ML052020101

Request for Additional Information (RAI) - Beaver Valley Power Station, Unit No. 1 (BVPS-1), Steam Generator Replacement, Partial Implementation of an Alternate Source Term

ML052020101
Person / Time
Site:	Beaver Valley
Issue date:	07/28/2005
From:	Colburn T NRC/NRR/DLPM/LPD1
To:	Pearce L FirstEnergy Nuclear Operating Co
Colburn T, NRR/DLPM, 415-1402
References
TAC MC6725
Download: ML052020101 (6)

Text

July 28, 2005 Mr. L. William Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) - RE: BEAVER VALLEY POWER STATION, UNIT NO. 1 (BVPS-1), STEAM GENERATOR REPLACEMENT, PARTIAL IMPLEMENTATION OF AN ALTERNATE SOURCE TERM (TAC NO. MC6725)

Dear Mr. Pearce:

By letter dated April 13, 2005, you submitted a license amendment request (LAR) for BVPS-1 to allow operation with replacement steam generators. Included in the application was a request for approval of a partial implementation of an alternate source term in accordance with Title 10 of the Code of Federal Regulations, Part 50, Section 50.67, Accident source term. The Nuclear Regulatory Commission (NRC) staff has determined that it will need the additional information identified in the enclosure to this letter to complete its review. These questions were discussed with your staff during a public meeting held on July 11, 2005, at NRC headquarters. As discussed with your staff, we request that you provide your response within 30 days of receipt of this request in order for the NRC staff to meet your requested LAR review schedule.

If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-334

Enclosure:

RAI cc: See next page

Mr. L. William Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) - RE: BEAVER VALLEY POWER STATION, UNIT NO. 1 (BVPS-1), STEAM GENERATOR REPLACEMENT, PARTIAL IMPLEMENTATION OF AN ALTERNATE SOURCE TERM (TAC NO. MC6725)

Dear Mr. Pearce:

By letter dated April 13, 2005, you submitted a license amendment request (LAR) for BVPS-1 to allow operation with replacement steam generators. Included in the application was a request for approval of a partial implementation of an alternate source term in accordance with Title 10 of the Code of Federal Regulations, Part 50, Section 50.67, Accident source term. The Nuclear Regulatory Commission (NRC) staff has determined that it will need the additional information identified in the enclosure to this letter to complete its review. These questions were discussed with your staff during a public meeting held on July 11, 2005, at NRC headquarters. As discussed with your staff, we request that you provide your response within 30 days of receipt of this request in order for the NRC staff to meet your requested LAR review schedule.

If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-334

Enclosure:

RAI cc: See next page DISTRIBUTION:

PUBLIC MO'Brien ACRS TColburn PDI-1 R/F LBrown RBellamy,RGN-I ADrozd JHayes RLaufer OGC DLPM/DPR RDennig ACCESSION NO.: ML052020101 OFFICE PDI-1/LA PDI-1/PM SPSB/SC PDI-1/SC NAME MOBrien TColburn ADrozd(A) RLaufer DATE 7/28/05 7/27/05 7/28/05 7/28/05 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION (RAI)

BEAVER VALLEY POWER STATION, UNIT NO. 1 (BVPS-1)

REPLACEMENT STEAM GENERATOR (RSG) LICENSE AMENDMENT REQUEST (LAR)

Table of Affected Technical Specifications The Nuclear Regulatory Commission (NRC) staff presumes that there needs to be a new definition of dose equivalent 131I since the doses will now be calculated as TEDE (total effective dose equivalent). Please review your definition to incorporate TEDE.

Section 5.4 Steam Generator Tube Rupture (SGTR)

With regard to Enclosure 1 of your July 8, 2005, extended power uprate (EPU) RAI response:

1. Item X.1, Section 5.4 of Enclosure 1 to your July 8, 2005, RAI response related to your extended power uprate LAR indicated that it would take 51 minutes to terminate the radioactive release from the ruptured tubes SG. Please provide the radiological analyses for this scenario which demonstrates that the 30-minute isolation time of your April 13, 2005, LAR is more limiting.

2. In your July 8, 2005, EPU RAI response to Item X.3, Section 5.4 of Enclosure 1, why wasnt failure of the atmospheric dump valve (ADV) considered at accident initiation?

Would it be more limiting than assuming failure of the ADV at accident initiation when the SG with the tube rupture is isolated?

With regard to enclosure 3 of the April 13, 2005, LAR:

3. Is it assumed or has it been verified that plant cooldown and steam releases from the intact SG cease at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the SGTR initiating event?

Section 5.11 Radiological Analysis

1. What is the basis for assuming a 30-minute purge of the control room envelope (CRE) following the completion of the accident sequence and are there procedures directing the operators to take such actions (Pg 5-225)?

2. It is stated that the control room shielding design is based upon the loss-of-coolant accident (LOCA) because the LOCA represents the worst case design-basis accident (DBA) relative to radioactivity releases. Does the LOCA represent the worst shine dose to the control room operators of any DBA (Pg 5-231)?

