L-08-106, License Renewal Application Amendment No. 3 Related to Appendix E-Applicant's Environmental Report, Severe Accident Mitigation Alternatives (SAMA) Information

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License Renewal Application Amendment No. 3 Related to Appendix E-Applicant's Environmental Report, Severe Accident Mitigation Alternatives (SAMA) Information
ML080920524
Person / Time
Site: Beaver Valley
Issue date: 03/28/2008
From: Sena P
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-106
Download: ML080920524 (15)


Text

FENOC FirstEnergyNuclear Operating Company PeterP. Sena /it 724-682-5234 Site Vice President Fax: 724-643-8069 March 28, 2008 L-08-106 10 CFR 54 ATTN: Document Control Desk U.-S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Beaver Valley Power Station, Units 1 and 2, License Renewal Application Amendment No. 3 Related to Appendix E-Applicant's Environmental Report, Severe Accident Mitigation Alternatives (SAMA) Information The listed Reference provided the FirstEnergy Nuclear Operating Company (FENOC)

License Renewal Application for the Beaver Valley Power Station (BVPS). This letter provides an Amendment to the BVPS License Renewal Application relative to corrections to the Severe Accident Mitigation Alternatives (SAMA) analyses in the Environmental Report. Calculation and translation errors to SAMA benefits and costs were identified; however, the subsequent corrections did not change the conclusions in the SAMA analyses.

The Enclosure provides tabulated revisions to the SAMA information for the BVPS License Renewal Application, Appendix E - Environmental Report, and includes a description of the errors.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

AIDE

/tICNtR

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-106 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 2L._., 2008.

Peter P. Sena III

Reference:

FENOC Letter L-07-113, "License Renewal Application," dated August 27, 2007.

Enclosure:

Tabulation of Revisions to the BVPS License Renewal Application, Appendix E, "Applicant's Environmental Report - Operating License Renewal Stage,"

Attachment C, "Severe Accident Mitigation Alternatives" cc: Mr. K. L. Howard, NRC Project Manager Mr. S. J. Collins, NRC Region I Administrator cc: w/o Enclosure Dr. P. T. Kuo, NRC Director, Division of License Renewal Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRR Project Manager Mr. D. J. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

ENCLOSURE Beaver Valley Power Station (BVPS) Unit Nos. 1 and 2 Letter L-08-106 Tabulation of Revisions to the Beaver Valley Power Station (BVPS) License Renewal Application, Appendix E. "Applicant's Environmental Report-Operating License Renewal Stage,"

Attachment C, "Severe Accident Mitigation Alternatives" Page 1 of 13 Description of Errors Unit I Attachment C-1 Table 8-1 Unit 2 Attachment C-2 Table 8-1

Enclosure L-08-106 Page 2 of 13 Description of Errors:

During reviews of the spreadsheet used to perform the arithmetic calculations associated with the cost benefit evaluations for Severe Accident Mitigation Alternatives (SAMAs), errors were observed in the:

  • Upper Bound Sensitivity calculation portion;

" Best Estimate Discount Rate Sensitivity portion; and,

" Unit 1 SAMA 164 "Cost".

The result of the Upper Bound Sensitivity calculation error was that the Upper Bound Sensitivity values (Column labeled "Benefit at UB" in Unit 1 and Unit 2 Table 8-1) for SAMAs were low. The overall result of correction of this error on the Unit 1 results was that the Upper Bound Sensitivity results increased a small amount. During the internal investigation and correction of this problem, it was noted that the Unit 2 calculations had inadvertently used a Unit 1 uncertainty value. Therefore, the Unit 2 calculations were also modified to reflect the correct uncertainty analysis value. The overall impact on the Unit 2 Upper Bound Sensitivity results was that the values were reduced. Correction of the calculations had no effect on the decisions made during the SAMA evaluation for either Unit 1 or Unit 2.

Another error was identified during the FENOC owner acceptance review which affected the Best Estimate Discount Rate Sensitivity (Column labeled "Benefit at BE Disc Rate" in Unit 1 and Unit 2 Table 8-1). This error resulted in calculating the replacement power costs with an equation only applicable to discount rates less than 5%. Correcting this equation resulted in an increase in the contribution to SAMA value due to replacement power costs, but has no impact on the decisions made during the SAMA evaluation of either Unit 1 or Unit 2 because this sensitivity information is not used in the decision making process for SAMAs.

The Unit 1 SAMA 164 "Cost" (Column labeled "Cost" in Unit 1 and Unit 2 Table 8-1) error consisted of a translation error. The "Cost" for SAMA 164 should be $50K instead of $31.4K, as it was listed in the BVPS Environmental Report submitted August 27, 2007. The $50K cost is still below the "Benefit at UB", and does not change the conclusion that SAMA 164 is potentially cost-beneficial.

Environmental Report Attachment C-1, "Beaver Valley Unit 1 SAMA Analysis,"

Table 8-1, "BVPS Unit 1 Sensitivity Evaluation," and Attachment C-2, "Beaver Valley Unit 2 SAMA Analysis," Table 8-1, "BVPS Unit 2 Sensitivity Evaluation," are revised and replaced in their entirety. The tables are shown below.

