ML080740392

Summary of Telephone Conference Between NRC and Firstenergy Nuclear Operating Company, Concerning Clarification of Severe Accident Mitigation Alternatives Request for Additional Information Pertaining to Beaver Valley Units 1 & 2

ML080740392
Person / Time
Site:	Beaver Valley
Issue date:	03/26/2008
From:	Kent Howard NRC/NRR/ADRO/DLR
To:
Sayoc, Manny, NRR/DLR/RLRB 415-1924
References
Download: ML080740392 (10)

Text

March 26, 2008 LICENSEE: FirstEnergy Nuclear Operating Company FACILITY: Beaver Valley Power Station, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JANUARY 16, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND FIRSTENERGY NUCLEAR OPERATING COMPANY, CONCERNING CLARIFICATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of FirstEnergy Nuclear Operating Company held a telephone conference call on January 16, 2008, to discuss clarification questions on the Severe Accident Mitigation Alternatives Request for Additional Information (RAI) concerning the Beaver Valley Power Station Units 1 and 2, license renewal application. Enclosure 1 is a list of the conference call participants. Enclosure 2 is a summary of the questions asked and the RAI clarification responses from NRC staff.

If you have any questions concerning the NRC staffs summary of this telephone conference, please contact Mr. Kent Howard, at 301-415-2989 or by e-mail at KLH1@nrc.gov.

Sincerely,

/RA/

Kent Howard, License Renewal Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

As stated cc w/encls: See next page

March 26, 2008 LICENSEE: FirstEnergy Nuclear Operating Company FACILITY: Beaver Valley Power Station, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JANUARY 16, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND FIRSTENERGY NUCLEAR OPERATING COMPANY, CONCERNING CLARIFICATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of FirstEnergy Nuclear Operating Company held a telephone conference call on January 16, 2008, to discuss clarification questions on the Severe Accident Mitigation Alternatives Request for Additional Information (RAI) concerning the Beaver Valley Power Station Units 1 and 2, license renewal application. Enclosure 1 is a list of the conference call participants. Enclosure 2 is a summary of the questions asked and the RAI clarification responses from NRC staff.

If you have any questions concerning the NRC staffs summary of this telephone conference, please contact Mr. Kent Howard, at 301-415-2989 or by e-mail at KLH1@nrc.gov.

Sincerely,

/RA/

Kent Howard, License Renewal Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

As stated cc w/encls: See next page DISTRIBUTION: See next page Adam Accession Nos: ML080740392 OFFICE: LA:DLR PM:DLR:RPB2 PM:DLR:RPB2 BC: DLR:RPB2 NAME: IKing ESayoc ESayoc for R. Franovich w/comments KHoward DATE: 3/26/08 3/26/08 03 /26/08 3/26/08 OFFICIAL RECORD COPY

LIST OF PARTICIPANTS FOR THE TELEPHONE CONFERENCE CALL FOR BEAVER VALLEY POWER STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION January 16, 2008 PARTICIPANTS AFFILIATIONS Kent Howard U.S. Nuclear Regulatory Commission (NRC)

Emmanuel Sayoc NRC Robert Palla NRC Bruce Mrowca ISL Inc.

Ali Azarm ISL Inc.

Cliff Custer FirstEnergy Nuclear Operating Company (FENOC)

Glenn Ritz FENOC Bill Etzel FENOC MIke Ressler FENOC Mike Phillips Scientech ENCLOSURE 1

SUMMARY

AND STAFF RESPONSES FOR THE TELEPHONE CONFERENCE CALL FOR BEAVER VALLEY POWER STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION January 16, 2008 Question 1:

RAI 1 - Two items c are listed; actual list should conclude with h. References that follow are relative to original listing.

Staff Response:

Yes that was a typographical error. RAI question 1 includes parts a-h.

Question 2:

RAI 1(a) - Is this question in regards to only the internal events (as shown on Table 3.1.1.1-1) that make-up the remaining 10% of internal CDF, or are all initiating events, both internal and external to be identified further.

Staff Response:

This regards to internal events only, without flooding.

Question 3:

RAI 1(c) - Please clarify the requested level of detail in the discussion (e.g., only major plant and PRA model differences).

Staff Response:

Discuss the plants differences in terms of physical features and modeling differences.

Question 4:

RAI 1(d) - The reasons for the reduction in CDF due to the Revision 3 changes (which also incorporated the resolutions to the WOG PRA Peer Review Category A and B F&Os that impacted the model) are provided in Appendix E, Attachment C on pages C.1-14 through C.1-16, and are listed in order of expected importance on the impacts to the PRA model. Is this information sufficient or is more information needed?

