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| | number = ML16071A122 | | | number = ML16071A122 |
| | issue date = 04/07/2016 | | | issue date = 04/07/2016 |
| | title = Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (CAC Nos. MF3301 and MF3302) | | | title = Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 |
| | author name = Lamb T A | | | author name = Lamb T |
| | author affiliation = NRC/NRR/DORL/LPLI-2 | | | author affiliation = NRC/NRR/DORL/LPLI-2 |
| | addressee name = Richey M L | | | addressee name = Richey M |
| | addressee affiliation = FirstEnergy Nuclear Operating Co | | | addressee affiliation = FirstEnergy Nuclear Operating Co |
| | docket = 05000334, 05000412 | | | docket = 05000334, 05000412 |
| | license number = DPR-066, NPF-073 | | | license number = DPR-066, NPF-073 |
| | contact person = Taylor L A, NRR/DORL/LPL1-2, 415-7128 | | | contact person = Taylor L, NRR/DORL/LPL1-2, 415-7128 |
| | case reference number = CAC MF3301, CAC MF3302 | | | case reference number = CAC MF3301, CAC MF3302 |
| | document type = Letter, Request for Additional Information (RAI) | | | document type = Letter, Request for Additional Information (RAI) |
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| =Text= | | =Text= |
| {{#Wiki_filter:Mr. Marty L. Richey Site Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 7, 2016 FirstEnergyNuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 7, 2016 Mr. Marty L. Richey Site Vice President FirstEnergyNuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| BEAVER VALLEY POWER STATION, UNITS 1 AND 2 -REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (CAC NOS. MF3301 AND MF3302) | | BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (CAC NOS. MF3301 AND MF3302) |
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| ==Dear Mr. Richey:== | | ==Dear Mr. Richey:== |
| By letter dated December 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14002A086), as supplemented by letters dated February 14, 2014; April 27, 2015; May 27, 2015; June 26, 2015; November 6, 2015; December 21, 2015; and February 24, 2016 (ADAMS Accession Nos. ML 14051A499, ML 15118A484, ML 15147A372, ML 15177A110, ML 15313A306, ML 15356A136, and ML 16055A160, respectively), FirstEnergy Nuclear Operating Company submitted a license amendment request to change the Beaver Valley Power Station, Units 1 and 2, fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated in Title 10 of the Code of Federal Regulations, Section 50.48(c). | | |
| To complete its review, the U.S. Nuclear Regulatory Commission staff requests a response to the enclosed Request for Additional Information. | | By letter dated December 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14002A086), as supplemented by letters dated February 14, 2014; April 27, 2015; May 27, 2015; June 26, 2015; November 6, 2015; December 21, 2015; and February 24, 2016 (ADAMS Accession Nos. ML14051A499, ML15118A484, ML15147A372, ML15177A110, ML15313A306, ML15356A136, and ML16055A160, respectively), FirstEnergy Nuclear Operating Company submitted a license amendment request to change the Beaver Valley Power Station, Units 1 and 2, fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated in Title 10 of the Code of Federal Regulations, Section 50.48(c). To complete its review, the U.S. Nuclear Regulatory Commission staff requests a response to the enclosed Request for Additional Information. |
| The draft questions were sent to Mr. Phil Lashley 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. | | The draft questions were sent to Mr. Phil Lashley 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 by May 14, 2015. |
| Please respond to the enclosed questions by May 14, 2015. | | |
| E. Larson If you have any questions regarding this matter, please contact me at (301) 415-7128 or Taylor.Lamb@nrc.gov. | | E. Larson If you have any questions regarding this matter, please contact me at (301) 415-7128 or Taylor.Lamb@nrc.gov. |
| Docket Nos. 50-334 and 50-412 | | Sincerely, |
| | ~~ |
| | Taylor A. Lamb, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412 |
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| ==Enclosure:== | | ==Enclosure:== |
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| Request for Additional Information cc w/enclosure: | | Request for Additional Information cc w/enclosure: Distribution via Listserv |
