Text

Issuance of Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time
	ML23102A147
Person / Time
Site:	Beaver Valley
Issue date:	05/22/2023
From:	Sujata Goetz; Plant Licensing Branch 1
To:	Blair B; Energy Harbor Nuclear Corp
	Goetz S
References
	EPID L-2020-LLA-0071
	Download: ML23102A147 (54)
	v • d • e

May 22, 2023

Mr. Barry N. Blair Site Vice President Energy Harbor Nuclear Corp.

Beaver Valley Power Station Mail Stop P-BV-SSB P.O. Box 4, Route 168 Shippingport, PA 15077-0004

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 321 AND 211 RE: CONSOLIDATE FUEL DECAY TIME TECHNCIAL SPECIFICATIONS IN A NEW LIMITING CONDITION FOR OPERATION TITLED DECAY TIME (EPID L-2022-LLA-0071)

Dear Mr. Blair:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment Nos. 321 and 211 to Renewed Facility Operating License Nos. DPR-66 and NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2, respectively. This amendment is in response to your application dated May 16, 2022, as supplemented by letters dated December 7, 2022, and February 14, 2023.

This amendment revises the Beaver Valley technical specifications (TS) to add a limiting condition for operation (LCO) titled Decay Time restricting movement of fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . The current TS restrictions on fuel movement involving fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months appear in the applicability statements and conditions of several TS LCOs. These restrictions will be consolidated in the new LCO titled Decay Time, which will ensure the decay time assumed in the design basis fuel handling accident is maintained.

B. Blair

A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Sujata Goetz, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 321 to DPR-66

2. Amendment No. 211 to NPF-73

3. Safety Evaluation

cc: Listserv ENERGY HARBOR NUCLEAR CORP.

ENERGY HARBOR NUCLEAR GENERATION LLC

DOCKET NO. 50-334

BEAVER VALLEY POWER STATION, UNIT NO. 1

AMENDMENT TO RENEWED FACI LITY OPERATING LICENSE

Amendment No. 321 Renewed License No. DPR-66

1. The U.S. Nuclear Regulatory Commission (NRC) has found that:

A. The application for amendment by Energy Harbor Nuclear Corp.* acting on its own behalf and as agent for Energy Harbor Nuclear Generation LLC (the licensees), dated May 16, 2022, as supplemented by letter dated December 7, 2022, and February 14, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I.

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Energy Harbor Nuclear Corp. is authorized to act as agent for Energy Harbor Nuclear Generation LLC and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Enclosure 1

2. Accordingly, the license is amended by changes to the TS as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-66 is hereby amended to read as follows:

(2) Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 321, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Hipólito J. González, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications

Date of Issuance: May 22, 2023 ENERGY HARBOR NUCLEAR CORP.

ENERGY HARBOR NUCLEAR GENERATION LLC

DOCKET NO. 50-412

BEAVER VALLEY POWER STATION, UNIT 2

AMENDMENT TO RENEWED FACI LITY OPERATING LICENSE

Amendment No. 211 Renewed License No. NPF-73

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Energy Harbor Nuclear Corp., acting on its own behalf and as agent for Energy Harbor Nuclear Generation LLC* (the licensees), dated May 16, 2022, as supplemented by letter dated December 7, 2022, and February 14, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Energy Harbor Nuclear Corp. is authorized to act as agent for Energy Harbor Nuclear Generation LLC and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-73 is hereby amended to read as follows:

(2) Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 211, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. Energy Harbor Nuclear Corp.

shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Hipólito J. González, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications

Date of Issuance: May 22, 2023 ATTACHMENT TO LICENSE AMENDMENT NOS. 321 AND 211

BEAVER VALLEY POWER STATION, UNITS 1 AND 2

RENEWED FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73

DOCKET NOS. 50-334 AND 50-412

Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Renewed Facility Operating License No. DPR-66

Remove Insert Page 3 Page 3

Renewed Facility Operating License No. NPF-73

Remove Insert Page 4 Page 4

Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Appendix A, Technical Specifications

Remove Insert

3.3.6-1 3.3.6-1 3.3.6-2 ---------

3.3.6-3 ---------

3.3.7-1 3.3.7-1 3.3.7-2 3.3.7-2 3.3.7-3 3.3.7-3 3.7.10-1 3.7.10-1 3.7.10-2 3.7.10-2 3.7.11-1 3.7.11-1 3.7.11-2 3.7.11-2 3.7.11-3 3.7.11-3 3.7.12-1 3.7.12-1 3.7.12-2 -----------

3.8.2-1 3.8.2-1 3.8.2-2 3.8.2-2 3.8.2-3 3.8.2-3 3.8.5-1 3.8.5-1 3.8.5-2 3.8.5-2 3.8.8-1 3.8.8-1

3.8.8-2 3.8.8-2 3.8.10-1 3.8.10-1 3.8.10-2 3.8.10-2 3.9.3-1 3.9.3-1 3.9.3-2 ---------

3.9.7-1 5.5-13 5.5-13 5.5-14 5.5-14 5.5-15 5.5-15 5.5-16 5.5-16 (3) Energy Harbor Nuclear Corp., pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

(4) Energy Harbor Nuclear Corp., pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components;

(5) Energy Harbor Nuclear Corp., pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level

Energy Harbor Nuclear Corp. is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.

(2) Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 321, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Auxiliary River Water System

(Deleted by Amendment No. 8)

Amendment No. 321 Beaver Valley Unit 1 Renewed Operating License DPR-66

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations set forth in 10 CFR Chapter 1 and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level

Energy Harbor Nuclear Corp. is authorized to operate the facility at a steady state reactor core power level of 2900 megawatts thermal.

(2) Technical Specifications

The Technical Specifications contained in Appendix A, as revised through Amendment No. 211, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. Energy Harbor Nuclear Corp. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 211 Beaver Valley Unit 2 Renewed Operating License NPF-73

Unit 2 Containment Purge and Exhaust Isolation Instrumentation 3.3.6

3.3 INSTRUMENTATION

3.3.6 Unit 2 Containment Purge and Exhaust Isolation Instrumentation

The requirement for the Unit 2 Containment Purge and Exhaust Isolation Instrumentation is deleted.

Beaver Valley Units 1 and 2 3.3.6 - 1 Amendments 2321/211 161 CREVS Actuation Instrumentation 3.3.7

3.3 INSTRUMENTATION

3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation

LCO 3.3.7 The CREVS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.7-1.

ACTIONS

-NOTE -

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more Functions A.1 Place one CREVS train in 7 days with one channel or train emergency pressurization inoperable. mode of operation.

B. One or more Functions B.1 Place one CREVS train in Immediately with two channels or two emergency pressurization trains inoperable. mode of operation.

AND

B.2 Enter applicable Conditions Immediately and Required Actions of LCO 3.7.10, "CREVS," for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

Beaver Valley Units 1 and 2 3.3.7 - 1 Amendments 27321/211 1 CREVS Actuation Instrumentation 3.3.7

SURVEILLANCE REQUIREMENTS

-NOTE -

Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation Function.

SURVEILLANCE FREQUENCY

SR 3.3.7.1 ------------------------------------------------------------------------

-NOTE -

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program

Beaver Valley Units 1 and 2 3.3.7 - 2 Amendments 321/211 CREVS Actuation Instrumentation 3.3.7

Table 3.3.7-1 (page 1 of 1)

CREVS Actuation Instrumentation

APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE FUNCTION CONDITIONS CHANNELS REQUIREMENTS

1. Manual Initiation 1, 2, 3, 4 2 trains SR 3.3.7.1

2. Containment Isolation - Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.b, for Phase B all initiation functions and requirements.

