L-08-229, Responses to a Request for Additional Information in Support of License Amendment Request No. 07-005

Responses to a Request for Additional Information in Support of License Amendment Request No.07-005

ML082180124
Person / Time
Site:	Beaver Valley
Issue date:	08/01/2008
From:	Ostrowski K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-229, LAR-07-005, TAC MD7531, TAC MD7532
Download: ML082180124 (12)

Text

FENOC FirstEnergy Nuclear Operating Company Kevin L. Ostrowski 724-682-7773 Director, Site Operations Fax: 724-643-1840 August 1, 2008 L-08-229 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission

'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. 50-412, License No. NPF-73 Responses to a Request for Additional Information in Support of License Amendment Request No.07-005 (TAC Nos. MD7531 and MD7532)

By letter dated June 27, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) pertaining to License Amendment Request (LAR) No.07-005. This LAR was submitted by FirstEnergy Nuclear Operating Company (FENOC) on December 21, 2007 by letter L-07-515 (Reference 1). The LAR involves relaxations of Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrumentation bypass test times, Completion Times, and Surveillance Frequencies for various instrumentation based on WCAP-14333-P-A, Revision 1 (Reference 2) and WCAP-1 5376-P-A, Revision 1 (Reference 3). contains the FENOC responses to the June 27, 2008 RAI. The regulatory commitments contained in this letter are listed in Attachment 2. FENOC requests approval of the proposed amendments by December 2008. Once approved, the amendments shall be implemented within 90 days.

If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager-FENOC Fleet Licensing, at 330-761-6071.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 1, 2008.

Sincerely, Kevi L.

Ot4' Kevin L. Ostrowski

Beaver Valley Power Station, Unit Nos. 1 and 2 Responses to a Request for Additional Information in Support of License Amendment Request No.07-005 (TAC Nos. MD7531 and MD7532)

L-08-229 Page 2 Attachments:

1.

Response to RAI Items

2.

Regulatory Commitment List

Reference:

1.

FENOC Letter L-07-515, License Amendment Request Number 07-005, dated December 21, 2007

2.

WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times," October 1998.

3.

WCAP-1 5376-P-A, Revision 1, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times,"

March 2003.

cc:

Mr. S. J. Collins, NRC Region I Administrator Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRR Project Manager Mr. D. J. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

ATTACHMENT 1 L-08-229 Responses to RAI Items REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE COMPLETION TIMES, BYPASS TEST TIMES AND SURVEILLANCE TEST INTERVALS BEAVER VALLEY POWER STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412 By letter dated December 21, 2007, (Agencywide Documents Access And Management Systems (Adams) Accession No. ML0703601008), FirstEnergy Nuclear Operating Company (licensee) submitted an application to amend the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) Technical Specifications (TSs). The proposed license amendment request (LAR) adopts changes as described in Westinghouse Commercial Atomic Power (WCAP) Topical Report WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS [reactor protection system] and'ESFAS [engineered safety features actuation system] Test Times and Completion Times," issued October 1998 and approved by the Nuclear Regulatory Commission (NRC) by letter dated July 15,1998.

Implementation of the proposed changes is in accordance with approved TS Task Force (TSTF) Traveler TSTF-418, Revision 2, "RPS and ESFAS Test Times and Completion Times (WCAP-14333)."

The proposed LAR also adopts changes as described in WCAP-15376-P-A, Revision 1, "Risk-Informed Assessment of the RTS [reactor trip system] and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," issued March 2003, as approved by the NRC by letter dated December 20, 2002. Implementation of the proposed changes is in accordance with approved TSTF-41 1, Revision 1, "Surveillance Test Interval Extension for Components of the Reactor Protection System (WCAP-15376)."

In order to complete the review, the NRC staff requests further information on the following items:

1.

