L-14-113, Extension Request Regarding the Flood Hazard Reevaluation Report Required by NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force (NTTF) Review of Insights.

Extension Request Regarding the Flood Hazard Reevaluation Report Required by NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force (NTTF) Review of Insights.

ML14070A371
Person / Time
Site:	Beaver Valley
Issue date:	03/11/2014
From:	Emily Larson FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-113
Download: ML14070A371 (5)

Text

FENOC' Beaver Valley Power Station P.O. Box 4 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Eric A. Larson 724-682-5234 Site Vice President Fax: 724-643-8069 March 11, 2014 L-14-113 10 CFR 50.54(f)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Extension Request Regarding the Flood Hazard Reevaluation Report Required by NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a letter titled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 2 of the 10 CFR 50.54(f) letter addresses NTTF Recommendation 2.1 for flooding. One of the required responses is for licensees to submit a Hazard Reevaluation Report (HRR) in accordance with the NRC's prioritization plan. By letter dated May 11, 2012, the NRC placed the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), in Category 2 requiring a response by March 12, 2014.

By letter dated March 1, 2013, the NRC provided supplemental information regarding flood hazard reevaluations stating that incomplete HRRs that only contain an analysis of some flooding hazard mechanisms would not be of substantive benefit for staff review and would not be acceptable. Therefore, licensees should not submit partial reports, but rather submit an extension request on or before the submittal due date. The letter also provided guidance in requesting extensions of the reporting requirement, in that the

Beaver Valley Power Station, Unit Nos. 1 and 2 L-14-113 Page 2 following information should be included: (1) the reason for the delay; (2) a proposed schedule for the submittal of a complete HRR; and (3) the basis for the acceptability of the revised schedule.

FirstEnergy Nuclear Operating Company (FENOC) hereby submits the attached extension request for BVPS (Attachment 1), which contains the reasons for the delay, the proposed schedule, and the basis for the acceptability of the revised schedule. identifies the regulatory commitment contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager- Fleet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March_lL, 2014.

Respectfully, z.c1 /~

Eric A. Larson Attachments:

1. Extension Request for Beaver Valley Power Station, Unit Nos. 1 and 2, Flood Hazard Reevaluation Report

2. Regulatory Commitment List cc: Director, Office of Nuclear Reactor Regulation (NRR)

NRC Region I Administrator NRC Resident Inspector NRR Project Manager Director BRP/DEP Site BRP/DEP Representative

Attachment 1 L-14-113 Extension Request for Beaver Valley Power Station, Unit Nos. 1 and 2, Flood Hazard Reevaluation Report Page 1of2 FirstEnergy Nuclear Operating Company (FENOC) hereby submits an extension request for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Flood Hazard Reevaluation Report (HRR), which contains the reasons for the delay, the proposed schedule, and the basis for the acceptability of the revised schedule.

Reason for the Delay Following the guidance of JLD-ISG-2013-01, Section 1.5.3, FENOC has contacted the Nuclear Regulatory Commission (NRC) (by letter dated December 17, 2013) requesting the NRC interface with the U.S. Army Corps of Engineers (USAGE). FENOC requires information from the USAGE in order to complete the Flooding HRR. An initial telecon was held between the NRC and FENOC on January 10, 2014. During that telecon, the NRC indicated that they would arrange a meeting with the NRC, USAGE, and FENOC staffs. At this time, a date for the meeting has not yet been established, and a schedule for receiving the information has not been determined.

Calculations to support the BVPS flooding reevaluation are not yet finalized. The on-going calculations will include incorporation of site-specific local intense precipitation (LIP) rainfall and USAGE dam information.

FENOC is performing a detailed 2D model of the LIP hazard for the BVPS site, and additional time is required to complete the 2D model and the verification and validation of the calculation assumptions, input data, and results.

Proposed Submittal Schedule FENOC will submit the required BVPS Flood Hazard Reevaluation Report within 180 days of receiving the USAGE information.

Basis for the Acceptability of the Revised Schedule As recognized in the request for information pursuant to 10 CFR 50.54(f), NRC letter dated March 12, 2012, the current regulatory approach and the resultant plant capabilities provide confidence that an accident with consequences similar to the Fukushima Dai-ichi accident is unlikely to occur in the United States, and that continued operation does not pose an imminent risk to the public health and safety. Therefore, the duration of this extension request has no impact on safe plant operations.

An updated analysis modeled the site configuration from April 2012 and the current design basis for the LIP event. This analysis verified that the combination of site configuration changes since the original analyses have not adversely affected the current design basis.

Attachment 1 L-14-113 Page 2 of 2 In addition, FENOC has completed walkdowns of the BVPS site and verified that existing flood barriers and protection features comply with current BVPS flooding licensing basis. The BVPS current licensing basis (CLB) is met.

The current plant operating procedure addressing flooding at the site provides actions to be taken in the event of a high river water level. These actions are initiated when the river reaches a pre-determined elevation as indicated on the river water level indicator at the BVPS intake structure. Continuing actions are described for incremental changes in water level. These actions include monitoring water levels, monitoring plant equipment, de-energizing plant equipment, communication with outside organizations on flooding forecasts and local dam conditions, and plant shutdown, as applicable for the water level. No additional actions beyond those currently in place are necessary.

The events being analyzed in the BVPS flood hazard reevaluation are beyond the plant design and licensing basis. Therefore, any reevaluation results based on beyond-design-basis events would not constitute an operability concern. This is consistent with the NRC supplemental information letter dated March 1, 2013.

Attachment 2 L-14-113 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, Unit Nos. 1 and 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. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810 of any questions regarding this document or associated Regulatory Commitments.

Regulatory Commitment Due Date

1. FENOC will submit the required BVPS Flood Within 180 days of receipt Hazard Reevaluation Report within 180 days of of USAGE information receiving the USAGE information.