Beaver Valley Units 1 and 2 3.3.7 - 3 Amendments 321/2111 CREVS 3.7.10

3.7 PLANT SYSTEMS

3.7.10 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.10 Two CREVS trains shall be OPERABLE.

-NOTE -

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. One required CREVS train A.1 Restore required CREVS 7 days inoperable for reasons train to OPERABLE status.

other than Condition B.

B. One or more required B.1 Initiate action to implement Immediately CREVS trains inoperable mitigating actions.

due to inoperable CRE boundary. AND

B.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant radiological exposures will not exceed limits and CRE occupants are protected from chemical and smoke hazards.

AND B.3 Restore CRE boundary to 90 days OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

Beaver Valley Units 1 and 2 3.7.10 - 1 Amendments 321/21163 CREVS 3.7.10

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. Two required CREVS D.1 Enter LCO 3.0.3. Immediately trains inoperable for reasons other than Condition B.

Beaver Valley Units 1 and 2 3.7.10 - 2 Amendments 321/21163 CREACS 3.7.11

3.7 PLANT SYSTEMS

3.7.11 Control Room Emergency Air Cooling System (CREACS)

LCO 3.7.11 Two CREACS trains shall be OPERABLE.

-NOTE -

For Unit 1, the heat removal function of CREACS is not required OPERABLE to support fuel movement involving irradiated fuel assemblies.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1).

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. One CREACS train A.1 Restore CREACS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met in MODE 1, 2, 3, B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months or 4.

Beaver Valley Units 1 and 2 3.7.11 - 1 Amendments 321/211161 CREACS 3.7.11

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C. ----------------------------------

- NOTE-Only applicable to Unit 1 during movement of irradiated fuel assemblies or fuel assemblies over irradiated fuel assemblies.

Required Action and C.1 Place OPERABLE Immediately associated Completion CREACS train in operation.

Time of Condition A not met. OR

C.2 Suspend movement of Immediately irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.7.11 - 2 Amendments 321/2111 CREACS 3.7.11

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. ----------------------------------

- NOTE-Only applicable to Unit 1 during movement of irradiated fuel assemblies or fuel assemblies over irradiated fuel assemblies.

Two CREACS trains D.1 Suspend movement of Immediately inoperable. irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies.

E. Two CREACS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.7.11.1 -------------------------------------------------------------------------

-NOTE -

For Unit 1, the verification of heat removal function of CREACS is not required to support the movement of irradiated fuel.

Verify each CREACS train has the capability to remove In accordance the required heat load and purge the control room with the atmosphere at the required flow rate. Surveillance Frequency Control Program

Beaver Valley Units 1 and 2 3.7.11 - 3 Amendments 321/211 SLCRS 3.7.12

3.7 PLANT SYSTEMS

3.7.12 Supplemental Leak Collection and Release System (SLCRS)

The requirement for the Supplementation Leak Collection and Release System (SLCRS) is deleted.

Beaver Valley Units 1 and 2 3.7.12 - 1 Amendments 321/21161 AC Sources - Shutdown 3.8.2

3.8 ELECTRICAL POWER SYSTEMS

3.8.2 AC Sources - Shutdown

LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown," and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1).

ACTIONS

-NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One required offsite circuit ------------------------------------------------

inoperable. -NOTE -

Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR

Beaver Valley Units 1 and 2 3.8.2 - 1 Amendments 2321/211 161 AC Sources - Shutdown 3.8.2

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

A.2.1 Suspend CORE Immediately ALTERATIONS.

AND

A.2.2 -----------------------------------

-NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND

A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.4 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

Beaver Valley Units 1 and 2 3.8.2 - 2 Amendments 321/21161 AC Sources - Shutdown 3.8.2

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND

B.2 -----------------------------------

-NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND

B.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.4 Initiate action to restore Immediately required DG to OPERABLE status.

Beaver Valley Units 1 and 2 3.8.2 - 3 Amendments 321/21161 DC Sources - Shutdown 3.8.5

3.8 ELECTRICAL POWER SYSTEMS

3.8.5 DC Sources - Shutdown

LCO 3.8.5 One DC electrical power subsystem shall be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1).

ACTIONS

-NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One required DC electrical A.1 Declare affected required Immediately power subsystem feature(s) inoperable.

inoperable.

OR

A.2.1 Suspend CORE Immediately ALTERATIONS.

AND

A.2.2 -----------------------------------

-NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.8.5 - 1 Amendments 2321/211 61 DC Sources - Shutdown 3.8.5

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

AND

A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND

A.2.4 Initiate action to restore Immediately required DC electrical power subsystems to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.8.5.1 ------------------------------------------------------------------------

-NOTE -

The following SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3

Beaver Valley Units 1 and 2 3.8.5 - 2 Amendments 321/21161 Inverters - Shutdown 3.8.8

3.8 ELECTRICAL POWER SYSTEMS

3.8.8 Inverters - Shutdown

LCO 3.8.8 Two inverters shall be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1).

ACTIONS

-NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more required A.1 Declare affected required Immediately inverters inoperable. feature(s) inoperable.

OR

A.2.1 Suspend CORE Immediately ALTERATIONS.

AND

A.2.2 -----------------------------------

-NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.8.8 - 1 Amendments 2321/211 61 Inverters - Shutdown 3.8.8

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

AND

A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND

A.2.4 Initiate action to restore Immediately required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.8.8.1 Verify correct inverter voltage and alignments to In accordance required AC vital buses. with the Surveillance Frequency Control Program

Beaver Valley Units 1 and 2 3.8.8 - 2 Amendments 321/21179 Distribution Systems - Shutdown 3.8.10

3.8 ELECTRICAL POWER SYSTEMS

3.8.10 Distribution Systems - Shutdown

LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1).

ACTIONS

-NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more required AC, A.1 Declare associated Immediately DC, or AC vital bus supported required electrical power distribution feature(s) inoperable.

subsystems inoperable.

OR

A.2.1 Suspend CORE Immediately ALTERATIONS.

AND

A.2.2 -----------------------------------

-NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.8.10 - 1 Amendments 321/211 Distribution Systems - Shutdown 3.8.10

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

AND

A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND

A.2.4 Initiate actions to restore Immediately required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

AND

A.2.5 Declare associated Immediately required residual heat removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.8.10.1 Verify correct breaker alignments and voltage to In accordance required AC, DC, and AC vital bus electrical power with the distribution subsystems. Surveillance Frequency Control Program

Beaver Valley Units 1 and 2 3.8.10 - 2 Amendments 321/211 Containment Penetrations 3.9.3

3.9 REFUELING OPERATIONS

3.9.3 Containment Penetrations

The requirement for the Containment Penetrations is deleted.

Beaver Valley Units 1 and 2 3.9.3 - 1 Amendments 321/2111 Decay Time 3.9.7

3.9 REFUELING OPERATIONS

3.9.7 Decay Time

LCO 3.9.7 The reactor shall be subcritical for 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months .

APPLICABILITY: During movement of irradiated fuel assemblies within containment, During movement of fuel assemblies over irradiated fuel assemblies within the containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. Reactor subcritical A.1 Suspend movement of Immediately

< 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . irradiated fuel assemblies within containment.

