ML091940215

Audit Summary Regarding the License Renewal Application for Beaver Valley Power Station, Units 1 and 2

ML091940215
Person / Time
Site:	Beaver Valley
Issue date:	08/24/2008
From:	Kent Howard License Renewal Projects Branch 2
To:	Sena P FirstEnergy Nuclear Operating Co
Howard K, NRR/DLR/RPB2, 415-2989
References
Download: ML091940215 (6)

Text

August 24, 2009 Mr. Peter P. Sena, III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

AUDIT

SUMMARY

REGARDING THE LICENSE RENEWAL APPLICATION FOR BEAVER VALLEY POWER STATION, UNITS 1 AND 2

Dear Mr. Sena:

By letter dated August 27, 2007, FirstEnergy Nuclear Operating Company submitted an application for review by the U.S. Nuclear Regulatory Commission (NRC) pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) to renew the operating license for Beaver Valley Power Station, Units 1 and 2 (BVPS). On June 26, 2009, the NRC staff completed an audit of the process used in the cycle counting reconstitution related to metal fatigue evaluation at the BVPS. The audit summary is enclosed.

If you have any questions, please contact me at 301-415-2989 or by e-mail at Kent.Howard@nrc.gov.

/RA/ Kent Howard, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations Docket Nos. 50-334 & 50-412

Enclosure:

As stated cc w/encl: See next page August 24, 2009 Mr. Peter P. Sena, III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

AUDIT

SUMMARY

REGARDING THE LICENSE RENEWAL APPLICATION FOR BEAVER VALLEY POWER STATION, UNITS 1 AND 2

Dear Mr. Sena:

By letter dated August 27, 2007, FirstEnergy Nuclear Operating Company submitted an application for review by the U.S. Nuclear Regulatory Commission (NRC) pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) to renew the operating license for Beaver Valley Power Station, Units 1 and 2 (BVPS). On June 26, 2009, the NRC staff completed an audit of the process used in the cycle counting reconstitution related to metal fatigue evaluation at the BVPS. The audit summary is enclosed.

If you have any questions, please contact me at 301-415-2989 or by e-mail at Kent.Howard@nrc.gov. /RA/ Kent Howard, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations

Docket Nos. 50-334 & 50-412

Enclosure:

As stated

cc w/encl: See next page DISTRIBUTION

See next page

ADAMS Accession Number: ML091940215 OFFICE LA:DLR PM:RPB2:DLR BC:RPB1:DLR BC:RPB2:DLR NAME IKing KHoward JDozier DWrona DATE 07/15/09 07/27/09 07/31/09 08/06/09 OFFICE OGC PM:RPB2:DLR NAME LSubin (NLO) KHoward (Signature) DATE 08/12/09 08/24/09 OFFICIAL RECORD COPY Letter to Peter P. Sena from Kent Howard dated August 24, 2009

SUBJECT:

AUDIT

SUMMARY

REGARDING THE LICENSE RENEWAL APPLICATION FOR BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DISTRIBUTION

HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRer1 Resource RidsNrrDlrRer2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource ------------- KHoward ESayoc NMorgan MModes, RI PCataldo, RI DWerkheiser, RI ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL AUDIT

SUMMARY

REGARDING THE LICENSE RENEWAL APPLICATION FOR THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2 Docket Nos: 50-334 & 50-412

License Nos: DPR-66 & NPF-73 Applicant: FirstEnergy Nuclear Operating Company, Inc. (FENOC)

Location: NPOC Offices 11426 Rockville Pike, Suite 230 Rockville, MD 20852

Date: June 26, 2009 NRC Staff: K. Howard, Project Manager, Division of License Renewal (DLR) C. Yang, Sr. Mechanical Engineer, DLR A. Hiser, Senior Technical Advisor, DLR O. Yee, Mechanical Engineer, DLR Licensee Staff: C. Custer, License Renewal Manager, FENOC C. Mancuso, FENOC L. Hinkle, FENOC S. Buffington, FENOC

Approved By: David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Jerry Dozier, Chief Engineering Review Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Introduction On August 27, 2007, FirstEnergy Nuclear Operating Company (FENOC or the applicant) submitted a license renewal application (LRA) for the Beaver Valley Power Station, Units 1 and 2 (BVPS). The Safety Evaluation Report of the BVPS LRA, dated June 2009 (ML091600216) describes the use of transient cycle counting in the BVPS "Metal Fatigue of Reactor Coolant Pressure Boundary Program." During a meeting with the Advisory Committee of Reactor Safeguards (ACRS) license renewal subcommittee on February 4, 2009, ACRS members questioned the methodology used by the applicant to project transient cycles for use in evaluating metal fatigue of critical reactor coolant system (RCS) locations. During this discussion at the ACRS meeting, the applicant identified that it was completing a "reconstitution" of the heat-up (and cool-down) cycle history for BVPS, which would be used as a benchmark for future cycle accumulation as the units operated. Since the number of transient cycles experienced by RCS materials is directly tied to the fatigue usage by the material, the accuracy of the cycle count is critical to the accuracy of the determination of fatigue usage.

