ML20072N040

Request for Additional Information - Control Envelope Habitability LAR

ML20072N040
Person / Time
Site:	Beaver Valley
Issue date:	03/12/2020
From:	Jennifer Tobin Plant Licensing Branch 1
To:	Penfield R Energy Harbor Nuclear Corp
Tobin J, NRR/DORL/LPL1, 415-2328
References
EPID 2019-LLA-0223
Download: ML20072N040 (4)

Text

From: Tobin, Jennifer To: rpenfield@firstenergycorp.com Cc: Lashley, Phil H (EH); McCreary, Dave M (EH)

Subject:

Beaver Valley Units 1 and 2 - Request for Additional Information - Control Envelope Habitability LAR (EPID L-2019-LLA-0223)

Date: Thursday, March 12, 2020 11:00:00 AM

Dear Mr. Penfield,

By letter dated October 20, 2019, First Energy Nuclear Operating Company. (FENOC), the licensee, submitted a license amendment request to revise Beaver Valley Power Station Units 1 and 2 Technical Specifications (TS). The requested changes revise TS 3.4.16, RCS Specific Activity, 3.7.13 Secondary Specific Activity, 5.5.7, Ventilation Filter Testing Program (VFTP), and 5.5.14, Control Room Envelope Habitability Program. The proposed changes to TSs 3.4.16 and 3.7.13 would reduce the allowed reactor coolant system and secondary coolant specific activities for Unit 2 and make administrative changes to Unit 1 TS. The proposed changes to TS 5.5.7 for the control room emergency ventilation system (CREVS) change the acceptance criteria for the CREVS penetration and system bypass requirement and CREVS charcoal adsorber removal efficiency based on the licensees evaluation in the LAR. The proposed change to the Control Room Envelope (CRE) Habitability Program in TS 5.5.14 would add a note allowing a one-time extension of three years to the unfiltered air inleakage test frequency following the test failure that occurred in October 2017.

Regulatory Analysis Basis (one-time extension of testing)

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires each license authorizing operation of a production or utilization facility of a type described in § 50.21 or § 50.22 will include technical specifications. The technical specification will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34.

In Section 3.4 of the LAR the licensee provided an evaluation of the proposed change to add a note allowing a one-time extension of three years to the unfiltered air inleakage test frequency following the test failure that occurred in October 2017.

Licensee clarifications and explanations of items in section 3.4 of the LAR are required for the staff to make a conclusion regarding whether or not the TS, as amended by the proposed changes, will continue to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto provide thereby continuing to provide reasonable assurance of adequate protection of public health and safety.

1) The licensee stated the following in the second paragraph of Section 3.4: FENOC has high confidence that the CRE has not continued to degrade based upon improving test results between 2015 and 2017 due to plant modifications and system rebalancing efforts for the normal and recirculation (isolation) modes. However the issue that triggered the need for a test after 3 years is the failure in 2017. It does not appear appropriate to justify the proposed test extension using test results prior to the failure in 2017. Please provide an appropriate justification for the proposed test extension or revise the request to not include a proposed test extension.

2) The licensee also made the following statements in Section 3.4 of the LAR:

For the Unit 1 and Unit 2 pressurization (emergency) modes, the step change that occurred between 2008 and 2015 has remained essentially unchanged over the most recent two-year test period; therefore, it is not anticipated to degrade any further. Additionally, the proposed acceptance criteria in this license amendment request are expected to provide sufficient margin for potential CRE boundary degradation in the future.

While the first sentence appears to support the justification for the need for the proposed changes, the second sentence appears to refute the statement that further boundary degradation is not expected and therefore refute the justification for the need for the proposed changes. Please clarify whether or not the licensee expects the boundary to continue to degrade and why a test extension would be appropriate.

3) In the third paragraph of Section 3.4 of the LAR the licensee stated:

Therefore, with the last test performed in October 2017, the next CRE unfiltered air inleakage would be performed no later than April 2025 with the current provisions of TS 5.5.14.f included. FENOC intends to perform the three-year self-assessment that would be required by Figure 1 in RG 1.197 as if the periodic CRE testing were on the normal six-year cycle.

