L-21-063, Facility Id 04-13361, Unit 2 Emergency Diesel Generator Day Tanks

Facility Id 04-13361, Unit 2 Emergency Diesel Generator Day Tanks

ML21043A254
Person / Time
Site:	Beaver Valley
Issue date:	02/01/2021
From:	Enos M Energy Harbor Corp
To:	Carr S Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection
References
L-21-063
Download: ML21043A254 (5)

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energy Beaver Valley Power Station Route 168 P.O. Box4 harbor Shippingport, PA 15077-0004 February 1, 2021 L-21-063 Ms. Sharon Carr Department of Environmental Protection Bureau qf Environmental Cleanup and Brownfields Storage T~nk Section

.Southwest Regional Office 400 Waterfront Drive Pittsburgh, PA 15222

SUBJECT:

Beaver Valley Power Station, Faclllty ID 04-13361, Unit 2 Emergency Diesel Generator Day Tanks -

The lnfonnation contained in this letter is provided in response to the Pennsylvania Department of Environmenta! Protection's_ request during the January 27, 2Q21 virtual meeting concerning the Beaver Valley Power Station, Unit 2 (BVPS-2) emergency dlesel generator day tanks 009 and 0010.

When a potential station modification is identified, a series of rigorous processes are followed to ensure - procedura1 and regulatory requirements are identified and dispositioned in accordance* with station- procedures. .Gen.erally, these processes include identification of outage modifications at least 15 months In advance of a planned outage, presentation to our station Plant Health Committee requesting-endorsement of the modifi~tion, allocation of funding, development of the engineering design change, planning an~ finally Implementation.

Time requirements contained in the BVPS-2 Renewed Facility Operating License NPF-73 issued by the NRC dictate that while operating, one emergency diesel generator cannot be removed from service -for longer than a specified duration.

Although the despribed design mo~ificatlon has not been finalized, it is believed that Implementation of the modtfication would exceed the duration permitted by the BVPS-2 Technical Specifications and would require the plant to be in shutdown. To avoid an unnecessary plant shutdown, the station intends to complete this design modification

. during a pl~nned outage.

BVPS has taken the following steps to begin this process for the Installation of emergency vents on the BVPS-2 emergency dlesel generator day tanks as required by 25 Pa. Code Chapter 245. BVPS has consulted with an engineering firm and requested a proposal for Engineering services to perform the detailed design work for the modification arid has consulted with a certified tank Inspector on the required scope to

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energy Beaver Valley Power Station Route 168 P.O. Box4 harbor Shippingport, PA 16077-0004 Beaver Valley Power Station, Unit No. 2 L-21-063 Page2 achieve compliance. A presentation to the Plant Health Committee is being scheduled to endorse making this design motjificatlon.

BVPS appreciates the Department's flexibility a.s .it navigates this matter and looks forward to working with the Department to resolve ~is issue.

Should you have any questions regarding this matter, please direct them to Amy

• savage, at 724-682-7359,.

M s General Plant Manager

• cc: GiMm'e d~

• US NRG commitments are contained in this letter.)

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REGULATORY CORRESPONDENCE REVIEW FORM*

NOP-LP-4007--01 Rev. 03 Page1of 1 (1) LETTER NUMBER: (2) LETTER

SUBJECT:

Beaver Valley Power station NPDES Unit 2 Emergency Diesel L-21-063 Generator Day Tanks (3) SUBMITTAL DUE: (4) PREPARER 02/05/2021 Name: Amy Savage PHONE NO.:n4-682-7359 (5) POSTING REQUIRED (6) LICENSING BASIS DOCUMENT (7) OATH OR AFFIRMATION REQUIRED BY 10CFR19.11 CHANGE REQUIRED:

YES [81 NO YES l8J NO nYEs ~NO (8) PREPARER COMMENTS, SPECIAL INSTRUCTIONS: None (9) LICENSING, TECHNICAL STAFF AND MANAGEMENT REVIEW Signature Indicates that the review is COIYIPlete In accordance _with NOP-l,P-4007, and to the beet of the ~ r ' s knowledge, the submittal Is accurate and complete, and no *lgnlficant Information has been presented In or excluded from the submittal such that the reader could be misled. ~anagement ~

• algnatures also *Indicate that the level of review provided by their respective organization la acceptable. Where commitment ownership is Indicated, slg~re Indicates acceptance of responsibllity' for completlon of the Identified commitment Where Enclosure Verification Is Indicated, signature lnd1cates that the content of the Identified enclosure has been verified to be complete and accurate bv the mlaned oraanlzatlon.

