examination of a minimum minimum of 75 one-foot square areas of line'rplate. liner plate, selected randomly.

selected randomly, prior to the start of period of extended extended operation.

2 May 2027 May Complete volumetric volumetric examination examination of 8 or more areas of liner plate. plate, focused on areas most likely likely to experience

_to experience degradation degradation based on past operating experience. .

The supplemental supplemental volumetric volumetric inspections inspections will identify identify the minimum liher liner thickness and document document any degradation patterns by scanning the entire one-foot one-foot square sample area. In its letter dated September September 4, 2009, the applicant clarified that the purpose purpose of the volumetricvolumetric examinations examinations of the minimum of 75 random samples is to ensure ensure with a 95 percent percent confidence that 95 percent percent of the the accessible ultrasonically accessible ultrasonically untested portion of the containment liner is not experiencing containment experiencing degradation degradation due to corrosion with greater greater than 10 10 percent loss of material. Liner plate thinning thinning attributed attributed to degradation degradation on the insideinside surface surface of the liner will be managed in accordance accordance with the existing ASME Subsection Subsection IWE aging managementmanagement program.

The applicant's acceptance acceptance criteria criteria for the volumetric volumetric examinations examinations of the concrete concrete to liner interface defines a statisticalstatistical sample failure failure as a random location location with greatergreater than 10 percent percent loss of material, material, unless through through engineering evaluation evaluation it is attributed attributed to fabrication/erection fabrication/erection practices. Samples Samples with greatergreater than 10 percent percent loss of liner material would be re-examined re-examined during subsequent outages during subsequent outages until dispositioned.

until dispositioned.

Indications of liner plate loss of thickness of less than 10 percent that can be attributed Indications attributed to corrosion will be entered entered into the corrective action program corrective program and tracked tracked as a point of interest during subsequent dispositioned.

subsequent outages until dispositioned.

The applicant has committed appropriate/applicable statistical methodologies committed to evaluate appropriate/applicable methodologies to gain gain additional insight into potential additional potential liner corrosion. Data gathered gathered will be used to determine the the general state of the liner.

For all of the plahned planned supplemental supplemental volumetric volumetric examinations, examinations, adverse adverse findings will be addressed by the applicant's corrective action program applicant's corrective program! as described above.

The staff has determined determined that the random sampling sampling plan, which includes the initial examinations examinations of a minimum of 75 one-foot one-foot square locations locations and any needed needed scope expansion locations of the the accessible accessible portions of the containment containment liner, will result in 95 percent confidence that 95 percent 3-9 3-9

accessible portion of the containment of the accessible containment liner experiencing corrosion liner is not experiencing corrosion with with greater greater than than 10 percent 10 percent loss material (95/95 confidence).

loss of material approach is used confidence). This approach routinely in the nuclear used routinely nuclear industry for investigation industry different commodities degradation in different investigation of degradation commodities and and is considered to be aa high is considered high confidence confidence levellevel from a statistical statistical standpoint. Degradation in standpoint. Degradation in the liner liner plate plate found during April found during 2009 where the corrective 2009 where corrective actions actions have been taken taken is not aa part random inspection part of the random inspection plan, plan, and is not required considered to determine required to be considered determine the sample size for aa new random plan.

the sample plan.

random volumetric The random volumetric examinations examinations will commence commence by the end end of Refueling Outage of the Unit 1 Refueling Outage 2010 and will be completed in 2010 completed over outages prior over the next three refueling outages prior to the period period of extended operation extended operation in in January examinations will commence January 2016. The Unit 22 examinations commence by the end end of thethe Unit 22 refueling Unit outage in 2011 refueling outage 2011 and and will be be completed prior to the period of completed prior of extended extended operation.

operation.

