ML20079F816

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Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 Regarding Weld Examination Coverage for the Fourth Inservice Inspection Interval
ML20079F816
Person / Time
Site: Beaver Valley
Issue date: 03/26/2020
From: Jennifer Tobin
Plant Licensing Branch 1
To: Penfield R
Energy Harbor Nuclear Corp
Tobin J
References
EPID L-2019-LLR-0083
Download: ML20079F816 (12)


Text

March 26, 2020 Mr. Rod Penfield Site Vice President Energy Harbor Nuclear Corp.

Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NO. 1 - RELIEF REQUESTS 1-TYP-4-C2.21-1 AND 1-TYP-4-RA-1 REGARDING WELD EXAMINATION COVERAGE FOR THE FOURTH INSERVICE INSPECTION INTERVAL (EPID L-2019-LLR-0083)

Dear Mr. Penfield:

By letter dated August 23, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19238A056), FirstEnergy Nuclear Operating Company (the licensee)1 requested relief from certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV Code),Section XI. Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 pertain to examination coverage of Class 2 vessel welds and Class 1 and 2 pipe welds at the Beaver Valley Power Station (Beaver Valley),

Unit No. 1.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iii),

the licensee requested relief from the required examination coverage and to use alternative requirements (if necessary) for inservice inspection of the vessel and pipe welds on the basis that the ASME BPV Code requirements are impractical.

The U.S. Nuclear Regulatory Commission (NRC) staff has concluded that the proposed alternative in Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative for the fourth 10-year inservice inspection interval, which began on April 1, 2008, and ended on August 28, 2018.

All other ASME BPV Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

1 On February 27, 2020, the NRC approved an order and conforming amendments for the license transfer from FirstEnergy Nuclear Operating Company to Energy Harbor Nuclear Corp. (ADAMS Accession No. ML20030A440).

R. Penfield If you have any questions, please contact the Beaver Valley Project Manager, Jennifer Tobin, at 301-415-2328 or Jennifer.Tobin@nrc.gov.

Sincerely,

/RA/

James G. Danna, Chief Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-334

Enclosure:

Safety Evaluation cc: Listserv

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING RELIEF REQUESTS 1-TYP-4-C2.21-1 AND 1-TYP-4-RA-1 REGARDING WELD EXAMINATION COVERAGE ENERGY HARBOR NUCLEAR CORP.

ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION, UNIT NO. 1 DOCKET NO. 50-334

1.0 INTRODUCTION

By letter dated August 23, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession ML19238A056), FirstEnergy Nuclear Operating Company (the licensee)1 requested relief from certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV Code or Code),Section XI. Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 pertain to examination coverage of Class 2 vessel welds and Class 1 and 2 pipe welds at the Beaver Valley Power Station (Beaver Valley),

Unit No. 1.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iii),

the licensee requested relief from the required examination coverage and to use alternative requirements (if necessary), for inservice inspection (ISI) of the vessel and pipe welds on the basis that the ASME BPV Code requirements are impractical.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(g)(4)(ii), ISI of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the ASME BPV Code, incorporated by reference in 10 CFR 50.55a(a), 12 months before the start of the 120-month inspection interval (or the optional ASME Code Cases listed in Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, when using ASME Code,Section XI, as incorporated by reference in 10 CFR 50.55a(a)(3)(ii)), subject to the conditions listed in 10 CFR 50.55a(b).

1 On February 27, 2020, the NRC approved an order and conforming amendments for the license transfer from FirstEnergy Nuclear Operating Company to Energy Harbor Nuclear Corp. (ADAMS Accession No. ML20030A440).

Enclosure

Pursuant to 10 CFR 50.55a(g)(5)(iii), if the licensee has determined that conformance with ASME Code requirements is impractical for its facility, the licensee must notify the U.S. Nuclear Regulatory Commission (NRC or the Commission) and submit, as specified in 10 CFR 50.4, information to support the determinations. Determinations of impracticality in accordance with 10 CFR 50.55a must be based on the demonstrated limitations experienced when attempting to comply with the ASME Code requirements during the ISI interval for which the request is being submitted. Requests for relief made in accordance with 10 CFR 50.55a must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.

Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations under 10 CFR 50.55a(g)(5) that ASME Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the NRC to grant the relief requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Background

By letter dated March 23, 2011 (ADAMS Accession No. ML110630403), the NRC approved implementation of the risk-informed ISI (RI-ISI) program for the Class 1 pipe welds and the Class 2 pipe welds in the fourth 10-year ISI interval of Beaver Valley, Unit No. 1. The licensee developed the Beaver Valley RI-ISI program in accordance with methodology described in WCAP-14572, Revision 1-NP-A, Westinghouse Structural Reliability and Risk Assessment (SRRA) Model for Piping Risk-Informed Inservice Inspection.

3.2 Component Affected In its letter dated August 23, 2019, the licensee submitted Relief Request 1-TYP-4-C2.21-1 as Enclosure A and 1-TYP-4-RA-1 as Enclosure B. The licensee identified the affected welds in Table 1 of both enclosures to the letter, which are listed below.

Enclosure A: Three Class 2, Category C-B, Item Number C2.21 nozzle-to-vessel welds in two vessels:

Safety injection boric acid tank nozzle-to-vessel weld SI-TK-2-N-3 Safety injection boric acid tank nozzle-to-vessel weld SI-TK-2-N-4 Steam generator nozzle-to-vessel weld RC-E-1A-N-9 Enclosure B: Seven Class 1 and 2, Category R-A, Item Number R1.11 piping welds:

Residual heat removal pipe segment-to-isolation valve weld RH-1-3-F-04 Residual heat removal pipe segment-to-isolation valve weld RH-1-3-F-05 Residual heat removal pump outlet-to-pipe reducer weld RH-4-1-F-01

Residual heat removal discharge valve-to-pipe reducer weld RH-4-1-F-02 Residual heat removal pump outlet-to-pipe weld RH-5-1-F-01 Residual heat removal discharge valve-to-pipe reducer weld RH-5-1-F-02 Refueling water storage tank flange-to-nozzle weld QS-9-1-F-01 In Enclosures A and B, the licensee provided the nominal pipe size, materials of construction, and additional details for each weld.

3.3 Applicable ASME Code Edition and Addenda The ASME Code of record for the fourth 10-year ISI interval is the 2001 Edition through 2003 Addenda of the ASME Code.

3.4 Duration of Relief Requests The licensee submitted 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 for the fourth 10-year ISI interval, which started on April 1, 2008, and ended on August 28, 2018.

3.5 ASME Code Requirement For the Examination Category C-B, Class 2 nozzle-to-vessel welds, the applicable ASME Code examination requirements are in Table IWC-2500-1, Examination Category C-B, Pressure Retaining Nozzle Welds in Vessels. For these welds, the ASME Code requires surface and volumetric examinations of all nozzles at terminal ends of piping runs. The extent of required examination coverage is defined to be essentially 100 percent (i.e., greater than 90 percent coverage) by ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI. This Code Case has been incorporated by reference into 10 CFR 50.55a by inclusion in Regulatory Guide 1.147, Revision 18.

The ASME Code requirements applicable to the Examination Category R-A, Class 1 and 2 pipe welds originate in Section XI, Tables IWB-2500-1 and IWC-2500-1, respectively. The Beaver Valley RI-ISI program was approved as an alternative to the ASME Code requirements by the NRC in its safety evaluation dated March 23, 2011. In accordance with the licensees RI-ISI program, the pipe welds in 1-TYP-4-RA-1 are required to be volumetrically examined, and essentially 100 percent coverage of the required examination volume per ASME Code Case N-460 must be achieved.