AND

A.2 Suspend movement of fuel Immediately assemblies over irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.9.7.1 The reactor shall be determined to have been Prior to movement subcritical for at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months by verification of the of irradiated fuel date and time of subcriticality. assemblies within containment

Beaver Valley Units 1 and 2 3.9.7 - 1 Amendments 321/21179 Programs and Manuals 5.5

5.5 Programs and Manuals

5.5.6 Secondary Water Chemistry Program

This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables,

b. Identification of the procedures used to measure the values of the critical variables,

c. Identification of process sampling points,

d. Procedures for the recording and management of data,

e. Procedures defining corrective actions for all off control point chemistry conditions, and

f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems for the Control Room Emergency Ventilation System (CREVS).

Tests described in Specifications 5.5.7.a and 5.5.7.b shall be performed at least once per 18 months and after the following:

Each complete or partial replacement of the high efficiency particulate air (HEPA) filter or charcoal adsorber bank;

Any structural maintenance on the HEPA filter or charcoal adsorber housing; and

Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the system is operating.

Beaver Valley Units 1 and 2 5.5 - 13 Amendments 321/21184 Programs and Manuals 5.5

5.5 Programs and Manuals

5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

Tests described in Specification 5.5.7.c shall be performed at least once per 18 months and after the following:

720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of adsorber operation (for the Unit 1 and 2 CREVS);

Any structural maintenance on the charcoal adsorber bank housing; and Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the system is operating.

Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed at least once per 18 months.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

a. Demonstrate for each of the required ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass specified below when tested in accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS) at the system flowrate specified below:

ESF Ventilation System Penetration Flowrate

CREVS 0.05% 800 cfm and 1000 cfm

b. Demonstrate for each of the required ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass specified below when tested in accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS) at the system flowrate specified below:

Beaver Valley Units 1 and 2 5.5 - 14 Amendments 321/21184 Programs and Manuals 5.5

5.5 Programs and Manuals

5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

ESF Ventilation System Penetration Flowrate

CREVS 0.5% 800 cfm and 1000 cfm

c. Demonstrate for each of the required ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, or using a slotted tube sampler in accordance with ANSI N509-1980 shows, within 31 days after removal, the methyl iodide removal efficiency greater than or equal to the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30C, an inlet methyl iodide concentration of 1.75 mg/m3, and an air flow velocity and relative humidity (RH) specified below:

ESF Ventilation Removal System Efficiency Air Flow Velocity RH

CREVS 99.5% (Unit 1) 0.68 ft/sec (Unit 1) 70% (Unit 1) 99.5% (Unit 2) 0.7 ft/sec (Unit 2) 70% (Unit 2)

d. Demonstrate for each of the required ESF systems that the pressure drop across the combined HEPA filters and the charcoal adsorbers is less than the value specified below when tested at the system flowrate specified as follows:

ESF Ventilation System Delta P Flowrate

CREVS 6 inches Water Gauge 800 cfm and 1000 cfm (Unit 1)

(Unit 1) 5.6 inches Water 800 cfm and 1000 cfm (Unit 2)

Gauge (Unit 2)

Beaver Valley Units 1 and 2 5.5 - 15 Amendments 321/2115 Programs and Manuals 5.5

5.5 Programs and Manuals

5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Wattage

CREVS 3.87 kW and 5.50 kW

5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program

This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in waste gas decay tanks (Unit 1) and gaseous waste storage tanks (Unit 2), and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure." The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures."

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained. Such limits shall ensure that the concentration of hydrogen and oxygen is maintained below flammability limits,

b. A surveillance program to ensure that the quantity of radioactivity contained in each waste gas decay tank (Unit 1) and each connected group of waste gas storage tanks (Unit 2) is less than the amount that would result in a whole body exposure of > 0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents, and

c. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is less than the amount that would result in concentrations greater than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

Beaver Valley Units 1 and 2 5.5 - 16 Amendments 321/21184 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO AMENDMENT NOS. 321 AND 211 TO RENEWED

FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73

ENERGY HARBOR NUCLEAR GENERATION LLC

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2

DOCKET NOS. 50-334 AND 50-412

1.0 INTRODUCTION

By letter dated May 16, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22137A049), supplemented by letters dated December 7, 2022, (ML22341A614), February 14, 2023 (ML23045A105), Energy Harbor Nuclear Corp. (the licensee) submitted a license amendment request (LAR) to the renewed facility operating licenses numbered DPR-66 and NPF-73 for the Beaver Valley Power Station (Beaver Valley),

Unit Nos.1 and 2, respectively.

The proposed change would revise the Beaver Valley technical specifications (TS) to add limiting condition for operation (LCO) titled Decay Time restricting movement of fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . The current TS restrictions on fuel movement involving fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months appear in the APPLIC ABILITY statements and CONDITIONS of several TS LCOs. These restrictions will be consolidated in a new LCO titled Decay Time, so that decay time assumed in the design basis fuel handling accident (FHA) is maintained.

The supplemental letters provided by Energy Harbor Nuclear Corp on December 7, 2022, and February 14, 2023, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register dated July 15, 2022 (87 FR 42509).

Enclosure 3

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements

The NRC is guided by the considerations that gove rn the issuance of initial licenses to the extent applicable when determining whether an amendment to a license will be issued. The regulatory requirements and guidance which the NRC staff considered in its review of this license amendment request are as follows:

Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2)(ii) of the Technical Specifications, states in part, that:

A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier

Title 10 CFR 50.67, Accident source term. states in part, that:

(i) An individual located at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release, would not receive a radiation dose in excess of 0.25 [Sievert] Sv (25 rem) total effective dose equivalent (TEDE).

(ii) An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage), would not receive a radiation dose in excess of 0.25 Sv (25 rem) total effective dose equivalent (TEDE).

(iii) Adequate radiation protection is provided to permit access to and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5rem) total effective dose equivalent (TEDE) for the duration of the accident.

Appendix A to 10 CFR Part 50 - General Design Criteria [GDC] for Nuclear Power Plants, Criterion 13, Instrumentation and control, states:

Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and

systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the cont ainment and its associated systems.

Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

GDC Criterion 19 - Control room, states:

A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

The regulations in 10 CFR 100.11, Determination of exclusion area, low population zone, and population center distances, describes how to set an exclusion area by requiring an applicant to consider fission release from the core, the containment as well as the meteorological conditions when defining an exclusion area. The exclusion area or a low population zone should be set so that for two hours immediately following a release, a person would not receive a total radiation dose of more than of 25 rem whole body value or 300 rem to the thyroid from iodine exposure.

NUREG-0800, Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Section 15.0.1, Radiological Consequence Analyses Using Alternative Source Terms, Rev. 0, July 2000 provides review guidance to the NRC staff for the review of al ternative source term amendment requests. It states that the NRC reviewer should eval uate the proposed change against the guidance in Regulatory Guide (RG) 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. The dose acceptance criteria for the FHA are a TEDE of 6.3 rem at the exclusion area boundary for the worst two hours, 6.3 rem at the outer boundary of the low population zone for the duration of the accident, and 5 rem in the control room for the duration of the accident.

NUREG-1431, Standard Technical Specifications - Westinghouse Plants, as it relates to the development of standard TS based on the criteria in the Final Commission Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132), which was subsequently codified by changes to 10 CFR 50.36. Licensees are encouraged to upgrade their technical specificati ons consistent with those criteria and conforming, to the extent practical.

RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, Rev. 0, July 2000 provides the methodology for analyzing the radiological consequences of several DBA to comply with 10 CFR 50.67. RG 1.183 provides guidance to licensees on acceptable application of alternate source term submittals, including acceptable radiological analysis assumptions for use in conjunction with the accepted alternate source term.

