L-20-009, License Amendment Request - Proposed Change to Technical Specifications Sections 1.1. Definitions, and 5.0 Administrative Controls. for Permanently Defueled Condition

License Amendment Request - Proposed Change to Technical Specifications Sections 1.1. Definitions, and 5.0 Administrative Controls. for Permanently Defueled Condition

ML20043F441
Person / Time
Site:	Beaver Valley
Issue date:	02/11/2020
From:	Penfield R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-20-009
Download: ML20043F441 (37)

Text

FENOC," Beave r Valley Powe r Sfalron P.O. Box 4 F irstE nergy Nucle ar Aperating Campany Shippingpott, PA 15077 Rod L. Penfield 724-682-5234 SrIe Vrbe President Fax: 724-643-8069 February 11 ,2020 L-20-009 10 cFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Units No. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 License Amendm Request - Proposed Chano e to Technica! Specifications Sections 1.1. "De finitions " and 5.0 "Administrative Controls." for Permanentlv Defueled Condition ln accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," FirstEnergy Nuclear Operating Cornpany (FENOC) requests an amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License Nos. DPR-66 and NPF-73 for Beaver Valley Power Station, Unit Nos 1 (BVPS-1) and 2 (BVPS-2).

By letter dated April 25,2018 (Accession No. ML18115A007), FENOC provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.82(aX1)(i) and 10 CFR 50.4(bXB) of the intention to permanently cease poweroperations at BVPS-1 by May 31,2021 and BVPS-2 by October 31,2021 .

Once the certifications of permanent cessation of power operations and of permanent remova! of fuel from the reactor vessel are docketed for a unit, in accordance with 10 CFR 50.82(aX1Xi) and (ii), and pursuant to 10 CFR 50.82(aX2),

the 10 CFR 50 license will no longer authorize reactor operation or emplacernent or retention of fuel in the reactor vessel for that unit.

The purpose for this proposed license amendment request (LAR) is that certain TS administrative controls may be added to reflect the permanently defueled condition of one unit at the dual unit site, while maintaining the operational requirements for the other unit until such time similar certifications are docketed for the second unit.

Specifically, this LAR proposes changes to the organization, staffing, and training requirements contained in Section 5.0, "Administrative Controls" of the BVPS-1 and BVPS-2 TS and defines two new positions for Certified Fuel Handler and

Beaver Valley Power Station, Unit Nos. 1 and 2 L-20-009 Page 2 Non-Certified Operator in Sectisn 1.1, "Definitions." The proposed amendment also supports implementation of the FENOC Certified Fue[ Handler Training and Retraining Program that was approved by the NRC by letter dated April 11, 2019

{Accession No. ML19028A030).

The enclosure to this letter provides a detailed description and evaluation of the proposed change to the TS, including a markup of the current TS pages depicting the proposed change.

FENOC requests review and approval of this proposed amendment by February 26,2021 to support the current schedule for the BVPS-1 transition to a permanently defueled facility. Once approved, the amendment shall be implemented within 30 days.

FENOC has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "lssuance of amendment."

There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Mr. Thomas A.

Lentz, Manager, FENOC Nuclear Licensing and Regulatory Affairs, at (330) 31s-6810.

I declare under pe nalty of perjury that the foregoing is true and correct. Executed on February i) 2020.

Sin Rod L. Penfield

Enclosure:

Evaluation of Proposed Change CC NRC Region I Administrator NRC Resident lnspector NRR Project Manager Director BRPIDEP Site BRP/DEP Representative

Evaluation of Proposed Change Page 1 of 24

Subject:

Proposed Change to Technical Specifications Sections 1.1 and 5.0 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Analysis 4.3 Conclusions

6.0 REFERENCES

7.0 ATTACHMENTS

1. Technical Specification Page Markups

Evaluation of Proposed Change Page 2 of 24 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, FirstEnergy Nuclear Operating Company (FENOC) proposes changes to Appendix A, Technical Specifications (TS) of Renewed Facility Operating License Nos. DPR-66 and NPF-73 for Beaver Valley Power Station, Unit Nos. 1 (BVPS-1) and 2 (BVPS-2).

By letter dated April 25, 2018 (Reference 1), FENOC provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8) of the intention to permanently cease power operations at BVPS-1 by May 31, 2021 and BVPS-2 by October 31, 2021.

Based on this schedule for the dual unit site, once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel for one unit (currently scheduled to be BVPS-1) is submitted to the NRC pursuant to 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, the other unit (currently scheduled to be BVPS-2) will still be in operation at that time.

For a unit that is in a permanently shutdown and defueled condition, the focus of nuclear safety narrows to concerns associated with nuclear fuel (that is, the safe storage and handling of the nuclear fuel). This license amendment request (LAR) proposes changes to better delineate the TS requirements for each unit [that is, an operating unit versus a permanently defueled unit (a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2))].

To support activities at BVPS once a unit is in a permanently shutdown and defueled condition, some administrative controls will no longer be applicable. Therefore, this LAR proposes changes that would add certain organization, staffing, and training requirements for a permanently defueled unit in Section 5.0, Administrative Controls, of the BVPS-1 and BVPS-2 TS to further support plant activities and decommissioning efforts following permanent cessation of power operations for either unit. The requirements would be added as new sections, each with a NOTE to indicate the applicability. A new NOTE is also proposed for each of the following existing Section 5.0 requirements to clarify that the applicability is for an operating unit.

Section 5.2, Organization Section 5.3, Unit Staff Qualifications Section 5.4, Procedures In addition, by letter dated April 11, 2019 (Reference 2), the NRC approved the FENOC Certified Fuel Handler Training and Retraining Program. This LAR will support implementation of this program, since licensed reactor operators will no longer be

Evaluation of Proposed Change Page 3 of 24 required to support plant operations at a unit after FENOC has submitted the required 10 CFR 50.82(a)(1)(ii) certification that the unit has been permanently defueled. The need for licensed reactor operators is specified in TS Section 5.0. The new terms that support implementation of this program, Certified Fuel Handler and Non-Certified Operator, will be added to TS Section 1.1, Definitions.