Any degradation discovered that degradation discovered that does does not meet meet the volumetric examination the volumetric examination acceptance acceptance criteria, criteria, as noted as noted above, will result in examination examination of additional additional randomly selected samples, randomly selected samples, as necessary described above. In addition, the applicant confidence criterion described to meet the 95/95 confidence applicant will evaluate evaluate applicable statistical applicable statistical methodologies methodologies to characterize containment liner characterize the general state of the containment liner selection of the initial plate. The staff finds the selection random sample of a minimum initial random minimum of 75 locations and and the inclusion of additional random random samples, in case more of the initial case one or more initial sample fails thethe examination acceptance guidance provided in Section criteria, conforms to the guidance acceptance criteria, Section 4 of EPRI report TR-107514 and NUREG 1475. In any and NUREG applicant will perform any case, the applicant perform sufficient sufficient random sampling to ensure ensure 95 percent percent confidence accessible portion of the confidence that 95 percent of the accessible the containment containment linerliner is not experiencing localized pitting corrosion of concern experiencing localized concern with greater greater than 1

100 percent percent loss loss of material.

material.

examination of a minimum of eight non-supplemental volumetric examination The staff notes that the supplemental non-,

randomly selected areas will focus on those locations that the applicant believes are most likely randomly likely experience degradation to experience experience. These non- random degradation based on prior experience. random volumetric volumetric examinations will provide additional examinations confidence that the liner plate is performing its intended additional confidence intended function as a leak tight membrane. The applicant has committed committed to commence these examinations on-line examinations refueling outage in 2010 and to complete them on-line prior to beginning of Unit 1 refueling no later than December December 31, 2010. The staff believes that this non-random 31,2010. selection of '

non-random selection volumetric examination at a minimum minimum of eight areas will supplement examinations supplement the results of examinations randomly selected locations and will provide an early indication at randomly containment liner indication of loss of containment liner plate integrity and leak tightness. Adverse findings from the examinations examinations will be addressed addressed in corrective action process as described above, and will involve additional examinations, the corrective assessments, and repairs, as necessary. In addition, the applicant applicant will provide NRC a summary report of the results from the volumetric examinations examinations for each unit after completion of each phase of testing.

Based on its review, the staff finds the applicant's responses to RAls 8ased RAIs 8.2.3-4, B.2.3-5, 8.2.5-1, B.2.3-4, 8.2.3-5, B.2.5-1, clarifications in their July 28, 2009, September 2, 2009, September 4, 2009, September and clarifications September 8, September 14,2009, 2009, and September acceptable because the applicant's 14, 2009, letters, acceptable applicant's aging management plant-specific operating experience. The modified procedures, program incorporates the recent plant-specific examination of the liner plate during the next outage and the along with the 100 percent visual examination the examinations of a minimum of 75 random samples and a minimum of 8 supplemental volumetric examinations non-random areas prior to entering the period of extended operation, provide reasonable non-random reasonable assurance that the AMP is adequate adequate to manage the aging effects for which itit is credited in the the LRA. The applicant's commitment to perform volumetric examination examination of the minimum of 8 non-random areas in Unit 1 on-line by December December 2010 will confirm ifif corrosion at the liner concrete concrete 3-10 3-10

interface is interface is present present at at the most most likely likely locations. Completing volumetric locations. Completing examinations for Unit volumetric examinations Unit 2 before the period before period ofof extended extended operation acceptable since operation is acceptable since liner degradation has only liner plate degradation only been identified been in Unit identified in Unit 1. The The staff staff had included a proposed had included proposed license ensures for condition, which ensures license condition, for continued containment continued containment linerliner volumetric volumetric examinations examinations as as necessary, discussed in SER necessary, which is discussed Section 1.6, Section Proposed License 1.6, "Summary of Proposed License Conditions."

response to RAI B.2.3-5 In response In B.2.3-5 dated June June 1, 2009, the applicant that the aging applicant stated that aging management management program program was not enhanced not enhanced to achieve GALL consistency achieve GALL consistency as described in NUREG-1 described in NUREG-1B01. 801. TheThe procedures discussed above, to identify additional modified, as discussed procedures were modified, actions in the event that additional actions that surfaces are suspect surfaces suspect visual inspection.