Attachment A states that, "FENOC will review applicable BVPS programs and revise them as necessary to ensure that the intent of the RTS and ESFAS equipment unavailability and component failure modeling assumptions in WCAP-14333 and WCAP-15376 are met at BVPS." In addition, confirm the following conditions and limitations from WCAP-14333 and WCAP-1 5376 are to be included in the above licensee commitment. Please provide your commitment to meet the topical report conditions and limitations, i.e.:

For WCAP-14333, See Enclosure 1, Page 21 of the license amendment request (LAR):

a. To preserve anticipated transient without scram (ATWS) mitigation capability, activities that degrade the ability of the auxiliary feedwater (AFW) system, reactor coolant system (RCS) pressure relief systems (pressurizer power operated relief valves (PORVS) and safety valves), ATWS mitigating system actuation circuitry (AMSAC), or turbine trip should not be scheduled when a logic train is inoperable.

, L-08-229 Page 2 of 9

b. To preserve loss-of-coolant accident (LOCA) mitigation capability, one complete emergency core cooling system (ECCS) train that can be actuated automatically must be maintained when a logic train is inoperable.

c. To preserve reactor trip and safeguards actuation capability, activities that cause master relays or slave relays in the available train to be unavailable and activities that cause analog channels to be unavailable should not be scheduled when a logic train is inoperable.

d. Activities in electrical systems (e.g., AC and DC power) and cooling systems (e.g.,

service water and component cooling water) that support the systems or functions listed in the first three bullets should not be scheduled when a logic train is inoperable. That is, one complete train of a function that supports a complete train of a function noted above must be available.

For WCAP-1 5376, See Enclosure 1, Page 23 of the LAR:

e. The probability of failing to trip the reactor on demand will increase when an RTB train is removed from service; therefore, systems designed for mitigating an ATWS event should be maintained and available. RCS pressure relief power operated relief valves (PORVS) and safety valves, AFW flow (for RCS heat removal), AMSAC, and turbine trip are important to ATWS mitigation. Therefore, activities that degrade the availability of the AFW, RCS pressure relief system (pressurizer PORVs and safety valves), AMSAC, or turbine trip should not be scheduled when an RTB is inoperable.

f. Due to the increased dependence on the available reactor trip train when one logic train is unavailable, activities that degrade other components of the RTS, including master relays or slave relays, and activities that cause analog channels to be unavailable, should not be scheduled when a logic train is inoperable.

g. Activities in electrical systems (e.g., AC and DC power) that support the systems or functions listed in e and f should not be scheduled when an RTB is inoperable.

Response

As discussed above, the subject conditions and limitations of WCAP-14333 and WCAP-1 5376 are listed on pages 21 and 23 of Enclosure 1 of the LAR. These conditions and limitations also appear in Enclosure 1 Attachment B, Proposed Technical Specification Bases Changes. Refer to the Bases mark-ups for RTS Instrumentation shown on pages B.3.3.1-41, B.3.3.1-41a, B.3.3.1-41b and B.3.3.1-41c and the Bases mark-ups for ESFAS Instrumentation shown on pages B.3.3.2-34, B.3.3.2-34a, B.3.3.2-37 and B.3.3.2-37a. FENOC commits to revising the applicable portions of the BVPS Technical Specification Bases to incorporate the subject conditions and limitations of WCAP-14333 and WCAP-1 5376 as part of the implementation of the requested amendments.

, L-08-229 Page 3 of 9

2.

Identify the latest revision of the probabilistic risk assessment (PRA) and the PRA revision used for this LAR. Identify BVPS-1 and 2 plant LARs, plant modifications, or plant procedure changes not reflected in the PRA revision referenced for this LAR. See Section 3.1.7.3 of the LAR. Verify that the proposed WCAP-14333 and WCAP-15376 extended completion times and surveillance test intervals are not impacted by changes not incorporated into the BVPS PRA.

Response

The latest revisions of the BVPS-1 and BVPS-2 PRA models are the Revision 4 models; BV1 REV4 and BV2REV4, respectively. These revisions of the PRA models were also used in the assessments performed to justify the changes proposed in this LAR.

