L-17-296, Response to Request for Additional Information Re Request to Revise the Emergency Plan

Response to Request for Additional Information Re Request to Revise the Emergency Plan

ML17264A034
Person / Time
Site:	Beaver Valley
Issue date:	09/20/2017
From:	Bologna R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8448, CAC MF8449, L-17-296
Download: ML17264A034 (8)

Text

FENOC," Beaver Valley Power Slafion P.O. Box 4 F irstEnergy Nuclear Operating Company Shippingport, PA 15077 Richard D. Bologna 724-682-5234 Sife Vice President Fax: 724-643-8069 September 20, 2017 L-17-296 10 CFR 50, Appendix E 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. 50412, License No. NPF-73 Response to Request for Add itional lnformation Reqardino a Reouest to Revise the Emeroencv Plan (CAC Nos. MF84$8 AND MFB449)

By correspondence dated September 28, 2016 (Accession No. ML162774194), as supplemented by correspondence dated May 10, 2017 (Accession No. ML171444484) and September 7,2017 (Accession No. ML172508169) FirstEnergy Nuclear Operating Company (FENOC) submitted a request to revise the current Beaver Valley Power Station Unit Nos. 1 and 2 (BVPS) Emergency Plan emergency action level scheme to one based on Nuclear Energy Institute (NEl) 99-01, "Development of EmergencyAction Levels for Non-Passive Reactors," Revision 6.

By correspondence dated September 13,2017 the Nuclear Regulatory Commission (NRC) requested additional information to complete its review. FENOC's response is attached. As a result, the EmergencyAction Level (EAL) Bases Document has been revised, and the revised pages are enclosed.

The information contained in this supplement does not impact the conclusions of the significant hazards consideration determination or environmental considerations of the original request provided in Enclosure A of FENOC letter dated September 28, 2016 (Accession No. ML1 6277 A1g4l.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-17-296 Page 2 There are no regulatory commitments contained in this submittal. lf there are any questions or additional information is required, please contact Mr, Thomas A Lentz, Manager - Fleet Licensing, at (330) 315-6810.

I declare undpr penalty of perjury that the foregoing is true and correct. Executed on Septemb*, J O, 2o1i.

Sincerely, Richard D. Bologna

Attachment:

Response to September 13, 2017 Request for Additional lnformation Enclosu re:

Emergency Action Level Technical Bases Document - HG1 Only cc NRC Region I Administrator NRC Resident lnspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

ATTACHMENT L-17-296 Response to September 13, 2017 Request for Additional Information Page 1 of 1 By application dated September 28, 2016 (Accession No. ML16277A194), as supplemented by letters dated May 20, 2017 (Accession No. ML17144A484) and September 7, 2017 (Accession No. ML17250B169), First Energy Nuclear Operating Company (the licensee) requested approval of changes to revise the emergency action level (EAL) scheme for the Beaver Valley Power Station, Unit Nos. 1 and 2, to one based on the Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 21, 2012 (Accession No. ML12326A805). By correspondence dated September 13, 2017, NRC staff requested additional information to complete its review.

The requested information is presented below in bold type, followed by the FENOC response.

EAL HG1.1 Basis: RAI-BVPS-33

1. The clarification to the threshold value of Damage to spent fuel has occurred or is IMMINENT (as determined by lowering of spent fuel pool (SFP) level reading less than or equal to 0.5 feet or cannot be monitored for two hours or longer) is not part of the EAL. This could cause inconsistencies in the application of the EAL. Please include it as part of the EAL or as a note, included in the wallboard.

Response

EAL HG1.1 (Unit 1) was revised to include the following note, Note 18: IMMINENT damage to the spent fuel can be determined by spent fuel pool level (Ll-1FC-200A/B) reading 0.5ft. (Level 3).

EAL HG1.1 (Unit 2) was revised to include the following note, Note 19: IMMINENT damage to the spent fuel can be determined by spent fuel pool level (2FNC-Ll101 A/B) reading 0.5ft. (Level 3).

2. Please provide a justification for including an inability to monitor the SFP for two hours. As proposed, a loss of SFP level indication without indications of a loss of SFP integrity does not justify a General Emergency classification.

Response

The statement or cannot be monitored for two hours or longer has been deleted from the EAL HG1.1 (Unit 1 and Unit 2) basis section.

Enclosure L-17-296 Emergency Action Level Technical Bases Document - HG1 Only (4 pages follow)

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HG1.1 Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility.

EAL:

HG1.1 General Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Shift Supervisor AND EITHER of the following has occurred:

1. ANY of the following safety functions cannot be controlled or maintained.

Reactivity Control (ability to shut down the reactor and keep it shut down)

Core Cooling RCS heat removal OR

2. Damage to spent fuel has occurred or is IMMINENT (Note 18)

Note 18: IMMINENT damage to the spent fuel can be determined by spent fuel pool level (Ll-1FC-200A/B) reading 0.5ft. (Level 3).

Mode Applicability:

All Basis:

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g. pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained as determined by spent fuel pool level (LI-1FC-200A/B) reading 0.5 ft. (Level 3).

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

4 - 111

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL Technical Bases No Changes - Information Only HG1.1 Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the BVPS Physical Security/Contingency Plan (ref 1).

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HG1

3. NEI 99-01 Rev. 6 AS2

4. ECP No. 13-0561-000, Reference Documents for ECP-13-0561 - Installation of Spent Fuel Pool Level Instrumentation for Beyond Design Basis External Events 4 - 112

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:

Unit 2 EAL Technical Bases Category: H - Hazards HG1.1 Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility.

EAL:

HG1.1 General Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Shift Supervisor .

AND EITHER of the following has occured:

1. ANY of the following safety functions cannot be controlled or maintained.

Reactivity control (ability to shut down the reactor and keep it shut down)

Core cooling RCS heat removal OR

2. Damage to the spent fuel has occurred or is IMMINENT (Note 19)

Note 19: IMMINENT damage to the spent fuel can be determined by spent fuel pool level (2FNC-Ll101 A/B) reading 0.5ft. (Level 3).

Mode Applicability:

All Basis:

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls. etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level can not be maintained as determined by spent fuel pool level (2FNC-Ll101A/B) reading 0.5 ft. (Level 3).

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

4 - 331

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:

Unit 2 EAL Technical Bases No Changes - Information Only HG1.1 Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the BVPS Physical Security/Contingency Plan (ref. 1).

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HG1

3. NEI 99-01 Rev. 6 AS2

4. ECP No. 13-0561-000, Reference Documents for ECP-13-0561 - Installation of Spent Fuel Pool Level Instrumentation for Beyond Design Basis External Events 4 - 332