Enclosure L-08-106 Page 3 of 13 Unit I SAMAs, Attachment C-1, Table 8-1 Table 8-1 BVPS Unit 1 Sensitivity Evaluation BVI Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate years I Provide additional DC battery capacity. Extended DC power availability during an DCOI $13.9K $20.1K 512.5K 116.5K $28.4K $50K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

SBO.

2 Replace lead-acid batteries with fuel cells. Extended DC power availability during an DCOI $13.9K S20.1 K $12.5K S16.5K 128.4K 150K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

SBO.

4 Improve DC bus load shedding. Extended DC power availability during an DCOI $13.9K S20.1K 512.5K $16.5K $28.4K $50K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

SBO.

5 Provide DC bus cross-ties. Improved availability ofDC power system DCOI $13.9K S20. IK 1$12.5K $16.5K $28.4K S50K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

6 Provide additional DC power to the 120/240V Increased availability ofthe 120 V vital AC DCO1 $13.9K $20. IK 512.5K $16.5K 528.4K S50K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

vital AC system. bus.

13 Install an additional, buried off-site power source. Reduced probability of loss of off-site power. NOLOSP $73.7K $105K $66.4K 586.5K $150K >52,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

14 Install a gas turbine generator. Increased availability of on-site AC power. NOSEB $400K S577K S360K $473K $815K >57,000K Expert Panel Not Cost-Beneficial. Cost exceeds benefit.

This SAMA affects both units; see SAMA 14 in Unit 2.

See report section 7.3.

25 Install an independent active or passive high Inmproved prevention of core melt sequences. LOCA02 $23.7K $34.5K $21.4K $28.2K $48.4K >$100K Screening Not Cost-Beneficial Cost exceeds benefit.

pressure injection system. Hardware Change Value 26 Provide an additional high pressure injection Reduced frequency of core melt from small LOCA02 $23.7K $34.5K 521.4K $28.2K 148.4K >5100K Screening Not Cost-Beneficial Cost exceeds benefit.

pump with independent diesel. LOCA and SEQ sequences. Hardware Change

_______________________________________Value_____________

28 Add a diverse low pressure injection system. Improved injection capability. LOCA03 $2. 1K $3.3K $1.8K $2.6K $4.2K >1100K Screening Not Cost-Beneficial Cost exceeds benefit.

Hardware Change Value 29 Provide capability for alternate injection via Improved injection capability. LOCA03 $2.1K $3.3K $1.8K $2.6K $4.2K >$100K Screening Not Cost-Beneficial Cost exceeds benefit.

diesel-driven fire pump. Hardware Change Value 37 Upgrade the chemical and volume control system For a plant like the Westinghouse AP600, LOCAOI 148.0K $69.2K 143.2K $56.7K $97.8K >51,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

to mitigate small LOCAs. where the chemical and volume control system cannot mitigate a small LOCA, an upgrade would decrease the frequency of core damage.

39 Replace two of the four electric safety injection Reduced common cause failure of the safety LOCA02 $23.7K $34.5K $21.4K $28.2K 148.4K >S 100K Screening Not Cost-Beneficial Cost exceeds benefit.

pumps with diesel-powered pumps. injection system This SAMA was originally Hardware Change intended for the Westinghouse-CE System Value 80+, which has four trains of safety injection.

However, the intent of this SAMA is to provide diversity within the high- and low-pressure safety injections systems.

41 Create a reactor coolant depressurization system. Allows low pressure emergency core cooling LOCAOI $48.0K $69.2K 143.2K $56.7K $97.8K >51,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

system injection in the event of small LOCA and high-pressure safety injection failure.

48 Cap downstream piping oftnormially closed Reduced frequency of loss of component CCWO0 <$IK <SIK <IlK <$IK <$lK >$50K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

component cooling water drain and vent valves, cooling water initiating events, some of which can be attributed to catastrophic failure of one of the many single isolation valves.

Enclosure L-08-106 Page 4 of 13 Table 8-1 BVPS Unit I Sensitivity Evaluation BVI Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate years 54 Increase charging pump lube oil capacity. Increased time before charging pump failure CHGOI <$IK <IK <I K <$lK <$IK >$300K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

due to lube oil overheating in loss of cooling water sequences.

55 Install an independent reactor coolant pump seal Reduced frequency of core damage from loss RCPLOCA2 $1,303K $1,867K $1,174K $1,532K $2,656K >$4,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

injection system, with dedicated diesel, of component cooling water, service water, or station blackout.

56 Install an independent reactor coolant pump seal Reduced frequency of core damage from loss RCPLOCA2 $1,303K $1,867K $1,174K $1,532K $2,656K >$4,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

injection system, without dedicated diesel, of component cooling water or service water, but not a station blackout.

64 Implement procedure and hardware modifications Improved abilitysto cool residual heat CCW0l <$IK <IlK <$IK <$IK <$IK >$15K Screening Not Cost-Beneficial Cost exceeds benefit.

to allow manual alignment of the fire water removal heat exchangers. Procedure system to the component cooling water system, or Change Value install a component cooling water header cross-tie.

65 Install a digital feed water upgrade. Reduced chance of loss of main feed water FWOI $37.2K $55.1K $33.5K $44.9K $75.9K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

following a plant trip.

