ML080640216

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

ML080640216
Person / Time
Site:	Beaver Valley
Issue date:	03/05/2008
From:	Kent Howard NRC/NRR/ADRO/DLR
To:	Sena P FirstEnergy Nuclear Operating Co
HOWARD, KENT, NRR/ADRO/RPB2, 415-2989
References
TAC MD6593, TAC MD6594
Download: ML080640216 (11)

Text

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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NO. MD6593, MD6594)

Dear Mr. Sena:

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

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

Docket Nos. 50-334 and 50-412

Enclosure:

As stated

cc w/encl: See next page

ML080640216 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME SFigueroa (MSayoc for) KHoward RFranovich DATE 3/4/08 3/4/08 3/5/08 BEAVER VALLEY POWER STATION (BVPS), UNITS 1 AND 2 LICENSE RENEWAL APPLICATION (LRA) REQUEST FOR ADDITIONAL INFORMATION (RAI)

RAI #1 Tables 4.2-5 and 4.2-6 of the Beaver Valley License Renewal Application (LRA) lists Chemistry Factor (CF) and pressurized thermal shock (PTS) reference temperature (RT PTS) values for several reactor vessel (RV) beltline materials that were calculated in accordance with both Regulatory Positions (RPs) 1.1 and 2.1 of Regulatory Guide (RG) 1.99, Rev. 2. Only one of these two RPs may be used for determining the actual CF, adjusted reference temperature (ART), and RTPTS values for each material. Therefore, please indicate which RP (RP 1.1 or RP 2.1) was used in determining the actual CF, ART, and RT PTS values for the RV beltline materials. Please provide justification for the selection of RP 1.1 or 2.1 for each material, based on factors such as surveillance data credibility or non-credibility, conservatism of RP 2.1 data, or other factors (i.e., NRC recommendation that non-credible surveillance data be used for calculating the CF for limiting plate B6903-1 with full ? margin of 17 °F).

RAI #2 For Beaver Valley, Unit 1 (Beaver Valley 1), the staff noted several discrepancies among LRA Section 4.2.2, LRA Table 4.2-5, Appendix D of WCAP-15571, "Analysis of Capsule Y from First Energy Company Beaver Valley Unit 1 Reactor Vessel Radiation Surveillance Program, Rev. 0" (Surveillance Data Credibility Analysis), and WCAP-15571, Supplement 1, regarding the application of surveillance data for determining the RTPTS value for Intermediate Shell Longitudinal Weld 19-714 (Heat 305424).

First, Page D-5 of Appendix D of WCAP-15571 states: "The surveillance weld [Heat 305424] has two out of four data points outside the 28 °F scatter band. Hence, the surveillance data is not credible." Please reconcile this statement with the statement in the second paragraph of Page 4.2-6 of the LRA, which indicates that the "data for the Unit 1 surveillance program weld material is deemed credible" and the similar statement in Section 6.1 of Supplement 1 to WCAP-15571 indicating that "the data for the surveillance program weld material is deemed credible." It should be noted in reconciling these statements that Intermediate Shell Longitudinal Weld 19-714 (Heat 305424) is represented in the Beaver Valley 1 surveillance program. However, a review of Appendix D of WCAP-15571 shows that two of the four surveillance data points (Capsules "V" and "Y") fall outside of the 28 °F ?RT NDT scatter band. Therefore, the surveillance weld data is not credible, and the CF for Weld 19-714 must be determined using RP 1.1.

Second, the second paragraph of Page 4.2-6 of the LRA states that the data for the Beaver Valley 1 surveillance program weld material was "used with a OL115\f"SymbolPropBT"\s11

? margin of 14 °F." Likewise, Section 6.1 of Supplement 1 to WCAP-15571 indicates that "The [surveillance program weld] data was used with a ? margin of 14 °F." Please reconcile these statements with the 28 °F value for ? presented in Table 4.2-5 for Intermediate Shell ENCLOSURE Longitudinal Weld 19-714, based on RP 2.1. It should be noted that, per RG 1.99, Rev. 2, the correct value for ? is 28 °F, based on RP 1.1, and the use of RP 2.1 is not permitted for this weld because the surveillance data is not credible. Furthermore, the use of a ? value of 14 °F is not permitted because the surveillance data is not credible.

RAI #3 Intermediate-to-Lower Shell Circumferential Weld 11-714 (Heat 90136) and Lower Shell Longitudinal Weld 20-714 (Heat 305414) are not represented in the Beaver Valley 1 surveillance program. However, CF and RTPTS values based on RP 2.1 were reported in Table 4.2-5 for these welds. Please confirm whether the heats for these welds are represented in the surveillance programs for St. Lucie (Heat 90136) and Fort Calhoun (Heat 305414).

The staff reviewed Revision 4 of the Beaver Valley 1 Pressure-Temperature Limits Report (PTLR), which was referenced in the LRA (LRA Section 4.2.6, Reference 4.2-8). Table 4.2-4a of the Beaver Valley 1 PTLR provides a note indicating that the use of the St. Lucie and Fort Calhoun surveillance capsule data was approved by the NRC by letter dated February 20, 2002. Per your response to RAI Question 1, please indicate whether this surveillance data was used (per RP 2.1) in the determination of the actual CF, RT PTS, and ART values for these welds. Please verify whether these surveillance data sets were deemed credible in accordance with RG 1.99, Rev. 2, and provide references for the documents where the analyses for determining credibility (or non-credibility) may be found.