Name & Orgenlza!lon Commitment EnclOSl.l'II Signature Date No Comments J..-1y::,,,i_ .. .., Verification r"'- t\ Comments Provided Preparer A. Savaaa NIA NIA \ LA1 \r\ \V\"r\ t/~b NIA NIA

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Peer Reviewer ~

D. Lebec S,upervisor NIA NIA

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i-/i,lt-t. g R. Winters NIA NIA

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(10) RECOMMENDATION FOR SIGNATURE Nane&Orgarization Commitment Enclosure Signature Date No Comments Ownershlo Venffcatloo Comments Provided Eli Crosby ,-J/1c . rJIA ~-:;:( "_Q_, ~Ld21 ~

(11) *REVIEWER-COMMENTS- NO RESPONSE REQUIRED (P~coniments'requl~ 18Jlonse on Form NOP-LP-4007-03):

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REGULATORY CORRESPONDENCE CHECKLIST NOP-LP-4007-02 Rev. 02 Page 1 of 2 Letter Number/Subject- L-21-063 The reviewers of this correspondence signify the review of the Items on the checklist by placing initials in the boxes below. As necessary, explain deviations, exceptions and non-applicable items in the Comments sections provided.

A. Peer Review:

No. Item Checked Initials

1. Correct organizations are listed on the review and routing fonns, including organizations providing statements of fact DL

2. References to Codes and Standards are accurate and in sufficient detail. OL

3. Subject line of an NRC cover letter references the NRC TAC number if applicable. Iv}/\

4. The letter number has been entered on the letter and subseQuent pages. OL

5. Format and presentation are consistent with NORM-LP-4003 and anv deviations justified. .OL 6.. Paces containinQ information pursuant to 10 CFR 2.390 are approprlatetv marked.

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7. Oath or affirmation (if required) - unswom declaration is present. N'/A

8. Dates are correct and consistent throuahout the submittal. /)L

9. Grammar soellina and editorial presentation have been verified to be correct. DL

10. All applicable oarts of the submittal are present (e.g. letter enclosures attachments affidavits). o,

11. If Regulatory Commitments are included in NRC correspondence, the regulatory commitments are re-stated on an attachment (Regulatory Commitment List) to the submittal and identified for ownership on the Regulatory Correspondence Review Form (NOP-LP-4007-01). If no regulatory commibnents are included In NRC correspondence, a statement to that effect Is provided in the correspondence. For Al/ft non-NRC correspondence, no statement regarding regulatory commitments is necessary.

12. The letter content is factually complete Is presented loalcallv and suooorts conclusions reached. OL

13. Enclosures and attachments are appropriately identified and contain' all the necessary information to support conclusion of the submittal without the need to obtain other reference material. , DL

14. If action Is requested of the NRC, the requested action date has been included with appropriate justification. JV/ft

15. If the letter is in response to NRC requests, there Is a clear tie between each question/request and the associated response, and each question/request is completely and clearly answered in the resoonse. ¥/ft

16. References listed have been reviewed, are available, and support the information contained In the correspondence. DL

17. Statements of fact have been verified to be accurate. DJ

18. Actions stated as being complete have been verified to be complete. DI

19. Submittal does not contain information that has a material effect on information previously submitted to the NRC in response to a Notice of Violation or other enforcement action (e.g., Davis-Besse head event) or may significantly affect the NRC's understanding of plant activities. If it does, expedited rv/1 communication paths with the NRC have been determined.

Review Performed Bv (Pnnt Name and Slan): ()V\":.s Lehic {),._ 1--- Date: .2- Ii l'LI Comments: I I

REGULATORY CORRESPONDENCE CHECKLIS T NOP-LP-4007-02 Rev. 02 Page 2 of 2 Letter Number/

Subject:

L-21-063 B. Cognizant Manager Review (Flnal Submittal Review Prior to Signature Authority):

No. Item Checked Initials

1. Comments obtained during the review cycle have been resolved and incorporated within the applicable sections of the submittal. The submittal remains factual and com lete.

2. Review signatures, or equivalent, have been obtained on Correspondence Review Forms NOP-LP-4007-01 .

3. The correspondence has been reviewed for regulatory commitments, licensing positions, prudency, a ro riate wordln and tentlal ulato im act

4. If the letter is In response to NRC questions or requests, there is a clear and complete response to each uestion or uest and all uestions have been satisfactori addressed.

Review Performed Comments: .,

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C. Responsible Organization Review (Administrative Support Follow-up):

No. Item Checked Initials

1. Date is on the letter and the letter has been put on the appropriate company letterhead.

2. Submittal cover letter is signed correctly.

3. Oath or Affirmation (if required) - unswom declaration is present. If a notarized statement Is requested b the si nature authori the statement e is si ned and notarized.

4. When appropriate, initial notification and copy of submittal has been provided to the NRC via electronic mail. *

5. Submittal has been malled, or provided electronically (In accordance with NRC guidance on electronic submittals to all a ro riate reci lents with a ro riate enclosures attachments etc.

6. Internal FENOC distribution Is complete.

7. Regulatory Commitments have been documented in accordance with FENOC commibnent mana ement rocedures.

a. Additional FENOC actions have been documented, as necessary, in appropriate activity tracking s stems.

9. Correspondence documentation package Is complete, and ready for Mure referral.

Comments: