L-08-342, Request for Notice of Enforcement Discretion, Technical Specification 3.5.2, Emergency Core Cooling System (ECCS) - Operating

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Request for Notice of Enforcement Discretion, Technical Specification 3.5.2, Emergency Core Cooling System (ECCS) - Operating
ML083030135
Person / Time
Site: Beaver Valley
Issue date: 10/24/2008
From: Sena P
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-342
Download: ML083030135 (17)
v • d • e


Text

FENOC Beaver Valley Power Station P.O. Box 4 FirstEnergyNuclear Operating Company Shippingport, PA 15077 PeterP. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 October 24, 2008 L-08-342 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit No. 2 Docket No. 50-412, License No. NPF-73 Request for Notice of Enforcement Discretion Technical Specification 3.5.2, Emergency Core Cooling System (ECCS) - Operating On October 22, 2008, FirstEnergy Nuclear Operating Company (FENOC) requested a Notice of Enforcement Discretion (NOED) associated with Technical Specification 3.5.2, titled Emergency Core Cooling System (ECCS) - Operating for Beaver Valley Power Station Unit 2 (BVPS-2).

The need for the NOED occurred when the BVPS-2 Train "A" Low Head Safety Injection (LHSI) Pump (2SIS-P21A) failed to rotate more than 3/4 of a turn by hand during a planned preventative maintenance activity. When the LHSI pump failed to rotate, BVPS-2 was in Technical Specification 3.5.2 Condition "A" for the inoperable LHSI pump. Condition "A" requires the inoperable LHSI pump be restored to Operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. When Condition "A" is not met, Condition "B" is then applicable and requires the plant to be placed in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The completion time of Condition "A" expired on October 22, 2008 at 2326 hours0.0269 days <br />0.646 hours <br />0.00385 weeks <br />8.85043e-4 months <br />.

Enforcement discretion to not comply with BVPS-2 Technical Specification 3.5.2 Condition "B" Required Actions for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> was requested in order to allow sufficient time to complete pump reassembly and testing. The extended time permitted by the NOED will expire at 1126 hours0.013 days <br />0.313 hours <br />0.00186 weeks <br />4.28443e-4 months <br /> on October 24, 2008. If the LHSI pump is not returned to Operable status by the NOED expiration time, BVPS-2 would then be required to initiate a plant shutdown to Mode 4 in accordance with Technical Specification 3.5.2 Condition "B" Required Actions.

The requested NOED was verbally granted by the NRC at 1105 hours0.0128 days <br />0.307 hours <br />0.00183 weeks <br />4.204525e-4 months <br /> on October 22, 2008. In accordance with the guidance provided in Regulatory Information Summary 2005-01, "Changes to Notice of Enforcement Discretion (NOED) Process and Staff Aoa/z

Beaver Valley Power Station, Unit No. 2 L-08-342 Page 2 Guidance," and NRC Inspection Manual Part 9900, "Operations - Notices of Enforcement Discretion," Attachment 1 to this letter provides FENOC's written NOED request for BVPS-2.

Portions of the attached NOED request regarding PRA analysis and maintenance history have been revised due to additional information obtained after the NOED was verbally granted by the NRC.

Since unexpected difficulties have delayed the reassembly of the pump, FENOC management decided to proactively shut down Beaver Valley Power Station Unit No. 2 beginning at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> on October 23, 2008. Beaver Valley Power Station Unit No. 2 entered Mode 3 at 0519 hours0.00601 days <br />0.144 hours <br />8.581349e-4 weeks <br />1.974795e-4 months <br /> on October 24, 2008, as part of the planned controlled shutdown. On October 24, 2008, at 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />, Technical Specification 3.5.2, Condition B was entered based on a determination that the projected work completion time for restoring 2SIS-P21A to operable status would not meet the conditions of the enforcement discretion. Technical Specification 3.5.2, Required Action B.1 was met since the plant was in Mode 3, the plant is continuing the cooldown to be in Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per Required Action B.2.

The regulatory commitment is listed in Attachment 2.

If there are any questions or additional information is required, please contact Colin P.

Keller, Manager - Site Regulatory Compliance, at 724-682-4284.