Staff Response:

Identify the top two or three changes with greatest impact on the lowering of CDF in Revision 3.

Question 5:

RAI 1(f) - The common systems and structures are discussed and identified in LRA sections 1.2 (paragraph 5), 2.3.3.1 (paragraph 2), and Tables 2.2-1 thru 2.2-5 (designated as common);

[see pdf file transmitted separately]. Please clarify that only the ones modeled in the PRAs need to be addressed.

Staff Response:

Yes, only those modeled in the PRA.

ENCLOSURE 2

Question 6:

RAI 1(g) - Please clarify what is meant by the term breakdown and identify how many flood scenarios should be included as top flood scenarios (is it the same number as dominant flood sequences), and whether these summaries should describe the Level 1 (leading to CDF) or Level 2 (leading to CDF followed by a release) scenarios. [please see data table at end of list]

Staff Response:

There is no set number of scenarios, what is important here is that all dominant initiating events or scenarios are captured in the ER and that each event or scenario is addressed by a candidate SAMA.

Question 7:

RAI 2(a) - Appendix E, Attachment C, Tables 3.2.1-6 on pages C.1-34 and C.2-34 provide a brief description of the 14 accident sequences analyzed using MAAP-DBA to evaluate each of the release categories identified in the BVPS SAMA evaluation. Is this information sufficient or is more information needed?

Staff Response:

Sequence descriptions in Table 3.2.1-6 are acceptable, however provide fission product release fractions for each release category.

Question 8:

RAI 2(b) - The MAAP-DBA code is the current, approved, BVPS CLB analysis tool. A discussion of the MAAP-DBA code is docketed in FENOC Letter L-03-188 dated November 11, 2003. Furthermore, the fission product models are the same in both versions of MAAP. Is a comparison to MAAP 4.0.4 required?

Staff Response:

Provide a discussion on the background, and use of MAAP-DBA and how the source terms predicted by MAAP-DBA compare to those for MAAP4.04.

Question 9:

RAI 3(a) - Please concur with our definition of dominant as used in reference to flooding, fire, seismic, and total CDF scenarios [RAI 1(g), 3(a), 3(b), & 5(b)]:

Using the ASME PRA Standard RA-Sb-2005 definition for significant accident sequence (which is an aggregate core damage frequency (CDF) percentage of 95% or an individual CDF percentage of 1%) as a basis, we define the term dominant accident sequence as having an aggregate CDF percentage of 50% or an individual CDF percentage greater than 2%, and shall consist of a minimum of the top 10 CDF sequences. For specific accident groups (e.g., fire, seismic, or floods), these same thresholds will be used but shall consist of a minimum of the top 5 sequences for the specific accident group evaluated. [Please see reference data table for RAI 1(g), 3(a),

3(b), & 5(b) at the end of list]

Also state whether these summaries should describe the Level 1 (leading to CDF) or Level 2 (leading to CDF followed by a release) scenarios. Additionally, the term plant initiator is not fully understood if fire frequency and SSC impact are provided.

Staff Response:

In terms of fire events, provide the area, or scenario, or initiating event where the plant is most vulnerable. List these by CDF contribution. These top vulnerability listings are deemed dominant. What is important here is that all areas, events or scenarios are captured in the ER and that each event or scenario is addressed by a candidate SAMA.

Question 10:

RAI 3(b) - Please concur with our above definition of dominant as used in reference to seismic scenarios, and whether these summaries should describe the Level 1 (leading to CDF) or Level 2 (leading to CDF followed by a release) scenarios. Additionally, the term plant initiator is not fully understood if seismic frequency and SSC impact are provided. [please see data table at end of list]

Staff Response:

The response related to RAI 3(a) applies except here seismic events are the focus.

Question 11:

RAI 4(a) - The referenced calculation is available, however, the NEI 95-01 numbers are furnished in NEI 95-01 as examples. The SAMA analysis uses site specific economic input values for MACCS2. Therefore, the basis for the 15 to 70 percent difference statement is unclear. Please clarify so we respond to the question appropriately.

Staff Response:

Please provide a document/reference providing the basis for selection of site specific values.

Question 12:

RAI 4(b) - Since BVPS first identified and corrected for the three (3) referenced SECPOP2000 issues, is a response necessary? We provided information to NRC via telecom and e-mail prior to submittal. This included the INPO OE report describing the workarounds for each of the issues. Is more information needed or just the previous information on the docket?

Staff Response:

The staff acknowledges that BVPS first identified and corrected for the three referenced SECPOP2000 issues. Please provide emphasis in the ER that these issues have been identified and properly addressed.