In the development of the proposed TS changes, FENOC evaluated the applicable guidance in NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 4.0 (Reference 3).

This LAR provides a discussion and description of the proposed TS changes, a technical evaluation of the proposed TS changes, and information supporting a finding of no significant hazards consideration (NSHC).

2.0 DETAILED DESCRIPTION contains a markup of the current TS pages. The specific changes affecting TS Sections 1.1 and 5.0 are described in this section; the supporting technical evaluation is presented in Section 3.0 of this enclosure. Proposed revisions in this section are shown in Bold-Italics and deletions are shown using strikethrough. All revised formatting, numbering, and wording in TS Section 5.0 is consistent with Section 5.0 of Reference 3, except where noted to make the specification germane with a permanently defueled reactor at the BVPS site.

TS Section 1.1 - Definitions Current TS Proposed TS

[A term and definition for CERTIFIED FUEL Term HANDLER is not listed in the current TS.]

CERTIFIED FUEL HANDLER Definition A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER training and retraining program required by Specification 5.3A.4.

[A term and definition for NON-CERTIFIED Term OPERATOR is not listed in the current TS.]

NON-CERTIFIED OPERATOR Definition A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3A.3, but is not a CERTIFIED FUEL HANDLER.

Evaluation of Proposed Change Page 4 of 24 TS Section 5.2 - Organization Current TS Proposed TS

[A NOTE for this section is not listed in the current --------------------------------------------------------------------

TS.] -NOTE-This TS Section is only applicable to an operating unit. TS Section 5.2A is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

[New] TS Section 5.2A - Organization (Permanently Defueled Unit)

Current TS Proposed TS

[This section is not listed in the current TS. It is 5.2A Organization (Permanently Defueled Unit) added with a numbering sequence that deviates from Reference 3 to delineate requirements for a --------------------------------------------------------------------

permanently defueled unit.] -NOTE-This TS Section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). TS Section 5.2 is applicable to an operating unit.

[This section is not listed in the current TS. It is 5.2A.1 Onsite and Offsite Organizations added with a numbering sequence that deviates from Reference 3 to delineate requirements for a Onsite and offsite organizations shall be permanently defueled unit.] established for unit staff and corporate management. The onsite and offsite organizations shall include the positions for activities affecting the safe storage and handling of nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all unit organization positions. These relationships shall be documented and updated, as appropriate, in organization descriptions, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in

Evaluation of Proposed Change Page 5 of 24

[New] TS Section 5.2A - Organization (Permanently Defueled Unit)

Current TS Proposed TS equivalent forms of documentation.

These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the Unit 2 UFSAR,

b. The plant manager shall be responsible for overall safe operation of the unit and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel,

c. A corporate officer with direct responsibility for the unit shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the unit to ensure safe management of nuclear fuel, and

d. The individuals who train the CERTIFIED FUEL HANDLERs, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

[This section is not listed in the current TS. It is 5.2A.2 Unit Staff added with a numbering sequence that deviates from Reference 3 to delineate requirements for a The unit staff organization shall include permanently defueled unit.] the following:

a. Each on duty shift shall be composed of at least one shift manager and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

b. Shift crew composition may be less than the minimum requirement of

Evaluation of Proposed Change Page 6 of 24

[New] TS Section 5.2A - Organization (Permanently Defueled Unit)

Current TS Proposed TS Specification 5.2A.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and the following conditions are met:

1) No nuclear fuel movements are in progress;

2) No movement of loads over nuclear fuel is in progress; and

3) No unmanned shift positions during shift turnover shall be permitted due to an incoming shift crew member being late or absent.

c. An individual qualified in radiation protection procedures shall be on site during movement of nuclear fuel and during the movement of loads over nuclear fuel. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

d. At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.

e. The shift manager shall be a CERTIFIED FUEL HANDLER.

f. Oversight of nuclear fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

Evaluation of Proposed Change Page 7 of 24 TS Section 5.3 - Unit Staff Qualifications Current TS Proposed TS

[A NOTE for this section is not listed in the current --------------------------------------------------------------------

TS.] -NOTE-This TS Section is only applicable to an operating unit. TS Section 5.3A is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

[New] TS Section 5.3A - Unit Staff Qualifications (Permanently Defueled Unit)

Current TS Proposed TS

[This section is not listed in the current TS. It is 5.3A Unit Staff Qualifications (Permanently added with a numbering sequence that deviates Defueled Unit) from Reference 3 to delineate requirements for a permanently defueled unit.] --------------------------------------------------------------------

-NOTE-This TS Section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). TS Section 5.3 is applicable to an operating unit.

[This section is not listed in the current TS. It is 5.3A.1 Each member of the unit and radiation added with a numbering sequence that deviates protection staff shall meet or exceed the from Reference 3 to delineate requirements for a minimum qualifications of ANSI N18.1-permanently defueled unit.] 1971 for comparable positions, except for the following:

The shift manager as specified in Specification 5.2A.2.e, and The radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

Evaluation of Proposed Change Page 8 of 24

[New] TS Section 5.3A - Unit Staff Qualifications (Permanently Defueled Unit)

Current TS Proposed TS

[This section is not listed in the current TS. It is 5.3A.2 The NRC-approved training and retraining added with a numbering sequence that deviates program for CERTIFIED FUEL HANDLERs from Reference 3 to delineate requirements for a shall be maintained.

permanently defueled unit.]