89 Improve SRV and MSIV pneumatic components. Improved availability ofSRVs and MSIVs. INSTAIRI <$IK <IlK <$IK <$IK <$IK >$100K Screening Not Cost-Beneficial Cost exceeds benefit.

Hardware Change Value 94 Install a filtered containment vent to remove Increased decay heat removal capability for CONT01 $1,239K $1,732K $1,118K $1,429K $2,526K $9,000K Industry studies Not Cost-Beneficial Some venting capability decay heat. Option 1: Gravel Bed Filter, Option non-ATWS events, with scrubbing of (NUREG 1437 currently exists but the 2: Multiple Venturi Scrubber released fission products. supplements), post-accident environment with inflation could preclude venting. A different vent was considered necessary to assure continued filtering.

96 Provide post-accident containment inerting Reduced likelihood of hydrogen and carbon H2BURN $30.4K 142.3K $27.4K $34.9K $61.9K >1500K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

capability, monoxide gas combustion. Hydrogen recombiners previously abandoned in place.

98 Create a core melt source reduction system. Increased cooling and containment ofmolten H2BURN $30.4K $42.3K $27.4K $34.9K $61.9K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

core debris. Refractory material would be Hydrogen recombiners placed underneath the reactor vessel such previously abandoned in that a molten core falling on the material place.

would melt and combine with the material.

Subsequent spreading and heat removal from the vitrified compound would be facilitated, and concrete attack would not occur.

104 Improve leak detection procedures. Increased piping surveillance to identify LOCA05 $10.7K $16.2K 19.6K $13.2K $21.9K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit. Have leaks prior to complete failure. Improved implemented RI-ISI.

leak detection would reduce LOCA frequency.

107 Install a redundant containment spray system. Increased containment heat removal ability. CONT01 $1,239K $1,732K $1,118K $1,429K $2,526K $10,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

Ill Install additional pressure or leak monitoring Reduced ISLOCA frequency. LOCA06 $9.9K $14.0K $8.9K $11.5K $20.2K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

instruments for detection of ISLOCAs.

112 Add redundant and diverse limit switches to each Reduced frequency ofcontainment isolation CONT02 $5.8K $8.2K $5.2K $6.7K $11.8K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

Icontainment isolation valve, failure and ISLOCAs.

113 Increase leak testing of valves in ISLOCA paths. Reduced ISLOCA frequency. LOCA06 $9.9K $14.0K $8.9K $11.5K $20.2K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

Increased outage frequency/duration.

Enclosure L-08-106 Page 5 of 13 Table 8-1 BVPS Unit I Sensitivity Evaluation BVI Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate years I18 Improve operator training on ISLOCA coping. Decreased ISLOCA consequences. LOCA06 $9.9K $14.0K $8.9K $11.5K $20.2K See Note See Note 1. Not Cost-Beneficial The current operating Iprocedures and training meet industry standards and include place-keeping and check-off. No cost beneficial improvements could be identified to either training or procedures that would result in a significant change the HEP. Not cost beneficial.

119 Institute a maintenance practice to perform a Reduced frequency of steam generator tube NOSGTR 131.5K S44.5K 528.4K 536.6K S64.2K >$3,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

100% inspection of steam generator tubes during ruptures.

each refueling outage.

122 Install a redundant spray system to depressurize Enhanced depressurization capabilities NOSGTR $31.5K $44.5K 128.4K $36.6K $64.2K >5100K Expert Panel - Not Cost-Beneficial Cost exceeds benefit.

the primary system during a steam generator tube during steam generator tube rupture. Screening rupture hardware change value.

130 Add an independent boron injection system. Improved availability of boron injection NOATWS 513.3K $21.7K SI 1.9K $17.3K S27.1K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

during ATWS.

131 Add a system of relief valves to prevent Improved equipment availability after an NOATWS S13.3K 521.7K $11.9K 517.3K 527.1K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

equipment damage from pressure spikes during an ATWS.

ATWS.

133 Install an ATWS sized filtered containment vent Increased ability to remove reactor heat from NOATWS $13.3K $21.7K $11.9K 517.3K S27.1K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

to remove decay heat. ATWS events.

136 Install motor generator set trip breakers in control Reduced frequency of core damage due to an NOATWS $13.3K $21.7K $1 1.9K $17.3K $27.1K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

room. ATWS.

137 Provide capability to remove power from the bus Decreased time required to insert control NOATWS $13.3K $21.7K $11.9K $17.3K $27.1K >$100K Expert Panel - Not Cost-Beneficial Cost exceeds benefit.

powering the control rods. rods if the reactor trip breakers fail (during a 2004 Strategic loss of feedwater ATWS which has rapid Action Plan pressure excursion).

147 Install digital large break LOCA protection Reduced probability of a large break LOCA LOCAOS $10.7K $16.2K $9.6K 113.2K 521.9K >1100K Expert Panel - Not Cost-Beneficial Cost exceeds benefit system (a leak before break). Screening Hardware Change Value 153 Install secondary side guard pipes up to the main Prevents secondary side depressurization NOSLB <$IK <$1K <IlK <$IK $1. 1K >$100K Screening Not Cost-Beneficial Cost exceeds benefit.

steam isolation valves, should a steam line break occur upstream of Hardware Change the main steam isolation valves. Also guards Value against or prevents consequential multiple steam generator tube ruptures following a main steam line break event.