This response reflects clarifications obtained during a conference call with the NRC staff on June 19, 2008. As noted in Section 3.1.7.3 of the proposed LAR, the current BVPS PRA models have incorporated the extended power uprate modifications and all risk-informed changes that were implemented prior to April 20, 2006 and November 13, 2006 for BVPS-1 and BVPS-2, respectively. Plant modifications and changes to plant procedures that are credited in the PRA models that have been implemented after these dates were evaluated and shown not to significantly impact the current revisions of the PRA models. Additionally, the only LARs submitted after these dates which could potentially impact the PRA models, were changes to the recirculation spray system pump start signal due to the containment sump screen modifications. The impact on the PRA models, and resultant increases in core damage frequency and large early release frequency, from this submittal were determined to be insignificant and the pump start signal changes were subsequently approved by BVPS-1 Amendment No. 280 (Reference 1) and BVPS-2 Amendment No.164 (Reference 2). In addition, since this new ESFAS Function is a plant specific signal that was not addressed by the WCAP-1 0271-P-A series of topical reports, WCAP-14333-P-A, Revision 1 or WCAP-1 5376-P-A, Revision 1, a plant specific justification was provided in Section 3.1.5 of this proposed LAR and found to be acceptable for the proposed completion time and surveillance frequency extensions.

As of July 3, 2008, there are no outstanding LARs, plant modifications, or plant procedure changes that have been implemented that are not reflected in the PRA models used in the assessments of this proposed LAR, which would impact the proposed WCAP-14333 and WCAP-1 5376 extended completion times and surveillance test intervals.

3.

A high winds, floods and other (HFOs) external event risk evaluation was not provided in the LAR. Confirm that the conclusions stated in the IPEEE continue to represent the HFO risk at BVPS-1 and 2 (HFO events screened out).

Response

The potential plant vulnerabilities from external events at BVPS-1 and BVPS-2 have not significantly changed since the original design analyses and IPEEE submittals. Additionally, there have not been any significant changes in the occurrence frequencies of high winds, flooding, or other (HFOs) external events since the IPEEE submittals. Therefore, the conclusions stated in the IPEEE submittals continue to represent the HFO risk at BVPS-1 and BVPS-2.

, L-08-229 Page 4 of 9 Higqh Winds/Tornados Based on the NRC Safety Evaluation Report (SER) for BVPS Unit 2 (NUREG-1 057, "Safety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2"), the BVPS-2 IPEEE determined that the plant was in conformance with the 1975 Standard Review Plan (SRP) for high winds and tornados, so these external events screened out in accordance with NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities." In the SER, the 1 0 latitude-longitude square tornado strike frequency for the site was calculated to be 1.6E-04 per year using tornado data from 1954 to 1981. Since 1981, there have been 7 Fujita Scale Category FO or higher tornado occurrences in Beaver County, with the latest occurrence in 1998, based on data reported by the National Climatic Data Center through February 28, 2008. However, the 1 0 latitude-longitude square tornado strike frequency for the BVPS location (400 latitude, 800 longitude) remains essentially the same, at 1.677E-04 per year, as reported in NUREG/CR-4461, "Tornado Climatology of the Continuous United States", Revision 1 (based on tornado data from 1950 through August 2003). This more current tornado strike frequency is also lower than the 1.02E-03 value computed in the BVPS Unit 1 IPEEE.

Therefore, the IPEEE conclusions that the tornado high wind loading and generated missile contribution to core damage frequency are less than 1.OE-06 per year, would screen out in accordance with NUREG-1407, and that there are no potential vulnerabilities associated with high wind hazards, remain valid.

External Floods In the BVPS-1 and BVPS-2 IPEEEs it was determined that the plants' designs meet the 1975 SRP criteria, and that the core damage frequency due to external flooding was estimated to be less than 1.OE-06 per year using Hydrometeorological Reports (HMRs) 51 and 52 as referenced in NUREG-1057 to determine probable maximum precipitation values and to evaluate site flooding.

Based on a review of the design evaluation process utilized at BVPS, there have not been any plant changes that significantly affect the plants' hazard data or licensing bases with respect to flooding following the IPEEE submittals. Therefore, it is judged that the IPEEE conclusions that there are no potential vulnerabilities associated with flooding hazards remain valid.