Commission policy statement, Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132) as it relates to the implementation of improved standard TS expec ted to improve the safety of nuclear power plants using more operator-oriented technical specification, improved technical specification bases, a reduced action statement induced plant tr ansients, and more efficient use of the NRC and industry resources.

The Beaver Valley updated final safety analysis report (UFSAR) for Unit 2 Section 15.7.4, discusses the most severe radiological consequences of an FHA.

2.2 System Description

2.2.1 TS 3.3.6 Containment Purge and Exhaust Isolation Instrumentation

The containment purge and exhaust isolation instrumentation provide controls to close the purge and exhaust system containment isolation valves. Upon receipt of an isolation signal from either manual initiation or high radiation, the containment atmosphere is isolated from the environment to minimize releases of radioactivity in the event of an FHA involving recently irradiated fuel.

The containment purge and exhaust isolation instrument requirements are applicable during movement of recently irradiated fuel assemblies within containment when the potential for the limiting FHA exists. In MODES 1, 2, 3, and 4, containment penetration requirements (including the purge and exhaust isolation valves) are addressed by LCO 3.6.3, Containment Isolation Valves and LCO 3.6.1, Containment OPERABILITY. In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for an FHA does not exist.

2.2.2 TS 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation

The CREVS provides a protected environment for occupants of the main control room following an uncontrolled release of radioactivity. During normal operation, the control room ventilation system recirculates the control room air and provides unfiltered makeup air and cooling. Upon receipt of a CREVs actuation signal from either unit (manual initiation, control room radiation, or containment isolation Phase (B)), Beaver Valley, Units 1 and 2 control room ventilation intake and exhaust ducts are isolated to prevent unfiltered makeup air from entering the control room.

Once the control room ventilation intake and exhaust ducts are isolated, and the CREVS fan provide filtered makeup, control room ventilation in the emergency pressurization mode of operation.

2.2.3 TS 3.7.10 Control Room Emergency Ventilation System (CREVS)

The CREVS provides filtered makeup air to pressurize the main control room following an uncontrolled release of radioactivity. The CREVS consists of pressurization subsystems, the control room envelop (CRE) isolation subsystems, and a CRE boundary that limits the in-leakage of unfiltered air. The CREVS is required to be operable in MODES 1 through 4, and during fuel movement involving recently irradiated fuel. In MODES 5 and 6, when no fuel movement involving recently irradiated fuel is taking place, there are no requirements for CREVS operability consistent with the safety analyses assumptions applicable in these modes.

2.2.4 TS 3.7.11 Control Room Emergen cy Air Cooling System; (CREACS)

The CREACS maintains temperature and humidity conditions for the proper operation of the control room equipment and instrumentation and for the comfort and efficiency of the operating personnel during accident conditions. This is achieved by operating the control room air conditioning system at 100 percent recirculation with (1) a control room heat removal function following isolation of the control room, and (2) control room atmosphere purge capability for the combined units main control room. The heat removal function ensures that the control equipment qualification is maintained following isolation of the control room. The purge function is necessary to limit the dose received by control room personnel following certain design basis accidents(DBAs). The CREACS is required to be operable in MODES 1 through 4, and during fuel movement involving recently irradiated fuel.

2.2.5 TS 3.7.12 Supplemental Leak Coll ection and Release System (SLCRS)

The SLCRS filters airborne radioactivity from the leak collection areas, fuel building, and waste gas storage tank area. Receipt of a high-high activity alarm signal from any of these sources will cause these effluents to pass through a prefilter/charcoal/high efficiency particulate air filter complex in the supplementary leak collection and release system before discharge via the reactor building/SLCRS release point. This ensures that, prior to release to the environment, the exhaust from these areas in the event of an FHA is limited to radioactive releases within 10 CFR 50.67 limits. Since the SLCRS is not credited in any existing DBA analysis applicable in MODES 1 through 6, the SLCRS is not required to be OPERABLE in these MODES, except as required to support fuel movement involving recently irradiated fuel.

2.2.6 TS 3.8.2 AC [alternating current] Sources - Shutdown

The AC power system provides independence and redundancy to ensure power is available to mitigate accidents during shutdown to support emergency systems. The AC sources consist of offsite power source and onsite standby power sources such as diesel generators. The AC sources are needed to provide adequate cooling for fuel assemblies.

2.2.7 TS 3.8.5 DC [direct current] Sources - Shutdown

The DC electrical power system is designed to have independence and redundancy to perform its safety function by providing emergency power. Each of the DC electrical power subsystems consist of two batteries, a battery charger for each battery and the corresponding control equipment. The interconnecting cabling supplying power to the associated bus within the train ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after a postulated accident.

2.2.8 TS 3.8.8 Inverters - Shutdown

The inverters ensure the availability of electrical power for systems required to shut down the reactor and maintain it in a safe condition after a postulated DBA. The function of the inverter is to provide AC electrical power to the vital buses. The inverters are the preferred source of power for the AC vital buses because they provide stability and reliability. The inverters can be powered from an internal AC source, a battery charger or from the station battery.

2.2.9 TS 3.8.10 Distribution Systems

The onsite electrical power distribution systems is divided by train into two redundant and independent AC, DC, and AC vital bus electrical power distribution subsystems. The AC electrical power subsystem for each train consists of two buses and load centers. Each engineered safety feature (ESF) bus has at least one separate and independent offsite source of power as well as a dedicated onsite diesel generator source. Each ESF bus is normally connected to a unit source.

If all offsite sources are unavailable, the onsite emergency diesel generator supplies power to the ESF bus.

2.2.10 TS 3.9.3 Containment Penetrations

The containment penetrations close all potential escape paths during movement of fuel involving recently irradiated fuel in containment to prevent a release of fission products to the environment.

2.2.11 TS 5.5.7 Ventilation Filter Testing Program (VFTP)

TS 5.5.7 establishes a program to implement the required testing of ESF filter ventilation systems for the CREVS and SLCRS. The VFTP specifies maintenance requirements and frequencies, as well as test criteria for the CREVS and SLCRS ventilation systems. Surveillance Requirement (SR) 3.7.10.2 states that required CREVS filter testing in accordance with the VFTP is required. Similarly, SR 3.7.12.2 states that required SLCRS filter testing in accordance with the VFTP is required.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the licensees proposed TS changes to add LCO Decay Time and the current radiological consequences analysis to de termine whether the requested changes meet the requirements of record for a design basis FHA. The NRC staff used the regulations listed in section 2.0 of this safety evaluation (SE) as a guide to determine if operation with the new allowable instrumentation values in the proposed TS Decay Time will provide reasonable assurance that the health and safety of the public is not endangered.

The systems impacted by this proposed change are those that are required during movement of recently irradiated fuel or movement of fuel over recently irradiated fuel. System requirements in MODES or other specified CONDITIONS, beyond re cently irradiated fuel movement conditions, are not affected by this proposed change. The only DBA impacted by this proposed change is the FHA involving movement of fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , that is, recently irradiated fuel.

The Beaver Valley TSs contain APPLICABILITY statements involving movement of recently irradiated fuel, restrictions in various conditions and surveillance notes. However, the TSs do not have an FHA analysis to support movement of recently irradiated fuel. Consequently, the movement of recently irradiated fuel is prohibited and these LCOs are never entered. This situation, as described by the licensee, has led to the performance of the associated TS surveillances representing a burden with no commensurate safety benefit. The licensee also stated that use of the terms recently irradiated fuel and non-recently irradiated fuel has caused confusion and can create potential error traps during operations. The proposed change

would revise the current Beaver Valley TSs to add an LCO titled Decay Time, which would restrict the movement of fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , thereby ensuring decay time assumed in the design basis in an FHA is maintained.

The licensee proposed that adding an LCO, titled Decay Time, which would prohibit movement of recently irradiated fuel would make it unnecessary to have the individual requirements in the affected technical specification LCOs, applic ability statements, conditions, and notes. This change would be consistent with the Commissions Final Policy Statement on technical specification improvements for nuclear power pl ants by streamlining the Beaver Valley TS to provide clearer, more readily understandable requirements that ensure safer operation of the units, while still satisfying the requirements of 10 CFR 50.36.

3.1 Evaluation of Proposed Changes to TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation

The licensee proposed to delete TS 3.3.6 in its entirety. Current TS 3.3.6 applies to Beaver Valley, Unit 2 containment purge and exhaust isolation instrumentation during movement of irradiated fuel. In the event of an FHA involving recently irradiated fuel, Beaver Valley, Unit 2 containment purge and exhaust isolation instrum entation closes the containment isolation valves which isolates the containment atmosphere from the environment to minimize releases of radioactivity.

MODES 1, 2, 3, and 4 containment penetration requirements (including the purge and exhaust isolation valves) are addressed by LCO 3.6.3, Containment Isolation Valves and LCO 3.6.1, Containment Operability, without being changed, so containment penetration requirements are not affected.

TS LCO 3.9.6, Refueling Cavity Water Level in conjunction with the proposed TS 3.9.7, Decay Time, provides a justification for the proposed deletion of TS 3.3.6 when movement of irradiated fuel assemblies within containment is being conducted. Specifically, the refueling cavity water level is required to be maintained greater than or equal to ( ) 23 feet above the top of the reactor vessel flange during fuel movement involving irradiated fuel within containment and a minimum decay time of 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months will be required prior to fuel movement involving irradiated fuel. These two requirements together ensure that the resulting offsite and control room dose resulting from the limiting FHA are within the limits required by the regulatory acceptance criteria without the need for containment purge and exhaust isolation.

The NRC staff finds that the deletion of TS 3.3.6 is acceptable because the function of TS 3.3.6 is to close containment isolation valves involving recently irradiated fuel and the newly proposed TS LCO 3.9.7 will prohibit the movement of fuel involving recently irradiated fuel.

3.2 Evaluation of Proposed Changes to TS 3.3.7, Control Room Emergency Ventilation (CREVS) Actuation Instrumentation.

Current TS LCO 3.3.7 requires that the CREVS actuation instrumentation for each function in Table 3.3.7-1 be operable as applicable according to Table 3.3.7-1. Table 3.3.7-1 lists all the CREVS actuation instrumentation, including:

(1) Manual Initiation during MODES 1, 2, 3, and 4, and footnote (a) During movement of recently irradiated fuel assemblies and during movement of fuel assemblies over recently irradiated fuel assemblies.

(2) Control Room Area Radiation Monitors foot note (a) During movement of recently irradiated fuel and over recently irradiated fuel assemblies.

(3) Containment Isolation Phase B.

Manual initiation is required to be operable in MODES 1 through 4, and during fuel movement involving recently irradiated fuel. The applicable safety analyses for all DBAs considered in MODES 1, 2, 3, and 4, except a loss-of-coolant accident (LOCA), assume manual initiation of the emergency pressurization mode of operation of control room ventilation. A LOCA accident analysis assumes an automatic control room ventilation system isolation on a containment isolation - Phase B signal and subsequent manual initiation of a CREVS fan for filtered makeup and pressurization of the control room. The current safety analyses do not assume the control room area radiation monitors provide a CREVS actuation signal for any DBA.

In the license amendment request, the licensee proposed to delete Table 3.3.7-1 CREVS Actuation Instrumentation, which provides the functions and applicability for CREVS actuation instrumentation in its entirety. The licensees proposed change would only include the manual initiation function with applicability in MODES 1, 2, 3, and 4.

Condition D to LCO 3.3.7 requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The licensees proposal to delete Condition D is acceptable by the NRC staff since the proposed new LCO 3.9.7 ensures that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur.

The licensee is also proposing to delete SR 3.3.7.1, CHANNEL CHECK, SR 3.3.7.2, CHANNEL OPERATIONL TEST, and SR 3.3.7.4 CHANNEL CALIBRATION. Since these SRs are only applicable during fuel movements involving recently irradiated fuel, the NRC staff finds this deletion acceptable considering that the proposed new LCO 3.9.7 ensures that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur.

Manual Function

The NRC staff finds that the proposed new TS LCO 3.9.7 Decay Time, which requires the suspension of fuel movement involving recently irradiated fuel, can be used to justify the deletion of the manual initiation function in TS 3.3.7 related to movement of recently irradiated fuel, because actuation of the CREVS would no longer be required. In the new TS 3.3.7 proposed by the licensee, the manual initiation function to actuate the CREVS during MODES 1, 2, 3, and 4 remains unchanged. Therefore, this portion of the proposed TS LCO 3.3.7 relating to manual initiation in MODES 1, 2, 3, and 4 is acceptable.

Control Room Area Radiation Monitors

Table 3.3.7-1, Function 2 Control Room Area Radiation Monitors, requires control room area radiation monitors to initiate actuation of the CREVS during movement of fuel involving recently irradiated fuel. In the LAR, the licensee stated that the licensee-controlled License Requirement

Manual (LRM) LR 3.3.14, Control Room Isolat ion Radiation Monitors, requires radiation monitors during MODE 1 through 4. LRM LR 3.3.14 remains unchanged. By letter dated February 21, 2007 (ML070160593), Beaver Valley Power Station, Unit Nos. 1 And 2 - Issuance Of Amendment Re: The Conversion To The Improved Technical Specifications With Beyond-Scope Issues, the NRC issued Amendment Nos. 278 and 161 for Beaver Valley, Units 1 and 2, respectively, which provided t he NRC staff safety evaluations explaining why these functions do not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion in the TS and are in the LRM.

The current safety analyses in Chapter 14 of the UFSAR, describes maintaining postulated operator dose results within the regulatory dose acceptance criteria, but does not assume the control room area radiation monitors provide a CREVS actuation signal for any DBA. In addition, the CREVS instrumentation initiation by the control room area radiation monitors is not required to mitigate the consequences of an FHA involving non-recently irradiated fuel. However, when fuel movement involving recently irradiated fuel is taking place, the instrumentation for the CREVS initiation by the control room area radiation monitors is required. The NRC staff found that removing the CREVS initiation by control room area radiation monitors during movement involving recently irradiated fuel acceptable because the proposed TS LCO 3.9.7 prohibits fuel movement involving recently irradiated fuel and, therefore, an FHA involving recently irradiated fuel cannot occur.

Containment Isolation - Phase B

The APPLICABILITY of current TS 3.3.7 controls several engineered safety feature actuation system (ESFAS) signals for the CREVS actuation, including the Containment Isolation -

Phase B (CIB) which signals to actuate the CREVS. The licensee proposed to remove the actuation signal of the CIB from TS 3.3.7. According to the LAR, the CREVS provides the justifications for the removal of this actuation signal from the current TS APPLICABILITY requirements because the CIB actuation signal is redundant to LCO 3.3.2 Engineered Safety Feature Actuation System (ESFAS), Table 3.3.2-1 Function 3.b.