155 Reactor Trip breaker failure, Enhance Procedures Enhanced recovery potential for rapid NOATWS 13.3K 21.7K $ 1.9K $17.3K S27. IK >$100K Expert Panel - Not Cost-Beneficial Cost exceeds benefit.

for removing power from the bus pressure spikes (- I to 2 minutes) during Screening ATWS. Hardware Change 1_ _7_ _1_1__Value I

Enclosure L-08-106 Page 6 of 13 Table 8-1 BVPS Unit I Sensitivity Evaluation BIV1 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate years 164 Modify emergency procedures to isolate a faulted Reduce release due to SGTR. NOSGTR $31.5K $44.5K $28.4K $36.6K $64.2K $50K Expert Panel Potentially Cost- SAMA is potentially cost ruptured SG due to a stuck open safety valve. Beneficial (because beneficial. Loop stop This SAMA to provide procedural guidance to the upper bound valves are also not designed close the RCS loop stop valve to isolate the sensitivity benefit to close against differential generator from the core and provide mechanical exceeds the cost) pressure and under accident device to close a stuck open SG safety valve, conditions will not fully seat since hoses must be installed to provide pressure between the seats to fully seat the valve.

165 Install an independent RCP Seal Injection system. Reduce frequency of RCP seal failure. RCPLOCA2 $1,303K $1,867K $1,174K $1,532K $2,656K >$4,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

S166 Provide additional emergency 125V DC battery Better coping for long tem station lackouts DC01 $13.9K $20.1K $12.5K $16.5K $28.4K 550K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

capability.

167 Increase the seismic ruggedness of the emergency Reduce failure of batteries due to seismic DC02 $1,302K $1,844K $1,173K $1,517K $2,653K $300K Expert Panel Potentially Cost- Potentially cost beneficial 125V DC battery block walls induced failure of battery room block walls. Beneficial 168 Install fire barriers for HVAC fans in the cable Eliminate failure of fire propagating from FIREOI $133K $188K S120K $155K S271K $80K Expert Panel Potentially Cost- Potentially cost beneficial, spreading room one fan to another. Beneficial reference SAMA 143 169 Improve operator performance. Operator starts One of top 10operator actions, OPRWAI HEPI $3.2K 54.7K $2.9K $3.8K $6.6K See Note See Note I. Not Cost-Beneficial See Note 1.

sAux RW pump given offsite power is available. I.

170 Improve operator performance. Operator starts One of top t0 operator actions, OPRWBV3 HEP2 593.4K S132K $84.2K S109K $190K See Note See Note I. Not Cost-Beneficial See Note I.

portable fans & open doors in emergency I.

switchgear room 171 Improve operator performance. Operator initiates One of top 10operator actions, OPROS6 HEP3 $3.0K 54.3K $2.7K $3.5K $6.1K See Note See Note 1. Not Cost-Beneficial See Note I.

Safety Injection I_.

172 Improve operator performance. Operator initiates One of top 10operator actions, OPROB2 HEP4 $56.7K $83.7K $51.0K $68.3K St 16K See Note See Note I. Not Cost-Beneficial See Note 1.

bleed and feed cooling given failure of prior I.

actions to restore feedwater systems.

173 Improve operator performance. Operator initiates One of top 10operator actions, OPRWMI HEP5 <$IK <$1K <51K <$1K $1.2K See Note See Note I. Not Cost-Beneficial See Note 1.

makeup of RWST 1 1.

174 Improve operator performance. Operator trips One of top 10operator actions, OPROCI HEP6 59.8K $14. IK 58.9K $11.6K 520.0K See Note See Note I. Not Cost-Beneficial See Note 1.

RCPs during loss of CCR. 1.

175 Improve operator performance. Operator initiates One of top 10operator actions, OPROD2 HEP7 <$IK <51K <51K <5IK <$1K See Note See Note I. Not Cost-Beneficial See Note I.

depressurization of RCS given a general transient I.

initiating event.

176 Improve operator performance. Operator initiates One of top 10operator actions, OPROD I HEP8 <$I K <51K <$IK <$1K <$1K See Note See Note 1. Not Cost-Beneficial See Note I.

depressurization of RCS given a SGTR event. 1.

177 Improve operator performance. Operator initiates One of top 10operator actions, OPRCD6 HEP9 <51K $1.3K <51K <$IK 51.5K See Note See Note 1. Not Cost-Beneficial See Note I.

cooldown and depressurization of RCS given a I.

Small LOCA and failure of HHS1.

178 Improve operator perfornance. Operator aligns One oftop t0 operator actions, OPRLRI HEPIO <$1K <$IK <$1K <$1K <$1K See Note See Note 1. Not Cost-Beneficial See Note I.

hot leg recirculation. I.

180 Reroute River Water pump power cable IPEEE issue with CV-3 fire. SWO0 $30.2K $43.5K $27.2K 535.7K $61.5K >$100K Screening Not Cost-Beneficial Cost exceeds benefit.

