View source for L-03-135, Withdrawal of the Containment Conversion Portion (Phase 2) of License Amendment Request Nos. 300 and 172

{{Adams
| number = ML032541026
| issue date = 09/05/2003
| title = Withdrawal of the Containment Conversion Portion (Phase 2) of License Amendment Request Nos. 300 and 172
| author name = Pearce L
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000334, 05000412
| license number = DPR-066, NPF-073
| contact person = 
| case reference number = L-03-135
| document type = Letter type:L
| page count = 6
| project = 
| stage = Withdrawal
}}

=Text=
{{#Wiki_filter:FENOC                                                                                   Beaver Valley Power Station Route   168 PO. Box 4 fw           lNudear Opetating Company                                                    Shippingport. PA 15077-0004 L. William Pearce                                                                            724-682-5234 Site Vice President                                                                    Fax: 724-643-8069 September 5, 2003 L-03-135 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

==Subject:==
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50412, License No. NPF-73 Withdrawal of the Containment Conversion Portion (Phase 2) of License Amendment Request Nos. 300 and 172 On June 5, 2002, by letter L-02-069, FirstEnergy Nuclear Operating Company (FENOC) submitted License Amendment Request (LAR) Nos. 300 (Unit 1) and 172 (Unit 2). This LAR requested revisions to the Beaver Valley Power Station (BVPS) Technical Specifications that would permit each of the BVPS units to be operated with an atmospheric containment. The submittal also proposed changes to the Control Room Habitability Technical Specifications and requested approval of the selective implementation of the Alternative Source Term Methodology of Regulatory Guide 1.183 "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors."
On March 31, 2003, by letter L-03-038, FENOC submitted a proposed phased approach for implementation of the requested amendments. Phase 1 of the implementation plan requested approval of changes to the Control Room Habitability Technical Specifications and the selective implementation of the Alternative Source Term Methodology. The NRC staff has indicated that amendments approving these changes will be issued in the near future. Phase 2 of the plan would have requested approval of the remaining changes submitted in L-02-069 such that each BVPS unit could be operated with an atmospheric containment.
This letter withdraws the Technical Specifications changes, including the applicable regulatory commitments proposed for Phase 2, the containment conversion portion, of LAR Nos. 300 (Unit 1) and 172 (Unit 2). The Phase 2 changes are those proposed in L-02-069, except those listed as applicable to Phase 1 in FENOC letter L-03-038.
Attachment A provides a listing and discussion of the proposed technical specification changes being withdrawn by this letter. Attachment B provides a status of all of the regulatory commitments made in LAR Nos. 300 and 172 and their supplemental

Beaver Valley Power Station, Unit No. 1 and No. 2 Withdrawal of the Containment Conversion Portion (Phase 2) of LAR Nos. 300 & 172 L-03-135 Page 2 submittals. This withdrawal is being made because the containment conversion portion of the LAR was based on WCAP-15844, Revision 0, Westinghouse Proprietary Class 2, March 2002, "Topical Report on the MAAP5 PWR Large Dry Containment Model,"
which has been withdrawn from NRC review by Westinghouse.
On August 5, 2003, FENOC met with the NRC staff to discuss the going forward plans for containment conversion at BVPS. FENOC documented the topics discussed at the meeting in FENOC letter L-03-127, dated August 22,2003.
No new commitments are contained in this submittal. If there are any questions concerning this matter, please contact Mr. Larry R. Freeland, Manager, Regulatory Affairs/Performance Improvement at 724-682-5284.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September *1.2003.
ncerely, L. William Pearce Attachments:
A. Proposed Technical Specification Changes Being Withdrawn B. Commitment Status c:    Mr. T. G. Colburn, NRR Senior Project Manager Mr. D. M. Kern, NRC Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

Attachment A Proposed Technical Specification Changes Being Withdrawn The following provides a description of the containment conversion related technical specification changes proposed by FENOC letter L-02-069 being withdrawn by this letter.
Change No. la (Units 1 & 2)
Technical Specification 3.3.2.1, Engineered Safety Features Actuation System Instrumentation, would have been revised by changing the allowable values for containment pressure high, containment pressure high-high, and containment pressure intermediate high-high (items l.c, 2.c, 3.b.3 and 4.c) in Table 3.3-3.
Change No. lb (Units 1 & 2)
Table 3.3-3, Engineered Safety Feature Actuation System Instrumentation, would have been revised by changing the allowable values for Refueling Water Storage Tank Level-Low (Unit 1, item I. .c) and Refueling Water Storage Tank Level-Extreme Low (Unit 2, item l.l.b).
Change No. lc (Unit 1 change only)
Table 3.3-3, item 1.l.d "Refueling Water Storage Tank Level - Auto QS Flow Reduction" would have been deleted from the table along with the associated surveillance requirements for this function in Table 4.3-2.
Change No. 2 (Units 1 & 2)
Technical Specification 3.6.1.3, Containment Air Locks, would have been revised by changing the value for Pa in Surveillance Requirement 4.6.1.3. Pa is the peak calculated containment internal pressure for the design basis loss of coolant accident (LOCA).
A corresponding change would have been made to Technical Specification 6.17, Containment Leakage Rate Testing Program. The Unit 1 value for Pa would have been revised from 40.0 psig to 42.5 psig and the Unit 2 value would have been revised from 44.7 psig to 43.4 psig.
Change No. 3 (Units 1 & 2)
Technical Specification 3.6.1.4, Internal Pressure, would have been revised by replacing the air partial pressure requirement with a containment total air pressure requirement of 2 12 psia and < 16 psia. This change would have eliminated the need for Figure 3.6-1.
The word "primary" would have also been removed from the containment description.
Change No. 4 (Units 1 & 2)
Technical Specification 3.6.1.5, Air Temperature, for containment average air temperature would have been revised to replace the existing average air temperature requirement based on Figure 3.6-1 with an average air temperature range of 2 70'F and
 < 105lF. In addition, surveillance requirement (SR) 4.6.1.5 would have been revised by relocating the specific temperature sensor location details for determining containment average air temperature to the TS Bases. The word "primary" would have been removed from the containment description.

