L-16-201, Firstenerqy Nuclear Operating Companys (Fenocs) Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
| ML16218A279 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/05/2016 |
| From: | Richey M FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAC MF0841, EA-12-049, L-16-201 | |
| Download: ML16218A279 (9) | |
Text
FENOC-FirstEnergy Nuclear @rating Campany Beaver V alley Power Sfafrbn P.O. Box 4 Shippingpart, PA 15077 Mafty L. Richey Srfe Vice President 724-68?5234 Fax:724643-8069 August 5, 2016 L-16-21 0
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.2A2
SUBJECT:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 FirstEnerqv Nuclear Operetino Companv's (FENOC's)
Seventh Six-Month Status Report in Response to March 12. 2012 Commission Order Modifuins Licenses with RegaJd tg-Requirements for Mitigation Strateqies f_or Bevond-Design-E?sis Fxternal Events (Order Number EA-12-049)
On March 1 2,2A12, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference 1) to FENOC. Reference 1 was immediately effective and directs FENOC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.
Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference
- 2) and an overall integrated plan pursuant to Section lV, Condition C. Reference2 endorsed industry guidance document Nuclear Energy Institute (NEl) 12-A6, Revision 0 (Reference
- 3) with clarifications and exceptions identified in Reference 2. Referenre 4 provided the FENOC initial status report regarding mitigation strategies. Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station (DBNPS),
and Perry Nuclear Power Plant (PNPP).
Reference 1 requires submission of a status report at six-month interuals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the seventh six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that
Beaver Valley Power Station, Unit No. 1 L-16-21 0
Page 2 delineates progress made in implementing the reguirements of Reference 1. The attached report for BVPS provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
This letter contains no new regulatory commitments. lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager
- Fleet Licensing, at 330-315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on August "5.., 2010.
Respectfully;
{,eF>
MartfL Rich\\
Attachment:
Beaver Valley Power Station Seventh Six-Month Status Report for the lmplementation of Order EA-12-A49, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
References:
1.
NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to 2.
Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2A12.
NRC Interim Staff Guidance JLD-lSG-201 2-01, Compliance with Order EA-12-A49, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29,2012.
NEI 12-06, Diverse and Ffexible Coping Strategies (FLEX) lmplementation
- Guide, Revision 0, dated August2012.
FirstEnergy Nuclear Operating Company's (FENOC's) lnitial Status Report in
Response
to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),
dated October 26, 20't2.
FirstEnergy Nuclear Operating Company's (FENOC's)
Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated February 27, 2013.
3.
4.
5.
Beaver Valley Power Station, Unit No. 1 L-16-210 Page 3 Director, Office of Nuclear Reactor Regulation (NRR)
NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP (without Attachments)
Site BRP/DEP Representative (without Attachments)
Attachment L-16-210 Beaver Valley Power Station Seventh Six-Month Status Report for the lmplementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 6 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Beaver Valley Power Station, Unit Nos. 1 and 2 (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Referen ce 2. This attachment provides an update of milestone accomplishrnents since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any. The information reported pertains to Unit No. 1 only. (Unit No.2 compliancewith Reference2was achieved and reported by letter dated Decernber 21, 2015.)
2 Milestone Accomplishments The following milestone(s) have been compfeted since February 12,2016 and are current as of July 31, 2A16.
Update 6 was submitted 3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
The milestones related to BVPS Unit No. 2 were removed from the schedule because compliance with Referen ce 2 was achieved.
There are no revised milestone target completion dates.