Other External Events Air Transportation Accidents After September 11, 2001, the Federal Aviation Administration established additional temporary flight restrictions over sensitive sites in the United States, which include nuclear plants. With this restriction in low altitude airspace above the BVPS site, and a decline in airport operations around the BVPS vicinity over the past few years, it is judged that the IPEEE conclusions on air transportation accidents remain valid.

Marine Transportation Accidents No significant changes in the Ohio River barge traffic passing by the BVPS site have been observed since the IPEEE submittals. This is believed to be due in part to the decline in industry in the BVPS vicinity and the river transportation restrictions imposed since September 11, 2001. It is therefore judged that the IPEEE conclusions on marine transportation accidents are still valid.

, L-08-229 Page 5 of 9 Hazardous Substances from Offsite Sources There have not been any significant changes in the toxic gas hazards from offsite sources since the IPEEE submittals. However, there has been one new offsite hazard source identified within 5 miles of the BVPS site that was not evaluated in the IPEEEs.

This hazard source is a new propane pipeline terminal and wholesale distribution facility that went operational in late 2006. The principal types of potential hazards from this facility include a release of propane gas to incapacitate control room operators, overpressure resulting from the ignition and explosion of a vapor cloud, missile effects attributable to explosion debris, and thermal effects attributable to fires. The impacts of these potential hazards were assessed and it was concluded that either the hazard is not of consequence to the site or all postulated types of accidents from this offsite hazard having the potential to cause onsite accidents leading to the release of significant quantities of radioactive fission products have a sufficiently low probability of occurrence and fall within the scope of the low-probability-of-occurrence required by 10 CFR 100.20(b) based on criterion of 10 CFR 50.34(a)(1) as it relates to the requirements of 10 CFR Part 100. Therefore, all nearby facility and transportation accidents associated with the propane pipeline terminal and distribution facility, which could impact the safe operation of BVPS, do not pose an undue risk of public exposure and need not be considered as new design basis accidents at BVPS.

Hazardous Material via Pipeline Ruptures There have not been any significant changes in the pipeline hazards since the IPEEE submittals. The hazards associated with the new propane pipeline that feeds the wholesale distribution facility were assessed to have insignificant impact on the BVPS Units, as noted above.

Lightning A review of the corrective action program for lightning strike events that have occurred at the site since the IPEEE submittals was conducted. This review demonstrated that no lightning strike events were more severe than a complete loss of offsite power to either BVPS-1 or BVPS-2 (none of the events impacted PRA modeled structures, systems or components).

Therefore, the IPEEE conclusions that lightning is an insignificant contributor to core damage frequency remain valid.

4.

In the Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation TS 3.3.5 Functional Units 1, 2, 3, and 4, Condition B completion time is revised to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on WCAP-14333 implementation for BVPS-1 and

2. Also in TS 3.3.2, ESFAS Functional Unit 7.b, "Refueling Water Storage Tank Level Extreme Low, " Condition J completion time is revised to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on WCAP-14333 implementation for BVPS-1 and 2.

The justification for the completion time change referenced on Page 31 of is based on the applicability to WCAP-1 0271, as approved by the NRC in Amendment Nos. 267 and 149 for BVPS-1 and 2, respectively. As stated in the original submittal, the application of the proposed completion time, bypass test times, and surveillance intervals to functional units not specifically covered by WCAP-14333 and WCAP-15376 may be applicable, if previously accepted under the plant-specific implementation of WCAP-10271. The BVPS-1 and 2 WCAP-

, L-08-229 Page 6 of 9 10271 LARs for the above functional units increased the surveillance interval from monthly to quarterly, but did not discuss a revised completion time per WCAP-10271. Clarify the LAR justifying a change to completion times based on WCAP-10271 implementation.

Response

Amendment Nos. 267 and 149 to the Beaver Valley Power Station Technical Specifications (Reference 4) only approved changes to the Frequency (surveillance test interval (STI)) for TS 3.3.2, "ESFAS Instrumentation," Functional Unit 7.b, and TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation," Functional Units 1, 2, 3, and 4 from monthly to quarterly, since these STI changes were the only changes proposed by LAR Nos.