TS Section 5.4 - Procedures Current TS Proposed TS

[A NOTE for this section is not listed in the current --------------------------------------------------------------------

TS.] -NOTE-This TS Section is only applicable to an operating unit. TS Section 5.4A is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

[New] TS Section 5.4A - Procedures (Permanently Defueled Unit)

Current TS Proposed TS

[This section is not listed in the current TS. It is 5.4A Procedures (Permanently Defueled Unit) added with a numbering sequence that deviates from Reference 3 to delineate requirements for a --------------------------------------------------------------------

permanently defueled unit.] -NOTE-This TS Section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). TS Section 5.4 is applicable to an operating unit.

[This section is not listed in the current TS. It is 5.4A.1 Written procedures shall be established, added with a numbering sequence that deviates implemented, and maintained covering from Reference 3 to delineate requirements for a the following activities:

permanently defueled unit.]

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,

Evaluation of Proposed Change Page 9 of 24

[New] TS Section 5.4A - Procedures (Permanently Defueled Unit)

Current TS Proposed TS

b. Quality assurance for effluent and environmental monitoring,

c. Fire Protection Program implementation, and

d. All programs specified in Specification 5.5.

3.0 TECHNICAL EVALUATION

This technical evaluation is for administrative changes to BVPS-1 and BVPS-2 TS Section 5.0, Administrative Controls and the addition of two new terms to TS Section 1.1, Definitions. All revised formatting, numbering, and wording is consistent with Section 5.0 of Reference 3, except where noted to make the specification germane with a permanently defueled reactor. As a result, the TS will be readily readable, and therefore understandable, by plant operators as well as other users. The reformatting, renumbering, repagination, and rewording process involves no technical changes to the existing TS, except where specifically noted.

TS Section 1.1 - Definitions FENOC proposes to add two new terms, CERTIFIED FUEL HANDLER and NON-CERTIFIED OPERATOR, and associated definitions to the BVPS-1 and BVPS-2 TS to ensure consistent understanding and application throughout the TS. Further discussion of the CERTIFIED FUEL HANDLER and NON-CERTIFIED OPERATOR are included in several of the proposed TS Section 5.0 changes below.

TS Section 5.2 - Organization This section identifies overall organizational positions and staff responsibilities required to ensure nuclear power plant safety for an operating nuclear power plant. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, in the case of a dual unit site such as BVPS, the other unit may still be an operating unit. To better delineate the onsite and offsite organization requirements and staff responsibilities for each unit, the proposed change adds a NOTE to clarify that this TS section is only applicable to an operating unit. The NOTE also identifies that TS Section 5.2A (a new section proposed as part of this LAR) is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel are docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

Evaluation of Proposed Change Page 10 of 24 The organizational requirements for an operating unit remain unchanged. The NOTE adds the clarification that TS 5.2 applies to an operating unit and refers to the TS that is applicable to a permanently defueled unit. The TS 5.2 proposed change is administrative.

[New] TS Section 5.2A - Organization (Permanently Defueled Unit)

For a unit that is in a permanently shutdown and defueled condition, the focus of nuclear safety narrows to concerns associated with nuclear fuel (that is, the safe storage and handling of the nuclear fuel). This new TS section identifies overall organizational positions and staff responsibilities required to ensure the safe management of nuclear fuel. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, as discussed above for a dual unit site such as BVPS, the other unit may still be an operating unit. To better delineate the onsite and offsite organization requirements and staff for a permanently defueled unit, the proposed change adds this new section, including a NOTE to clarify that this TS section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel are docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). The NOTE also identifies that TS Section 5.2 is applicable to an operating unit.

The numbering of this new section deviates from Reference 3 by adding an A character to the TS numbering scheme. This provides a clear delineation and separation of the requirements related to the permanently defueled unit, while leaving the operating unit requirements relatively unaffected.

A discussion of each of the specifications under new TS 5.2A is provided below, including how it differs from those of an operating unit. The changes proposed for this new section are administrative.

[New] TS 5.2A.1 - This new TS titled Onsite and Offsite Organizations addresses staff organization applicable to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. As described above, once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit.

The introduction to TS 5.2A.1 identifies the requirement that organizational positions be established for unit staff and corporate management. The onsite and offsite organizations shall include the positions that are responsible for the safe storage and handling of nuclear fuel. This removes the implication that the unit can return to operation once the certifications required by 10 CFR 50.82(a)(1) are docketed. The terms safe storage and maintenance of nuclear fuel, safe management of nuclear fuel, and safe storage and handling of nuclear fuel are considered analogous to the terms nuclear safety and safety of the nuclear power plant for a unit that will be in the

Evaluation of Proposed Change Page 11 of 24 permanently defueled condition. The use of one of these analogues serves to narrow the focus of nuclear safety concerns to those associated with nuclear fuel.

[New] TS 5.2A.1.a - This new TS identifies lines of authority, responsibility, and communication throughout the organization at a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.2.1.a with minor alterations to reflect a permanently shutdown and defueled reactor. The terms all unit organization positions and organization descriptions are used in place of all operating organization positions and organization charts, respectively.

[New] TS 5.2A.1.b - This new TS identifies the organizational position responsible for the safe operation of the unit and for control of activities necessary for the safe storage and maintenance of the nuclear fuel at a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.2.1.b with minor alterations. To reflect the change in nuclear safety focus from an operating plant to a permanently shutdown and defueled unit, the responsibility for control of activities necessary for the safe storage and maintenance of the nuclear fuel is used in place of safe operation and maintenance of the plant. The proposed TS includes the use of unit in place of plant.

[New] TS 5.2A.1.c - This new TS identifies the organizational position with direct responsibility for the safe storage and handling of nuclear fuel at a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.2.1.c with minor alterations. To reflect the change in nuclear safety focus from an operating plant to a permanently shutdown and defueled facility, the responsibility for the safe storage and handling of nuclear fuel is used in place of overall plant nuclear safety, and the responsibility for providing technical support is changed to ensure safe management of nuclear fuel instead of ensure nuclear safety. The proposed TS includes the use of unit in place of plant.