Hardware Change Value 182 Reroute CCR pump or HHSI suction MOV IPEEE fire issue for PA-I fire. FIRE02 <$1K <$IK <$IK <$1K <SIK >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

cables. 1 _

183 Reroute river water or auxiliary river water pump IPEEE fire issue for CS-I fire, NE corner. FIRE03 $163K S232K S147K $191K $333K >52,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

power and control cables 184 Reroute river water or auxiliary river water pump IPEEE fire issue for NS-I fire, south wall. F1RE04 $50.0K S72.2K $45. IK $59.2K $102K >$2,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

power and control cables

Enclosure L-08-106 Page 7 of 13 Table 8-1 BVPS Unit I Sensitivity Evaluation BVI Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate years 186 Add guidance to the SAMG to consider post- Reduce or prevent the release of CONT01 $1,239K $1,732K $ I,l 18K $1,429K $2,526K >S10,000 Expert Panel Not Cost-Beneficial. Cost exceeds benefit.

accident cross-tie of the two unit containments radionuclides as a result of containment K This SAMA affects through the gaseous waste system failure. both units; see SAMA 190 in Unit

2. See report section 7.3.

187 Increase seismic ruggedness of the ERF Increased reliability of the ERF diesel SEISMICI 5525K $758K 1473K S621K $1,071 K 5300K Expert Panel Potentially Cost- Potentially Cost-Beneficial Substation batteries. This applies to the battery following seismic events Beneficial. This rack only and not the entire structure. SAMA affects both units; see SAMA 186 in Unit 2. See report section 7.3.

188 Install a cross-tie between the Unit I and Unit 2 Increased availability of the RWST for LOCA04 S729K $1,047K S657K $858K $1,487K >14,000K Expert Panel Not Cost-Beneficial. Cost will exceed benefit.

RWST. injection. This SAMA affects BVPS plans to implement both units; the Unit this SAMA by using an 2 affect is too small alternate mitigation strategy to be identified as a that will provide portable SAMA. See report pumps that can be used for section 7.3. RWST makeup by the end of 2007.

189 Provide Diesel backed power for the fuel pool Increased availability of the RWST during LOCA04 $729K S1,047K $657K S858K $1,487K S200K Expert panel Potentially Cost- Potentially cost beneficial.

purification pumps and valves used for makeup to loss of offisite power and station blackout Beneficial BVPS plans to implement the RWST. events. this SAMA by using an alternate mitigation strategy that will provide portable pumps that can be used for RWST makeup by the end of 2007.

190 Reduce or eliminate the risk from control room PRA fire issue. Procedures already exist for FIRE05 I48.0K $70.7K 143.1K 1$57.7K $97.7K >$200K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

fire CRI LIP. Provide fire barrier or mitigation local control of the equipment impacted for inside connected control panels. this fire. I

Enclosure L-08-106 Page 8 of 13 Unit 2 SAMAs, Attachment C-2, Table 8-1 Table 8-1 BVPS Unit 2 Sensitivity Evaluation BV2 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate Years 3 Add additional battery charger or Improved availability of DC power DCOI $1,544K $2,227K $1,390K $2,009K $2,499K $120K Expert Panel Potentially Cost- Potentially cost Beneficial.

portable, diesel-driven battery system. Beneficial TDAFW does not require DC charger to existing DC system. power to continue running.

This item is to provide portable generator to supply SG level indication.

13 Install an additional, buried off-site Reduced probability of loss of off- NOLOSP $519K $746K 3467K $673K $840K >$2,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

power source. site power. I 14 Install a gas turbine generator. Increased availability of on-site AC NOSBO $1,495K $2,158K $1,346K $1,947K $2,420K >37,000K Expert Panel Not Cost-Beneficial. Cost Exceeds benefit.

power. This SAMA affects both units; see SAMA 14 in Unit 1. See report section 7.3.

17 Create a cross-tie for diesel fuel oil Increased diesel generator SBOI $36.IK $52.0K $32.5K $47.0K 58g.4K $500K Expert Panel Not Cost-Beneficial No fuel oil cross-tie exists on (multi-unit site). availability. Unit 2, neither between the Unit 2 trains nor to Unit I.

Implementation would require a modification since there are no existing valves large enough to provide even temporary connection ability.

Cost exceeds benefit.

25 Install an independent active or Improved prevention of core melt LOCA02 $22. 1K 332.8K $19.9K $29.8K $35.8K >$100K Screening Hardware Not Cost-Beneficial Cost exceeds benefit.

passive high pressure injection sequences. Change Value system.

26 Provide an additional high pressure Reduced frequency of core melt LOCA02 $22.1K $32.8K $19.9K $29.8K $35.8K >$100K Screening Hardware Not Cost-Beneficial Cost exceeds benefit.

injection pump with independent from small LOCA and SBO Change Value diesel. sequences.

28 Add a diverse low pressure injection Improved injection capability. LOCA03 $2.2K $3.4K $2.0K $3.2K $3.5K >$100K Screening Hardware Not Cost-Beneficial Cost exceeds benefit.

system. Change Value 29 Provide capability for alternate Improved injection capability. LOCA03 $2.2K $3.4K $2.0K $3.2K $3.5K >$100K Screening Hardware Not Cost-Beneficial Cost exceeds benefit.

injection via diesel-driven fire Change Value Pump.