Question 13:

RAI 5(b) - Please clarify the use of the term dominant in reference to flood, fire and seismic event scenarios used for the SAMA identification. Is it in regards to dominant CDF sequences when all initiating events are ranked-ordered by decreasing frequency (i.e., based on total CDF), or is it in regards to dominant CDF sequences when specific accident groups are ranked-ordered by decreasing frequency (i.e., based on each specific accident group CDF, as assumed in RAI 3(a), 3(b))?

For example, at Unit 1 only the top 7 CDF sequences have an individual percent contribution to total CDF that is greater than 2%, and consist of 5 seismic event sequences and 2 fire sequences. No floods would be considered dominant contributors to the total CDF, since the highest ranked flooding initiator would only contribute less than 0.1% to the total BVPS-1 CDF (1.18E-08 / 1.95E-5) and would be ranked 209th

amongst all initiators when ranked-ordered by decreasing frequency. However, if dominant is in regards to a specific accident group CDF, 11 flooding sequences would have a greater than 2% individual percent contribution to CDF due to floods, and the same highest ranked flooding initiator would contribute to 9.5% of the CDF due to floods (1.18E-08 / 1.24E-7). Note that in the reference data table at the end of the list only 9 flood sequences would be considered dominant, since their aggregate CDF due to floods is 51.9%.

Staff Response:

The response for 3(a) and 3(b) applies here. Essentially, it is important that all identified scenarios, or initiating events, or dominant vulnerabilities in question 3 have a corresponding SAMA candidate for evaluation.

Question 14:

RAI 6(e)1 - The Benefits column of data presented in Tables 7-1 includes the Offsite Economic Cost Risk (OECR), but does not break it out individually. Please elaborate on why the offsite cost is thought to have been left out, especially since the SAMA benefits are dominated by offsite impacts.

Staff Response:

Please provide an extra column added to Tables 7-1 which shows individual delta OECR shown in percentages.

Question 15:

RAI 7 - A discussion of dual unit SAMAs is included in section 7.3 of the SAMA reports in Attachment C-1 and C-2 of Appendix E. Please clarify what additional detail is needed.

Staff Response:

Please explain/clarify how cost was derived per unit for joint SAMAs.

Letter to FirstEnergy from K. Howard, dated March 26, 2008 DISTRIBUTION:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JANUARY 16, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND FIRSTENERGY NUCLEAR OPERATING COMPANY, CONCERNING CLARIFICATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE BEAVER VALLEY POWER STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION HARD COPY:

DLR RF E-MAIL:

PUBLIC BPalla SSmith (srs3)

SDuraiswamy RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDlrRlrc RidsNrrDlrReba RidsNrrDlrRebb RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSbwb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter KHoward ESayoc NMorgan MModes, RI PCataldo, RI DWerkheiser, RI

Beaver Valley Power Station, Units 1 and 2 cc:

Joseph J. Hagan Manager, Fleet Licensing President and Chief Nuclear Officer FirstEnergy Nuclear Operating FirstEnergy Nuclear Operating Company Company Mail Stop A-GO-2 Mail Stop A-GO-19 76 South Main Street 76 South Main Street Akron, OH 44308 Akron, OH 44308 Ohio EPA-DERR James H. Lash ATTN: Zack A. Clayton Senior Vice President of Operations P.O. Box 1049 and Chief Operating Officer Columbus, OH 43266-0149 FirstEnergy Nuclear Operating Company Director, Fleet Regulatory Affairs Mail Stop A-GO-14 FirstEnergy Nuclear Operating 76 South Main Street Company Akron, OH 44308 Mail Stop A-GO-2 76 South Main Street Danny L. Pace Akron, OH 44308 Senior Vice President, Fleet Engineering Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating FirstEnergy Nuclear Operating Company Company Mail Stop A-GO-14 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-A Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Jeannie M. Rinckel Vice President, Fleet Oversight Commissioner James R. Lewis FirstEnergy Nuclear Operating West Virginia Division of Labor Company 749-B, Building No. 6 Mail Stop A-GO-14 Capitol Complex 76 South Main Street Charleston, WV 25305 Akron, OH 44308 Director, Utilities Department David W. Jenkins, Attorney Public Utilities Commission FirstEnergy Nuclear Operating 180 East Broad Street Company Columbus, OH 43266-0573 Mail Stop A-GO-15 76 South Main Street Director, Pennsylvania Emergency Akron, OH 44308 Management Agency 2605 Interstate Drive Harrisburg, PA 17110-9364

Beaver Valley Power Station, Units 1 and 2 cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077 Cliff Custer FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077 Mike Banko FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077 Julie Firestone FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077