[New] TS 5.2A.1.d - This new TS provides the requirement for organizational independence of the personnel who train the certified fuel handlers, carry out radiation protection, or perform quality assurance functions to ensure their ability to perform their assigned functions at a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.2.1.d with minor alterations to reflect a permanently shutdown and defueled reactor. CERTIFIED FUEL HANDLERs is used in place of Operating staff and their ability to perform their assigned functions replaces their independence from operating pressures. The proposed TS reflects the changed function of the unit staff to a focus on safe handling and storage of nuclear fuel and removes the implication that the unit can return to operation once the certifications required by 10 CFR 50.82(a)(1) are docketed.

[New] TS 5.2A.2 - This new TS titled Unit Staff addresses the unit staff organization applicable to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. The introduction to

Evaluation of Proposed Change Page 12 of 24 TS 5.2A.2 is the same as the introduction to TS 5.2.2 and is still applicable for a unit in a permanently defueled condition. Therefore, it is retained in the new TS section.

[New] TS 5.2A.2.a - This new TS stipulates the on-duty shift composition for a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. This new TS is proposed in place of the wording used in TS 5.2.2.a. Because the typical operating shift composition will not be applicable at a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed, the minimum requirement is changed to a minimum crew complement of one shift manager and one non-certified operator. This proposed TS reflects the reduced number of systems, compared to an operating reactor, required to provide and support spent fuel pool cooling and monitor spent fuel pool parameters, such as spent fuel pool level and temperature, while still maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner at the unit.

Moreover, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safety will be greatly reduced from that at an operating unit. The shift manager will be qualified as a certified fuel handler in accordance with proposed new TS 5.2A.2.e. In this position, this individual will retain command and control responsibility for operational decisions and will be responsible for the functions required for event reporting and emergency response.

[New] TS 5.2A.2.b - This new TS provides the conditions under which the minimum shift complement may be reduced for a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.2.2.b with minor alterations to reflect a permanently shutdown and defueled reactor. The proposed TS does not include a reference to 10 CFR 50.54(m)(2)(i) because a permanently defueled unit will not return to operation once the certifications required by 10 CFR 50.82(a)(1) are docketed, and the requirement for licensed operating personnel as stated in 10 CFR 50.54(m) will no longer be required to protect public health and safety for a permanently defueled unit. No exemption from 10 CFR 50.54(m)(2)(i) is needed or requested to support this proposed TS, based on the NRC response to a similar request from Vermont Yankee Nuclear Power Station in June 2014 (Reference 4).

The proposed TS addresses the conditions under which the minimum shift complement may be reduced at a permanently defueled unit, due to unforeseen circumstances. It allows for shift crew composition to be less than the minimum requirement of the proposed new TS 5.2A.2.a for a period of time, not to exceed two hours, in order to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the shift crew composition to within the minimum requirements. It also ensures that no nuclear fuel movement or movement of loads over the nuclear fuel at a permanently defueled unit occur during an absence. The proposed TS does not permit shift positions to be unmanned during shift turnover due to an incoming shift crew member being late or absent. This prevents intentionally reducing crew composition below the minimum requirement. For example, the restriction would prevent an outgoing shift crew member from leaving the facility prior to an incoming shift crew members arrival.

Evaluation of Proposed Change Page 13 of 24

[New] TS 5.2A.2.c - This new TS establishes the requirement for a radiation protection technician to be onsite during certain nuclear fuel activities for a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.2.2.c with minor alterations to reflect a permanently shutdown and defueled reactor. The new TS ensures that a radiation protection technician is present on-site during the movement of nuclear fuel and during the movement of loads over the nuclear fuel because fuel will not be allowed to be placed or stored in the reactor vessel once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit. This new TS also allows for the position to be vacant for not more than two hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

[New] TS 5.2A.2.d - This new TS adds a requirement applicable only to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The requirement is that At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool. This reflects the reduced requirement for control room personnel training and qualification for a unit authorized for nuclear fuel storage only. The control room will remain the physical center of the command function for a permanently defueled unit. However, since control of activities may be performed either remotely from the control room or locally in the facility, the location of the command center is functionally where the shift manager is located.

Adding this requirement ensures that the primary functions of the control room at a permanently shutdown reactor, such as monitoring plant systems, response to abnormal conditions, communications with on-site personnel and offsite agencies, emergency response, and coordination of facility activities, will be maintained at all times when nuclear fuel is stored in the spent fuel pool.

[New] TS 5.2A.2.e - This new TS adds a requirement applicable only to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The new TS replaces the TS 5.2.2.e requirements for senior reactor operator (SRO) licenses with a requirement that The shift manager shall be a CERTIFIED FUEL HANDLER. Once the certifications required by 10 CFR 50.82(a)(1) have been docketed for a unit, the requirements of 10 CFR 50.54(m) will no longer be applicable to that unit because the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need for licensed operators, including a senior license holder, as specified in 10 CFR 55, Operators Licenses. Therefore, there is no longer a need for operations management staff for a permanently defueled unit to hold an SRO license. Replacing this with a requirement that the shift manager be a certified fuel handler ensures that the senior individual directing activities on shift for a permanently defueled unit is appropriately trained and qualified in accordance with an NRC-approved Certified Fuel Handler Training and Retraining Program. As discussed above, no exemption from 10 CFR 50.54(m) is needed or requested to support this change.

Evaluation of Proposed Change Page 14 of 24 Once a unit is permanently shutdown and defueled, the time available to mitigate credible events is expected to be greater than that for current design basis events. As such, management oversight of the permanently defueled unit can be performed by individuals meeting the applicable requirements of American National Standards Institute (ANSI)/American Nuclear Society (ANS) 18.1-1971 (as required by proposed new TS 5.3A.1) and need not be qualified as certified fuel handlers.