Sincerely, Peter P. Sena III Attachments

1. Request for NOED
2. Commitment List cc: Mr. S. J. Collins, NRC Region I Administrator Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRR Project Manager

ATTACHMENT 1 L-08-342 Request for NOED Page 1 of 14

1. Technical Specification or other license conditions that will be violated.

On October 19, 2008, the Beaver Valley Power Station Unit 2 (BVPS-2) Train "A" Low Head Safety Injection (LHSI) Pump (2SIS-P21A) was removed from service and declared inoperable at 2326 hours0.0269 days <br />0.646 hours <br />0.00385 weeks <br />8.85043e-4 months <br /> in order to perform routine maintenance.

BVPS-2 Technical Specification 3.5.2, "ECCS - Operating", Condition "A",

Required Action A.1 was entered due to the Train "A" LHSI pump being declared inoperable. Required Action A.1 requires that the ECCS train(s) be restored to an OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and is applicable in MODES 1, 2, and 3.

Failure to meet Condition "A", within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, requires entry into Condition "B" and the following actions apply:

1. Be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. Be in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

FirstEnergy Nuclear Operating Company (FENOC) requests enforcement discretion for BVPS-2 to not comply with the Required Actions of Condition "B" for an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The extended time would expire at 1126 hours0.013 days <br />0.313 hours <br />0.00186 weeks <br />4.28443e-4 months <br /> on October 24, 2008. The 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> extension would provide sufficient time to take the required actions to return the Train "A" LHSI Pump to operable status.

2. The circumstances surrounding the situation: including likely causes; the need for prompt action; action taken in an attempt to avoid the need for a NOED; and identification of any relevant historical events.

At BVPS-2, the Low Head Safety Injection Pump (2SIS-P21A) is a motor driven, horizontal shaft centrifugal type pump. The pump takes suction from the refueling water storage tank and starts automatically upon receipt of a safety injection signal or a diesel loading sequence signal.

On October 19, 2008 at 2326 hours0.0269 days <br />0.646 hours <br />0.00385 weeks <br />8.85043e-4 months <br />, the Train "A" Low Head Safety Injection Pump was declared inoperable for the posting of clearance 2W08-1 1-SIS-001.

This clearance performed normal preventive maintenance on the pump, motor and breaker. Work being performed on the pump included changing the inboard and outboard bearing housing oil and lubricating the drive coupling.

During performance of preventive maintenance Order 200276114 on October 20, 2008 to change the 2SIS-P21A reservoir oil and grease the coupling, maintenance personnel noted the pump would not rotate by hand a full 360 degrees with the pump and motor coupled. After approximately 270 degrees L-08-342 Page2of 14 of rotation a rubbing sound was heard and the shaft could no longer be rotated by hand. Maintenance notified the Control Room at 0640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br /> on October 20, 2008. The pump was uncoupled from the motor and the motor rotated freely.

Maintenance attempted to rotate the pump, but each attempt resulted in less movement, eventually resulting in final movement in each direction of approximately 11/4 inches.

A problem solving team was assembled on October 20, 2008 to determine the cause for 2SIS-P21A pump shaft failing to rotate by hand, uncoupled from the pump. A failure modes analysis was performed and identified 10 possible causes for the pump shaft failing to rotate by hand. Four possible causes were immediately ruled out. The other six causes required the pump to be disassembled to obtain more information.

The pump was found to have a light rub after turning the shaft approximately 270 degrees by hand. The shaft was then rotated back and forth in numerous attempts to clear the rub. Instead of clearing, the rub got worse and worse until there was almost no remaining shaft rotation.

Based on the results of disassembly and inspection of the pump, damage occurred to the pump casing wear rings due to galling of the 316 Stainless Steel (SS) material when it was attempted to rotate the pump by hand. The most probable cause of damage between the two wear rings is that the pump rotating assembly was not centralized in the casing bore causing the clearances between the two wear rings to be significantly reduced or the two rings to just touch.

The pump would not rotate by hand or using a strap wrench because the outboard impeller wear ring and the outboard casing wear ring had touched together causing scoring and raised metal. The 316 SS wear rings are very susceptible to galling and this prevented relative movement between the two parts.

The Train "A" LHSI pump (2SIS-P21A) was run for a quarterly ASME surveillance test on recirculation in July 2008. Vibration and hydraulic performance were satisfactory.

Based on dimensional checks taken during reassembly of Train "B" LHSI pump (2SIS-P21B) as documented in Order 200146714 (performed in April 2005) there is good assurance that the 21 B rotating assembly is sufficiently centered in the casing wear rings. The work order records indicate that the pump wear rings were machined during the overhaul and the as-left tolerances were at the high end of the acceptable range. The 2SIS-P21B inboard casing wear ring was replaced during this overhaul.