| Distribution via Listserv Sincerely, Taylor A. Lamb, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS," FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-334 AND 50-412 By letter dated December 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14002A086), as supplemented by letters dated February 14, 2014; April 27, 2015; May 27, 2015; June 26, 2015; November 6, 2015; December 21, 2015; and February 24, 2016 (ADAMS Accession Nos. ML 14051A499, ML 15118A484, ML 15147A372, ML 15177A110, ML 15313A306, ML 15356A136, and ML 16055A 160, respectively), FirstEnergy Nuclear Operating Company submitted a license amendment request to change the Beaver Valley Power Station, Units 1 and 2, fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 1 O of the Code of Federal Regulations (10 CFR), Section 50.48(c). | | |
| To complete its review, the U.S. Nuclear Regulatory Commission (NRC) staff requests a response to the questions below. Probabilistic Risk Assessment (PRA) Request for Additional Information (RAI) 01.f.ii.01.01 The responses to RAI 01.f. and RAI 01.f.ii.01 did not provide information that the NRC staff can use to conclude that the quantitative fire risk estimates exclude the impact of unrealistically low joint human error probabilities (HEPs) consisting of pairs of HEPs and longer strings. Instead, the responses indicate that many thousands of joint HEPs with unrealistically low probabilities may be embedded within the logic sequences frequencies. | | REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS," |
| These low probabilities may lead to significant underestimates of affected sequence fire risks and have an indeterminate impact on the NFPA-805 change-in-risk estimates. | | FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-334 AND 50-412 By letter dated December 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14002A086), as supplemented by letters dated February 14, 2014; April 27, 2015; May 27, 2015; June 26, 2015; November 6, 2015; December 21, 2015; and February 24, 2016 (ADAMS Accession Nos. ML14051A499, ML15118A484, ML15147A372, ML15177A110, ML15313A306, ML15356A136, and ML16055A160, respectively), FirstEnergy Nuclear Operating Company submitted a license amendment request to change the Beaver Valley Power Station, Units 1 and 2, fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 1O of the Code of Federal Regulations (10 CFR), Section 50.48(c). To complete its review, the U.S. Nuclear Regulatory Commission (NRC) staff requests a response to the questions below. |
| | Probabilistic Risk Assessment (PRA) Request for Additional Information (RAI) 01.f.ii.01.01 The responses to RAI 01.f. and RAI 01.f.ii.01 did not provide information that the NRC staff can use to conclude that the quantitative fire risk estimates exclude the impact of unrealistically low joint human error probabilities (HEPs) consisting of pairs of HEPs and longer strings. Instead, the responses indicate that many thousands of joint HEPs with unrealistically low probabilities may be embedded within the logic sequences frequencies. These low probabilities may lead to significant underestimates of affected sequence fire risks and have an indeterminate impact on the NFPA-805 change-in-risk estimates. |
| The reference to "two" HEPs in RAI 01.f.ii.01 is only a reflection that a "joint" HEP must have at least two individual HEPs and assigns no significance to pairs of HEPs. Longer strings of HEPs can occur frequently, and the error associated with simply multiplying individual probabilities in these longer strings can be many orders of magnitude. | | The reference to "two" HEPs in RAI 01.f.ii.01 is only a reflection that a "joint" HEP must have at least two individual HEPs and assigns no significance to pairs of HEPs. Longer strings of HEPs can occur frequently, and the error associated with simply multiplying individual probabilities in these longer strings can be many orders of magnitude. |
| The response states, in part, that the RISKMAN structure itself precludes dependency concerns; however, this is not entirely clear to the staff. Enclosure The staff has accepted applications, which have used the following: | | The response states, in part, that the RISKMAN structure itself precludes dependency concerns; however, this is not entirely clear to the staff. |
| : 1. Minimum joint HEPs of 1 E-05 within an accident sequence cutset; or 2. Using joint HEPs in accident sequence cutsets: a. Identifying the number of sequences (or the fraction of core damage frequency and large early release frequency) in which joint HEP values of less than 1 E-05 contribute, b. Describing the range of joint HEP values in sequences where the joint HEP value is less than 1 E-05, and c. Confirming that a justification (e.g., narrative) for each joint HEP value below 1 E-05 has been documented, consistent with the scenario, and that the justification was developed by reviewing each applicable sequence and the joint HEP(s) contributing to the sequence. | | Enclosure |
| Alternately, the Beaver Valley Power Station can use an alternative method to demonstrate that every joint HEP value less than 1 E-05 is evaluated within the sequence that it is used, and confirm that an evaluation for each joint HEP is documented. | | |