[New] TS 5.2A.2.f - This new TS adds a requirement applicable only to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The new TS replaces the TS 5.2.2.f requirements regarding advisory technical support. The new TS adds the requirement that Oversight of nuclear fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER. The advisory technical support position is only required for a plant authorized for power operations. Once the certifications required by 10 CFR 50.82(a)(1) have been docketed for a unit, the license for that unit will no longer authorize operations of the reactor or emplacement or retention of fuel in the reactor vessel.

The new requirement ensures that movement of nuclear fuel at a permanently defueled unit is only performed under the oversight of an individual who has been trained and qualified on the procedures, processes, requirements and standards for safe movement of nuclear fuel. Oversight of fuel handling operations refers to the authorization from the shift manager/certified fuel handler to move fuel. This aligns with proposed TS 5.2A.2.e, which requires the shift manager to be a certified fuel handler.

TS Section 5.3 - Unit Staff Qualifications This section identifies overall qualifications required for nuclear power plant staff at an operating nuclear power plant. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, in the case of a dual unit site such as BVPS, the other unit may still be an operating unit. To better delineate the onsite and offsite organization requirements and staff responsibilities for each unit, the proposed change adds a NOTE to clarify that this TS section is only applicable to an operating unit. The NOTE also identifies that TS Section 5.3A (a new section proposed as part of this LAR) is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

The unit staff qualification requirements for an operating unit remain unchanged. The NOTE adds the clarification that TS 5.3 applies to an operating unit and refers to the TS that is applicable to a permanently defueled unit. The TS 5.3 proposed change is administrative.

Evaluation of Proposed Change Page 15 of 24

[New] TS Section 5.3A - Unit Staff Qualifications (Permanently Defueled Unit)

For a unit that is in a permanently shutdown and defueled condition, the focus of nuclear safety narrows to concerns associated with nuclear fuel (that is, the safe storage and handling of the nuclear fuel). This new TS section identifies overall qualifications required for unit staff at a permanently defueled unit. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, as discussed above in the case of a dual unit site such as BVPS, the other unit may still be an operating unit. To better delineate the unit staff qualifications for a permanently defueled unit, the proposed change adds this new section, including a NOTE to clarify that this TS section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel are docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

The NOTE also identifies that TS Section 5.3 is applicable to an operating unit.

The numbering of this new section deviates from Reference 3 by adding an A character to the TS numbering scheme. This provides a clear delineation and separation of the requirements related to the permanently defueled unit, while leaving the operating unit requirements relatively unaffected.

A discussion of each of the specifications under new TS 5.3A is provided below, including how it differs from those of an operating unit. The changes proposed for this new section are administrative.

[New] TS 5.3A.1 - This new TS provides the minimum qualifications for the staff of a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.3.1 with minor alterations to reflect a permanently shutdown and defueled reactor. The proposed TS requires that each member of the permanently defueled unit and radiation protection staff meets or exceeds the minimum qualifications specified in ANSI 18.1-1971, for comparable positions, except for the shift manager and radiation protection manager. The shift manager shall be qualified as required by the new proposed TS 5.2A.2.e. The proposed TS 5.3A.1 uses shift manager in place of operations manager to reflect the permanently shutdown and defueled condition. The requirement for the radiation protection manager remains the same as that specified in TS 5.3.1 and is still applicable for a unit in a permanently defueled condition. Therefore, it is retained in the new TS section.

Because the advisory technical support position is only required for a plant authorized for power operations, the exception for the technical advisory engineering representative is not applicable for a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. Once the certifications required by 10 CFR 50.82(a)(1) have been docketed for a unit, the license for that unit will no longer authorize operations of the reactor or emplacement or retention of fuel in the reactor vessel.

Evaluation of Proposed Change Page 16 of 24 Once the certifications required by 10 CFR 50.82(a)(1) have been docketed for a unit, the requirements of 10 CFR 50.54(m) will no longer be applicable for that unit because the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need for licensed operators as specified in 10 CFR 55. Therefore, this exception is not applicable for a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed.

[New] TS 5.3A.2 - This new TS adds a requirement applicable only to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The requirement is that The NRC-approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained. The new TS replaces the requirements of TS 5.3.2, which defines licensed senior operators and licensed operators as the individuals who perform the functions described in 10 CFR 50.54(m).

Once the certifications required by 10 CFR 50.82(a)(1) have been docketed, the requirements of 10 CFR 50.54(m) will no longer be applicable, nor will there be a need for licensed operators as specified in 10 CFR 55. Therefore, this requirement is not applicable to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. As discussed above, no exemption from 10 CFR 50.54(m) is needed or requested to support this TS.

The FENOC Certified Fuel Handler Training and Retraining Program ensures that certified fuel handler qualifications are commensurate with the tasks to be performed and the conditions requiring response actions. Regulation 10 CFR 50.120, Training and qualification of nuclear power plant personnel, requires training programs to be derived using a systems approach to training (SAT) as defined in 10 CFR 55.4.

Although the requirements of 10 CFR 50.120 apply to holders of an operating license issued under 10 CFR 50, and the permanently defueled unit license will no longer authorize operation following docketing of the certifications required by 10 CFR 50.82(a)(1), the FENOC Certified Fuel Handler Training and Retraining Program nonetheless aligns with those requirements. The Certified Fuel Handler Training and Retraining Program provides confidence that appropriate SAT-based training of personnel who will perform the duties of a certified fuel handler is conducted to ensure the unit is maintained in a safe and stable condition. By letter dated April 11, 2019 (Reference 2), the NRC approved the FENOC Certified Fuel Handler Training and Retraining Program.