identified by the IWE visual are identified inspection. The applicant further The applicant further stated stated that UT examinations were performed examinations performed on the area area of degradation degradation discovered during the 2006 steam discovered during outage which replacement outage generator replacement generator which waswas left in place. applicant explained place. The applicant explained that these these examinations were corrective examinations corrective actions actions related to the degradation and are not the degradation considered IWE not considered IWE augmented examinations since the degradation augmented discovered outside degradation was discovered outside of the scheduled scheduled IWE IWE examinations. The applicant also also stated that through-wall degradation that the through-wall discovered in degradation discovered April 2009 April 2009 during an IWE examination does IWE examination does not require augmented examinations because augmented examinations because the the degraded degraded area area was replaced. corrective actions from the 2009 degradation replaced. The corrective degradation include include 100 percent percent visual examination accessible liner during the next outage, a volumetric examination of the accessible volumetric inspection replaced area, and inspection of the replaced supplemental volumetric and supplemental examination. These volumetric examination. corrective These corrective characterized by the applicant as IWE augmented actions are not characterized actions augmented examinations.

Based on its review of the applicant's response to RAI B.2.3-5, the staff finds the response applicant's response response.

acceptable acceptable because corrective actions because it explains how the corrective implemented and actions were implemented and why the the degraded areas do not fall under the IWE Examination degraded Category E-C (augmented examination).

Examination Category examination).

degradation was not discovered during The 2006 degradation examination and the corrective during an IWE examination corrective actions actions are not tracked under the IWE AMP, while the 2009 degradation degradation does not require IWE IWE examinations per IWE-2420 augmented examinations because the area was replaced. The staffs concerns IWE-2420 because concerns described in RAI B.2.3-5 described 8.2.3-5 are resolved.

resolved.

The staff confirmed that the "operating experience" program element criterion element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.1 A.1.2.3.10. program O. The staff finds the program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement UFSAR supplement for the ASME ASME Code Section XI, Subsection IWE Program Xl, Subsection Program in LRA Section A.1.3. The staff reviewed this this Section and determines that the information supplement is an adequate information in the UFSAR supplement adequate summary description of the program, as required by 10 CFR 54.21 description (d).

54.21(d).

Conclusion. The staff reviewed the information in LRA Section B.2.3 and additional information information provided by the applicant in letters letters dated June 16, 200B,2008, June 1, 28, 2009, 1, 2009, July 2B, September 2,2009, September 4, 2, 2009, September 2009, September 8, 4,2009, B, 2009, and September 14, 2009. The September 14,2009. The staff finds that those attributes of the applicant's ASME Code Section XI, Xl, Subsection IWE IWE Program for which the applicant claimed consistency with the GALL Report Report are consistent with with the GALL Report. In addition, the staff reviewed the applicant's exception and justification and determines that the AMP, with the exception, and the additional commitments for the liner visual determines and volumetric inspection is adequate adequate to manage the aging effects for which the LRA credits it. it.

3-11 3-11

Based on its review, the staff concludes concludes that the applicant applicant has demonstrated demonstrated that the effects of of aging will be adequately aging adequately managed managed so that the intended functions will be maintained consistent consistent with the CLB for the period of extended extended operation, as required by 10 CFR 54.21(a)(3).

54.21 (a)(3).

The staff also reviewed reviewed the UFSAR supplement supplement for this AMP and concludes concludes that itit provides provides an adequate summary description of the program, program, as required required by 10 CFR 54.21 54.21(d).

(d).

3-12 3-12

SECTION 44 SECTION TIME TIME LIMITED AGING ANALYSIS LIMITED AGING ANALYSIS The staff The staff does not have does not have any changes or any changes or update update to this section to this section of of the original SER the original SER (ML091600216).

(ML091600216).

4-1

SECTION 5 REVIEW REVIEW BY THE ADVISORY COMMITTEE COMMITTEE ON REACTOR REACTOR SAFEGUARDS SAFEGUARDS The staff has provided the Advisory Committee on Reactor Safeguards with a copy of this Reactor Safeguards this Supplemental Supplemental Safety Evaluation Evaluation Report.

5-1

SECTION 6 CONCLUSION CONCLUSION The staff does not have any changes changes or update update to this section of the original SER SER (ML091600216).

(ML091600216).