On June 26, 2009, the U.S. Nuclear Regulatory Commission (NRC or the staff) staff conducted an audit of this cycle reconstitution by the applicant. The focus of the audit was to gain understanding of the process used by the applicant in its cycle reconstitution, in particular through review of data for time periods when this reconstitution identified fewer cycles than a previous analysis completed in 2003.

In performing this audit, the NRC staff examined the data used by the applicant in its cycle reconstitution, including data used to substantiate the 2003 analysis and that used in the reconstitution. The NRC staff also interviewed FENOC representatives to obtain additional clarification related to the reconstitution. This summary documents the NRC staff activities during this audit.

Cycle Count Reconstitution During its audit, the NRC staff reviewed numerous documents, as listed below, and interviewed FENOC representatives regarding the methodology used in the reconstitution process.

DOCUMENT T ITLE R EVISION Westinghouse calculation note, OPES(99)-044 Beaver Valley Power Station, Units 1 and 2 Historic Transient Baseline Revision 0 (Dated 4/3/2000) Letter to U.S. Nuclear Regulatory Commission providing Beaver Valley Power Station, Units 1 and 2 Monthly Operating Report Beaver Valley Power Station, Units 1 and 2 Monthly Operating Reports, covering period from 1996 to 1999 Revision 0 FENOC representatives described the source of the initial cycle count histogram, identified as "2003 Count" (hereinafter "previous data") in the attached figure, as coming from the Westinghouse calculation listed above. In the course of reviewing the previous data, the applicant identified errors in the data and decided to reanalyze ("reconstitute") the heat-up and cool-down transients for both BVPS units. The results of this reconstitution are illustrated in the attached figure as "Actual" counts of the cycles for Unit 1. The reconstitution results in a reduction of 11 cycles for Unit 1 and a minimal change in the number of cycles for Unit 2.

During the audit, the staff compared the historic records of thermal events (mainly operating Mode changes during heat-up and cool-down operations) that can be identified in BVPS "Monthly Operating Reports" (MOR) against those described in Appendix A of the Westinghouse calculation. The data in Appendix A of the Westinghouse calculation is the basis for the "2003 Count" cycle count histogram illustrated in the attached figure. As described by the applicant, the cycle counts identified in Appendix A of the Westinghouse calculation represent a composite of plant operating data from different sources, including procedure sheets from the control room. However, in preparing Appendix A of the Westinghouse calculation, the time stamp information for the procedure sheets from the records at BVPS, was used to indicate implementation of the procedure, as opposed to the actual time when the procedure was implemented. The problem identified by the applicant is that this time stamp information indicates, in some cases, mode changes that are neither consistent with nor comport with other reported information, such as that provided in the MORs. Specifically, the temporal mismatch between the time stamps and other records, for example the MORs, resulted in time gaps that were accommodated by assumptions of intermediate mode changes in the plant operating condition in Appendix A of the Westinghouse calculation. In Appendix A of the Westinghouse calculation, the assumption of an intermediate mode change in the plant operating conditions resulted in the identification of "extra" thermal events that were mistakenly counted as accrued cycles. This was an incorrect interpretation of the temporal mismatch between the time stamps and other records.

The staff verified the validity of these incorrect interpretations by reviewing the records of interest for most months of 1996 and 1997, and a few in 1998, because it was in this three-year time frame that the discrepancy between the 2003 count and reconstitution achieved the disparity between the two counts. After 1999, the two curves became parallel indicating equivalent counts between the two analyses. By 2003, the total number of Unit 1 heat-up cycles accrued was 111 based on the 2003 counting but it was reduced to 100 based on the 2009 reconstitution.

The staff's review focused on time periods in which the 2003 count (from Appendix A of the Westinghouse calculation) indicated a heat-up condition at the plant, but the reconstitution did not. In the cases examined, the MOR for the time period generally indicated that the plant was in Mode 1 operating at 100 percent or a somewhat lower power level. No mode changes, trips or other transient activities were identified in the MORs in these instances. For comparison, the staff reviewed other MORs where outages had occurred and noted the high level of detail provided for mode and power changes in the MOR for these instances. Based on this comparison, the staff gained confidence that the applicant's approach for the reconstitution appropriately dispositioned the actual plant condition during the time period when the disparity in cycle counts developed.

The staff notes that the reconstitution for the early periods of plant operation identified more cycles than the prior 2003 data; in addition, the applicant also identified an additional cycle during one of the time periods reviewed by the staff. The specific instance was during a power ascension period for which the applicant reviewed strip chart records of RCS temperature to identify the additional thermal cycle.

The applicant provided adequate responses to all of the audit team's questions and concerns.

B V-1 2009 Event Reconstitution 0 50 100 150 2000246810 121416 18 2022 24 26 283032 34363840 424446 48 50 52 54 56 58 60YearsofServiceHeatup Events 2003 Count Actual109 Thru 12/31/20082 events per year4 events per year final 10 years of operation183 - final projection116 thru 10/15/2003 Figure 4 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

Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 David W. Jenkins, Attorney FirstEnergy Corporation 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 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

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

Steve Dort 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