TS Section 5.4 - Procedures This TS provides a description and requirements regarding administration of written procedures for an operating unit. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, in the case of a dual unit site such as BVPS, the other unit may still be an operating unit. To better delineate the requirements for each unit,

Evaluation of Proposed Change Page 17 of 24 the proposed change adds a NOTE to clarify that this TS section is only applicable to an operating unit. The NOTE also identifies that TS Section 5.4A (a new section proposed as part of this LAR) is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

The description and requirements regarding administration of written procedures for an operating unit remain unchanged. The NOTE adds the clarification that TS 5.4 applies to an operating unit and refers to the TS that is applicable to a permanently defueled unit. The TS 5.4 proposed change is administrative.

[New] TS Section 5.4A - Procedures (Permanently Defueled Unit)

For a unit that is in a permanently shutdown and defueled condition, the focus of nuclear safety narrows to concerns associated with nuclear fuel (that is, the safe storage and handling of the nuclear fuel). This new TS section provides a description and requirements regarding administration of written procedures applicable only to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. Once the certifications required by 10 CFR 50.82(a)(1) are docketed for a unit, the 10 CFR 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel for that unit. However, as discussed above in the case of a dual unit site such as BVPS, the other unit may still be an operating unit. To better delineate the unit staff qualifications for a permanently defueled unit, the proposed change adds this new section, including a NOTE to clarify that this TS section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel are docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

The NOTE also identifies that TS Section 5.4 is applicable to an operating unit.

The numbering of this new section deviates from Reference 3 by adding an A character to the TS numbering scheme. This provides a clear delineation and separation of the requirements related to the permanently defueled unit, while leaving the operating unit requirements relatively unaffected.

A discussion of each of the specifications under new TS 5.4A is provided below, including how it differs from those of an operating unit. The changes proposed for this new section are administrative.

[New] TS 5.4A.1 - This new TS provides a description and requirements regarding administration of written procedures applicable only to a unit for which the certifications required by 10 CFR 50.82(a)(1) are docketed. The proposed TS is comparable to TS 5.4 with minor alterations to reflect a permanently shutdown and defueled reactor.

Relevant procedures will continue to be controlled per 10 CFR 50, Appendix B, Criterion VI, Document Control. Activities involving security and emergency planning and preparedness will continue to be controlled by procedure.

Evaluation of Proposed Change Page 18 of 24

[New] TS 5.4A.1.a - This new TS identifies the applicable procedures to be maintained.

The proposed TS is comparable to TS 5.4.1.a with a minor alteration to reflect a permanently shutdown and defueled reactor. The new TS revises the applicability of the procedures to those applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Because operating and refueling the reactor will both be prohibited by the 10 CFR 50 license once the certifications required by 10 CFR 50.82(a)(1) have been docketed, procedures associated with these activities will no longer need to be maintained. Procedures governing fuel handling operations will provide the guidance necessary to ensure safe handling of nuclear fuel in the spent fuel pool and transfer from the spent fuel pool to dry fuel storage casks. Procedures governing responses to fuel handling accidents, personnel injuries, spent fuel pool events, and external events provide the necessary guidance to mitigate the consequences of such events. No change to the actions in response to a fuel handling accident is proposed.

[New] TS 5.4A.1.b - This new TS provides the requirement to maintain written procedures covering the activity of quality assurance for effluent and environmental monitoring. This requirement is the same as that specified in TS 5.4.c and is still applicable for a unit in a permanently defueled condition. Therefore, it is retained in the new TS section.

[New] TS 5.4A.1.c - This new TS provides the requirement to maintain written procedures covering the activity of Fire Protection Program implementation. This requirement is the same as that specified in TS 5.4.d and is still applicable for a unit in a permanently defueled condition. Therefore, it is retained in the new TS section.

[New] TS 5.4A.1.d - This new TS provides the requirement to maintain written procedures covering the programs specified in Specification 5.5. This requirement is the same as that specified in TS 5.4.e and is still applicable for a unit in a permanently defueled condition. Therefore, it is retained in the new TS section.

The proposed new TS Section 5.4A does not include a requirement comparable to TS 5.4.b, which requires emergency operating procedures that implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter (GL) 82-33. This TS is not proposed in the new TS section as GL 82-33 was only addressed to licensees of operating reactors, applicants for operating licenses, and holders of construction permits, none of which would apply to a unit at BVPS in the permanently defueled condition. As discussed above, procedures governing the site response to accidents, events, and injuries will provide the necessary guidance to mitigate the consequences of such events.

Evaluation of Proposed Change Page 19 of 24

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. FENOC has determined that the proposed changes do not require any exemptions or relief from regulatory requirements.

10 CFR 50.82(a)(1) requires that when a licensee has determined to permanently cease operations, the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of 10 CFR 50.4(b)(8), and once fuel has been permanently removed from the reactor vessel, the licensee shall submit a written certification to the NRC that meets the requirements of 10 CFR 50.4(b)(9). By letter dated April 25, 2018 (Reference 1), FENOC provided formal notification to the NRC of FENOCs intention to permanently cease power operations at BVPS-1 by May 31, 2021 and BVPS-2 by October 31, 2021.

10 CFR 50.82(a)(2) states: Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

10 CFR 50.36 establishes the requirements for TS. 10 CFR 50.36(c)(5),

Administrative Controls, identifies that an Administrative Controls section shall be included in the TS and shall include provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. This request is proposing changes to the Administrative Controls section, with conforming changes proposed to additional sections, consistent with the pending decommissioning status of the plant. This request applies the principles identified in 10 CFR 50.36(c)(6), Decommissioning, for a dual unit facility that has submitted certifications required by 10 CFR 50.82(a)(1) and proposes changes to the Administrative Controls appropriate for a unit in the permanently defueled condition, while maintaining operational requirements for the other unit until such time similar certifications are docketed for that unit. As 10 CFR 50.36(c)(6) states, this type of change should be considered on a case-by-case basis.