6-1

'Appendix Appendix A

APPENDIX APPENDIX A BVPS UNITS UNITS 1 AND AND 2 LICENSE RENEWAL COMMITMENTS COMMITMENTS During the review of the Beaver Valley Power Station, Units 1 and 2 (BVPS) license renewal Nuclear Regulatory Commission (NRC) application (LRA) by the staff of the United States (US) Nuclear (the staff), FirstEnergy FirstEnergy Nuclear Nuclear Operating commitments related Operating Company (the applicant) made commitments to aging management programs (AMPs) to manage management programs structures and manage the aging effects of structures (SCs) both prior to and during components (SCs) extended operation. The following during the period of extended following as commitment 32 for Unit 1 and a revised commitment 33 for Unit 2, as well as tables list a revised commitment commitments 33, 34 and 35 for Unit 1 and new commitments new commitments commitments 34, 35 and 36 for Unit 2.

A-1 A-1

BVPS UNIT BVPS UNIT I1 LICENSE LICENSE RENEWAL RENEWAL COMMITMENTS COMMITMENTS Related LRA Related LRA Item Item Commitment Implementation Implementation Source Section No./

Commitment Source Section No.;

Number Schedule Schedule Comments Comments Supplemental volumetric Supplemental volumetric Unit inspections for Unit 1 inspections FENOe Letter FENOC None None 32 32 examinations will be examinations be sample lot of the initial sample L-09-205, L-09-205, performed on performed on the Unit 1 minimum of 75 aa minimum FENOC Letter FENOe Letter containment liner prior containment prior to random random ultrasonic ultrasonic L-09-242, and L-09-242, the period of extended the period extended examinations will be examinations be FENOe Letter FENOC Letter operation. minimum operation. A minimum of completed completed in the next next L-09-243 L-09-243 seventy-five (one foot seventy-five three refueling outages, randomly selected square) randomly selected beginning with the Unit beginning Unit described in FENOC (as described FENOe outage in refueling outage 1 refueling Letter L-09-205) sample 2010. The random random locations will be examined locations examined sample sample planplan will be be (as described in in FENOC FENOe completed by January completed Letter L-09-243).

L-09-243). If If 29, 2016 29,2016 degradation identified, it degradation is identified, addressed through will be addressed through corrective action the corrective action program (as described in FENOC FENOe Letter L-09-243).

Supplemental Supplemental volumetric Examinations will Examinations FENOe Letter FENOC None None 33 examinations will be examinations commence on-line, commence L-09-205, performed on the Unit 1 performed prior to the beginning beginning of FENOe Letter FENOC Letter containment containment liner. A the Unit1 Refueling Unit.1 L-09-242, and minimum of 8 non-randomly non-randomly outage inin 2010. FENOe Letter FENOC Letter selected locations will be selected Examinations will be Examinations L-09-245 L-09-245 examined, focusing on examined, completed by areas most likely to areas December 31, December 2010 31,2010 experience degradation experience degradation based on past operating operating experience described in experience (as described in FENOC Letter L-09-242). IfIf FENOe degradation is identified, itit degradation will be addressed through the corrective action program.

34 A summary of results for January January 29, 2016 FENOC Letter FENOe None None each phase of volumetric L-09-242 and testing (described in in Unit 1 FENOe Letter FENOC Commitments No. 32 and L-09-245 L-09-245 No. 33) will be documented in a letter to the NRC.

35 FENOC will evaluate ififan FENOe January 29, 2016 FENOC Letter FENOe None-appropriate/applicable appropriate/applicable L-09-242 and statistical method exists to FENOe Letter FENOC Letter gain additional insight into L-09-243 potential liner degradation.

Data gathered Data gathered will be be evaluated and used to determine the general state liner.

of the liner.

A-2

BVPS UNIT UNIT 2 LICENSE LICENSE RENEWAL RENEWAL COMMITMENTS COMMITMENTS Related Related LRA LRA Item Item Numer Commitment Implementation Impleduentto Implementation Source Section LR No./

Commitment Source Section No.1 Number Schedule Number CSchedule Comments Comments Supplemental Supplemental volumetric volumetric Examinations will FENOC Letter FENOe None None 33 examinations examinations will be commence commence by the end L-09-205, performed on the Unit 2 of the Unit 2 refueling FENOC Letter FENOe containment liner prior to outage inin 2011.