3.6 Impracticality of Compliance For the Examination Category C-B Class 2 nozzle-to-vessel welds, the licensee stated that examination volume requirements were determined to be impractical. The licensee also stated that for the steam generator feedwater inlet nozzle weld (RC-E-1A-N-9), the surface exam area was determined to be impractical. This was based upon the details of the weld joint design and obstructions by insulation support material that prevented greater than 90 percent of the required examination volume or surface exam area. There were no coverage limitations for the surface examination performed for the safety injection boric acid tank nozzle-to-vessel welds (SI-TK-2-N-3 and SI-TK-2-N 4); therefore, the licensee did not request relief for the surface examination requirement.

In Enclosure A, the licensee described and illustrated the limitations that prevented ultrasonic and/or visual examination of the welds. The licensee stated that redesign of the supports

installed around the steam generator body and redesign of the safety injection boric acid tank nozzles would be required to obtain the specified examination volume. The licensee stated that it evaluated the option to remove the insulation bracket obstruction for the steam generator feedwater nozzle. The licensee determined that it would require an excessive amount of man hours and radiological dose to obtain the best possible coverage, and therefore was considered a burden on the licensee without a commensurate increase in safety.

For the Examination Category R-A, Class 1 and 2 pipe welds, the licensee stated that it was not possible to obtain greater than 90 percent of the ASME Code-required examination volume due to limitations, which include configuration and geometry of the subject pipe welds and associated components, obstructions by other components, surface conditions, and/or metallurgical constraints. In Section 4 and Table 1 of Enclosure B, the licensee described the limitations that prevented ultrasonic scanning of the welds. Examples include a valve body or a pump body geometry and/or weld neck flange configuration that limits access to valve or pump side of the weld, and that restricts the ultrasonic scanning from valve or pump side (i.e.,

single-sided scanning).

The licensee stated that the burden caused by compliance includes major modification of plant components which include redesign and replacement of the welds and associated components.

3.7 Proposed Alternative and Basis for Use For the two safety injection boric acid tank nozzle-to-vessel welds (SI-TK-2-N-3 and SI-TK-2-N 4), the alternative that the licensee proposed is performing the ultrasonic examination to the maximum extent practical and crediting leakage walkdowns. The surface exam was completed without coverage limitations and no indications were found.

The licensee stated that (1) leakage walkdowns, surface examinations, and ultrasonic testing (UT) examination coverage detailed in its submittal provide reasonable assurance of continued reliability of these welds; (2) a review of previous examinations showed no history of indications within these welds; and (3) condition monitoring already in place would detect a through-wall leak within a reasonable amount of time.

For the steam generator nozzle-to-vessel weld (RC-E-1A-N-9), the alternative that the licensee proposed is performing the ultrasonic and magnetic particle examinations to the maximum extent practical, continuing leakage walkdowns, and monitoring for leakage in accordance with plant technical specifications.

The licensee stated that (1) leakage walkdowns, surface examinations, and UT examination coverage detailed in its submittal provide reasonable assurance of continued reliability of these welds; (2) a review of previous examinations showed no history of degradation in these welds; and )3) condition monitoring already in place would detect a through-wall leak within a reasonable amount of time.

For the Examination Category R-A, Class 1 and 2 pipe welds, the licensee reported the percent coverage achieved for each pipe weld examined in Table 1 of Enclosure B. This is summarized in Table 1.

Table 1- ASME Code Coverage for Pipe Welds in 1-TYP-4-RA-1 Weld Designation Coverage Obtained (Percent)

RH-1-3-F-04 50 RH-1-3-F-05 50 RH-4-1-F-01 50 RH-4-1-F-02 50 RH-5-1-F-01 50 RH-5-1-F-02 50 QS-9-1-F-01 50 The licensee proposed the above alternative coverage in lieu of the required essentially 100 percent coverage.