37 Upgrade the chemical and volume For a plant like the Westinghouse LOCAOI $83.8K $122K $75.4K $110K $136K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

control system to mitigate small AP600, where the chemical and LOCAs. volume control system cannot mitigate a small LOCA, an upgrade would decrease the frequency of core damage.

39 Replace two of the four electric Reduced common cause failure of LOCA02 $22.1 K 332.8K $19.9K $29.8K $35.8K >$100K Screening Hardware Not Cost-Beneficial Cost exceeds benefit.

safety injection pumps with diesel- the safety injection system. This Change Value powered pumps. SAMA was originally intended for the Westinghouse-CE System 80+,

which has four trains of safety injection. However, the intent of this SAMA is to provide diversity within the high- and low-pressure safety injection systems.

Enclosure L-08-106 Page 9 of 13 Table 8-1 BVPS Unit 2 Sensitivity Evaluation BV2 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate Years 41 Create a reactor coolant Allows.low pressure emergency LOCA01 $83.8K $122K $75.4K $110K S136K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

depressun-izationsystem. core cooling system injection in the event of small LOCA and high-pressure safety injection failure.

54 Increase charging pump lube oil Increased time before charging CHGOI <$IK <$IK <$tK <$IK <$IK >$300K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

capacity. pump failure due to lube oil overheating in loss of cooling water sequences.

55 Install an independent reactor Reduced frequency of core damage RCPLOCA $1,358K $1,959K $1,223K $1,768K $2,198K >14,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

coolant pump seal injection system, from loss of component cooling with dedicated diesel, water, service water, or station blackout.

56 Install an independent reactor Reduced frequency of core damage RCPLOCA $1,358K $1,959K $1,223K $1,768K $2,198K >$4,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

coolant pump seal injection system, from loss of component cooling without dedicated diesel, water or service water, but not a station blackout.

64 Implement procedure and hardware Improved ability to cool residual CCWOI $6.0K $8.7K $5.4K $7.9K $9.7K $130K Expert Panel Not Cost-Beneficial Hardware modification modifications to allow manual heat removal heat exchangers. required as well as procedure alignment of the fire water system to changes.

the component cooling water system, or install a component cooling water header cross-tic.

65 Install a digital feed water upgrade. Reduced chance of loss of main FWOI $27.2K $39.8K $24.5K $36.1K $44.1K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

feed water following a plant trip.

78 Modify the startup feedwater pump Increased reliability ofdecay heat DAFW $1,810K $2,612K $1,630K $2,358K $2,930K $3,000K Expert Panel Potentially Cost- Cost to purchase pump, so that it can be used as a backup to removal. Beneficial (because the installation, piping, the emergency feedwater system, upper bound sensitivity procedures, etc. to install a including during a station blackout benefit exceeds the cost) dedicated feedwater system scenario. similar to Unit I and would provide a significant reduction in CDF.

89 Improve SRV and MSIV pneumatic Improved availability of SRVs and INSTAIRI <$IK <$IK <$IK <$IK <$IK >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

components. MSIVs. Screening Hardware Change Value 94 Install a filtered containment vent to Increased decay beat removal CONTO I 12,427K 13,392K $2,189K $3,026K $3,930K $9,000K Industry studies Not Cost-Beneficial Some venting capability remove decay heat. Option 1: capability for non-ATWS events, (NUREG 1437 currently exists but the post-Gravel Bed Filter; Option 2: with scrubbing of released fission supplements) with accident environment could Multiple Venturi Scrubber products. inflation preclude venting. A different vent was considered necessary I_ to assure continued filtering.

96 Provide post-accident containment Reduced likelihood of hydrogen H2BURN $25.8K S36.1K $23.3K $32.2K $41.8K >$500K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

inerting capability, and carbon monoxide gas Hydrogen recombiners combustion. previously abandoned in place.

104 Improve leak detection procedures. Increased piping surveillance to LOCA05 $8.5K $12.9K $7.6K $11.8K $13.7K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit. Have identify leaks prior to complete implemented RI-ISI.

failure. Improved leak detection would reduce LOCA frequency.

107 Install a redundant containment Increased containment heat CONTOI $2,427K $3,392K $2,189K $3,026K $3,930K >$10,000K Expert Panel Not Cost-Beneficial Cost exceeds the benefit.

spray system. removal ability. I Ill Install additional pressure or leak Reduced ISLOCA frequency. LOCA06 S135K S191K $122K $171K $219K >$1,000K Expert Panel

  • Not Cost-Beneficial Cost exceeds benefit.

monitoring instruments for detection of ISLOCAs. I I I IIII

Enclosure L-08-106.

Page 10 of 13 Table 8-1 BVPS Unit 2 Sensitivity Evaluation BV2 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate Years 112 Add redundant and diverse limit Reduced frequency of containment CONT02 $20.1 K $28.6K S$IK $25.7K $32.6K >$1,OOOK Expert Panel Not Cost-Beneficial Cost exceeds benefit.

switches to each containment isolation failure and ISLOCAs.

isolation valve.

113 Increase leak testing of valves in Reduced ISLOCA frequency. LOCA06 $135K $191K $122K $171K $219K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

ISLOCA paths. Increased outage frequency/duration.