10 CFR 50.54(m) establishes the requirements for having reactor operators and senior reactor operators licensed in accordance with 10 CFR 55 based on plant conditions. Given the impending permanent cessation of operation for the units at BVPS, the requirements of this section will no longer apply once the certifications required by 10 CFR 50.82(a)(1) have been docketed for a unit, and it will be permissible to remove those positions for that unit from the TS, while

Evaluation of Proposed Change Page 20 of 24 retaining operational requirements for the other unit until such time similar certifications are docketed for that other unit.

4.2 No Significant Hazards Consideration Analysis The proposed changes would add certain requirements contained within the Beaver Valley Power Station, Unit No. 1 (BVPS-1) and Beaver Valley Power Station, Unit No. 2 (BVPS-2), Technical Specifications (TS), Section 1.1, Definitions, and Section 5.0, Administrative Controls. The TS requirements being added would be applicable once the certifications required by 10 CFR 50.82(a)(1) have been docketed for either of the units. The FENOC Certified Fuel Handler Training and Retraining Program has already been approved by the NRC. Once the certifications for permanent cessation of operations and permanent fuel removal are made for a unit, the 10 CFR 50 license for that unit will no longer authorize operation of the reactor or placement of fuel in the reactor vessel, in accordance with 10 CFR 50.82(a)(2). Operational requirements for the other unit would remain in effect until such time similar certifications are docketed for that unit.

FirstEnergy Nuclear Operating Company (FENOC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment would revise the BVPS-1 and BVPS-2 TS by adding certain portions to the TS administrative controls described in Section 5.0 that are only applicable to a permanently shutdown and defueled unit. In addition, the terms CERTIFIED FUEL HANDLER and NON-CERTIFIED OPERATOR would be added to Section 1.1 to define these positions that are applicable to a permanently shutdown and defueled unit.

The addition of provisions of the administrative controls do not directly affect the design of structures, systems, and components (SSCs) necessary for safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the spent fuel pool. The changes are administrative in nature and do not affect any accidents applicable to the safe management of irradiated fuel or the permanently shutdown and

Evaluation of Proposed Change Page 21 of 24 defueled condition of the reactor. Thus, the consequences of an accident previously evaluated are not increased.

In a permanently defueled condition, it is expected that the only credible accidents are the fuel handling accident (FHA) and those involving radioactive waste systems remaining in service. The probability of occurrence of previously evaluated accidents is not increased because extended operation in a defueled condition will be the only operation allowed. This mode of operation is bounded by the existing analyses. In addition, the occurrence of postulated accidents associated with reactor operation is no longer credible in a permanently defueled reactor. This significantly reduces the scope of applicable accidents.

Operational requirements for both units remain unchanged until such time as certifications are docketed for a unit that places that unit in a permanently defueled condition. During the time when only one unit is in a permanently defueled condition, operations at the other unit are bounded by the existing analyses.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment has no impact on facility SSCs affecting the safe storage of irradiated fuel, or on the methods of operation of such SSCs, or on the handling and storage of irradiated fuel itself. The administrative additions to the TS that are related only to administration of the facility cannot result in different or more adverse failure modes or accidents than previously evaluated because a unit reactor will be permanently shutdown and defueled, and that unit will no longer be authorized to operate the reactor or retain or place fuel in the reactor vessel.

The proposed amendment to the BVPS-1 and BVPS-2 TS does not affect systems credited in the accident analysis for the FHA or radioactive waste system upsets at a permanently defueled unit. The proposed TS will continue to require proper control and monitoring of safety significant parameters and activities.

The proposed amendment does not result in any new mechanisms that could initiate damage to the remaining relevant safety barriers for defueled plants (fuel cladding and spent fuel pool cooling). Extended operation in a defueled condition will be the only operation allowed, and it is bounded by

Evaluation of Proposed Change Page 22 of 24 the existing analyses, therefore such a condition does not create the possibility of a new or different kind of accident.

Operational requirements for both units remain unchanged until such time as certifications are docketed for a unit that places that unit in a permanently defueled condition. During the time when only one unit is in a permanently defueled condition, operations at the other unit are bounded by the existing analyses.

The proposed amendment does not involve any physical alterations to the facility.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Because the 10 CFR 50 license for a unit will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel once the certifications required by 10 CFR 50.82(a)(1) are docketed, as specified in 10 CFR 50.82(a)(2), the occurrence of postulated accidents associated with reactor operation is no longer credible. The only remaining credible accidents are a FHA and those involving radioactive waste systems remaining in service. The proposed amendment does not adversely affect the inputs or assumptions of any of the design basis analyses that impact these analyzed conditions.

Operational requirements for both units remain unchanged until such time as certifications are docketed for a unit that places that unit in a permanently defueled condition. During the time when only one unit is in a permanently defueled condition, operations at the other unit are bounded by the existing analyses.

The proposed changes are limited to those portions of the TS that are not related to the SSCs that are important to the safe storage of spent nuclear fuel. The requirements that are proposed to be added to the BVPS-1 and BVPS-2 TS are not credited in the existing accident analysis for the remaining applicable postulated accidents; and, therefore, do not contribute to the margin of safety associated with the accident analysis.

Postulated design basis accidents involving the reactor are no longer possible because the reactor will be permanently shutdown and defueled, and FENOC will no longer be authorized to operate the reactor or retain or place fuel in the reactor vessel.

Evaluation of Proposed Change Page 23 of 24 Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, FENOC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment involves adding certain TS administrative controls in support of proposed decommissioning efforts to reflect the permanently shutdown and defueled condition for either BVPS unit. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

In addition, the proposed changes involve changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. FENOC Letter to NRC, Certification of Permanent Cessation of Power Operations for Beaver Valley Power Station, Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station, Unit No. 1, and Perry Nuclear Power Plant, Unit No. 1, dated April 25, 2018 (Accession No. ML18115A007)

2. NRC Letter to FENOC, FENOC Fleet - Beaver Valley Power Station, Unit Nos. 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1 - Approval of Certified Fuel Handler

Evaluation of Proposed Change Page 24 of 24 Training and Retraining Program (EPID L-2018-LLL-0023), dated April 11, 2019 (Accession No. ML19028A030)

3. NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 4.0, Published April 2012

4. NRC Letter to Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station - Request for Exemption from the Requirements of 10 CFR 50.54(m) (TAC No. MF2990), dated June 18, 2014 (ML14147A216) 7.0 ATTACHMENTS

1. Technical Specification Page Markups

Attachment 1 Technical Specification Page Markups (10 pages follow)

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

- NOTE -

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals (AFD) between the top and bottom halves of a two section excore neutron detector.

CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER training and retraining program required by Specification 5.3A.4.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

Beaver Valley Units 1 and 2 1.1 - 1 Amendments 278 / 161

Definitions 1.1 1.1 Definitions MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing all master relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required master relay. The MASTER RELAY TEST shall include a continuity check of each associated required slave relay. The MASTER RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3A.3, but is not a CERTIFIED FUEL HANDLER.

OPERABLE - OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in Chapter 14, Initial Test Program of the Unit 2 UFSAR, and Chapter 13, Initial Tests and Operation, of the Unit 1 UFSAR,

b. Authorized under the provisions of 10 CFR 50.59, or

c. Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates and the Overpressure Protection System setpoint and enable temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.4.

Beaver Valley Units 1 and 2 1.1 - 4 Amendments 278 / 161

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization

-NOTE-This TS Section is only applicable to an operating unit. TS Section 5.2A is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the Unit 2 UFSAR,

b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant,

c. A corporate officer with direct responsibility for the plant shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety, and

d. The individuals who train the operating staff, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

Beaver Valley Units 1 and 2 5.2 - 1 Amendments 278 / 161

Organization 5.2 5.2 Organization 5.2.2 Unit Staff The unit staff organization shall include the following:

a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

d. Deleted.

e. The operations manager shall either hold an SRO license or have held an SRO license for a pressurized water reactor. The assistant operations manager shall hold a current SRO license.

f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. A single qualified person can be used to satisfy this position for both units.

Beaver Valley Units 1 and 2 5.2 - 2 Amendments 284 / 169

Organization (Permanently Defueled Unit) 5.2A 5.0 ADMINISTRATIVE CONTROLS 5.2A Organization (Permanently Defueled Unit)

-NOTE-This TS Section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). TS Section 5.2 is applicable to an operating unit.

5.2A.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit staff and corporate management. The onsite and offsite organizations shall include the positions for activities affecting the safe storage and handling of nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all unit organization positions. These relationships shall be documented and updated, as appropriate, in organization descriptions, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the Unit 2 UFSAR,

b. The plant manager shall be responsible for overall safe operation of the unit and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel,

c. A corporate officer with direct responsibility for the unit shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the unit to ensure safe management of nuclear fuel, and

d. The individuals who train the CERTIFIED FUEL HANDLERs, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

Beaver Valley Units 1 and 2 5.2A - 1 Amendments TBD / TBD

Organization (Permanently Defueled Unit) 5.2A 5.2A Organization (Permanently Defueled Unit) 5.2A.2 Unit Staff The unit staff organization shall include the following:

a. Each on duty shift shall be composed of at least one shift manager and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

b. Shift crew composition may be less than the minimum requirement of Specification 5.2A.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and the following conditions are met:

1) No nuclear fuel movements are in progress;

2) No movement of loads over nuclear fuel is in progress; and

3) No unmanned shift positions during shift turnover shall be permitted due to an incoming shift crew member being late or absent.

c. An individual qualified in radiation protection procedures shall be on site during movement of nuclear fuel and during the movement of loads over nuclear fuel. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

d. At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.

e. The shift manager shall be a CERTIFIED FUEL HANDLER.

f. Oversight of nuclear fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

Beaver Valley Units 1 and 2 5.2A - 2 Amendments TBD / TBD

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications

-NOTE-This TS Section is only applicable to an operating unit. TS Section 5.3A is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

5.3.1 Each member of the unit and radiation protection staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

• The operations manager as specified in Specification 5.2.2.e,

• The radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and

• The technical advisory engineering representative who shall have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design and response analysis of the plant for transients and accidents.

• The licensed operators who shall comply only with the requirements of 10 CFR 55.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Beaver Valley Units 1 and 2 5.3 - 1 Amendments 297 / 185

Unit Staff Qualifications (Permanently Defueled Unit) 5.3A 5.0 ADMINISTRATIVE CONTROLS 5.3A Unit Staff Qualifications (Permanently Defueled Unit)

-NOTE-This TS Section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). TS Section 5.3 is applicable to an operating unit.

5.3A.1 Each member of the unit and radiation protection staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the following:

• The shift manager as specified in Specification 5.2A.2.e, and

• The radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

5.3A.2 The NRC-approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained.

Beaver Valley Units 1 and 2 5.3A - 1 Amendments TBD / TBD

Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures

-NOTE-This TS Section is only applicable to an operating unit. TS Section 5.4A is applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2).

5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and to NUREG-0737, Supplement 1, as stated in Generic Letter 82-33,

c. Quality assurance for effluent and environmental monitoring,

d. Fire Protection Program implementation, and

e. All programs specified in Specification 5.5.

Beaver Valley Units 1 and 2 5.4 - 1 Amendments 278 / 161

Procedures (Permanently Defueled Unit) 5.4A 5.0 ADMINISTRATIVE CONTROLS 5.4A Procedures (Permanently Defueled Unit)

-NOTE-This TS Section is only applicable to a unit for which the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel is docketed in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2). TS Section 5.4 is applicable to an operating unit.

5.4A.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,

b. Quality assurance for effluent and environmental monitoring,

c. Fire Protection Program implementation, and

d. All programs specified in Specification 5.5.

Beaver Valley Units 1 and 2 5.4A - 1 Amendments /