Text

Order Establishing Interim Inspection Requirements for RPV Heads
	ML030660587
Person / Time
Site:	Beaver Valley
Issue date:	03/03/2003
From:	Bezilla M; FirstEnergy Nuclear Operating Co
To:	; NRC/SECY/RAS
References
	BL-02-002, EA-03-009, L-03-035
	Download: ML030660587 (4)
	v • d • e

'EIJOC Beaver Valley Power Station Route 168

"*-% P.O Box 4 FirstEnergyNuclear OperatingCompany Shippingport, PA 15077-0004 Mark B. Bezilla 724-682-5234 Site Vice President Fax. 724-643-8069 March 3, 2003 L-03-035 Secretary, Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Attn: Rulemakings and Adjudications Staff Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Order Establishing Interim Inspection Requirements for RPV Heads By letter dated February 11, 2003, the Nuclear Regulatory Commission (NRC) issued an immediately effective Order establishing interim inspection requirements for reactor pressure vessel (RPV) heads at pressurized water reactors (henceforth, the Order). The Order applied to all addressees listed in the Attachment to the Order. Beaver Valley Power Station (BVPS), Unit No. 1 and Unit No. 2 were included in the list of addressees.

This letter is submitted in accordance with the requirements of 10 CFR 2.202, which require a written response within twenty days of the date of the Order.

By letter dated September 11, 2002 (L-02-095), the FirstEnergy Nuclear Operating Company (FENOC) provided a response for BVPS to NRC Bulletin 2002-02, "Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle Inspection Programs," dated August 9, 2002. This letter, submitted in response to the Order, supercedes the commitments made in response to Bulletin 2002-02.

This letter identifies that BVPS will comply with the inspection frequency specified for the High, Moderate, and Low Categories described in Section IV, Paragraph B of the Order. This letter also identifies in Attachment A the proposed deviations to the Order being submitted for relaxation in accordance with Section IV, Paragraph F of the Order.

Several of these issues were discussed during the NRC meeting with Industry held on February 24, 2003.

BVPS intends to comply with the Order with the noted deviations listed in Attachment A being submitted to the NRC for relaxation. By consenting to the Order, licensees waive the right to request a hearing on all or any part of the Order, pursuant to 10 CFR 2.202(a)(3). However, FENOC recognizes that this waiver of a right to a

Beaver Valley Power Station, Unit No. 1 and No. 2 Order Establishing Interim Inspection Requirements for RPV Heads L-03-035 Page 2 hearing is limited to the specific language of the Order and not to any future right to a hearing, or to any other legal process, that the licensees might have concerning any other order, issuance, or determination by the NRC.

There are no new regulatory commitments contained in this letter. If there are any questions concerning this matter, please contact Mr. Larry R. Freeland, Manager, Regulatory Affairs/Performance Improvement at 724-682-5284.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 3, 2003.

Sincerely, Mark B. Bezil Attachments c: Mr. T. G. Colburn, NRR Senior Project Manager Mr. D. M. Kern, NRC Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Mr. S. J. Collins, Director, Office of Nuclear Reactor Regulation NRC Document Control Desk NRC Assistant General Counsel for Materials Litigation and Enforcement

ATTACHMENT A Order Description of Reason for Deviation Justification and Safety Impact of Section Requirement Alternative ProposedAlternative To utilize the same definition EFPYj = operating EFPY =of EFPY as was used to Since all rankings to date use the

" time in years at (n Wh/MWego0%)x(1/8760) develop the EDY equation alternative definition there would be Ahj time in years(ThIheat 1 x ) originally and to be consistent no change in the Safety Assessment Theadj time in years at Theadj with the definitions in the currently applied by the Industry.

proposed ASME Code work.

Calculate the Calculate the susceptibility Calculating the EDY for a susceptibility category of each reactor reactor category of each vessel head in terms of EDY ratrvse vessel head edoc once the h The elimination of the continued reactor vessel head for the end of each operating High susceptibility category is EDY calculation once the High "i

reatorvermslo bead for cle untl theah oreached will not affect the category is reached does not affect in terms of EDY for cycle until the High fthe safety assessment or inspection the end of each susceptibility category is frequency since the threshold commitments.

operating cycle. reached. was reached.