118 Improve operator training on Decreased ISLOCA consequences. LOCA06A <$1K <$1K <$lK <$IK <$1K >$15K Expert Panel Not Cost-Beneficial The PRA case to evaluate the ISLOCA coping. benefit ofthis SAMA significantly over estimates the benefit. The PRA model does not contain a human error event for failure of the operators to isolate the ISLOCA since the leak pathway contains three check valves, all of which must fail for the ISLOCA to occur. Ifa human action is credited, the benefit would be extremely small. The results provided are from a sensitivity case comparing the baseline (in which credit is given for break isolation) with the elimination of all ISLOCAs. This is very conservative and still yields extremely small benefits.

119 Institute a maintenance practice to Reduced frequency of steam NOSGTR $165K $234K $149K $210K $268K >$3,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

perform a 100% inspection of steam generator tube ruptures.

generator tubes during each refueling outage.

130 Add an independent boron injection Improved availability of boron NOATWS $4.8K $8.0K $4.3K $7.5K $7.8K >$1,OOOK Expert Panel Not Cost-Beneficial Cost exceeds benefit.

_ system, injection during ATWS.

131 Add a system of relief valves to Improved equipment availability NOATWS $4.8K $8.0K 84.3K $7.5K $7.8K >$1,OOOK Expert Panel Not Cost-Beneficial Cost exceeds benefit.

prevent equipment damage from after an ATWS.

pressure spikes during an ATWS.

133 Install an ATWS sized filtered Increased ability to remove reactor NOATWS $4.8K $8.0K $4.3K $7.5K $7.8K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

containment vent to remove decay heat from ATWS events.

heat.

136 Install motor generator set trip Reduced frequency of core damage NOATWS $4.8K $80K $4.3K $7.5K $7.8K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

breakers in control room. due to an ATWS. Screening Hardware Change Value 137 Provide capability to remove power Decreased time required to insert NOATWS $4.8K $8.0K $4.3K $7.5K $7.8K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

from the bus powering the control control rods if the reactor trip rods. breakers fail (during a loss of feedwater ATWS which has rapid

'tressure excursion). ______ ____ ____ _____

Enclosure L-08-106 Page 11 of 13 Table 8-1 BVPS Unit 2 Sensitivity Evaluation BV2 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate Years 153 Install secondary side guard pipes Prevents secondary side NOSLB $1.7K $2.4K $1.5K $2.2K $2.7K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

up to the main steam isolation depressurization should a steam Screening Hardware valves, line break occur upstream of the Change Value main steam isolation valves. Also guards against or prevents consequential multiple steam generator tube ruptures following a main steam line break event.

155 Reactor Trip breaker failure Enhanced recovery potential for NOATWS S4.8K $8.0K $4.3K $7.5K $7.8K >$100K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

Enhance Procedures for removing rapid pressure spikes (- I to 2 Implementation will power from the bus minutes) during ATWS. require plant modification.

164 Modify emergency procedures to Reduce release due to SGTR. SGTR4 $86.4K $122K $77.8K $109K S140K $50K Expert Panel Potentially Cost- SAMA is potentially cost isolate a faulted ruptured SG due to Beneficial beneficial. Loop stop valves a stuck open safety valve. This are also not design to close SAMA to provide procedural against differential pressure guidance to close the RCS oop stop and under accident conditions valve to isolate the generator from will not fully seat since hoses the core and provide mechanical must be installed to provide device to close a stuck open SG pressure between the seats to safety valve, fully seat the valve.

165 Install an independent RCP Seal Reduce frequency of RCP seal RCPLOCA $1,358K 1$1,959K $1,223K $1,768K $2,198K >14,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit Injection system. failure.

169 Improve operator performance. Top l0 operator actions OPRWM I HEPI $10.7K $15.1K $9.6K $13.5K $17.3K See Note I. See Note 1. Not Cost-Beneficial See Note I Operator fails to align makeup to RWST - SGTR, secondary leak 170 Improve operator performance. Top 10operator actions OPROTI HEP2 <$IK $1.5K <$IK $1.4K $1.6K See Note 1. See Note I. Not Cost-Beneficial See Note I Operator fails to manually trip reactor - ATWS 171 irmprove operator performance. Top 10operator actions OPROF2 HEP3 $13.6K $19.6K S12.3K $17.7K $22.0K See Note I. See Note I. Not Cost-Beneficial See Note I Operator fails to realign main feedwater - no SI signal 172 Improve operator performance. Top 10operator actions OPROS6 HEP4 $42.6K $61.2K $38.3K $55.2K 168.9K See Note I. See Note 1. Not Cost-Beneficial See Note I Operator fails to initiate AFW following transient 173 Improve operator performance. Top 10 operator actions OPRDC2 HEP5 $5.2K $7.6K 14.7K $6.8K $8.5K See Note 1. See Note I. Not Cost-Beneficial See Note I Operator aligns spare battery charger 2-9 to 2-2 174 Improve operator performance. Top 10operator actions OPRDCI HEP6 $5.5K $8.0K $5.0K $7.2K $8.9K See Note I. See Note I. Not Cost-Beneficial See Note I Operator aligns spare battery charger 2-7 to 2-1 175 Improve operator performance. Top 10 operator actions OPROB2 HEP7 $20.2K $30.6K $18.2K $28. 1K $32.8K See Note I. See Note I. Not Cost-Beneficial See Note I Operator fails to initiate bleed and feed 176 Improve operator performance. Top 10 operator actions OPROC I HEP8 $6.4K $9.3K $5.8K $8.5K $I0.4K See Note 1. See Note I. Not Cost-Beneficial See Note I Operator fails to trip RCP during loss of CCP 177 Improve operator performance. Top 10 operator actions OPROB I HEP9 $1.8K $2.7K $1.6K $2.5K $2.9K See Note I. See Note 1. Not Cost-Beneficial See Note I Operator fails to initiate bleed and feed 178 Improve operator performance. Top 10 operator actions OPRSLI HEPIO $17.6K $24.8K $15.8K $22.2K $28.5K See Note 1. See Note I. Not Cost-Beneficial See Note I Operator fails to identify raptured SG or initiate isolation I I II