By email dated November 8, 2022 (ML22312A591), the NRC staff sent a request for additional information (RAI) requesting clarification for this redundancy. By letter dated December 7, 2022 (ML22341A614), the licensee responded to the NRC staffs RAI. On December 21, 2022, the NRC held a public meeting with the licensee to discuss and further clarify their response.

Subsequently, by letter dated February 14, 2023 (ML23045A105), the licensee supplemented the application and proposed to retain Table 3. 3.7-1 and remove FUNCTION 2 Control Room Area Radiation, and Footnote (a) During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies over recently irradiated fuel assemblies.

The APPLICABILITY of current TS 3.3.7 requires the CIB as one of the signals to actuate the CREVS. According to TS 3.3.7, when actuating the CREVS, the CIB function states, Refer to LCO 3.3.2, ESFAS Instrumentation, Function 3.b, for all initiation functions and requirements.

This remains unchanged in the proposed TS 3.3.7. Containment Isolation - Phase B, is currently Function 3 in Table 3.3.7-1, and is proposed to be renumbered as Function 2. This change is administrative and therefore the proposed TS LCO 3.3.7 relating to CIB is acceptable.

3.3 Evaluation of Proposed Changes to TS 3.7.10, Control Room Emergency Ventilation System (CREVS)

The licensee proposed to delete the portion of LCO 3.7.10 APPLICABILITY relating to the movement of fuel involving recently irradiated fuel, and associated actions. Currently LCO 3.7.10 requires that CREVS be OPERABLE in MODES 1, 2, 3, and 4 as well as during movement of fuel involving recently irradiated fuel.

Since the proposed TS LCO 3.9.7 requires the suspension of movement of recently irradiated fuel, the NRC staff finds the proposed changes of TS 3.7.10 acceptable because a CREVS involving recently irradiated fuel is no l onger required. The operability requirement for a CREVS in TS 3.7.10 for MODES 1, 2, 3, and 4 and associated actions remain unchanged.

3.4 Evaluation of Proposed Changes to TS 3. 7.11, Control Room Emergency Air Cooling System (CREACS)

Current TS LCO 3.7.11 requires that the CREACS be OPERABLE in MODES 1, 2, 3, and 4 as well as during movement of non-recently irradiated fuel assembly for Beaver Valley, Unit 1, and during movement of fuel involving recently irradiated fuel for Unit 2. The proposed changes delete portions of applicability of LCO 3.7.11 relating to the movement of fuel involving recently irradiated fuel, and associated actions for Unit 2.

Note 2 of Condition C in LCO 3.7.11 is only applicable to Beaver Valley, Unit 2, during movement of recently irradiated fuel assemblies and of fuel assemblies over recently irradiated fuel assemblies. The LAR proposes to delete Note 2 of Condition C since the addition of LCO 3.9.7 will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, and CREACS is not required to mitigate the consequences of an FHA at Unit 2 involving non-recently irradiated fuel.

The NOTE in LCO 3.7.11 states: For Unit 1, the heat removal function of CREACS is not required to be OPERABLE to support fuel movement involving non-recently irradiated fuel assemblies. The LAR proposes to delete, non-recently in the NOTE.

Section 15.7.4 of the Beaver Valley, Unit 2, UFSAR states that the radiological consequences of an FHA and control room purge is not assumed. In a letter dated October 21, 2020, Beaver Valley Power Station, Units 1 And 2 - Correction to Amendment Nos. 305 and 195 Issued September 23, 2020, Re: Modification Of Primary And Secondary Coolant Activity Technical Specifications (ML20285A266), the NRC staff found t hat for an FHA, a control room purge is credited for Unit 1 only and not for Unit 2.

Based on the above, the NRC staff finds the proposed changes to TS 3.7.11 acceptable. The function of TS 3.7.11 for CREACS involving recently irradiated fuel for Unit 2 is no longer required, due to newly proposed TS LCO 3.9.7. The proposed TS LCO 3.9.7 requires the movement of fuel involving recently irradiated fuel be suspended. The operability requirement for CREACS in TS 3.7.11 for MODES 1, 2, 3, and 4 and associated actions remain unchanged.

The applicability for a Unit 1 FHA remains unchanged as described above.

3.5 Evaluation of Proposed Changes to TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS)

The licensee proposes to delete TS 3.7.12, SLCRS, in its entirety. The function of the SLCRS is to filter airborne radioactivity from the Beaver Valley, Unit 1, containment building and the Beaver Valley, Units 1 and 2, fuel buildings following an FHA involving recently irradiated fuel.

This is to ensure that, in the event of an FHA, the exhausted radioactive releases from these areas is within 10 CFR 50.67 limits. Since the SLCRS is not credited in any existing DBA analysis applicable in MODES 1 through 6, the SLCRS is not required to be operable in these MODES, except as required to support fuel movement involving recently irradiated fuel.

The SLCRS may be used for normal as well as post-accident atmospheric cleanup functions and provides ventilation and heat removal functions to the areas it serves. In a letter dated February 21, 2007, Beaver Valley Power Station, Unit Nos. 1 And 2 - Issuance of Amendment Re: The Conversion to The Improved Technical Specifications with Beyond-Scope Issues (ML070160593), the NRC staff states these functions do not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion in the technical specifications and therefore are in the LRM. These atmospheric cleanup actions are ensured by the Unit 1 and Unit 2 LRM LC 3.7.7, which requires SLCRS operability in MODES 1 through 4 and are not affected by the proposed change.

Current TS LCO 3.7.12 specifies that one SLCRS train shall be OPERABLE and in operation.

The applicability of this LCO occurs (1) during movement of fuel involving recently irradiated fuel and (2) when required in accordance with LCO 3.9.3.c.3 (Unit 1 only). LCO 3.9.3.c.3 states that the containment purge and exhaust system penetrations may be open when the system airflow is exhausted to an operable filtered supplement leak collection and release train. The proposed change is to delete TS 3.7.12, SLCRS, in its entirely.

The licensees proposed deletion of the statement regarding movement of recently irradiated fuel is acceptable because the newly proposed TS LCO 3.9.7 prohibits the movement of recently irradiated fuel. The proposed deletion of the reference to LCO 3.9.3.c.3 is acceptable because LCO 3.9.3, Containment Penetrations is also proposed to be deleted. LCO 3.9.3.c.3 is no longer required as discussed in Section 3.7 of this SE relating to the containment penetrations in refueling operation. Therefore, the NRC staff finds the proposed deletion of the entire TS 3.7.12 acceptable because the new TS LCO 3.9.7 will prohibit the movement of recently irradiated fuel.

3.6 TS 3.8.2, AC Sources - Shutdown

The licensee proposes to delete the APPLICABILITY of LCO 3.8.2 during the movement of fuel assemblies in Beaver Valley, Unit 2. AC sources are not required to mitigate the consequences of an FHA involving non-recently irradiated fuel at Unit 2. AC sources are only required to be operable in shutdown mode and during fuel movement involving fuel that has decayed at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months is taking place at Unit 1.

Since the proposed addition of LCO 3.9.7 will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur, and AC sources-shutdown are only required in shutdown mode and during fuel movements involving irradiated fuel in Unit 1.