Attachment L-16-21A Page 2 of 6 Milestone Target Completion Date Activity Status (as of 71311161 Revised Target Gompletion Date Submit FLEX Integrated lmplementation Plan 02t28t13 Cornplete 6 Month NRC Status Updates 08t28t16 Started Update I 08t28t13 Compfete Update 2 02t28t14 Gomplete Update 3 a8t28t14 Complete Update 4 02t27115 Comolete Update 5 08t28t15 Complete Update 6" 02t28t16 Complete Update 7" a8128116 Started Gomplete FLEX Strategy Review March-2013 Complete Validation September-2016 Started Walk-throughs or Demonsfrafions-Unit 1" September-2O16 Started Gomplete Staffing Analysis November-2014 Complete Submit NEI 12-01 Phase I Staffino Sfudv April-2O13 Complete Submit NEI 12-01 Phase 2 Staffins Studv November-2A14 Complete Complete Plant Modifications November-2016 Started T a rget pl ant madificafions April-2013 Complete Unit 1 Modifications complete November-2O16 Started Complete I R22 autase modifications November-2013 Complete Complete on-line madificalions September-2016 Started Complete 1 R23 outase modificafions May-2015 Complete Complete I R24 autage modifications*
November-2016 Started FLEX Storage Gomplete October-2015 Complete Complete Buildins Desisn March-2O15 Complete Commence Construction March-2015 Complete Complete Construction October-2A15 Complete River (UHS) Access Complete October-2014 Complete Fence & Gate Modificatian Desi,sn Februarv-2014 Complete New Fence & Gate Construction Auqust-2014 Complete SecurV Barrier Pipe Penetrations Desr-sn March-2014 Complete Security Barrier Pipe Penetration Construction October-2014 Complete On-site FLEX Equipment September-2016 Started Confirm FLEX Equipment Requirements November-2013 Complete FLEX Equipment Ordered April-2015 Complete FLEX Equipment Delivered-Unit 1*
September-2016 Started Off-site FLEX Equipment October-2A15 Gomplete Develop Sfrafegr'e s with RRC"**
June-2015 Complete Phase 3 Sife Access Sfrafe.qr'e s in Place June-2015 Complete Complete Near Srfe Sfaging Location (as needed)
October-2015 Gomplete Procedures Complete October-2016 Started PWROG issues NSSS-sp ecific suidelines June-2O13 Complete
/ssue Beaver Valley Unit I FSG" October-z016 Started lssue Maintenance Procedures October-2015 Complete
Attachment L16-210 Page 3 of 6
- Submittal of completion report occurs after end of refueling outage.
- Regional
Response
Center (RRC) is now called National SAFER Response Center (NSRC) 4 Ghanges to Compliance Method There are no further changes to the compliance method as documented in the OIP (Reference
- 1) and previous updates.
5 Need for RelieflRelaxation and Basis for the Relief/Relaxation Relief/relaxation of the Referen en 2 requirement for cornpletion of fulf implementation for Beaver Valley Power Station Unit No. 1 (BVPS-1) until the completion of the fall of 2A16 refueling outage for reactor coolant pump shutdown (RCP) seal installation was granted on May 20,2014 (Reference 4).
6 Open ltems from Overall lntegrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Staff Evaluation (lSE) (Reference
- 3) and the status of each item.
Milestone Target Completion Date Activity Status (as of 7t311161 Revised Target Completion Date Training Gomplete September-2O16 Started Develop Training Plan December-2014 Complete lmplement Unit I Training" September-2O16 Started Submit Completion Report January-2017*"
Not Started
- Milestones added as a result of relief/relaxation for Unit 1 (Reference 4)
Overall Integrated Plan Open ltem Status Ol 1. Finalize the location of the FLEX storage buiHing. The deployment routes, distances, and tirnes provided in this report are bounded for the currently proposed locations but will be updated as necessary.
Complete. (Described in February-z01 4 status report and updated in the February -2015 status report.)
Ol 2. Perform containment evaluation based on the boundary conditions described in Section 2 of NEI
[Nuclear Energy Institute]
12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.
Complete. (Described in February-z015 status report.)
Ol 3. Modify the RWST [refueling water storage tankJ at each unit to protect it from tornado missibs or identify a borated souree that is protected from tornados and can be utilized to provide core cooling when steam generators are not available.
Complete. (Described in February-201 4 status report.)
Attachment L-16-210 Page 4 of 6 Interim Staff Evaluation Open ltem Status 3.2.1.6.A Verify that the TDAFW [turbine driven auxiliary feedwaterJ pump exhaust stacks are adequatelv protected from tornado missile hazards.
Started.
I 3.2.1.8.A Verify resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS [reactor coolant system] under natural circulation conditions potentiallv involving two-phase flow.
Complete. (Described in February
-201 4 status report.)
ISE Confirmatorv ltem Status 3.1.1.4.A Confirm that primary and secondary staging areas for the RRC [regional response centerl equipment have been selected and will meet the requirements of the applicable site response plan.
Complete. (Described in Aug ust-201 5 status report.)
3.1.2.4.4 Confirm that the primary and secondary staging areas have been identified and that the plan for the use of offsite resources will comply with NEI 12-06, Section 6.2.3.4 regarding the need to evaluate for flooding hazard. This confirmation should include a description of the methods to be used to deliver the equipment to the site.
Complete, (Described in Aug ust-z01 5 status report.)
3.1.3.1.A Confirm that the location of the storage and protection building for FLEX equipment has been identified. Confirm that the FLEX storage building is designed to withstand tornado missiles at a level equal to, or greater than, the plant's tornado missile desiqn basis.