| | The staff has accepted applications, which have used the following: |
| | : 1. Minimum joint HEPs of 1E-05 within an accident sequence cutset; or |
| | : 2. Using joint HEPs in accident sequence cutsets: |
| | : a. Identifying the number of sequences (or the fraction of core damage frequency and large early release frequency) in which joint HEP values of less than 1E-05 contribute, |
| | : b. Describing the range of joint HEP values in sequences where the joint HEP value is less than 1E-05, and |
| | : c. Confirming that a justification (e.g., narrative) for each joint HEP value below 1E-05 has been documented, consistent with the scenario, and that the justification was developed by reviewing each applicable sequence and the joint HEP(s) contributing to the sequence. |
| | Alternately, the Beaver Valley Power Station can use an alternative method to demonstrate that every joint HEP value less than 1E-05 is evaluated within the sequence that it is used, and confirm that an evaluation for each joint HEP is documented. |
| Please provide adequate justification that the quantitative fire risk estimates exclude the impact of unrealistically low joint HEPs. Summarize any review of dependency, in addition to a pairwise review, that is done on longer strings of HEPs to identify if a dependency exists between the full set of actions in these longer strings within the sequence. | | Please provide adequate justification that the quantitative fire risk estimates exclude the impact of unrealistically low joint HEPs. Summarize any review of dependency, in addition to a pairwise review, that is done on longer strings of HEPs to identify if a dependency exists between the full set of actions in these longer strings within the sequence. |
| PRA RAI 08.01.01 The response to PRA RAI 08.01 explains that confined areas behind substantial cable tray stacks are excluded from evaluation of transient fires in the fire PRA. The response states: These spaces are not part of any normal travel path through the plant. The crowded tray spacing and configuration completely encloses the area, making it extremely difficult to enter the space. The excluded locations in this fire compartment contain no equipment, significantly minimizing or eliminating maintenance and modification activities. | | PRA RAI 08.01.01 The response to PRA RAI 08.01 explains that confined areas behind substantial cable tray stacks are excluded from evaluation of transient fires in the fire PRA. The response states: |
| This exclusion is inconsistent with guidance in NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Final Report (NUREG/CR-6850, EPRI 1011989)." NUREG/CR-6850 states in Section 6.5.7.2 that areas not precluded by design or operation should be evaluated for transient fires, and although these areas are difficult to access, their access is not precluded. | | These spaces are not part of any normal travel path through the plant. The crowded tray spacing and configuration completely encloses the area, making it extremely difficult to enter the space. The excluded locations in this fire compartment contain no equipment, significantly minimizing or eliminating maintenance and modification activities. |
| Additionally, transient combustibles placed in these areas could go unnoticed. | | This exclusion is inconsistent with guidance in NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Final Report (NUREG/CR-6850, EPRI 1011989)." |
| NRC staff notes that Frequently Asked Question 12-0064, "Hot work/transient fire frequency: | | NUREG/CR-6850 states in Section 6.5.7.2 that areas not precluded by design or operation should be evaluated for transient fires, and although these areas are difficult to access, their access is not precluded. Additionally, transient combustibles placed in these areas could go unnoticed. NRC staff notes that Frequently Asked Question 12-0064, "Hot work/transient fire frequency: influence factors," provides guidance on the use of weighting factors for fire areas less likely to have transient combustibles. Include the evaluation of transient fires for these spaces in the integrated analysis in response to PRA RAI 03, dated March 4, 2015 (ADAMS Accession No. ML15049A507). |
| influence factors," provides guidance on the use of weighting factors for fire areas less likely to have transient combustibles. | |
| Include the evaluation of transient fires for these spaces in the integrated analysis in response to PRA RAI 03, dated March 4, 2015 (ADAMS Accession No. ML 15049A507). | |
| E. Larson If you have any questions regarding this matter, please contact me at (301) 415-7128 or Taylor.Lamb@nrc.gov.