The addition of the proposed LCO 3.9.7, Decay Time, will make it unnecessary for AC sources to be operable during fuel movement of recently irradiated fuel in Unit 2. Therefore, deletion of REQUIRED ACTION A.2.3 is acceptable and Required Actions A.2.4 and A.2.5 will be renumbered accordingly. Required Action B.3 re quires the immediate suspension of movement of recently irradiated fuel assemblies and therefore, deletion of Required Action B.3 is acceptable. The AND preceding Required Action B.3 is deleted and Required Actions B.4 and B.5 are renumbered accordingly.

TS 3.8.2 is required to be operable in MODES 4 and 6, during fuel movement in Unit 1, and if fuel movement involving recently irradiated fuel is taking place in Unit 2. The proposed addition of LCO 3.9.7, Decay Time, makes it unnecessary for AC sources to be operable during fuel movement involving recently irradiated fuel at Unit 2.

For these reasons, the staff finds that the proposed changes to LCO 3.8.2 are consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii) and are therefore acceptable.

3.7 TS 3.8.5, DC Sources - Shutdown

The licensee proposes to delete the APPLICABILITY of LCO 3.8.5 during the movement of fuel assemblies in Beaver Valley, Unit 2.

Currently, LCO 3.8.5 requires DC sources to be operable in shutdown modes, during fuel movement in Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. The DC electrical power system provides normal and emergency DC power for the AC emergency power system during all modes of operation. DC Sources are not required to mitigate the consequences of an FHA involving fuel that has decayed at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months in Unit 2.

The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel and will ensure that movement of recently irradiated fuel assemblies does not occur, making the need for this Required Action A.2.3 unnecessary. Therefore, deletion of Required Action A.2.3 is acceptable and Required Actions A.2.4 and A.2.5 are renumbered accordingly.

DC sources (TS 3.8.5) are only required to be operable in shutdown modes, during fuel movement in Beaver Valley, Unit 1, and if fuel movement involving recently irradiated fuel is taking place in Unit 2. The proposed addition of LCO 3.9.7, Decay Time, makes it unnecessary for AC sources to be operable during fuel movement involving recently irradiated fuel at Unit 2.

For these reasons, the staff finds that the proposed changes to LCO 3.8.5 are consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii) and are therefore acceptable.

3.8 TS 3.8.8, Inverters - Shutdown

The licensee proposed to delete the APPLICABILITY of LCO 3.8.8 during the movement of fuel assemblies in Beaver Valley, Units 1 and 2.

Currently, LCO 3.8.8 requires that the inverters are only required to be operable in shutdown modes and during fuel movement in Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. The inverters are not required to mitigate the consequences of a Unit 2 FHA, involving non-recently irradiated fuel. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot

occur and the inverters are only required in shutdown modes, and during fuel movements involving irradiated fuel at Unit 1.

The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel in Unit 2, making this Required Action A.2.3 unnecessary. Therefore, deletion of Required Action A.2.3 is acceptable and Required Actions A.2.4 and A.2.5 are renumbered accordingly.

TS 3.8.8 is only required to be operable in MODES 5 and 6, during fuel movement in Unit 1, and if fuel movement involving recently irradiated fuel is taking place in Unit 2. The proposed addition of LCO 3.9.7, Decay Time, obviates the need for AC sources to be operable during fuel movement involving recently irradiated fuel at Unit 2.

For these reasons, the staff finds that the proposed changes to LCOs 3.8.2, 3.8.5, 3.8.8 and 3.8.10 are consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii) and are therefore acceptable.

3.9 TS 3.8.10, Distribution Systems - Shutdown

The licensee proposed to delete the APPLICABILITY of LCO 3.8.8 during the movement of fuel assemblies in Beaver Valley, Unit 2.

The inverters are only required to be operable in MODES 5 and 6, during fuel movement at Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. The inverters are not required to mitigate the consequences of a Unit 2 FHA involving non-recently irradiated fuel.

Since the proposed LCO 3.9.7, Decay Time, eliminates the need for AC sources-shutdown, DC sources-shutdown, inverters-shutdown, and distribution systems - shutdown, to be operable during fuel movement involving recently irradiated fuel at Unit 2, the new LCO 3.9.7 will prohibit fuel movement involving recently irradiated fuel, so an FHA involving recently irradiated fuel cannot occur.

The electrical distribution systems are only required to be operable in shutdown modes, during fuel movement at Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. The electrical distribution systems are not required to mitigate the consequences of a Unit 2 FHA involving non-recently irradiated fuel.

The onsite AC emergency power system includes power supplies, a distribution system, and load groups arranged to provide AC power to Class 1E loads. The system has two 4,160 V, three phase, 60 Hz diesel-driven synchronous generators. The two generator sets are electrically and physically isolated from each other.

The AC Sources (TS 3.8.2), DC sources (TS 3.8.5), Inverters (TS 3.8.8) and Distribution Systems (TS 3.8.10) are only required to be operable in MODES 5 and 6, during fuel movement in Beaver Valley, Unit 1, and if fuel movement involving recently irradiated fuel is taking place in Unit 2. The proposed addition of LCO 3.9.7, Decay Time, obviates the need for AC sources to be operable during fuel movement involving recently irradiated fuel at Unit 2. For these reasons, the staff finds that the proposed changes to LCOs 3.8.2, 3.8.5, 3.8.8 and 3.8.10 are consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii) and are therefore acceptable.

3.10 Evaluation of Proposed Changes to TS 3.9.3, Containment Penetrations

The licensee proposed to delete TS 3.9.6 Refueling Cavity Water Level in its entirely. TS 3.9.3 provides the requirements for containment penetrations in refueling operations during movement of fuel assemblies involving recently irradiated fuel.

The NRC staff finds the proposed changes to delete TS 3.9.3 acceptable because the function of TS 3.9.3 is to isolate containment penetrations for an FHA in refueling operation. The applicability of this TS is during movement of fuel assemblies involving recently irradiated fuel.

This function is no longer required, because the newly proposed TS LCO 3.9.7 requires the movement of fuel involving recently irradiated fuel be suspended.

3.11 Evaluation of Proposed Changes to TS 5.5.7, Ventilation Filter Testing Program (VFTP)

The licensee proposed to remove all the portions of the VFTP testing and maintenance requirements for the SLCRS, and the requirements relating to the CREVS are not affected.

TS 5.5.7, Ventilation Filter Testing Program (VFTP), implements the required testing of ESF filter ventilation systems for the CREVS and SLCRS. The VFTP specifies maintenance requirements and frequencies, as well as test criteria for the CREVS and SLCRS ventilation systems. SR 3.7.10.2 states that required CREVS filter testing in accordance with the VFTP is required. Similarly, SR 3.7.12.2 testing states that required SLCRS filter testing in accordance with the VFTP is required. The VFTP is to address the requirements of SR 3.7.10.2 and SR 3.7.12.2

The NRC staff finds the proposed changes which remove testing and maintenance requirements associated with SLCRS acceptable because TS 3.7.12, which addresses SLCRS operability, will be deleted. Such deletion has been found to be acceptable as discussed in Section 3.5 of this SE, which discusses the SLCRS.

3.12 Evaluation - General Design Criteria for Nuclear Power Plants, Criterion 13, Instrumentation and control

The NRC staff reviewed the LAR and the supplement against GDC 13. Based on the NRC staffs review, the proposed changes provide the instrumentation to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and t he containment and its associated systems.

Additionally, the proposed changes provide appropriate controls to maintain these variables and systems within prescribed operating ranges. The NRC staff also reviewed the USFAR, with the LAR and the supplement and determined the proposed changes are consistent with the current design basis. Therefore, the NRC staff conclude s the proposed changes meet the requirements of GDC 13.

