ML14133A069

Beaver Valley Power Station, Units 1 and 2 - Request for Additional Information License Amendment Request to Adopt Technical Specifications Task Force Traveler 425 (TAC Nos. MF2942 and MF2943)

ML14133A069
Person / Time
Site:	Beaver Valley
Issue date:	06/03/2014
From:	Whited J A Plant Licensing Branch 1
To:	Larson E A FirstEnergy Nuclear Operating Co
Whited J A, NRR/DORL/LPLI-2
References
TAC MF2942, TAC MF2943
Download: ML14133A069 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 3, 2014 Mr. Eric A. Larson, Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 SUBJECT: BEAVER VALLEY POWER STATION, UNITS 1 AND 2-REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 425 (TAC NOS. MF2942 AND MF2943) Dear Mr. Larson: By letter dated October 18, 2013, FirstEnergy Nuclear Operating Company (the licensee) submitted a license amendment request for Beaver Valley Power Station, Units 1 and 2 (BVPS). The proposed amendment would modify the BVPS Technical Specifications by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." To complete its review, the Nuclear Regulatory Commission staff requests a response to the enclosed questions. The draft questions were sent to Mr. Thomas Lentz, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Please respond to the enclosed questions within 30 days of the date of this letter. If you have any questions regarding this matter, please contact me at 301-415-4090. Docket Nos. 50-334 and 50-412 Enclosure: Request for Additional Information cc w/encl: Distribution via Listserv Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO AN AMENDMENT TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER 425 TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE-CONTROLLED PROGRAM BEAVER VALLEY POWER STATION. UNITS 1 AND 2 DOCKET NOS. 50-334 AND 50-412 By letter dated October 18, 2013,1 FirstEnergy Nuclear Operating Company (the licensee) submitted a license amendment request (LAR) for Beaver Valley Power Station, Units 1 and 2 (BVPS). The proposed amendment would modify the BVPS technical specifications by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies."2 To complete its review, the Nuclear Regulatory Commission (NRC) staff requests a response to the questions below. RAI 1: The finding pertaining to IF-D5-01, located in Table 2 of Enclosure B of the LAR, observes that the licensee uses outdated Internal Flooding Pipe and Tank Break frequencies for their Internal Flood (IF) assessment. The peer review team suggested that the licensee should update this Surveillance Requirement (SR) "to reflect more recent experience and should include plant specific experience." The licensee addressed this by stating that the latest IF model and focused peer review supersedes this finding and that the resolution is documented. Please describe the result of this SR in the updated PRA model and focused peer review and its associated resolution. RAI 2: The finding pertaining to IF-D5-02, also located in Table 2 of Enclosure B of the LAR, observes that the licensee uses generic capacity factor data, which lowers the Initiating Event Frequency (IEF) and causes inconsistent IF IEFs for pipe break. The peer review team suggested that "the calculation for IF IEF be revised to be consistent with the focused Peer Review Facts and Observations (F&Os) as well as with the method used for other IEFs." The licensee addressed this by stating that the latest IF model and focused peer review supersedes this finding and that the resolution is documented. Please describe the result of this SR in the updated PRA model and focused peer review and its associated resolution. 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13295A006. 2 ADAMS Accession No. ML071360456. Enclosure

-2 -RAI 3: Please describe, in more detail, how fire and seismic events will be assessed in terms of the NEI 04-10 guidance. The licensee discusses the use of a Seismic and Fire PRA in Section 3.0, "External Events Considerations," of Enclosure C of the LAR, and states that it has not been peer reviewed. However, the licensee indicated that they plan to use these models to quantify Surveillance Test Interval changes. NEI 04-10 states, in part, that "Plants implementing TSTF-425 shall evaluate their PRAs in accordance with [Regulatory Guide (RG) 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 13]." The statements made in the submittal indicated that the fire and seismic portions of the BVPS PRA have not been assessed against the PRA Standard referenced in RG 1.200, Revision 2.4 For fire and seismic external events, please explain whether a qualitative or bounding (step 1 0), or detailed risk analyses (step 11) described in the NEI 04-10 guidance will be used. It should be noted that the PRA model for step 11 should meet the technical adequacy of RG 1.200, Revision 2. RAI 4: In the F&O related to SY-81, located in Table 2 of Enclosure C of the LAR, the licensee resolved the peer review teams' unmet finding by using a different source of information than what was prescribed in the American Society of Mechanical Engineers (ASME) Sb-2005, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," PRA standard (ASME PRA Standard). The licensee further states that Westinghouse Commercial Atomic Power (WCAP)-16672-P was used because it "addressed the concerns that were raised regarding the consistency and correctness of the CCF [common-cause failure] events included in the NRC CCF database." Please provide the points of deviation between the WCAP and NUREG/CR-5497 and their potential impact on the risk result. RAI 5: The submittal highlights the licensee's PRA model changes and peer reviews against the ASME PRA standard. The ASME PRA Standard and RG 1.200, Revision 2 clarify the definition of a model update versus an upgrade. Please provide clarification on the model changes as to whether they were updates or upgrades. RAI 6: The licensee discusses all of the PRA model changes and subsequent peer reviews in the submittal but does not provide any information regarding the resolution of the F&Os that were considered to be documented. Please provide those applicable F&Os and their resolution. 3 ADAMS Accession No. ML070240001. 4 ADAMS Accession No. ML090410014.

Mr. Eric A. Larson, Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 June 3, 2014 SUBJECT: BEAVER VALLEY POWER STATION, UNITS 1 AND 2-REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 425 (TAC NOS. MF2942 AND MF2943) Dear Mr. Larson: By letter dated October 18, 2013, FirstEnergy Nuclear Operating Company (the licensee) submitted a license amendment request for Beaver Valley Power Station, Units 1 and 2 (BVPS). The proposed amendment would modify the BVPS Technical Specifications by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." To complete its review, the Nuclear Regulatory Commission staff requests a response to the enclosed questions. The draft questions were sent to Mr. Thomas Lentz, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Please respond to the enclosed questions within 30 days of the date of this letter. If you have any questions regarding this matter, please contact me at 301-415-4090. Docket Nos. 50-334 and 50-412 Enclosure: Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION: PUBLIC RidsAcrsAcnw_MaiiCTR Resource RidsNrrPMBeaverValley Resource JEvans, NRR ADAMS Accession No.: ML 14133A069 Sincerely, IRA/ Jeffrey Whited, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation LPLI-2 R/F RidsNrrDoriDpr Resource RidsNrrLAABaxter Resource *via e-mail RidsRgn1 MaiiCenter Resource RidsNrrDorllpl1-2 Resource RidsNrrDraApla Resource OFFICE LPLI-2/PM LPLI-2/LA APLNBC LPLI-2/BC LPLI-2/PM NAME JWhited ABaxter

• HHamzehee* MKhanna JWhited DATE 06/03/14 05/16/14 06/03/14 06/03/14 06/03/14 OFFICIAL RECORD COPY