2011. The L-09-243, and the period of extended extended random sample sample plan FENOC Letter FENOe operation. A minimum of will be completed completed by L-09-244.

seventy-five (one foot seventy-five May 27, 2027 27,2027 square) randomly selected (as described described in FENOeFENOC Letter L-09-205) samplesample locations will be examined described in (as described in FENOe FENOC Letter L-09-243).

L-09-243). If If degradation degradation is identified, it it will be addressed addressed through through the corrective corrective action action described in program (as described in FENOC FENOe Letter L-09-243).

Supplemental volumetric Supplemental volumetric May 27, 2027 27,2027 FENOC FENOe Letter None None 34 examinations examinations will be L-09-205, performed performed on the Unit 2 FENOC FENOe Letter Letter containment liner. A L-09-242, and minimum of 8 non-minimum FENOC FENOe Letter Letter randomly selected L-09-245 L-09-245 locations locations will be examined, examined, focusing on areas most likely to experience experience degradation degradation based on past operating experience (as operating experience (as described described in FENOC Letter in FENOe Letter L-09-242). If If degradation degradation is identified, itit will be be addressed through the the corrective action program.

35 35 A summary summary of of results for for May 27, 2027 27,2027 FENOC Letter FENOe None None each phase of volumetric L-09-242 and testing (described in in Unit 2 FENOC Letter FENOe Letter Commitments No. 33 and L-09-245 L-09-245 No. 34) will be documented documented in a letter to the NRC.

36 FENOC will evaluate FENOe evaluate ifif an May 27, 2027 27,2027 FENOC FENOe Letter None None appropriate/applicable appropriate/applicable L-09-242 and statistical method exists to FENOC FENOe Letter Letter gain additional additional insight into L-09-243 L-09-243 potential liner degradation.

degradation.

Data gathered will be be evaluated and used to evaluated to determine the general determine state of the liner.

A-3

Appendix B

APPENDIX B APPENDIX CHRONOLOGY CHRONOLOGY This appendix lists chronologically chronologically the routine routine licensing licensing correspondence correspondence between the staff of the the United States (US) Nuclear Nuclear Regulatory Commission Regulatory Commission (NRC or the staff) and FirstEnergy Nuclear FirstEnergy Nuclear Operating Company (FENOC). This appendix also lists other correspondence Operating Company correspondence on the staffs staffs review review of the Beaver Beaver Valley Power Station (BVPS), Units 1 and 2, license license renewal application (LRA) (under Docket Nos. 50-334 50-334 and 50-412).

Dte Accession No. SUbjec June 4, 2009 ML091390631 ACRS Meeting with the U.S. Nuclear Regulatory Commission, Commission, - June 4, 2009, Slides Slides June 8, 2009 June 8,2009 ML091550506 ML091550506 License Safety Evaluation Report Related to the License Renewal of Beaver Renewal Beaver Valley Power Station, Units 1 and 2 June 17, 2009 ML091550750 ML091550750 G20090309/LTR-09-0234/EDATS:

G20090309/L TR-09-0234/EDATS: SECY SECY-2009-

-2009-0259 - Theodore Theodore Robinson Beaver Valley Robinson Ltr re: Beaver Power Power Station, Units 1 and 2, Safety Evaluation Evaluation Report June 8, 2009 June 8,2009 ML091560200 ML091560200 Release-09-105: NRC Issues Final Safety Press Release-09-105:

Beaver Valley Nuclear Evaluation Report for Beaver Nuclear Power Plant License Renewal June 8, 2009 8,2009 ML091590247 ML091590247 Release-09-105: NRC Issues Final Safety Press Release-09-105:

Evaluation Report for Beaver Evaluation Report Beaver Valley Nuclear Power License Renewal Plant License June June 8, 2009 8,2009 ML091600216 ML091600216 Safety Evaluation Report Related Evaluation Report Related to the License License Renewal of Beaver Renewal Beaver Valley Power Station, Units 1 and 2 July 1, 2009 ML091910134 ML091910134 Citizen Power Ltr. re: Reply to June 17 17 Letter to Ted Robinson Robinson in Connection with Liner Degradation Degradation Problems Problems at Beaver Nuclear Station Beaver Valley Nuclear July 14, 2009 2009 ML091960450 ML091960450 FENOC Report on Containment FENOC Report Containment Liner, Part 2 July 7, 2009 7,2009 ML091900719 ML091900719 Concerns Regarding Concerns Regarding the Containment Containment Liner at Beaver Valley Power Power Station, Units 1 & &2 July 15, 2009 July 15, 2009 ML091960496 ML091960496 Beaver Valley, Beaver Unit 1, Valley, Unit 1, Cover Cover Letter Letter for FENOC for FENOC Report July 15, 2009 ML091960519 ML091960519 FENOC Report on Containment Liner, Part 3 B-1 8-1

• " Date Accession N--. Subject July 15, 2009 ML091960562 FENOC Report Report on Containment Containment Liner, Part 4 July 15, 2009 ML091960569 ML091960569 FENOC Report on Containment Liner, Part 5 July 28, 2009 ML092110117 ML092110117 Beaver Valley, Units 1 &

Beaver & 2 - Supplemental Information Review of License Information for the Review License Renewal Application Application and License Renewal Renewal Application Amendment No. 39 Amendment 39 August 6, 2009 ML092180038 ML092180038 Docketing of NRC Teleconference Teleconference Notes Pertaining Pertaining to the License Renewal Beaver Valley Power Renewal of the Beaver Station, Units 1 and 2 August 6, August 6, 2009 2009 ML092180378 ML092180378 Transcript of NRC License Renewal Transcript of Renewal Teleconference Teleconference Held on July 16, 2009 August 10, 2009 ML092190384 ML092190384 Letter to Citizens Power dated August 10, 2009, Response to July 7,2009, 7, 2009, Regarding Regarding Concerns Concems with Containment Containment Liners at Beaver Valley Units 1 & & 2, and Belief Proposed Proposed Inspection Techniques are Insufficient Given Insufficient Given Discovery of Corrosion Went Through-Wall August 11, 2009 August 11, 2009 ML092180206 ML092180206 Docketing of Docketing of NRC Teleconference Teleconference Notes Pertaining Notes Pertaining to the License Renewal of the Beaver Valley Power Power Station, Units 1 and 2 August 11, 11, 2009 ML092180214 ML092180214 Docketing of Docketing of NRC NRC Telephone Telephone Conference Notes Conference Notes Pertaining Pertaining to the License Renewal of the Beaver Valley Power Station, Units 1 and 2 August 12, 2009 August 12, 2009 ML092180557 ML092180557 Conference Call -- Containment Conference Call Liner Corrosion Containment Liner Corrosion --

Friday, July 24, 2009 11 11:30

30 a.m September 2,2009 2, 2009 ML092510168 ML092510168 Beaver Valley, Units 1 & & 2 - Supplemental Information for the Review of License Renewal Application and License License Renewal Application Renewal Application Amendment No. 40 Amendment September 4, 2009 4,2009 ML092530241 ML092530241 Beaver Valley, Units 1 & & 2 - Supplemental Information for the Review License Renewal Review of License Application and License License Renewal Application Renewal Application Amendment No. 41 Amendment September 8, 2009 ML092510226 ML092510226 Docketing of U.S Commission U.s Nuclear Regulatory Commission Teleconference Teleconference Notes Pertaining to Notes Pertaining to the the License License Renewal of the Beaver Valley Power Station, Units 1 and 2 September 8, September 8, 2009 2009 ML092510254 ML092510254 Transcript of U.S.

Transcript of Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Teleconference Teleconference held on August 26, 2009 26,2009 B-2 8-2

Date ' I Accession No.