3.13 Evaluation of GDC 19 Control Room

The NRC staff reviewed the LAR and the supplemental letters against GDC 19. Based on the staff review, the proposed changes continue to provide a control room from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a

safe condition under accident conditions, including loss-of-coolant accidents. Additionally, the proposed changes provide adequate radiation protection to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem for the whole body, or its equivalent to any part of the body, for the duration of the accident. The NRC staff also reviewed the USFAR, with the LAR and the supplement and determined the proposed changes are consistent with the current design basis. Therefore, the NRC staff concludes the proposed changes meet the requirements of GDC 19.

3.14 Evaluation of Proposed New TS 3.9.7, Decay Time

The regulations in 10 CFR 50.36(c)(2)(ii)(B) require that TS LCOs be established for a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The current Beaver Valley TS refers to recently irradiated fuel as well as non-recently irradiated fuel. Non-recently irradiated fuel is fuel that has not occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months .

The Beaver Valley TS have applicability statements involving movement of recently irradiated fuel as well as restrictions in various conditi ons and surveillance notes. However, Beaver Valley does not have an FHA analysis to support movement of recently irradiated fuel, and therefore, the movement of recently irradiated fuel is prohibited and these LCOs are never entered. This situation, as described by the licensee, has led to the performance of the associated TS SRs, which represent a burden for the licensee with no commensurate safety benefit. The licensee also stated in the LAR that use of the terms recently irradiated fuel and non-recently irradiated fuel has caused confusion and can create potential errors during operations. The proposed change would revise the Beaver Valley TSs to add TS 3.9.7 called Decay Time restricting movement involving fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . Proposed TS 3.9.7 Decay Time states the following:

LCO 3.9.7 The reactor shall be subcritical for 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months .

APPLICABILITY: During movement of irradiated fuel assemblies within containment, During movement of fuel assemblies over irradiated fuel assemblies within the containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.Reactor subcritical< A.1 Suspend movement of Immediately 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . irradiated fuel assemblies within containment.

AND

A.2 Suspend movement of fuel Immediately assemblies over irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY SR The reactor shall be determined to have been Prior to movement 3.9.7.1 subcritical for at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months by verification of the of irradiated fuel date and time of subcriticality. assemblies within containment

As documented in the Beaver Valley UFSAR, the analysis of record for the radiological consequences of the DBA FHA confirms the LCOs statement that the reactor is required to be subcritical for greater than or equal to 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months to ensure that the radiological consequences of a postulated FHA inside containment are within acceptable limits as provided by 10 CFR Part 100.

LCO 3.9.7 APPLICABILITY states that this TS is applicable during movement of irradiated fuel assemblies within containment and during movement of fuel assemblies over irradiated fuel assemblies within the containment. The NRC staff found the APPLICABLITY statement acceptable since the proposed change would restrict movement involving fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . This would ensure that the decay time assumed in the design basis FHA is maintained.

LCO Condition A requires that when the reactor is subcritical for less than 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , all movement of irradiated fuel within the containment and movement of fuel assemblies over irradiated fuel within containment must be suspended immediately. The staff found the LCO Condition A acceptable since the fuel movement involving irradiated fuel within containment is prohibited per the TS, during the first 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months following reactor shutdown.

The LCO SR 3.9.7.1 requires that the reactor must be found to have been subcritical for at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months by verifying the date and time of subcriticality prior to movement of irradiated fuel assemblies within containment. The NRC staff reviewed Beaver Valley UFSAR, Section 15.7.4, which discusses the most severe radiological consequences of an FHA and found the SR 3.9.7.1 and its associated frequency acceptable, since the LCO prohibits the movement of irradiated fuel within containment and movement of fuel assemblies over irradiated fuel within containment during the first 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months following reactor shutdown. Also, the frequency of prior to movement of irradiated fuel in the reactor core would ensure operation within the design basis assumption for decay time.

Section 3.0 of this SE provides the NRC staffs evaluation for specific changes to systems impacted by the proposed addition of the LCO 3.9.7. The LCOs associated with these systems specify requirements for the movement of recently irradiated fuel or movement of fuel over recently irradiated fuel. The NRC staffs evaluation shows that these requirements in modes or other specified conditions, beyond recently irradiated fuel movement conditions, are not affected by the proposed changes. The NRC staffs evaluation further shows that the addition of LCO 3.9.7 prohibits movement of recently irradiated fuel and precludes the need for the individual requirements in the affected technical specification LCOs, applicability statements, conditions, and notes. In addition, the proposed change would be consistent with the

Commissions Final Policy Statement on technica l specification improvements for nuclear power plants to streamline the Beaver Valley, Units 1 and 2, TS to provide clearer, more readily understandable requirements to ensure safer operation of the units, while still satisfying the requirements of 10 CFR 50.36.

3.15 Technical Conclusion

The NRC staff reviewed the assumptions, inputs, and methods used by the licensee to assess the radiological impacts of the proposed change s. The NRC staff finds that the licensee analysis of record, methods, and assumptions continue to be consistent with the guidance contained in RG 1.183. The NRC staff finds with reasonable a ssurance that the Beaver Valley technical specification, as modified by this proposed change, will continue to provide sufficient safety margins with adequate defense-in-depth to address unanticipated events and to compensate for uncertainties in accident progression and in analysis assumptions and parameters. The NRC staff concludes that the licensee has demonstrated that the radiological consequences for postulated accidents at Beaver Valley would not have consequences that could potentially exceed the applicable 10 CFR 100.11 and 10 CFR 50.67 criteria and RG 1.183 regulatory dose acceptance criteria. Therefore, the NRC staff finds the proposed changes to be acceptable from a dose consequence perspective.

Based on the above justification, the NRC staff finds the addition of LCO 3.9.7 in Beaver Valley, Units 1 and 2, TSs acceptable since it would ensure the FHA analysis initial condition of 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months minimum fuel decay time is maintained. Therefore, the TSs as modified by the inclusion of LCO 3.9.7, meet the Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B).

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Commonwealth of Pennsylvania official was notified of the proposed issuance of the amendments on April 28, 2023. The official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

These amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 or, these same amendments change SRs. The NRC staff has determined that these amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that these amendments involve no significant hazards consideration, as published in the Federal Register dated July 15, 2022 (87 FR 42509), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

Principal Contributors: B. Lee C. Cheung E. Dickson H. Kodali R. Grover

Date of Issuance: May 22, 2023

ML23102A147 *by memorandum OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DRA/ARCB NAME SGoetz KZeleznock KHsueh DATE 04/12/2023 04/14/2023 03/29/2023 OFFICE NRR/DEX/EICB/BC NRR/DSS/SCPB/BC NRR/DSS/SFNB/BC*

NAME MWaters BWittick SKrepel DATE 04/10/2023 04/11/2023 03/29/2023 OFFICE NRR/DSS/STSB/BC NRR/DEX/EEEB OGC - NLO NAME VCusumano WMorton MCarpentier DATE 04/07/2023 04/11/2023 05/04/2023 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME HGonzalez (MMarshall for) SGoetz DATE 5/19/2023 5/22/2023

v t e Letter Sequence Approval
EPID:L-2020-LLA-0071, Request for Exemption from Specific Provisions in 10 CFR 50 Appendix H (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other: ML20105A465
MONTHYEAR2020-04-20 [Table View]

ML23102A147

Text

SUBJECT:

Dear Mr. Blair:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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