3. There appears to be no value assumed for inleakage into the CRE during the period that the CRE is operating in its normal mode of operation. In addition, the tracer gas tests performed did not include the inleakage characteristics while the normal control room ventilation system was operating. Also, the ventilation filter testing program (VFTP) contains no testing criteria for the normal ventilation system. There needs to be testing Enclosure

criteria since the normal ventilation system is now part of the response to an accident.

Is there emergency power to the normal ventilation system and to the recirculation system? If not, can you assume that they are operating in the event of a loss-of-offsite power (LOOP) (Table 5.11.9-3)?

4. What is the basis for assuming that the iodine spike will occur for only 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as stated in Tables 5.11.9-4A, 5.11.9-5A and 5.11.9-9?

5. What is the basis for assuming that the faulted SG will be isolated in 30 minutes as stated in Table 5.11.9-5?

6. What is the basis for assumed particulate carry-over fraction in the SG as stated in Table 5.11.9-6?

7. What letdown demineralizer flow rate and removal efficiency were assumed in the determination of the release rate for the iodine spiking for the main steam line break (MSLB) and SGTR accidents?

With regard to Enclosure 2 of the April 13, 2005, LAR:

Meteorology

1. Were the following DBAs those for which new atmospheric dispersion factors (/Q values) were provided for use in the dose assessments: i) MSLB outside of containment, ii) SGTR, iii) locked-rotor accident (LRA), and iv) small line break (SLB) outside of containment?

2. Is this a complete list representing the limiting /Q values used in all of the new dose assessments for this LAR?

3. If so, is the following a correct pairing of the DBAs associated with each of the release/receptor locations?

Release Receptor Accident Unit 1 Ventilation Vent Unit 1 CR SLB Unit 1 MS Relief Valves Unit 1 CR MSLB Unit 1 MSL (break)/AEJ* Unit 1 CR MSLB, SGTR, LRA Unit 1 Ventilation Vent Unit 2 CR SLB Unit 1 MS Relief Valves Unit 2 CR MSLB Unit 1 MSL (break)/AEJ Unit 2 CR MSLB, SGTR, LRA Unit 2 Ventilation Vent Unit 1 CR SLB

Unit 2 MS Relief Valves Unit 1 CR MSLB Unit 2 Ventilation Vent Unit 2 CR SLB Unit 2 MS Relief Valves Unit 2 CR MSLB

• AEJ = air ejector

4. Why were /Q values associated with the ventilation vents and MS relief valves provided for postulated releases from BVPS-2 given that this LAR is for RSG at BVPS-1? Was the intent to use the BVPS-1-specific /Q values for the MSL (break)/AEJ dose assessment and the site limiting /Q values for the dose assessments related to postulated releases from the ventilation vent and MS relief valve, but not for the MSL (break)/AEJ? For the BVPS-1 MSL (break)/AEJ, is the break assumed to occur at the AEJ or were the more limiting /Q values assumed for a release from either the MSL (break) or AEJ?

5. What license proceeding approved the 1996-generated exclusion area boundary and low-population zone /Q values referenced in a prior LAR dated June 5, 2002, presented in the BVPS-1 and 2 Updated Final Safety Analysis Reports, and used in the dose assessments for this LAR?

6. Please provide reference to or the actual plant drawing of the site postulated release and receptor points applicable to this LAR of sufficient size and scale to facilitate a check that the inputs appear to be reasonable.

Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Mary OReilly, Attorney Rich Janati, Chief FirstEnergy Nuclear Operating Company Division of Nuclear Safety FirstEnergy Corporation Bureau of Radiation Protection 76 South Main Street Department of Environmental Protection Akron, OH 44308 Rachel Carson State Office Building P.O. Box 8469 FirstEnergy Nuclear Operating Company Harrisburg, PA 17105-8469 Regulatory Affairs/Performance Improvement Mayor of the Borough of Shippingport Larry R. Freeland, Manager P O Box 3 Beaver Valley Power Station Shippingport, PA 15077 Post Office Box 4, BV-A Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Commissioner James R. Lewis 475 Allendale Road West Virginia Division of Labor King of Prussia, PA 19406 749-B, Building No. 6 Capitol Complex Resident Inspector Charleston, WV 25305 U.S. Nuclear Regulatory Commission Post Office Box 298 Director, Utilities Department Shippingport, PA 15077 Public Utilities Commission 180 East Broad Street FirstEnergy Nuclear Operating Company Columbus, OH 43266-0573 Beaver Valley Power Station ATTN: R. G. Mende, Director Director, Pennsylvania Emergency Work Management (BV-IPAB)

Management Agency Post Office Box 4 2605 Interstate Dr. Shippingport, PA 15077 Harrisburg, PA 17110-9364 FirstEnergy Nuclear Operating Company Ohio EPA-DERR Beaver Valley Power Station ATTN: Zack A. Clayton Mr. B. F. Sepelak Post Office Box 1049 Post Office Box 4, BV-A Columbus, OH 43266-0149 Shippingport, PA 15077 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 J. H. Lash, Plant Manager (BV-IPAB)

FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077