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Category:Letter type:L
MONTHYEARL-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage L-23-059, Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-0022023-03-0909 March 2023 Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-002 L-22-212, CFR 50.55a Request RP-5 Regarding Inservice Pump Testing2023-03-0606 March 2023 CFR 50.55a Request RP-5 Regarding Inservice Pump Testing L-23-048, Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2023-03-0101 March 2023 Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report L-23-057, Energy Harbor Nuclear Corp Retrospective Premium Guarantee2023-02-20020 February 2023 Energy Harbor Nuclear Corp Retrospective Premium Guarantee L-22-253, Submittal of Pressure and Temperature Limits Report, Revision 52023-01-10010 January 2023 Submittal of Pressure and Temperature Limits Report, Revision 5 L-22-284, Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS)2022-12-28028 December 2022 Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS) L-22-211, Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2022-09-29029 September 2022 Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report L-22-216, Submittal of Pressure and Temperature Limits Report. Revision 42022-09-27027 September 2022 Submittal of Pressure and Temperature Limits Report. Revision 4 L-22-213, Occupational Radiation Exposure Report for Year 2021 - Correction2022-09-23023 September 2022 Occupational Radiation Exposure Report for Year 2021 - Correction L-22-129, Submittal of the Updated Final Safety Analysis Report, Revision 342022-09-20020 September 2022 Submittal of the Updated Final Safety Analysis Report, Revision 34 L-22-194, Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events2022-09-19019 September 2022 Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events L-22-203, Submittal of Evacuation Time Estimates2022-09-12012 September 2022 Submittal of Evacuation Time Estimates L-22-050, Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual2022-08-0909 August 2022 Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual L-22-152, Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan2022-07-0505 July 2022 Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan L-22-068, Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report2022-06-30030 June 2022 Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report L-22-037, 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2022-06-30030 June 2022 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-22-149, Post Accident Monitoring Report2022-06-23023 June 2022 Post Accident Monitoring Report L-22-153, Readiness for NRC Supplemental Inspection Required for a White Finding2022-06-22022 June 2022 Readiness for NRC Supplemental Inspection Required for a White Finding L-22-098, Withdrawal of Proposed Inservice Inspection Alternative RR-A22022-06-22022 June 2022 Withdrawal of Proposed Inservice Inspection Alternative RR-A2 L-22-136, Steam Generator Tube Circumferential Crack Report - Spring 2022 Refueling Outage2022-06-0707 June 2022 Steam Generator Tube Circumferential Crack Report - Spring 2022 Refueling Outage L-22-102, Report of Facility Changes, Tests, and Experiments2022-05-16016 May 2022 Report of Facility Changes, Tests, and Experiments L-22-092, Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 20212022-05-16016 May 2022 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2021 L-22-124, Response to Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building2022-05-12012 May 2022 Response to Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building L-22-047, Unit No.1 - Core Operating Limits Report, Cycle 23, Revision O and Revision 12022-05-10010 May 2022 Unit No.1 - Core Operating Limits Report, Cycle 23, Revision O and Revision 1 L-22-127, Readiness for NRC Supplemental Inspection Required for a Greater than Green Finding2022-05-0606 May 2022 Readiness for NRC Supplemental Inspection Required for a Greater than Green Finding L-22-089, Occupational Radiation Exposure Report for Year 20212022-04-12012 April 2022 Occupational Radiation Exposure Report for Year 2021 L-22-056, Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage2022-03-22022 March 2022 Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage L-22-059, Response to Request for Additional Information on Proposed Inservice Test Alternative RP-32022-03-21021 March 2022 Response to Request for Additional Information on Proposed Inservice Test Alternative RP-3 L-22-074, Response to Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-15015 March 2022 Response to Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations L-22-061, Ile Post Exam Letter L-22-0612022-02-24024 February 2022 Ile Post Exam Letter L-22-061 L-22-023, Retrospective Premium Guarantee2022-02-17017 February 2022 Retrospective Premium Guarantee L-21-266, Response to Request for Additional Information on Proposed Inservice Inspection Alternative RR-A22022-01-27027 January 2022 Response to Request for Additional Information on Proposed Inservice Inspection Alternative RR-A2 L-20-289, Emergency Plan Amendment Request2022-01-19019 January 2022 Emergency Plan Amendment Request L-21-290, Response to NRC Inspection Report 05000346/2021091, EA-21-1762021-12-21021 December 2021 Response to NRC Inspection Report 05000346/2021091, EA-21-176 2023-09-12
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FENOC 5501 North State Route 2 Oak Harbor, Ohio 43449 Mark B. Bezma 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 October 30, 2018 L-18-235 10 CFR 50.54(f)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Request for Deferral of Actions Related to Beyond-Design-Basis External Events Flooding Actions (CAC No. MF3721)
By this letter, FirstEnergy Nuclear Operating Company (FENOC) requests deferral of actions related to beyond-design-basis external events (BDBEE) flooding actions for Davis-Besse Nuclear Power Station (DBNPS).