309 and 181. However, the assessment supporting the change to the frequency also evaluated the impact of changes to the bypass test times and completion times (CT). This is discussed in the following paragraphs.

TS 3.3.2, ESFAS Functional Unit 7.b, Refueling Water Storage Tank Level Extreme Low A similarity assessment was used to demonstrate that the changes to the bypass test times, CTs, and STIs approved in WCAP-1 0271-P-A, Supplement 2, Revision 1 (Reference 5) are applicable to the RWST switchover signal. The similarity assessment compared the configuration of the RWST switchover signal to a signal that has a similar configuration which was analyzed in WCAP-1 0271-P-A, Supplement 2, Revision 1. This similarity assessment required a comparison of the RWST switchover signal configuration to that of other signals with respect to the logic cabinet, number of master and slave relays, and channel logic. Using the similarity assessment approach, the impact of the changes on the unavailability of the previously analyzed signal is then directly applicable to the signal of interest (RWST switchover). Therefore, the impact on the signal unavailability accounts for the STI change, CT change, and bypass test time change. It is concluded that all changes were considered and evaluated in the similarity assessment to demonstrate the acceptability of the STI change which the NRC approved by Amendment Nos. 267 and 149.

The impact on the signal unavailability for this function is discussed in the FENOC document "Response to Request for Additional Information in Support of LAR Nos. 309 and 181 to Increase Surveillance Test Interval for Reactor Trip System and Engineered Safety Features Actuation System Instrumentation" (Reference 6). In the fifth paragraph of the "Refueling Water Storage Tank Level Functional Unit" section, the signal unavailability increase is given as 1.4E-

03. The impact of this change, which included the bypass test time, CT, and STI changes, on core damage frequency was assessed to be 1.41 E-07/year as reported in the FENOC document "Response to Request for Additional Information in Support of LAR Nos. 309 and 181 to Increase Surveillance Test Interval for Reactor Trip System and Engineered Safety Features Actuation System Instrumentation" (Reference 7). See the response to RAI #3, "Refueling Water Storage Tank Level Functional Units" section, fifth paragraph in Reference 7. This impact accounts for not only the STI change, but also for the CT and the bypass test time changes.

TS 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation: Functional Units 1. 2, 3, and 4 In Reference 7, FENOC provided additional information to the NRC in response to RAI #3 that requested information related to the justification for the changes to the additional signals not

, L-08-229 Page 7 of 9 evaluated in Reference 5. In the response to RAI #3 in the "Loss of Power Functional Units" section (third paragraph) it is stated "The same fault tree logic was used for both the Pre-TOP and Proposed cases, but quantified with different failure probabilities due to the increase in the surveillance test interval, and changes in AOTs and bypass test times." A very similar statement is also contained in the NRC's Safety Evaluation for Amendments 267 and 149 (Reference 4, see Section 4.1.d.2). This was also stated in Reference 6 in the second paragraph of the section "Loss of Power Functional Units." Thus the impact of the increased bypass test time and CT were included in the evaluation to support the STI change.

The RAI response in Reference 6 goes on to provide the impact of changes to the STI, CT, and bypass test times on the TS 3.3.5 signals of interest as appropriate. Therefore, the signal unavailability results include the impact due to the STI, CT, and bypass test changes. Thus all changes were considered and evaluated in the assessment to demonstrate the acceptability of the STI change which the NRC approved by Amendment Nos. 267 and 149.

5.

The LAR states that 10 CFR 50.65 Maintenance Rule program at BVPS-1 and 2 includes condition monitoring requirements. The LAR also states that BVPS-1 and 2 will review applicable BVPS-1 and 2 programs and revise them as needed to ensure the intent of the RTS and ESFAS equipment unavailability and component failure modeling assumptions in WCAP-1 4333 and WCAP-1 5376 continue to be met. Describe the implementation and monitoring program per Regulatory Guide (RG) 1.[1]74, Section 3.4, "Implementation Plan and Performance Monitoring Documentation" including procedures to include applicable RTS and ESFAS equipment related to WCAP-14333 and WCAP-15376 in the implementation and monitoring program. Discuss component level criteria under 10 CFR 50.65 that reflect the assumptions in the topical reports. Identify any additional regulatory commitments. See Attachment A of the LAR.