Complete. (Described in August-2l1 5 status report.)
3.1.3.4,A Confirm that the ficensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06, Section 7.3.4 regarding hish wind hazards.
Complete. (Desdribed in August-201 5 status report.)
3.1.4.4,4 Confirm that the licensee's plan for the use of off,site resources would provide reasonable assurance that the plan will comply with NEI 12-Oo Section 8.3.4 regarding snow, ice and extreme cold hazards.
Complete. (Described in Aug ust-201 5 status report.)
3.2.1.1.A Confirm that the licensee has verified that reliance on the NOTRUMP code for the ELAP
[extended loss of AC powerJ analysis of Westinghouse pfants is limited to the flow conditions prior to reflux condensation initiation. This includes specifying an acceptable definition for reflux condensation cooling.
Complete. (Described in Aug ust-201 5 status report.)
Attachment L-16-210 Page 5 of 6 ISE Confirmatorv ltem Status 3.2.1.1.8 Confirm thatthe application of the WCAP-176A1 analysis simulating the ELAP transient is properlv established.
Complete. (Described in August-z91 5 status report.)
3.2.1.2.4 Confirm that, if the licensee continues to credit SHIELD shutdown seals, as planned, (e.9.,
1 gallon per minute leakage/seal) in the ELAP analyses for the RCS response, then the impacts of the Westinghouse 10 CFR Part 21 report, "Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21:'dated July 26,2013 (ADAMS Accession No. ML13211A168) on the use of the low seal leakage rate in the EIAP analysis are addressed.
Complete. (Described in August-z91 5 status report.)
3.2.1.2.8 Confirm that if the seals are changed, the acceptability of the seals used is addressed, and the RCP seal leakage rates for use in the ELAP analysis are iustified.
Complete. (Described in August-z01 5 status report.)
3.2.2.A Since the RWSTs are not currently fully protected against tornado missiles, confirm that the licensee has completed their review to determine whether or not the RWST will need to be further protected against missile hazards.
Complete. (Described in February
-2A14 status report.)
3.2.2.8 Confirm that opening doors provides adequate ventilation for SFP lspent fuel pooll area.
Complete. (Described in Ausust-z0l 5 status report.)
3.2.3.A Confirm that containment evaluations for all phases are performed based on the boundary conditions described in Section 2 of NEI 12-06.
Based on the results of this evaluation, confirm that required actions to ensure maintenance of containment integrity and required instrument function have been developed.
Complete. (Described in February
-2A15 status report.)
3.2.4.2,A Confirm that the licensee has clarified why the Integrated Plan stated the maximum temperature of the Unit llUnit 2 AFW [auxiliary feedwaterl pump roorns would reach 115.91112.3 degrees Fahrenheit
("F), respectively, while Cafculation 8700-DMC-2312, described during the audit process, indicated that the maximum temperature would reach 142.9"F, Complete. (Described in August-z91 5 status report.)
3.2.4.2.8 Confirm that the licensee has provided an analysis or calculation to demonstrate that the dissipation of heat generated by the batteries via natural circulation will be adequate to maintain the temperatures in the battery rooms within acceptable levels.
Complete. (Described in August-z$$ status report. )
Attachment L-16-210 Page 6 of 6 7 Potential lnterim Staff Evaluation lmpacts There are no potential irnpacts to the ISE identified at this time.
I References The following references support the updates to the OIP described in this attachment.
FirstEnergy Nuclear Operating Company's (FENOC's)
Overall lntegrated Plan in
Response
to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-A49),
dated February 27,2413.
NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2A12.
- 3. Beaver Valley Power Station, Units 1 and 2 - Interim Staff Evaluation Related To Overafl Integrated PIan In Response To Order EA-12-049 (Mitigation Strategies),
dated January 29,2A14.
- 4. NRC Letter, Beaver Valley Power Station, Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-049 "lssuance of Order to Modiflt Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events' (TAC No. MF0841),
dated May 24,2414.
1.
2.
ISE Confirmatory ltem Status 3.2.4.2.C Confirm that the licensee has addressed how hydrogen concentration in the battery rooms will be limited to acceptable levels.
Complete. (Described in August-z015 status report.)
3.2.4.6.A Confirm that the licensee has completed a review of Unit 1 AFW room and developed any plans required to maintain a suitable environment.
Compfete. (Described in August-z01 5 status report.)
3.4.A Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 12-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.
Compfete. (Described in August-201 5 status report.)