L-08-342 Page 3 of 14 Upon discovery of the problem, prompt action was taken to assemble a problem solving team and to disassemble the pump to identify the cause. Continuous coverage of maintenance and engineering personnel have been established until the pump is returned to operable status. Parts that were needed for the repair of the pump that were not available on site were expedited.

3. Information to show that the cause and proposed path to resolve the situation are understood by the licensee, such that there is a high likelihood that planned actions to resolve the situation can be completed within the proposed NOED time frame.

The combination of the susceptibility of the 316 SS wear rings to galling with the apparent cause that the pump rotating assembly was not centralized in the casing bore resulting in minimal clearance between the wear rings was determined to be the cause of the inoperability of the Train "A" Low Head Safety Injection Pump (2SIS-P21A). As part of the pump reassembly, the 316 SS wear rings are being replaced with Nitronic 60 material which is less susceptible to galling. In addition, the pump rotating assembly will be centralized in the casing bore.

Reassembly of the Train "A" LHSI pump is in progress with the parts needed for the repair onsite.

The corrective maintenance is projected to be completed by 2359 hours0.0273 days <br />0.655 hours <br />0.0039 weeks <br />8.975995e-4 months <br /> on October 23, 2008. The post-maintenance test takes approximately four (4) hours. The Train "A" LHSI pump (2SIS-P21A) is projected to be restored to its operable condition by 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on October 24, 2008. These activities will be worked around-the-clock until completed. The current schedule supports completion of the pump restoration activities within the proposed NOED timeframe.

L-08-342 Page 4 of 14

4. The safety basis for the request, including an evaluation of the safety significance and potential consequences of the proposed course of action.
a. Use the zero maintenance PRA model to establish the plant's baseline risk and the estimated risk increase associated with the period of enforcement discretion. For the plant-specific configuration the plant intends to operate in during the period of enforcement discretion, the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) should be quantified and compared with guidance thresholds of less than or equal to an ICCDP of 5E-7 and an ICLERP of 5E-8. These numerical guidance values are not pass-fail criteria.

The plant configuration risk is assessed based on the current Revision 4 of the BVPS-2 PRA model using the RISKMAN software zero maintenance model BV2R4NM. The BVPS-2 PRA model for online PRA risk assessment calculates the Core Damage Frequency (CDF) for Mode 1 and 2 operations but not for a shutdown condition. The baseline zero maintenance CDF is 2.16E-05 per year, and the large early release frequency (LERF) is 4.05E-07 per year. Based on the current plant configuration with the Train "A" LHSI pump 2SIS-P21A, the Secondary Component Cooling pump 2CCS-P21A, the Turbine Driven Aux Feedwater pump Steamline C isolation valve 2MSS-SOV105F, and the Service Water Pump 2SWS-P21 B being out of service, along with the RCS Power Operated Relief Valve 2RCS-PCV456 (PORV 456) available but isolated by its block valve 2RCS-MOV536, the calculated CDF is 2.27E-05 per year, and the LERF is 4.06E-07 per year.

During the 36-hour NOED period, the plant-specific configuration with the above components inoperable results in an incremental conditional core damage probability (ICCDP) of 4.8E-09, and meets the NOED threshold guidance value of less than 5.OE-07. In addition, the plant-specific configuration with the above components inoperable results in an incremental conditional large early release probability (ICLERP) of 5.6E-12 and meets the NOED threshold guidance value of less than' 5.0E-08.

No other BVPS-2 equipment required for core damage or large early release mitigation will be intentionally removed from service for surveillances or maintenance activities during the NOED period. It is also assumed that no emergent equipment failures will occur. In addition to the currently protected B Train, the compensatory action to perform an hourly fire tour in the B Train Safeguard room and #2 Diesel Generator room will L-08-342 Page 5 of 14 minimize the chance that any fire will occur within the area that could also affect the B LHSI pump 2SIS-P21B.

b. Discuss the dominant risk contributors (cut sets/sequences) and summarize the risk insights for the plant-specific configuration the plant intends to operate in during the period of enforcement discretion. This discussion should focus primarily on risk contributors that have changed (increased or decreased) from the baseline model as a result of the degraded condition and resultant compensatory measures, if any.

The baseline model dominant risk contributors are the loss of both trains of Emergency AC power (due to the initiating event on one train and the probabilistic failure of the opposite train), which would lead to a failure of the Service Water pumps, the Component Cooling Water pumps, and the Charging pumps, and result in the loss of all Reactor Coolant Pump (RCP) seal cooling. The loss of all RCP seal cooling will eventually lead to an RCP Seal LOCA and core damage. The dominant risk contributors while in the NOED configuration are the same as the zero maintenance baseline model's, but with an increased frequency due to the PORV 456 block valve being closed. This increase in the frequency of the dominant sequences is associated with the plant configuration that existed prior to the Train "A" LHSI Pump becoming inoperable.

c. Explain compensatory measures that will be taken to reduce the risk associated with the specified configuration. Compensatory measures to reduce plant vulnerabilities should focus on both event mitigation and initiating event likelihood. The objectives are to:
1) reduce the likelihood of initiating events;
2) reduce the likelihood of unavailability of trains redundant to the equipment that is out-of-service during the period of enforcement discretion;
3) increase the likelihood of successful operator recovery actions in response to initiating events.

An example is a situation where a motor-driven auxiliary feedwater (MDAFW) pump has failed and risk insights have established that plant transient initiators may be risk-significant events because the plant has no primary feed-and-bleed capability and only limited secondary feed capability is available. As a compensatory measure during the period of enforcement discretion, L-08-342 Page 6 of 14 the licensee may defer non-essential surveillances or other maintenance activities where human error contributes to the likelihood of a plant scram and subsequent demand on the remaining AFW pumps. Another example of appropriate compensatory measures would be actions that increase the likelihood of success in manually aligning or starting equipment in response to an initiating event (e.g., stationing operators locally at equipment, "just-in-time training", and/or additional contingency plans).

With 2SIS-P21A, 2CCS-P21A, 2MSS-SOV105F, and 2SWS-P21B being out of service, along with PORV 456 being available but isolated by its block valve 2RCS-MOV536, compensatory measures will be taken to reduce plant vulnerabilities and remain within the acceptable risk levels.

The compensatory measures during the NOED period are: 1) No additional risk significant components will be intentionally taken out of service; 2) No planned switchyard activities will be allowed; 3) No additional maintenance activities that would impact PRA/safety-monitor modeled equipment; 4) Protect B LHSI pump 2SIS-P21 B (aligned to the B header); 5) Protect #2 Emergency Diesel Generator EDG 2EGS-EG2-2; 6)

Hourly fire tour in the B train Safeguard room and #2 Diesel Generator room will be performed.

d. Discuss how the proposed compensatory measures are accounted for in the PRA. These modeled compensatory measures should be correlated, as applicable, to the dominant PRA sequences identified in item b. above. In addition, other measures not directly related to the equipment out-of-service may also be implemented to reduce overall plant risk and, as such, should be explained. Compensatory measures that cannot be modeled in the PRA should be assessed qualitatively.

The PRA model configuration risk during the period that this NOED is in effect assumes that no other safety related Technical Specification or PRA/safety monitor modeled plant equipment is taken out of service.

These additional compensatory actions as stated in the previous section 4.c will ensure that dominant risk contributor equipment is protected, a reliable offsite power source is maintained, and that fires will be detected in an expeditious manner. Initiating event frequencies remain unchanged in the PRA model.

e. Discuss the extent of condition of the failed or unavailable component(s) to other trains/divisions of equipment and what adjustments, if any, to the related PRA common cause factors have L-08-342 Page 7 of 14 been made to account for potential increases in their failure probabilities. The method used to determine the extent of condition should be discussed. It is recognized that a formal root cause or apparent cause is not required given the limited time available in determining acceptability of a proposed NOED. However, a discussion of the likely cause should be provided with an associated discussion of the potential for common cause failure.

The BVPS-2 PRA modeled the LHSI pumps 2SIS-P21A normally aligned to the A-Header and 2SIS-P21 B aligned to the B-Header. The model also addresses common cause failures between the two pumps. During the NOED discretion period, 2SIS-P21 B will be protected and aligned to the B-Header. Additionally, the compensatory action to perform an hourly fire tour of the B train Safeguard pump room will minimize any potential environmental risk of common cause failures for the LHSI pump 2SIS-P21 B.