Response

Section 3.4 of RG 1.174 states that the submittal should include a description and rationale for the implementation and performance monitoring strategy for the proposed licensing basis change. The Reactor Protection System (RPS), also referred to as the Reactor Trip System (RTS), at both BVPS units has been within the scope of the Maintenance Rule since the inception of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." The effectiveness of maintenance on these systems is monitored by establishing performance criteria in the following areas; plant level, system availability, maintenance preventable functional failures and condition monitoring. The changes proposed in the LAR are increases in Technical Specification completion times and bypass test times and extensions to the Technical Specification surveillance intervals. The proposed changes affect system availability in that increased completion and bypass test times allow for additional unavailability time to restore equipment to operable status and perform required surveillance testing. Additionally, the extensions to the surveillance intervals reduce unavailability time since the required surveillances (which are the largest contributor to system unavailability) are performed less often. Thus, monitoring of system availability is important for the changes being proposed. The RPS availability is currently monitored under the BVPS Maintenance Rule Program.

With the proposed extensions to the surveillance intervals, it is also important to monitor component failures to ensure that component performance is consistent with the modeling assumptions. Component failures within the RPS are currently monitored by the BVPS

, L-08-229 Page 8 of 9 Maintenance Rule Program with performance criteria established for maintenance preventable functional failures and component condition monitoring. The RPS component failures and/or surveillance testing results that do not meet the established test acceptance criteria are documented and evaluated using the corrective action program.

As stated in the LAR, FENOC will review applicable BVPS programs and revise them as necessary to ensure that the intent of the RTS and ESFAS equipment unavailability and component failure modeling assumptions in WCAP-14333 and WCAP-1 5376 are met at BVPS.

This activity is due to be completed prior to, or concurrent with, the implementation of the license amendments that approve the proposed changes. Thus, no additional regulatory commitments are necessary.

6.

The configuration risk management program (CRMP) is stated in the LAR to use a "PRA-based model" to assess configuration risk prior to a maintenance activity being performed consistent with 10 CFR 50.65(a)(4). Tier 3 guidance can be satisfied by the Maintenance Rule Section (a)(4), subject to the guidance provided in RG 1.177, Section 2.3.7.1, and the adequacy of the licensee's program and PRA model for the application. Discuss the BVPS-1 and 2 CRMP implementation (including Tier 2 conditions, TS, grid or weather) for WCAP-14333 and WCAP-

[1]5376 including revision, quality and verification of the BVPS-1 and 2 PRA applicable completion and bypass test times CRMP for this LAR.

Response

This response reflects clarifications obtained during a conference call with the NRC staff on June 19, 2008. The BVPS configuration risk management program (CRMP) was discussed in detail in the Emergency Diesel Generator License Amendment Request Nos. 306 and 176 (Reference 8), in Section 4.3.2, "Evaluation of Risk Impact," under the "Tier 3: Risk Informed Configuration Risk Management Program" subsection, and its RAI Responses (Reference 9).

These detailed descriptions still apply to the current CRMP at BVPS and will also apply following implementation of this LAR based on WCAP-14333 and WCAP-15376. The NRC assessment of the BVPS CRMP was documented in Section 3.4.6.3 of the Safety Evaluation Report for Amendment Nos. 268 (BVPS-1) and 150 (BVPS-2) (Reference 10).

Currently, the CRMP at BVPS uses the Safety Monitor Program Version 3.5a.02 to calculate core damage frequency for actual plant configurations. These Safety Monitor models already account for the Solid State Protection System train unavailability and Anticipated Transient Without Scam Mitigating System Actuation Circuitry unavailability by utilizing the Indirect Effects Module in Safety Monitor to set the baseline split fraction values for the corresponding top events to 1.0. Additionally, the reactor trip breakers, and any modeled components identified in the WCAP-14333 or WCAP-1 5376 Tier 2 restrictions, will be set to failures in the Safety Monitor when any test or maintenance work activities render them unavailable. The BVPS CRMP uses a qualitative assessment to address grid and weather events which do not actually result in any modeled component unavailability. Therefore, no additional modifications are required for the BVPS CRMP software to implement the completion and bypass test times proposed in this LAR.