By letter dated April 25, 2018 (Accession No. ML18115A007), FENOC provided notification to the Nuclear Regulatory Commission (NRC) that DBNPS would cease power operations in 2020. In light of the decision to permanently shut down and defuel, activities planned between now and the 2020 shutdown were reviewed. One of the activities scheduled during this period was the support of NRC staff review of the DBNPS focused evaluation (FE) for flooding that was submitted to meet the evaluation request documented in NRC letter dated September 1, 2015, "Coordination of Requests for Information Regarding Flooding Hazard Reevaluations and Mitigating Strategies for Beyond-Design-Basis External Events" (Accession No. ML15174A257).
FENOC provided the FE results for DBNPS by letter dated July 11, 2017 (Accession No. ML17192A069). This information is currently under review by NRC staff. FENOC no longer considers the continuance of the NRC staff review of the FE to be necessary given the results that unbounded reevaluated flood mechanisms previously submitted in the flood hazard reevaluation report, local intense precipitation (LIP) flood, and probable maximum storm surge (PMSS) flooding, do not impact key structures, systems, or components (SSCs) or challenge key safety functions at DBNPS.
Davis-Besse Nuclear Power Station L-18-235 Page 2 FENOC has performed and submitted the DBNPS mitigating strategies assessment (MSA) using the beyond-design-basis reevaluated flood hazards. The NRC has reviewed the MSA (Accession No. ML17086A499) and concluded that the DBNPS MSA was performed consistent with the guidance described in Appendix G of Nuclear Energy Institute (NEI) 12-06, Revision 2, and that the licensee has demonstrated that the mitigation strategies, if appropriately implemented, are reasonably protected from reevaluated flood hazards conditions for beyond-design-basis external events.
The DBNPS MSA for flood hazards identified that LIP and PMSS events challenged implementation of FLEX strategies in the Phase 3 strategy staging areas and the FLEX "N+1" equipment deployment path. For LIP, flooding levels develop for a depth above critical door sills for a period of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Waves and runup at the flooded locations are minimal, and therefore can be neglected. For PMSS, flooding levels impact critical station doors above elevation 585 feet for a period of 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. As a result, alternate staging areas were identified, and trigger points were developed that allow "N+1" equipment deployment prior to flooding of the deployment path. The FLEX final integrated plan (NORM-LP-7203) and applicable emergency plan off-normal occurrence procedures (RA-EP-02810, "Tornado or High Winds," and RA-EP-02830, "Flooding")
were updated to incorporate the established trigger points. Receiving a flood alert or high wind flood alert, as defined in the procedures, requires the site to take immediate action to ensure that the FLEX "N+1" equipment is relocated within two hours of receipt of the notification, providing adequate time for equipment to be staged prior to flooding of the deployment path.
As indicated in the results of the DBNPS FE, additional flooding analyses were performed to improve realism of the evaluated storm. Following Path 2 of NEI 16-05, Revision 1, site-specific analysis for a LIP event removed flooding from critical doors that lead directly to key SSCs. Non-critical doors that see minimal flooding are not designated as flood protection features. Following Path 1 of NEI 16-05, Revision 1, refined analysis for a PMSS event removed all flooding in the power block area.
Therefore, no safety-related structures are subject to flooding from a PMSS or LIP event. Based on these results, the current FLEX mitigating strategies provide reasonable protection from reevaluated flood hazards for BDBEE, and an integrated assessment is not needed.
Considering the FE results, time required for NRC review and determination if additional information or action is needed, and time for the plant to evaluate, provide, and implement any actions, there is insufficient time for the FE review effort to result in any appreciable safety benefit. With the decision to permanently shut down and defuel DBNPS, flooding activities being performed to meet the NRC 10 CFR 50.54(f) request for information (Accession No. ML12053A340) and any related support actions planned between now and the 2020 cessation of power operations, including further NRC staff review of the FE, are requested to be deferred.
Davis-Besse Nuclear Power Station L-18-235 Page 3 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager, FENOC Nuclear Licensing and Regulatory Affairs, at (330) 315-6808.
I declare under penalty of perjury that the foregoing is true and correct. Executed on October-3jl, 2018.
- )iJKJ Mark B. Bezilla cc
- Director, Office of Nuclear Reactor Regulation (NRR)
NRC Region Ill Administrator NRC Resident Inspector N RR Project Manager Utility Radiological Safety Board