As previously discussed in Section 2, based on dimensional checks taken during reassembly of Train "B" LHSI pump (2SIS-P21 B) as documented in Order 200146714 (performed in April 2005) there is good assurance that the 21 B rotating assembly is sufficiently centered in the casing wear rings.

The work order records indicate that the pump wear rings were machined during the overhaul and the as-left tolerances were at the high end of the acceptable range. The 2SIS-P21 B inboard casing wear ring was replaced during this overhaul.

f. Discuss external event risk for the specified plant configuration. An example of external event risk is a situation where a reactor core isolation cooling (RCIC) pump has failed and a review of the licensee's Individual Plant Examination of External Events or full-scope PRA model identifies that the RCIC pump is used to mitigate certain fire scenarios. Action may be taken to reduce fire ignition frequency in the affected areas or reduce human error associated with time-critical operator actions in response to such scenarios.

The plant configuration risk assessed using RISKMAN in response to item 4.a., above includes the risk from both internal and external events. The dominant contributors to external event risk while in the NOED are not significantly impacted by the unavailability of 2SIS-P21A and components listed above that are out of service for maintenance. Again, the compensatory action to perform an hourly fire tour in the B train Safeguard room, and ensuring the HHSI System availability will minimize the potential ICCDP, since the HHSI System is an important system to ensure L-08-342 Page 8 of 14 RCS injection to mitigate core damage during small break LOCAs, while LHSI is not available.

g. Discuss forecasted weather conditions for the NOED period and any plant vulnerabilities related to weather conditions.

The National Weather Service forecasted weather conditions for the NOED period are mostly clear to partly cloudy with temperatures ranging from the mid 50's for highs and the mid 30's for lows. No severe weather is expected or forecasted for the duration of the'NOED request.

Therefore, no plant vulnerabilities are expected for these conditions.

5. The justification for the duration of the noncompliance.

The above described activities to restore operability of the Low Head Safety Injection Pump (2SIS-P21A) are projected to be completed by 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on October 24, 2008 based on the current schedule. An additional time of approximately 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is included in the NOED request to allow for contingent or emergent activities such as increase time to properly align the pump and motor assemblies. This estimate is based on a review of the scheduled activities which include pump reassembly, motor reinstallation, pump and motor alignment, clearance removal and post maintenance testing. These activities will be worked around-the-clock until pump operability is restored.

6. The condition and operational status of the plant (including safety-related equipment out of service or otherwise inoperable).

BVPS-2 is in Mode 1 at 100% power.

The following Technical Specification components are currently inoperable at BVPS-2.

" 2SIS-P21A (Low Head Safety Injection Pump) Required Action A.1 of Condition A in Technical Specification 3.5.2 is currently applicable.

  • 2RCS-PCV456 (RCS Power Operated Relief Valve) was declared Inoperable on August 4, 2008 due to seat leakage; LCO 3.4.11, Condition A was entered and the required action was completed (close and maintain power to the associated block valve within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

L-08-342 Page 9 of 14 In addition, the following safety related/augmented quality equipment is inoperable:

  • 2RCS-HCV250A (RCS Head Vent Valve) was declared inoperable on August 28, 2008 due to a failed controller card. License Requirement 3.4.5 Condition A was entered and the valve was de-energized closed.

0 2SWS-RQ102 (Component Cooling Water Heat Exchanger Liquid Process Radiation Monitor Detector) due to a loss of sample flow.

0 2SWS-RQ100A, B, C, D (Recirculation Spray Heat Exchanger Liquid Process Radiation Monitor Detector) due to a loss of sample flow.

  • 2FPD-CONTPNL1-4 (Control Panel for C02 for generator exciter enclosure) - spurious alarm-fire watch established.
7. The status and potential challenges to off-site and on-site power sources.

There are no activities scheduled in the switchyard or on the plant transformers that will adversely affect risk during the 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> extension period. Administrative controls require any emergent activities relating to risk significant items affecting offsite or onsite power sources to be re-evaluated. The current status of the grid is normal (Green) and is projected to remain normal for the duration of the NOED request. All Technical Specification required onsite and offsite power sources are currently operable. The FirstEnergy Solutions, Commodity Operations Group has confirmed that there are no known challenges to the offsite power sources.

The Technical Specification required components of the onsite power distribution system are operable and capable of performing their design function. Note, one of the two output breakers from the main unit generator is unavailable.

Severe weather is not predicted for the extent of the NOED based on the National Weather Service seven (7) day forecast for Shippingport, PA.