• Subject September 8, 2009 ML092510260 Docketing Docketing of U.S. Nuclear Nuclear Regualtyory Regualtyory Commission Commission Teleconference Teleconference Notes Pertaining License Pertaining to the License Renewal of the Beaver Valley Power Power Station, Units 1 and 2 September 8, 2009 September ML092530242 ML092530242 Beaver Valley, Units 1 & 2 - Supplemental Information for the Review of License Information License Renewal Application Application and license License Renewal Renewal Application Amendment Amendment No. 42 September September 9, 2009 ML092520067 ML092520067 Docketing Commission Docketing of U.S. Nuclear Regulatory Commission Teleconference Pertaining to the license Teleconference Notes Pertaining License Renewal of the Beaver Valley Power Power Station, Units 1 and 2 September 9, September 2009 9,2009 ML092520166 ML092520166 Nuclear Regulatory Docketing of U.S. Nuclear Regulatory Commission Commission Teleconference.

Teleconference* Notes Pertaining License Pertaining to the License Renewal of the Beaver Valley Power Power Station, Units 1I and 2 (Enclosure)

September 14, 2009 September ML092590047 ML092590047 Beaver Valley, Units 1 and 2 - Supplemental Information for the Review Information Review of License Renewal Application Application and license Renewal License Application Renewal Application Ammendment Ammendment 43 B-3 8-3

NRC FORM 335 NRC U.S. NUCLEAR REGULATORY COMMISSION 1.REPORT NUMBER

1. NUMBER

,[9-2004)

..:10041 (Astlind (AssIgned by NRC, Add Val., Vol., Supp.,

Supp.* Rev.,

NRCQ0A NRCt.O:U 3.7 and Addendum Addendum Num.ers, Numbenl, if any.1 if any.

BIBLIOGRAPHIC BLG DATA SHEET BIBLIOGRAPHIC P DATAncko.

DATA SE SHEET f reverseNUREG.1929, Volumes I and 2, NUREG*1929, Volumes 1 and 2, (se* malnuans on te Ie~ee) Supplement 1 Supplement 1 2.TITLE

2. TITLE AND SUBTITLE 3. DATE

3. DATE REPORT PUBLISHED REPORT PUBLISHED Safety Evaluation Report Safety Evaluation Report Related Related to the License License Renewal Renewal of of Beaver Beaver ValleyValley Power Station, Units Power Station, Units MONTH yEAR YMONH VEAR 1 and 2 October October i 2009 2009

4. FIN OR GRANT NUMBER

4. NUMBER

5. AUTHOR(S)

S. 6.

B. TYPE OF REPORT Kent l.L. Howard

7. PERIOD PERIOD COVERED (Inclusive (nruve DafBs) Detes)

June June 8, 8, 2009-2009- Sept. Sept. 14, 14, 2009 2009

8. PERFORMING

8. ORGANIZATION *- NAME AND ADDRESS (IINRC, PERFORMING ORGANIZATION /11 NRC, pm'ide provide l)ivi$io<!. OeoiOfRat*on, Divion. 0fIicD Region, U.S NuciearRRIlguJa/Drt U.s. NvcJcBf tutatory Conmsnba, nff CcMmiI;t;iotI, and mailing adlms,,ifloreCtor.

IIddta1is; if conIrBClol',

pionide anldmaikii It6I11S IJnd provide "4117 addess.)

I'fIIliIing odr1teu)

Division of License Renewal Nuclear Reactor Office of Nuclear Regulation Reactor Regulation U.S.. Nuclear U.S. Regulatory Commission Nuclear Regulatory Commission Washington, DC 20555-0001

9. SPONSORING ORGANIZATION*

9. SPONSORING ORGANIZATION - NAME NAME AND ADDRESS (it F*RCtype 'Sam (II NRC, 'Same liS as abo\l8'; c*ntactro, proVIdfJ above*' if contracW, piovdo NRC Dvon,0IIIce NRC DIviiton, Office orRion, U.S Nudear 01' Region, U.S. Regulatory 'CommIssion, NUf:ilMJf FtlkoyrComrndsman.

an,d mailing eddross.)

and maEVng /Jdc1Ios$.j ,

Same as above

10. SUPPLEMENTARY SUPPLEMENTARY NOTES NOTES

11. ABSTRACT

11. ABSTRACT (200 200 IOOIlIs wards ortess) or less)

This This supplemental supplemental safety safety evaluation evaluation reportreport (SSER) documents the technical (SSER) documents review of the technical review the Beaver Beaver Valley Power Station (BVPS),

Units 11 and Units and 2, license renewal 2, license renewal application application (LRA)(LRA) by the United by the United States (US) (US) Nuclear Regulatory Commission (NRC) staff (staff).