Please provide an explanation regarding a proposed next test date of April 2025. Given the failure occurred in October 2017 and the program suggests a test 3 years later (October 2020) and the request for a 3 year extension in addition to the program suggested test date would appear to indicate a proposed nominal test date of October 2023.

4) It does not appear appropriate to use the 25% extension of TS 5.5.14.f for any amount of time associated with the proposed request for a three year extension. Please provide further justification for use of the 25% extension for the entire proposed nominal 6 year interval or revise the request to not use the extension.

Regulatory Analysis Basis (revision of accident dose consequence analyses)

The proposed changes in this LAR will affect the current licensing basis (CLB) accident dose consequence analyses for the eight design basis accidents: LOCA; control rod ejection accident (CREA); main steam line break (MSLB) outside of containment; steam generator tube rupture (SGTR); reactor coolant pump (RCP) locked rotor accident (LRA);

loss of alternating current power (LACP); fuel handling accident (FHA) in the fuel pool or in containment; and small line break (SLB) accident outside of containment. FENOC stated the waste gas system rupture (failure) events previously addressed in Amendment Nos.

275 (BVPS-1) and 156 (BVPS-2) was not addressed in this LAR as the proposed changes have been assessed and may be implemented accordance with 10 CFR 50.59.

As stated in NRC Regulatory Issue Summary (RIS) 2006-04, Experience with Implementation of Alternative Source Terms, dated March 7, 2006 (ADAMS Accession No. ML053460347), the level of detail contained in LARs should contain enough details (e.g.,

assumptions, computer analyses input and output) to allow the NRC staff to confirm the dose analyses results in independent calculations. The provision of sufficient detail is necessary for the NRC staff to be able to conclude, with reasonable assurance, whether

the licensees analyses and changes are acceptable.

RG 1.183, Section 1.5, Submittal Requirements, states in part, that, The amendment request should describe the licensees analyses of the radiological and nonradiological impacts of the proposed modification in sufficient detail to support review by the NRC staff.

The staff recommends that licensees submit affected FSAR pages annotated with changes that reflect the revised analyses or submit the actual calculation documentation. If the licensee has used a current approved version of an NRC-sponsored computer code, the NRC staff review can be made more efficient if the licensee identifies the code used and submits the inputs that the licensee used in the calculations made with that code.

NUREG-0800 Standard Review Plan (SRP) Section 15.0.1, Radiological Consequence Analyses Using Alternative Source Terms, dated July 2000 (ADAMS Accession No. ML003734190) states, in part, that, models, assumptions and parameter inputs used by the licensee should be reviewed to ensure that the conservative design basis assumptions outlined in RG 1.183 have been incorporated. In addition, SRP Section 15.0.1 states, in part, that, independent calculations should be performed as necessary to conclude, with reasonable assurance, that the applicants analyses are acceptable. , Comparison of Important Analysis Parameters, of the proposed LAR presents a comparison between the design input values used in the CLB radiological dose consequence analyses, for BVPS-1 and BVPS-2, to those used in the radiological dose consequence analyses. The information is arranged by design basis accident in tabular format. FENOC stated only those design parameters that have undergone a change are listed. As a result of the proposed LAR changes, the calculated radiological doses for several design basis accidents appear to either challenge the NRCs regulatory dose criteria and/or substantially increase in comparison with those in the CLB.

5) The NRC staff intends to perform independent calculations, as discussed above, to support its evaluation of this LAR to facilitate the staffs review, please provide additional information describing, for each design basis accident and unit affected by the proposed LAR changes, all the basic parameters used in the radiological dose consequence analyses. To support a timely NRC review, this information should include the CLB value, the revised value where applicable, the basis for any changes to the CLB on all basic parameters whether or not the individual parameter is being changed in separate tables for each affected design basis accident and unit.

6) Please provide additional information describing the models, assumptions, and parameter inputs used in BVPS calculations of the radiological dose consequence analyses affected by the proposed LAR changes for the revised LOCA, SGTR, and RCP LRA. Alternatively, to support a timely NRC review, the calculation packages which typically contain this information and in sufficient detail may be provided for the selected design basis accidents.

Please submit your response to this request for additional information by April 13th. A clarification call on the draft RAI was held March 11th and resulted in the deletion of one sentence in which NRC determined that information was not needed for the review.

If you have questions please dont hesitate to contact me.

Thanks!

-Jenny