8. The basis for the licensee's conclusion that the noncompliance will not be of potential detriment to the public health and safety.
a. The proposed Enforcement Discretion does not involve a significant increase in the probability or consequences of a previously evaluated accident. As discussed in the response to Question number 4 above, there is not a significant increase in core damage probability resulting from L-08-342 Page 10 of 14 the proposed Enforcement Discretion. The inoperability of one of the two required LHSI pumps does not affect the probability of occurrence of an analyzed accident as described in the BVPS-2 Updated Final Safety Analysis Report (UFSAR) since the Low Head Safety Injection System is not an accident initiator. The Unit 2 LHSI pump is used to mitigate the consequences of an analyzed accident. The remaining LHSI pump is capable of mitigating the consequences of a Large Break Loss of Coolant accident assuming no single active failure. Therefore, the proposed enforcement discretion does not involve a significant increase in the probability of a previously evaluated accident.

Based on the low probability of a Design Basis Accident (DBA) occurring during the period of time the Train "A" LHSI pump will be inoperable (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> + 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />), and the continued operability of the remaining Technical Specification required 100% redundant LHSI pump, the proposed NOED does not involve a significant increase in the consequences of a previously evaluated accident.

b. The proposed Enforcement Discretion does not create the possibility of a new or different accident from any previously evaluated. No new accident' precursors have been created due to the inoperability of the Train "A" LHSI pump. The requested 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> period for Enforcement Discretion from meeting the Technical Specification 3.5.2 Required Action B does not introduce any new modes of operation or new accident precursors and does not involve any physical modifications to the plant. Train "B" LHSI pump remains operable to mitigate a DBA involving a Large Break Loss of Coolant event without a single active failure.
c. The proposed Enforcement Discretion does not involve a significant reduction in the margin of safety. The 100% redundant Train "B" LHSI pump remains operable to mitigate a DBA involving a Large Break Loss of Coolant accident without a single active failure. Several compensatory measures will also be implemented to provide additional assurance that the assumptions in the risk evaluation are maintained and to minimize the likelihood of a plant transient for the duration of the NOED.
d. The compensatory measures during the NOED discretion period are:
1) No additional risk significant components will be intentionally taken out of service;
2) No scheduled switchyard activities will be allowed; L-08-342 Page 11 of 14
3) No additional maintenance activities that would impact PRA/safety-monitor modeled equipment;
4) Protect B LHSI pump 2SIS-P21 B (aligned to the B header);
5) Protect #2 Emergency Diesel Generator EDG 2EGS-EG2-2;
6) Hourly fire tours in the B train Safeguard room and #2 Diesel Generator room will be performed.
e. Based on the above, the proposed Enforcement Discretion will not be of potential detriment to the public health and safety.
9. The basis for the licensee's conclusion that the noncompliance will not involve adverse consequences to the environment.

The proposed Enforcement Discretion request has been evaluated against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed Enforcement Discretion request meets the criteria for categorical exclusion as provided for under 10 CFR 51.22(c)(9). The following is a discussion of how the proposed Enforcement Discretion request meets the criteria for categorical exclusion.

(i) The proposed change involves no Significant Hazards Consideration (refer to response to Question 8 above),

(ii) There are no significant changes in the types or significant increases in the amount of any effluent that may be released offsite since the proposed Enforcement Discretion request does not affect the generation of any radioactive effluent nor does the proposed request affect any of the permitted release paths. The proposed change does not involve a change to the facility or operating procedures that would cause an increase in the amount of effluents or create new types of effluents, and (iii) There is no significant increase in individual or cumulative occupational radiation exposure. The proposed change does not affect radiation levels at BVPS-2.

I L-08-342 Page 12 of 14

10. A statement that the request has been approved by the facility organization that normally reviews safety issues (Plant On-site Review Committee, or its equivalent).

The Plant Operations Review Committee reviewed and approved this NOED request.

11. The request must specifically address which of the NOED criteria for appropriate plant conditions specified in Section B (of NRC Inspection Manual Part 9900: Technical Guidance, Operations - Notices of Enforcement Discretion) is satisfied and how it is satisfied.

FENOC is submitting this NOED request for BVPS-2 in accordance with the guidance in "NRC Inspection Manual, Part 9900: Technical Guidance, .