, L-08-229 Page 9 of 9 References

1.

"Beaver Valley Power Station, Unit No. 1 - Issuance of Amendment Re: Changes to the Recirculation Spray System Pump Start Signal due to the Containment Sump Screen Modification (TAC No. MD4290)," Amendment 280, October 5, 2007, (ADAMS No.

ML07268097).

2.

"Beaver Valley Power Station, Unit No. 2 - Issuance of Amendment Re: Changes to the Recirculation Spray System Pump Start Signal due to the Containment Sump Screen Modification (TAC No. MD4291)," Amendment 164, March 11, 2008, (ADAMS No.

ML080420549).

3.

"Beaver Valley Power Station, Unit Nos. 1 and 2; BV-1 Docket No. 50-334, License No.

DPR-66; BV-2 Docket No. 50-412, License No. NPF-73; License Amendment Request Nos. 334 and 205," FENOC Letter L-07-017, February 9, 2007, (ADAMS No.

ML070440341).

4.

"Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) - Issuance of Amendment Re: Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrumentation Surveillance Extension (TAC Nos. MC3404 and MC3405)," Amendments 267 and 149, September 19, 2005, (ADAMS No.

ML052570153).

5.

"Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation System," WCAP-1 0271-P-A, Supplement 2, Revision 1, May 1989.

6.

"Beaver Valley Power Station, Unit Nos. 1 and 2; BV-1 Docket No. 50-334, License No.

DPR-66; BV-2 Docket No. 50-412, License No. NPF-73; Response to Request for Additional Information in Support of LAR Nos. 309 and 181 to Increase Surveillance Test Interval for Reactor Trip System and Engineered Safety Features Actuation System Instrumentation," FENOC Letter L-05-143, August 19, 2005, (ADAMS No.

ML052350561).

7.

"Beaver Valley Power Station, Unit Nos. 1 and 2; BV-1 Docket No. 50-334, License No.

DPR-66; BV-2 Docket No. 50-412, License No. NPF-73; Response to Request for Additional Information in Support of LAR Nos. 309 and 181 to Increase Surveillance Test Interval for Reactor Trip System and Engineered Safety Features Actuation System Instrumentation," FENOC Letter L-05-010, February 23, 2005, (ADAMS No.

ML050590240).

8.

"Beaver Valley Power Station, Unit Nos. 1 and 2; BV-1 Docket No. 50-334, License No.

DPR-66; BV-2 Docket No. 50-412, License No. NPF-73; License Amendment Request Nos. 306 and 176," FENOC Letter L-04-072, May 26, 2004, (ADAMS No.

ML041540355).

9.

"Beaver Valley Power Station, Unit Nos. 1 and 2; BV-1 Docket No. 50-334, License No.

DPR-66; BV-2 Docket No. 50-412, License No. NPF-73; Response to Request for Additional Information in Support of LAR Nos. 306 and 176 Emergency Diesel Generator Allowed Outage Time Extension," FENOC Letter L-04-152, December 3, 2004, (ADAMS No. ML043450095).

10.

"Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) - Issuance of Amendment Re: Increase of Emergency Diesel Generator (EDG) Allowed Outage Time from 72 Hours to 14 Days (TAC Nos. MC3331 and MC3332)," Amendments 268 and 150, September 29, 2005, (ADAMS No. ML052720259).

ATTACHMENT 2 L-08-229 Regulatory Commitment List Page 1 of 1 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. Thomas A. Lentz, Manager - Licensing, at (330) 761-6071 of any questions regarding this document or associated Regulatory Commitments.

Regulatory Commitments FENOC commits to revising the applicable portions of the BVPS Technical Specification Bases to incorporate the subject conditions and limitations of WCAP-14333 and WCAP-15376 as part of the implementation of the requested amendments.

Due Date Concurrent with implementation of the amendments.