Please indicate whether the CFs for these welds based on RP 2.1 (84.8 for Intermediate-to-Lower Shell Circumferential Weld 11-714 and 223.9 for Lower Shell Longitudinal Weld 20-714) were calculated by adjusting the measured ?RT NDT values by the ratio of the CF for the vessel weld to the CF for the surveillance weld, as prescribed in RG 1.99, Rev. 2. If the ?RT NDT values were properly adjusted for determining these CF values, please provide the CF ratio adjustment factors for these welds or a reference for the document where these adjustment factors may be obtained. If the ?RT NDT values were not adjusted for determining these CF values, please modify the Beaver Valley 1 PTLR and LRA Table 4.2-5 to include CF calculations based on RP 2.1 for these welds that account for this adjustment.

RAI #4 Table 4.2-5 of the Beaver Valley 1 PTLR (Rev. 4) states that the CF for Lower Shell Plate B6903-1 is 147.2 (based on RP 1.1). This is the incorrect CF for this plate, per the February 12, 1998 NRC-Industry meeting, where the NRC recommended that the non-credible surveillance data for this specific plate be used along with a full ? of 17 °F for RT PTS and ART calculations. LRA Section 4.2.2 accurately reflects that the non-credible surveillance data and full ? of 17 °F were used to arrive at a 54 effective full power year (EFPY) RT PTS value of 275.7 °F, based on a RP 2.1 CF value of 149.2. Furthermore, Table 4.2-7 of the PTLR provides ART calculations for this limiting plate that are based on the correct CF value of 149.2 and states that these calculations are based on the non-credible plate surveillance data and full ? of 17 °F. Please

modify Table 4.2-5 of the Beaver Valley 1 PTLR to reflect the correct CF (149.2) for Lower Shell Plate B6903-1. The application of surveillance data and selection of CFs for calculation of RT PTS and ART values in the Beaver Valley 1 PTLR should be consistent with the LRA.

RAI #5 LRA Section 4.2.2 states that a neutron flux management program is in place at Beaver Valley 1 for ensuring that the limiting material would meet the PTS screening requirements of 10 CFR 50.61 at the end of the current 40-year license term. Please verify whether the limiting material is projected to exceed the 270 °F screening limit of 10 CFR 50.61 in the year 2033 (43.87 EFPY) under this same flux management program. If the current flux management program will not maintain the limiting material below the PTS screening limit until 2033 (43.87 EFPY), please discuss any additional measures that are required to ensure that the limiting material does not exceed the PTS screening limit until 2033 (43.87 EFPY).

LRA Section 4.2.2 states that documentation of a flux reduction program for Beaver Valley 1 will be submitted in accordance with the requirements of 10 CFR 50.61. The staff requests that you provide a formal commitment to submit the appropriate documentation of your program for maintaining the limiting RV beltline plate (Plate B6903-1) below the 10 CFR 50.61 PTS screening criterion through the end of the period of extended operation (54 EFPY). This commitment must include a schedule for submitting this documentation relative to the projected date (year 2033, 43.87 EFPY) when the limiting material will exceed the 270 °F PTS screening limit.

Note: For the Palisades LRA, which documented a similar situation regarding PTS, the licensee provided Long Term Commitment No. 3, which reads as follows:

At the appropriate time, prior to exceeding the PTS screening criteria, Palisades will select the optimum alternative to manage PTS in accordance with the NRC regulations and make relevant submittals to obtain NRC review and approval.

RAI #6 The staff noted that the 54 EFPY Upper Shelf Energy (USE) value for the limiting plate at Beaver Valley 1 (Plate B6903-1) may be slightly less than 50 ft-lbs (lowest allowable USE value at EOL per 10 CFR Part 50, Appendix G), when calculated using Figure 2 from RG 1.99, Rev. 2, without applying the surveillance data. Please discuss why the surveillance data were deemed credible for determining the USE value for this plate, based on the five credibility criteria specified in Section B of RG 1.99, Rev. 2.

RAI #7 A review of Appendix D of WCAP-16527-NP indicates that the data for the surveillance weld at Beaver Valley 2 (Heat No. 83642) were not adjusted by the ratio of the CF for the vessel weld to

the CF for the surveillance weld, as prescribed in RG 1.99, Rev. 2. Please verify that the copper and nickel content of the surveillance weld is identical to that for all vessel welds at Beaver Valley 2. If there is a difference between the chemistry of the surveillance weld and that of the vessel welds, please modify LRA Section 4.2.2, LRA Table 4.2-6, and the Beaver Valley 2 PTLR to account for the CF ratio adjustment.

RAI #8 LRA Section 4.2.2, LRA Table 4.2-6, and WCAP-16527-NP, Supplement 1 all incorporate data from the evaluation of surveillance capsules "U", "V", "W" and "X" for Beaver Valley 2. However the Beaver Valley 2 PTLR (Rev. 2) only incorporates data from the evaluation surveillance capsules "U", "V", and "W". As the Beaver Valley 2 PTLR forms part of the basis for the Beaver Valley LRA, the staff requests that you update the Beaver Valley 2 PTLR to incorporate the results from the evaluation of surveillance capsule "X". The application of surveillance data and selection of CFs for calculation of RTPTS and ART values in the Beaver Valley 2 PTLR should be consistent with the LRA.

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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NO. MD6593, MD6594)

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

Beaver Valley Power Station, Units 1 and 2 cc: Joseph J. Hagan President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308

James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

David W. Jenkins, Attorney FirstEnergy Nuclear Operating Company Mail Stop A-GO-15 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308

Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-A P.O. Box 4, Route 168 Shippingport, PA 15077

Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305

Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573

Director, Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA 17110-9364

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803

Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection

Beaver Valley Power Station, Units 1 and 2 cc: Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077

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

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