Operations - Notices of Enforcement Discretion." Discretion is being requested based on Section 2.1, Situations Affecting Radiological Safety - Regular NOEDs, Criterion 1.a, which states:

1. For a plant in power operation, a NOED is intended to:

a) avoid unnecessary transients as a result of compliance with the license condition and, thus, minimize potential safety consequences and operational risks.

The NOED criteria in 2.1.1(a) for an operating plant are satisfied. BVPS-2 is operating at approximately 100% power. Compliance with Required Action B of Technical Specification 3.5.2 would initiate an unnecessary transient by requiring the plant to initiate a shutdown on October 22, 2008. The proposed action would allow continued plant operation to perform the required repair and testing.

Granting the NOED will preclude the operational risk associated with a transient during shutdown. No corresponding health and safety benefit is gained by requiring a plant shutdown. Based on above, the criteria are satisfied.

12. Unless otherwise agreed as discussed in Section B, a commitment is required from the licensee that the written NOED request will be submitted within 2 working days and the follow-up amendment will be submitted within 4 working days of verbally granting the NOED. The licensee's amendment request must describe and justify the exigent circumstances (see 10 CFR 50.91(a)(6)). The licensee should state if staff has agreed during the teleconference that a follow-up amendment is not needed. If the licensee intends to propose a temporary amendment, the licensee's amendment request shall include justification for the temporary nature of the requested amendment.

L-08-342 Page 13 of 14 On October 22, 2008 at 1105 hours0.0128 days <br />0.307 hours <br />0.00183 weeks <br />4.204525e-4 months <br />, the NRC granted verbal approval of the NOED request. This letter fulfills the requirement to submit a written NOED request within two working days of the NRC's verbal approval.

FENOC has concluded a license amendment request is not warranted for the following reasons:

0 The NOED will be in effect for a relatively short duration (i.e., 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />).

0 This action represents a one-time deferral to allow restoration of the Train "A" LHSI pump following discovery of an unexpected condition during routine maintenance activities.

0 It involves a non-recurring noncompliance and only involves a single request for extending the technical specification allowed outage time for an inoperable component.

  • Therefore, a change to extend the completion time stated in LCO 3.5.2 Condition A of the Technical Specifications to address this emergent issue is not required.

Following the NOED teleconference, the NRC concurred with FENOC's assessment that a follow-up license amendment is not required.

13. In addition to items 1-12 above, for a severe-weather NOED request the licensee must provide the following information:

The name, organization and telephone number of the official in the government or independent entity who made the emergency situation determination. If deemed necessary, the staff may contact the appropriate official to independently verify the information provided by the licensee prior to making a NOED determination.

Details of the basis and nature of the emergency situation including, but not limited to, its effect on:

1. on-site and off-site emergency preparedness;
2. plant and site ingress and egress;
3. off-site and on-site power sources;
4. grid stability; and
5. actions taken to avert and/or alleviate the emergency situation (e.g.,. coordinating with other utilities and the load dispatcher L-08-342 Page 14 of 14 organization for buying additional power or for cycling load, or shedding interruptible industrial or non-emergency loads).

Potential consequences of compliance with existing license requirements (e.g., plant trip, controlled shutdown).

The impact of the emergency situation on plant safety including the capability of the ultimate heat sink.

Potential adverse effects on public health and safety from enforcing compliance with specific license requirements during the emergency situation.

The proposed NOED is not related to severe weather.

ATTACHMENT 2 L-08-342 Regulatory Commitment List Page 1 of 1 The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS) Unit No. 2 in this document. Any other actions discussed in the submittal represent intended or planned actions by FENOC. They are described only as information and are not Regulatory Commitments. Please notify Mr. Colin P. Keller, Manager, Regulatory Compliance, at 724-682-4284 of any questions regarding this document or associated Regulatory Commitments.

Commitment Due Date

1. BVPS-2 will implement the following Duration of the NOED discretion compensatory measures during the period or until the Train "A" LHSI NOED discretion period: 1) No pump 2SIS-P21A is returned to additional risk significant components operable status.

will be intentionally taken out of service; 2) No scheduled switchyard activities will be allowed; 3) No additional maintenance activities that would impact PRA/safety-monitor modeled equipment; 4) Protect B LHSI pump 2SIS-P21B (aligned to the B header); 5) Protect #2 Emergency Diesel Generator EDG 2EGS-EG2-2;

6) Hourly fire tours in the B train Safeguard room and #2 Diesel Generator room will be performed.
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