The licensee described the reason for selecting two welds for examination from each of four piping segments. The licensee stated that as part of the RI-ISI program, and due to susceptibility to thermal fatigue, the program requires one weld to be selected within each high-safety significant piping segment (i.e., RH-002, RH-005, RH-006, and QS-042) and volumetrically inspected with full coverage. If the examination yields limited coverage, the RI-ISI program requires inspection of an additional weld in the same piping segment if available. For each of piping segments RH-002, RH-005, and RH-006, the licensee determined that there were no welds to select that would not result in a single-sided examination with limited coverage. No unacceptable indications were identified in any of the welds examined in these three piping segments. Pipe segment QS-042 is a short segment with only one weld that was selected for examination.

The licensee stated that it performed the UT to the maximum extent possible. Personnel who performed the UT were qualified, and the ultrasonic procedures used were performance-demonstrated in accordance with ASME Code,Section XI, Appendix VIII.

The licensee stated that as an effort to achieve additional coverage, it also performed a best effort scan of the pipe welds. The coverage achieved from the best effort examination is reported as best-effort coverage (%) or total % examined in Table 1 and Section 4 of Enclosure B to 1-TYP-4-RA-1. No credit was taken for the best effort scan coverage because the best effort scan is not an ASME Code-qualified examination. No unacceptable indications were identified in the volume examined by the best effort scan.

The licensee stated that in addition to volumetric examination, the pipe welds in 1-TYP-4-RA-1 have been subjected to ASME Code system leakage testing and VT-2 visual examination in the fourth 10-year ISI interval. For the VT-2, pipe segment QS-042 is located on the refueling water storage tank, which is accessible during normal operation, and pipe segments RH-002, RH-005, and RH-006 are located inside the reactor containment building and accessible during refueling outages. No sign of leakage has been identified in any of the pipe welds during the VT-2 examinations.

Additionally, the licensee stated that any potential leakage resulting from degradation of the subject pipe welds would be discovered within a reasonable amount of time by the following licensees activities. The refueling water storage tank is surveilled during walkdowns by system

engineering. For the segments in containment, leakage rates within containment are monitored and sources identified as part of compliance to plant technical specifications. For the Class 2 piping segments in containment, any leakage would be noted during Class 1 pressure test walkdowns performed after each refueling outage during startup.

3.8 NRC Staff Evaluation The NRC staff has evaluated Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 pursuant to 10 CFR 50.55a(g)(6)(i). The NRC staffs evaluation focused on (1) whether a technical justification exists to support the determination that the ASME Code requirement is impractical; (2) imposition of the Code-required inspections would result in a burden to the licensee; and (3) the licensees proposed alternative (accepting the reduced inspection coverage in this case) provides reasonable assurance of structural integrity and leaktightness of the subject pipe welds. The NRC staff finds that if these three criteria are met that the requirements of 10 CFR 50.55a(g)(6)(i), (i.e., granting the requested relief will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility) will also be met.

Examination Category C-B As previously stated, ASME Code,Section XI, Table IWC-2500-1, Category C-B, requires surface and volumetric examinations of all nozzles at terminal ends of piping runs.

For the two safety injection boric acid tank nozzle-to-vessel welds (SI-TK-2-N-3 and SI-TK-2-N 4), the licensee is requesting relief from the volumetric examination requirements because the configuration of nozzle weld prohibits the axial scan from the nozzle side of the weld and limits access for certain scan angles. The surface examination was performed using magnetic particle technique and did not have a coverage limitation. The licensee stated that the ultrasonic and surface examinations revealed no indications.

For the steam generator nozzle-to-vessel weld (RC-E-1A-N-9), the licensee is requesting relief from the examination requirements because (1) configuration of nozzle weld prohibits the axial scan from the nozzle side of the weld, and (2) the surface and volumetric exams were limited at the top and bottom of the weld by physical obstructions with nearby supports around the steam generator body. The licensee stated that the ultrasonic and surface examinations revealed no indications.

The NRC staff reviewed the licensees detailed drawings of the location of the welds and applicable obstructions showing the areas for which examination access is limited. The staff confirmed that each welds particular design configuration prevented the licensee from obtaining the required inspection coverage. Therefore, the NRC staff finds that a technical justification exists to support the determination that achieving essentially 100 percent coverage is impractical.

The licensee stated that it was not possible to remove the obstructions without significant work and increased radiation exposure with guarantee of increased examination coverage. The NRC staff finds that replacing or reconfiguring the components of the subject welds constitutes a burden on the licensee without a commensurate increase in safety.

The NRC staff considered whether the licensees proposed alternative provides reasonable assurance of structural integrity and leaktightness of the subject pipe welds based on (1) the examination coverage achieved, and (2) safety significance of unexamined volumes and unachievable coverage (e.g., the presence or absence of known active degradation mechanisms and essentially 100 percent coverage achieved for similar welds in similar environments subject to similar degradation mechanisms).

In evaluating the licensees proposed alternative coverage, the NRC staff assessed whether the licensee obtained as much coverage as reasonably possible and the manner in which the licensee reported the coverage achieved. The NRC staff verified that the coverage was calculated in a reasonable manner, coverage was limited by physical limitations or access (i.e., the configuration of one side of the weld did not permit access for scanning), and no unacceptable indications were identified. Therefore, the NRC staff found that the licensee made every effort to obtain as much coverage as reasonably possible with the ASME Code.

The two safety injection boric acid tank nozzle-to-vessel welds (SI-TK-2-N-3 and SI-TK-2-N 4) are located in the primary auxiliary building, which is accessible during operation. The licensee stated the boric acid tank is surveilled monthly during walkdowns so that leakage resulting from degradation would be discovered within a reasonable amount of time.

The steam generator nozzle-to-vessel weld (RC-E-1A-N-9) is located in the primary containment building. As per plant technical specifications, leakage rates within containment are monitored and sources identified. The licensee stated that a VT-2 exam for leakage is conducted at operating pressure once per period per ASME Code Category C-H, and that any leakage would be noted during Class 1 pressure test walkdowns performed after each outage during startup. The licensee stated that leakage resulting from degradation would be discovered within a reasonable amount of time.

Despite reduced coverage of the required examination volume, the NRC staff finds that leakage monitoring will provide additional assurance that any pattern of degradation, if it were to occur, would be detected, and the licensee will take appropriate correction actions.

Therefore, the NRC staff finds that the surface and volumetric examinations performed to the extent possible provide a reasonable assurance of structural integrity and leaktightness of the subject welds. Compliance with the ASME Code requirements for these welds would be a burden on the licensee without a commensurate increase in safety.

Examination Category R-A As described in the application, the predominant limitations that prevented the licensees UT to achieve essentially 100 percent coverage of the ASME Code-required volume were pipe-to-valve weld and pump-to-pipe weld configurations, obstructions, and/or metallurgical constraints. The licensee performed the UT from one side of welds (single-sided scan) because scanning from the valve or pump side of the welds was not possible. The NRC staff confirmed that each welds particular design configuration prevented the licensee from fully scanning the welds from both sides. Therefore, the NRC staff finds that a technical justification exists to support the determination that achieving essentially 100 percent coverage is impractical.

The licensee proposed that making the pipe welds accessible for inspection from both sides would require replacement or significant design modification to the welds and their associated components. The NRC staff finds that replacing or reconfiguring the components of the subject

pipe welds is the only reasonable means to achieve dual-sided coverage of these welds and that replacement or reconfiguration of the pipe, valve, and/or pump constitutes a burden on the licensee without a commensurate increase in safety.

The NRC staff considered whether the licensees proposed alternative provided reasonable assurance of structural integrity and leaktightness of the subject pipe welds based on (1) the examination coverage achieved and (2) safety significance of unexamined volumes and unachievable coverage (e.g., the presence or absence of known active degradation mechanisms and essentially 100 percent coverage achieved for similar welds in similar environments subject to similar degradation mechanisms).

In evaluating the licensees proposed alternative coverage, the NRC staff assessed whether the licensee obtained as much coverage as reasonably possible and the manner in which the licensee reported the coverage achieved. From review of the application, the NRC staff verified that:

The welds were examined using the appropriate equipment, ultrasonic modes of propagation, probe angles, frequencies, and scanning directions to obtain maximum coverage.

The coverage was calculated in a reasonable manner.

The personnel and UT procedures utilized for the examination were qualified as required by the regulation.

The coverage was limited by physical limitations or access (i.e., the configuration of one side of the weld did not permit access for scanning).

No unacceptable indications were identified.

Therefore, the NRC staff found that the licensee made every effort to obtain as much coverage as reasonably possible with the ASME Code-required UT.

In addition to the coverage analysis described above, the NRC staff evaluated the safety significance of the unexamined volumes of welds and unachievable coverage. From review of the licensees submittal, the NRC staff verified that:

The licensees UT has covered, to the extent possible, the regions (i.e., the weld root and the heat affected zone of the base material near the inside diameter surface of the joint) that are typically susceptible to higher stresses, and therefore, potential degradation.

For the austenitic stainless steel welds, the NRC staff notes that the coverage obtained was limited to the volume up to the weld centerline (near-side), because claiming coverage for the volume on the opposite side of the weld centerline (far-side) requires meeting the 10 CFR 50.55a(b)(2)(xv)(A)(2) far-side UT qualifications. The NRC staff verified that the far-side volume was inspected by the best effort examination, no indications were identified, and no credit was taken for the coverage achieved from the best effort examination.

During the fourth 10-year ISI interval, and as part of RI-ISI program, the licensee inspected additional welds in the subject piping segments that have the same materials subject to the same operating conditions and environment. Limited coverage was achieved, and no unacceptable indications were detected in the volumes examined.

Therefore, the NRC staff determined that based on the coverage achieved by the qualified UT, the supplemental best effort examinations and the examination of the weld root and its heat affected zone to the extent possible, it is reasonable to conclude that if significant service-induced degradation had occurred, evidence of it would have been detected by the examinations that the licensee performed.

In this analysis, the NRC staff also found that in addition to the required volumetric examinations, the subject pipe welds have received the system leakage test according to the ASME Code,Section XI, Table IWB-2500-1, Examination Category B-P, and Table IWC-2500-1, Examination Category C-H, as required for Class 1 and 2, respectively.

Despite reduced coverage of the required examination volume, the NRC staff finds that this inspection will provide additional assurance that any pattern of degradation, if it were to occur, would be detected, and the licensee will take appropriate correction actions.

Therefore, the NRC staff finds that the volumetric examinations performed to the extent possible provide a reasonable assurance of structural integrity and leaktightness of the subject pipe welds. Compliance with the ASME Code requirements for these welds would be a burden on the licensee without a commensurate increase in safety.

4.0 CONCLUSION

As set forth above, the NRC staff determines (1) that it is impractical for the licensee to comply with the ASME Code,Section XI requirements; (2) that the proposed weld examination coverage provides reasonable assurance of structural integrity and leaktightness of the subject welds; (3) and that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Accordingly, the NRC staff concludes that the licensee has adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(g)(6)(i).

Therefore, the NRC staff grants Relief Requests 1-TYP-4-C2.21-1 and 1-TYP-4-RA-1 at Beaver Valley, Unit No. 1, for the fourth 10-year ISI interval, which began on April 1, 2008, and ended on August 28, 2018.

All other ASME BPV Code,Section XI requirements for which relief was not specifically requested and authorized remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributors: A. Rezai M. Yoo Date: March 26, 2020

ML20079F816 *by e-mail OFFICE NRR/DORL/LPL1/PM* NRR/DORL/LPL1/LA NRR/DNRL/NVIB/BC*

NAME JTobin LRonewicz HGonzalez DATE 03/06/2020 03/21/2020 03/06/2020 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME JDanna JTobin DATE 03/26/2020 03/26/2020