Footnote 1 - Use of Flaw evaluation and repair Allows for the use of the latest This provides for improved N faluaw criteria to be used will be the approved evaluation and repair assessment and repair criteria to be C evaluation critenia in November 21, 2001 NRC approved techniques at criteria when addressing plant applied since the latest approved letter, the time of evaluation. findings, approaches can be utilized.

Visual examination of the top The area of interest is the top of the RPV head will be surface of the RPV head where conducted for evidence of leakage from above or from There is no change in safety Bare metal visual leakage from the RPV flange the RPV head penetrations assessment since all relevant areas C (,)(a) examination of area to the top center of the may occur. Areas on the RPV will be examined. All bare metal (1)and 100% of the RPV head. A bare metal visual flange and RPV stud holes are will betexaminetrall as wel C(2)(a) head surface examination of the top of the not in the area of interest for as between eah head as and (including 360' RPV head surface within the the bare metal visual as au 3600 eah Ad around each RPV ventilation shroud area where examination. While inspection penetration will be examined. Any C(3)(a) head penetration penetrations are present will coverage is specified as 100% presence of boric acid corrosion nozzle) be conducted. This includes of the surface, some den orflea o 360' around each RPV head obstructions from permanently identified.

penetration. Any limitations welded structures exist.

to 100% inspection when Therefore literal compliance to

Attachment A (continued) n i Order Description of Section Alternative Proposed Requirement T

conducting the bare metal visual shall be documented and identified to the NRC Ultrasonic testing is the current No change in the safety assessment Ultrasonic testing of technique applied, other is anticipated since the area of high C(i)(b) each RPV head Volumetric examination of volumetric techniques may stresses is being examined. The area (i)enetration nozzle each RPV head penetration developed in the future and at the bottom of the nozzle is not C(2)(b) . from 2" above nozzle ... from 2" above the should not be precluded. The pressure boundary and any the J-weld to the J-weld to the extent practical examination extent specifying indication in that area would take a C(3)(b) bottom of the near the bottom of the nozzle. to the 'bottom of the nozzle' significant amount of time to grow (i) nozzle. may not be attainable due to into a flaw that would reach the nozzle.

local geometry (threaded areas pressure boundary areas and would or tapers) be detected in future examinations.

Ultrasonic testing of Currently this approach has not The use of ultrasonic testing does C(1)(b) each RPV head been demonstrated as effective not reliably determine if leakage into (i) and penetration nozzle Eliminate the determination or reliable in detecting the the interference fit zone has C(2)(b)

(i) and ... and an to assessment of leakage into interference the by fit zone presence damage inoftheleakage or leakage occurred. Volumetric testing along interference fit with the bare metal visual provides C(3)(b) determine if leakage ultrasonic methodsb zone. Until such techniques reasonable assurance that leakage (i) has occurred into the are proven reliable, a into the interference zone has not interference fit zone. commitment to use them is not occurred that would cause a safety appropriate. concern.

Eddy current testing or dye Eddy current testing penetrant testing of the wetted No change in the safety assessment or dye penetrant surface of each J-Groove weld The areas of coverage would is anticipated since the area of high C(l)(b) testing of the wetted and RPV penetration nozzle include the surface of the J- stresses is being examined. The area (ii) and surface of each J- base material to at least two Groove weld and areas in the at the bottom of the nozzle is not C(2)(b) Groove weld and (2) inches above the J-Groove region of the pressure pressure boundary and any (ii) and RPV penetration weld excluding areas at the boundary. 100% of the surface indication in that area would take a C(3)(b) nozzle base material bottom of the RPV nozzle area of the nozzle that is significant amount of time to grow (ii) to at least two (2) penetration where geometry wetted may not be accessible into a flaw that would reach the inches above the J- (threaded areas and tapers) for meaningful examination, pressure boundary areas and would Groove weld would make testing a be detected in future examinations.

hardship.