L-05-050, Units, 1 and 2, 10 CFR 50.46 (a)(3)(ii) Schedule for Reanalysis

Units, 1 and 2, 10 CFR 50.46 (a)(3)(ii) Schedule for Reanalysis

ML051080236
Person / Time
Site:	Beaver Valley
Issue date:	04/13/2005
From:	Pearce L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-05-050
Download: ML051080236 (4)

Text

FENOC Beaver Valley Power Station PO. Box 4 FirstEnergy Nuclear Operating Company Shippingport, PA 15077-0004 L William Pearce 724-682-5234 Vice President Fax: 724-643-8069 April 13, 2005 L-05-050 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 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 10 CFR 50.46 (a)(3)(ii) Schedule for Reanalysis On February 11, 2005 (Letter L-05-006), FirstEnergy Nuclear Operating Company (FENOC) provided responses to items contained in a December 14, 2004 NRC Request for Additional Information (RAI) regarding License Amendment Request (LAR) Nos.

317 and 190 (containment conversion). Item 27 of the RAI and the FENOC response were subsequently clarified in a telephone conversation between FENOC and NRC staff on February 23, 2005. Item 27 requested information related to the impact of the proposed LARs (related to change of containment pressure) on calculated peak cladding temperature (PCT) for limiting large and small break loss of coolant accidents (LOCAs).

It also requested information involving the accumulated impact of changes to LOCA analyses reviewed and approved by the NRC since the time of that approval.

During that telephone conversation the NRC staff requested that FENOC provide schedules for reanalysis of large and small break LOCAs to satisfy 10 CFR 50.46.

Supplementary information related to LARs currently under NRC review that are related to or contain new analysis information that would satisfy these schedules was also requested. The following information is provided in that regard.

Large Break LOCA The FENOC response to the December 14, 2004 RAI provided commitments to reanalyze both BVPS-1 and BVPS-2 large break LOCAs within one year of implementing containment conversion. It was originally intended that these commitments would be satisfied by use of Westinghouse best-estimate LOCA (BELOCA) analysis methodology pending NRC approval of LARs 318 (BVPS- 1) and 191 (BVPS-2) currently under NRC review, and the completed BELOCA analyses described in these LARs as supporting information. The one year time period was selected to allow time for implementation of alternate analyses as a contingency if BELOCA is not approved by the NRC.

Beaver Valley Power Station, Unit Nos. I and 2 10 CFR 50.46 (a)(3)(ii) Schedule for Reanalysis L-05-050 Page 2 However, as a result of clarification during the teleconference, the need to provide a BVPS-1 large break LOCA reanalysis schedule even after approval of the BELOCA methodology and supporting analysis information was identified. This is because the analysis described by the LAR contains two changes that would exceed the 30-day 10 CFR 50.46 reporting threshold, in addition to a compensatory peaking factor restriction resulting in 209 degrees reduction in PCT (total increases of the other two changes is 86 degrees). FENOC proposes to modify the BVPS-1 commitment on the basis of this clarification such that the schedule for reanalysis will be dependent on approval of LAR 318. A reanalysis using BELOCA methodology will be completed within two fuel cycles of implementation of containment conversion. The additional time to reanalyze using BELOCA is required due to scheduling requirements with the analysis vendor. The BELOCA analysis associated with LAR 191 will be credited with satisfying the BVPS-2 commitment because no changes have been accumulated.

Implementation of containment conversion is not dependent on obtaining approval of other license amendments. However, the analysis results described in the BELOCA methodology LAR reflect conditions associated with containment conversion (LARs 317 and 190), extended power uprate (LARs 302 and 173), and relaxed axial offset control (LARs 310 and 182). With the exception of the extended power uprate (EPU)

LAR for BVPS-1, these LARS are all planned to be implemented concurrently at the respective unit. The Unit 1 amendments would be implemented during plant startup from the 1R17 refueling outage (spring of 2006). The Unit 2 amendments would be implemented during plant startup from the 2R12 refueling outage (fall of 2006).

Because the EPU LAR for BVPS-1 contains proposed technical specification changes needed to replace steam generators and the EPU LAR will not be approved in time to support steam generator replacement, FENOC plans to submit 3VPS-1 LAR 320 related to replacement steam generators (RSGs). The RSG LAR will be a subset of changes extracted from the EPU LAR, and is intended to enhance the review schedule to support steam generator replacement during IR17. Therefore, with respect to large break LOCA the RSG LAR contains the same information as the EPU LAR that has already been submitted. The RSG LAR will be implemented during lR17. The remaining BVPS-1 EPU changes will be implemented at a later time.

Small Break LOCA New small break LOCA analyses have been performed to support the EPU LARs (302 and 173) currently under NRC review. Information related to the new analyses has been submitted with the EPU LARs. For BVPS-1, the same information will also be contained in the RSG LAR (320). Therefore, the new small break analyses would become part of the licensing bases upon implementation of license amendments resulting from the BVPS-1 RSG LAR (expected during lR17), and the

Beaver Valley Power Station, Unit Nos. 1 and 2 10 CFR 50.46 (a)(3)(ii) Schedule for Reanalysis L-05-050 Page 3 BVPS-2 EPU LAR (expected during 2R12). Analyses provided in support of the RSG and/or EPU LARs will be credited for the purpose of meeting a commitment for reanalysis. As a contingency, in the event that the EPU and/or RSG LAR is not approved for either unit, the current small break LOCA analysis for each unit (reflected in the November 19, 2004 10 CFR 50.46 report) will be submitted by October 2006 for NRC review.

Other than the EPU LARs and BVPS-1 RSG LAR, small break LOCA analyses are not related to other LARs currently under NRC review or being prepared for submittal.

Attachment A lists the regulatory commitments made in this transmittal. If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Supervisor - Licensing, at 330-315-6944.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on April /Ž..,2005.

Sincerely, William Pearce

.Attachments:

A. Commitment List c: Mr. T. G. Colbum, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Sr. Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRPIDEP)

L-05-050 ATTACHMENT A Commitment List The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS) 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. Henry L. Hegrat, Supervisor - Licensing at 330-315-6944 of any questions regarding this document or associated regulatory commitments.

Commitment Due Date Complete and submit a reanalysis of large break Within two fuel cycles LOCA for BVPS Unit No. 1. following implementation of BVPS Unit No. I containment conversion As a contingency, in the event that the EPU and/or October 2006 in the event RSG LAR is not approved for either unit, the current that the EPU and/or RSG small break LOCA analysis for each unit (reflected LAR is not approved for in the November 19, 2004 10 CFR 50.46 report) will either unit.

be submitted for NRC review.