Nuclear Regulatory By letter By letter dated dated August August 27, 2001, 2007, FirstEnergy Nuclear Nuclear Operating Company (FENOC or the applicant) submitted the LRA in in accordance accordance with with Title Title 10, 10, Part 54, of Part 54. the Code of the Code of of Federal Regulations, "Requirements Federal Regulations, "Requirements for Renewal of Operating Licenses for Operating Ucensesfor Nuclear Power Nuclear Power Plants." Plants." FENOC requests renewal FENOC requests renewal of the Units Units 1 and 2, operating operating licenses licenses (Facility Operating License (Facility Operating License Numbers Numbers DPR-66 and DPR-66 and NPF-73, respectively) for NPF-73. respectively) for aa period period of 20 years of 20 years beyond the the current current expirations expirations at midnight midnight JanuaryJanuary 29,201629, 2016 for Unit 1, and 1, and midnight midnight May May 27,2027.

27, 2027, for for Unit Unit 2.2. This This SSER only provides provides changeschanges to the June June 2009 SER. SER.

This This SSER SSER documents documents the the NRCNRC staffs staffs evaluation evaluation of of information information provided provided by by the applicant applicant on supplemental supplemental volumetric volumetric examinations examinations of of thethe BVPS, BVPS,Units .Units 11 and and 22 containment containment liners. liners. The applicant provided The applicant provided additional additional information information regarding regarding examinations of examinations of the Units 1 the Units and 22 containment l' and containment liners liners asas aa result result of discussions discussions during during the AdviSOry Advisory Committee Committee of Reactor Reactor Safeguards meeting Safeguards meeting held held inin July July 2009 and by letters dated July 28, 28, 2009, 2009, September September 2; 2, 2009, September 4, 2009, September 2009. September 8, 2009, and 8.2009, September 14.

and September 14, 2009.

2009.

12. KEY

12. KEY WORDS/DESCRIPTORS WORDSIDESCRIPTORS lUst itjst words or phrases WOtUS Of phrasesthat that will wit/ass toa,-fo;in sS$i$l rf1SCDrclTor.; ,ocawtng tho iflloc4!/lng repaot.)

tho repotl,) 13. AVAILABILITY STATEMENT AVAILABILITY STATEMENT 10 CFR Part 10 Part 54, license renewal.

54, license Beaver Valley renewal, Beaver Valley Power Station, seoping Power Station, scoping and screening, aging and screening. aging unlimited management, time-limited management. time-limited aging aging analysis, safety evaluation analysis. safety evaluation report, Supplement 11 report, Supplement 14, SECURITY

14. SECURfTYCLASSIFICAnoN

.~...

CLASSIFICATION

. .*.*M.*_**__ **.. **_*_*_*** _" ....

(Thi Poage.

(ThiS 1'Dge) unclassified

"

(ThiSRepotlJ (Tl!iJ ePOPt) unclassified unclassified

15. NUMBER

16. NUMBER OF PAGES PAGES 16.

16. PRICE PRICE NRC FORM 335 (9.2004) PRINTED ON RECVCLED PRINTED RECYCLED PAPER PAPER

6 FSmeI pan"u.cySS "pm Recycling PnJgrom Foderal Recycling Program

NUREG-1929, NUREG-1929,Vols. I and Vols. 2 2 1 and Safety Evaluation Report Related to the License Renewal of SafetyBeaver EvaluaValley tion Report October 2009 Supplement I Supplement 1 PowerRelated Station,toUnits the License I and 2Renewal of Beaver Valley Power Station, Units 1 and 2 October 2009 UNITED STATES UNITED STATES NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION WASHINGTONDC WASHINGTON, 20555-0001

, DC 20555-0001 OFFICIAL BUSINESS OFFICIAL BUSINESS