Attachment A (continued)
L-03-135 Change No. 6 (Unit 1 only)
Technical Specification 3.6.2.3, Chemical Addition System, would have been revised by deleting surveillance requirement 4.6.2.3.d.4 which verifies that one of the two operating chemical addition pumps in each subsystem will stop following closure of the cut back control valve.
Change No. 7 (Units 1 & 2)
Technical Specification 3.6.3.1, Containment Isolation Valves, would have been revised to delete surveillance requirements 4.6.3.1.1.a.2 and 4.6.3.1.2.e and make minor format changes to surveillance requirement 4.6.3.1.1 as a result of these deletions. This change would have removed the requirement to cycle each spring or weight loaded containment isolation valve and verify that the valve remains closed with < 1.2 psid differential pressure across the valve and opens when the differential pressure is > 1.2 psid but < 6.0 psid.
Change No. 8 (Unit 2 only)
Technical Specification 3.6.4.2 for the Electric Hydrogen Recombiners would have been revised by changing the hydrogen recombiner system flow requirement in surveillance requirement 4.6.4.2 from 42 scfm to 50 scfm.
The following provides a description of the containment conversion related technical specification changes proposed by FENOC -letter L-02-069 that were previously withdrawn.
Change No. 5 (Units 1 & 2)
Technical Specification 3.6.2.2 for the containment recirculation spray system would have been revised by reducing the required recirculation spray heat exchangers minimum river/service water flow in surveillance requirement 4.6.2.2.e.3. For Unit 1 the minimum river water flow would have been changed from 8,000 gpm to 7,800 gpm. For Unit 2 the minimum service water flow would have been changed from 11,000 gpm to 10,600 gpm.
These changes have been previously withdrawn by FENOC letter L-03-044, dated March 19, 2003.

Attachment B Commitment Status The following table provides a listing and status of the commitments made in FENOC letters L-02-069, L-02-115, L-03-022, L-03-038 and L-03-044.
COMMITMENT                                 SOURCE/STATUS
: 1. The Emergency Operating Procedures will be            Commitment from L-02-069.
provided with guidance that, for small break LOCAs, manual actions are required to initiate      Being withdrawn.
the containment depressurization system prior to reaching the RWST automatic transfer to recirculation setpoint.
: 2. The installation and testing of cavitating venturi  Commitment from L-02-069.
flow elements in the Unit 1 Auxiliary Feedwater     Being withdrawn.
System will be completed prior to implementation of the approved amendment.
: 3. The installation and testing of new Main            Commitment from L-02-069.
Feedwater Isolation Valves in Unit 1 will be completed prior to implementation of the            Beig withdrawn.
approved amendment.
: 4. A maximum linear heat generation rate limitation    Commitment from L-02-069.
of 6.3 kW/ft peak rod average power for bum-ups     Will be completed prior to exceeding 54 GWDIMTU will be incorporated           implementation of Phase I of into future BVPS core designs to support            LARs 300 and 172.
assumptions for core gap release fractions used in the CREA radiological analysis. This design constraint will be reflected in the BVPS Core Design and Fuel Cycle Implementation Administrative Procedure.
: 5. A review of the training simulators for the         Commitment from L-02-069.
containment conversion will be conducted and        Being withdrawn.
revalidation, in accordance with ANSI/ANS 3.5-1985, will be completed by the next regularly scheduled benchmarking following implementation.
: 6. FENOC will provide, under a separate submittal,     Commitment from L-02-069 marked-up UFSAR pages reflecting the                and L-02-115.
necessary changes associated with the conversion     Completed by FENOC letter to an atmospheric containment.                      L-03 -022.

Attachment B (continued)
L-03-135 COMMITMENT                               SOURCE/STATUS
: 7. FENOC will provide, under a separate submittal,   Commitment from L-02-069.
a requested implementation schedule and details   Completed by FENOC letter concerning our containment conversion             L-03-038.
implementation plan.
: 8. Incorporate the necessary Unit 1 containment      Commitment from L-03-022.
conversion related UFSAR changes.                 Phase 1 related UFSAR changes to be completed following implementation of Phase 1 amendment.
Phase 2 related UFSAR changes being withdrawn.
: 9. Incorporate the necessary Unit 2 containment      Commitment from L-03-022.
conversion related UFSAR changes.                 Phase I related UFSAR changes to be completed following implementation of Phase I amendment.
Phase 2 related UFSAR changes being withdrawn.
: 10. FENOC will submit a revision to the                Commitment from L-03-038.
Containment Conversion Licensing Report that      Being withdrawn.
reflects resolution of the NRC concerns regarding the MAAP5 code.
: 11. FENOC will determine the need for NRC review Commitment from L-03-038.
and approval of any UFSAR changes necessitated Being withdrawn.
by the revised Containment Conversion Licensing Report and, if necessary, provide the UFSAR changes accordingly.
: 12. Change the recirculation spray heat exchanger      Commitment from L-03-044.
minimum flow rate in the Unit 1 UFSAR to          Being withdrawn.
reflect the Unit 1 flow rate proposed in FENOC letter L-02-069, dated June 5, 2002.
: 13. Change the recirculation spray heat exchanger      Commitment from L-03-044.
minimum flow rate in the Unit 2 UFSAR to reflect the Unit 2 flow rate proposed in FENOC    Beig withdrawn.
letter L-02-069, dated June 5, 2002.}}