ML14133A090

Draft Beaver Valley, Request for Additional Information Related to an Amendment to Adopt TSTF-425

ML14133A090
Person / Time
Site:	Beaver Valley
Issue date:	05/13/2014
From:	Jeffrey Whited Plant Licensing Branch 1
To:
Whited J, NRR/DORL/LPLI-2
References
Download: ML14133A090 (2)

Text

DRAFT REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO AN AMENDMENT TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-425 TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM BEAVER VALLEY POWER STATION - UNITS 1 AND 2 DOCKET NO. 50-344 AND 50-412 By letter dated October 18, 2013,1 FirstEnergy Nuclear Operating Company (the licensee) submitted a license amendment request for Beaver Valley Power Station Units 1 and 2 (BVPS). The proposed amendment would modify the BVPS Technical Specifications by relocating specific surveillance frequencies to a licensee controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." To complete its review, the Nuclear Regulatory Commission staff requests a response to the questions below.

RAI 1: In the section on Probabilistic Risk Assessment technical adequacy of the submittal, the licensee discusses its latest self-assessment of the PRA model and how they evaluated the PRA consistent with the ASME PRA standard, as clarified by Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 1. Please describe how the licensee has addressed the gaps between the ASME standards as clarified by RG 1.200 Rev. 1 and RG 1.200 Rev. 2.

RAI 2: The finding pertaining to IF-D5-01 observes that the licensee uses outdated Internal Flooding Pipe and Tank Break frequencies for their IF assessment. The peer review team suggested that the licensee should update this SR to reflect more recent experience and should include plant specific experience. The licensee addressed this by stating that the latest Internal Flood model and focused peer review supersedes this finding and that the resolution is documented. Please describe the result of this SR in the updated PRA model and focused peer review and its associated resolution.

RAI 3: The finding pertaining to IF-D5-02 observes that the licensee uses generic capacity factor data which lowers the Initiating Event Frequency (IEF) and causes inconsistent Internal Flooding IEFs for Pipe break. The peer review team suggested that the 1

Agencywide Documents Access and Management System (ADAMS) Accession No. ML13295A006.

DRAFT

calculation for IF IEF be revised to be consistent the focused Peer Review F&Os as well as with the method used for other IEFs. The licensee addressed this by stating that the latest IF model and focused peer review supersedes this finding and that the resolution is documented. Please describe the result of this SR in the updated PRA model and focused peer review and its associated resolution.

RAI 4: Please describe, in more detail, how fire and seismic events will be assessed in terms of NEI 04-10 guidance. The licensee discusses the use of a Seismic and Fire PRA in their submittal that has not been peer reviewed. However, the licensee indicates that they plan to use these models to quantify STI changes. NEI 04-10 states that, Plants implementing TSTF-425 shall evaluate their PRAs in accordance with [RG 1.200]. The Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2007-06 further states that, If an implementation period for routine, limited scope risk-informed license applications is needed, the NRC would expect licensees to fully address all [technical]

elements consistent with Revision 2 of RG 1.200 by the end of 2009. The statements made in the submittal indicated that the fire and seismic portions of the Beaver Valley PRA have not been assessed against the PRA Standard referenced in Regulatory Guide 1.200, Revision 2. For example, please explain whether a qualitative, bounding, or detailed risk analyses described in Steps 10 and 11 will be used.

RAI 5: In the F&O related to SY-B1, the licensee resolved the peer review teams unmet finding by using a different source of information than what was prescribed in the ASME PRA standard. The licensee further states that WCAP-16672-P was used because it addressed the concerns that were raised regarding the consistency and correctness of the CCF events included in the NRC CCF database. Please provide the points of deviation between the WCAP and NUREG/CR-5485 and their potential impact on the risk result.

RAI 6: Regulatory Guide 1.177, which the NEI 04-10 guidance is based, section 2.3.3 discusses standby and cyclic-demand time-related component unavailability. Please provide clarification on whether the licensee distinguishes between standby and cyclic-demand time-related component unavailability.

RAI 7: The submittal highlights the licensees PRA model changes and peer reviews against the ASME PRA standard. The ASME PRA Standard and RG 1.200 Revision 2 clarifies the definition of a model update versus an upgrade. Please provide clarification on the model changes as to whether they were updates or upgrades.