Enclosure L-08-106 Page 12 of 13 Table 8-1 BVPS Unit 2 Sensitivity Evaluation BV2 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate Years 179 Reduce risk contribution from fires Eliminationor improved mitigation FIRE05 $34.4K S52. Ig K 30.9K $47.8K &55.7K >SIOOK Expert Panel Not Cost-Beneficial Cost exceeds benefit originating in Zone CB-3, causing a of fires in this area.

total loss of main feedwater and auxiliary feedwater with subsequent failure of feed and bleed.

180 Reduce risk contribution from fires Elimination or improved mitigation FIRE06 $202K $292K S182K $264K S328K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit originating in zone CT-I, causing a of fues in this area.

total loss of service water.

181 Reduce risk contribution from fires Elimination or improved mitigation FIRE07 $10.7K $15.4K $9.6K $13.9K $17.3K IOOK Expert Panel Not Cost-Beneficial Cost exceeds benefit originating in zone SB-4, causing a of firemin this area.

total loss of normal AC power with subsequent failure of emergency AC power and station crosstie leading to station blackout.

183 Reduce risk contribution from fires Elimination or improved mitigation FIRE09 $54.6K $79.2K 149.2K $71.6K S88.4K >$1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit originating in zone CV-3, causing of fires in this area.

failure of component cooling water (thermal barrier cooling) and service water with subsequent failure of reactor coolant pump seal injection.

184 Reduce risk contribution from fires Elimination or improved mitigation FIREI0 $164K $237K S148K $214K S266K S1,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit.. This in EDG building, fire initiator of fires in this area. represents 1/2 the cost; DGILIA. remainder associated with SAMA 185.

185 Reduce risk contribution from fires Elimination or improved mitigation FIREII $163K $236K $147K 1213K 1265K SI,000K Expert Panel Not Cost-Beneficial Cost exceeds benefit. This in EDG building, fire initiator of fires in this area. represents 1/2 the cost; DG2LIA. remainder associated with SAMA 184.

186 Increase seismic ruggedness of the Increased reliability of the ERF SEISMICI $3.8K S5.5K 13.4K $5.0K $6.2K $300K Expert Panel Not Cost-Beneficial. Unit I benefit - Reference UI ERF Substation batteries. This diesel following seismic events This SAMA affects both SAMA 187 refers only to the battery racks, not units; see SAMA 187 in the entire structure. Unit I. See report section 7.3.

Enclosure L-08-106 Page 13 of 13 Table 8-1 BVPS Unit 2 Sensitivity Evaluation BV2 Potential Improvement Discussion SAMA Case Benefit Benefit at Benefit at Benefit at Benefit at Cost Cost Basis Evaluation Basis for Evaluation SAMA 3% Disc BE Disc Remaining UB Number Rate Rate Years 187 Reduce risk contribution from Eliminate or mitigate the FLOODID <IlK <$IK <$IK <IlK <$IK >$15K Expert Panel Not Cost-Beneficial Source of flooding is a 4" fire internal flooding in cable vault area, consequences of a flood in this water pipe that traverses the CV-2 735', by reducing the area. area.

frequency of the event or by improvements in mitigation of the The PRA currently does not resulting flooding. include credit for the procedure that is in place to isolate a leak/break in the subject piping; i.e., the PRA model does not contain the human error event for failure ofthe operators to isolate the flood source. If the human action is credited, the benefit for improvements in mitigate would be extremely small.

The results provided are from a sensitivity case comparing a revised baseline (in which credit is given for break isolation) (FLOODI D) with the elimination of this internal flooding scenario. This is very conservative and still yields extremely small benefits; no change in procedures or hardware would be cost-beneficial.

188 Reduce risk contribution from Eliminate or mitigate the FLOOD2 $63.4K $9l.SK $57.1K $82.6K $103K >$200K Expert Panel Not Cost-Beneficial Cost exceeds benefit.

internal flooding in Safeguards consequences of a flood in this building, N&S. (Source of flooding area.

is a RWST line.

190 Add guidance to the SAMG to Reduce or prevent the release of CONT01 $2,427K $3,392K $2,189K $3,026K $3,930K >$10,00K Expert Panel Not Cost-Beneficial. Cost will exceed benefit due consider post-accident cross-tie of radionuclides as a result of This SAMA affects both to cleanup costs and the two unit containments through containment failure. units; see SAMA 186 in replacement power at opposite the gaseous waste system. Unit I. See report unit.

section 7.3.