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| Docket Nos. 50-334 and 50-412
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| ==Enclosure:==
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| Request for Additional Information Sincerely, /RAJ Taylor A. Lamb, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc w/enclosure:
| | ML16071A122 OFFICE DORL/LPLl-2/PM DORL/LPLl-2/LA DRA/APLA/BC DORL/LPLl-2/BC DORL/LPLl-2/PM NAME Tlamb LRonewicz SRosenberg DBroaddus Tlamb DATE 4/7/16 4/7/16 4/6/16 4/6/16 4/7/16}} |
| Distribution via Listserv DISTRIBUTION:
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| PUBLIC RidsACRS_MailCTR Resource RidsNrrPMBeaverValley Resource RidsNrrDraApla Resource SDinsmore, NRR LPLl-2 R/F RidsNrrDorlDpr Resource RidsNrrLALRonewicz Resource RidsNrrDraAphb Resource AWu, NRR ADAMS Accession No.: ML 16071A122 OFFICE DORL/LPLl-2/PM DORL/LPLl-2/LA DRA/APLA/BC NAME Tlamb LRonewicz SRosenberg DATE 4/7/16 4/7/16 4/6/16 OFFICIAL RECORD COPY RidsRgn1 MailCenter Resource RidsNrrDorllpl1-2 Resource RidsNrrDraAfpb Resource JHyslop, NRR LFields, NRR DORL/LPLl-2/BC DORL/LPLl-2/PM DBroaddus Tlamb 4/6/16 4/7/16}}
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MONTHYEARL-15-150, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 8052015-05-27027 May 2015 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Response to RAI ML15280A0742015-10-0909 October 2015 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: RAI L-15-325, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 8052015-11-0606 November 2015 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Response to RAI ML15320A4132015-11-24024 November 2015 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: RAI L-15-371, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 8052015-12-21021 December 2015 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Response to RAI L-16-058, Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 8052016-02-24024 February 2016 Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Supplement ML16099A0112016-03-0303 March 2016 NRR E-mail Capture - Draft 3rd Round PRA RAIs - Beaver Valley Units 1 & 2 - NFPA-805 LAR (CAC Nos. MF3301 & MF3302) Project stage: Draft RAI ML16084A8442016-03-30030 March 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: RAI ML16089A0622016-03-30030 March 2016 Meeting to Discuss BVPS Draft PRA RAI - Slides Project stage: Request ML16071A1222016-04-0707 April 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: RAI ML16105A0082016-04-25025 April 2016 March 30, 2016, Summary of Meeting with Firstenergy Nuclear Operating Company on Its Draft Probabilistic Risk Assessment RAI Related to Its License Amendment Request to Adopt NFPA Standard 805 Project stage: Draft RAI L-16-162, Response to Requests for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, and Request to Change Implementation Schedule2016-05-12012 May 2016 Response to Requests for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, and Request to Change Implementation Schedule Project stage: Response to RAI ML16158A0022016-06-0101 June 2016 NRR E-mail Capture - Beaver Valley, Units 1 & 2 - Update on NFPA 805 (CAC Nos. MF3301 & MF3302) Project stage: Other ML16333A0162016-12-0202 December 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: RAI L-17-024, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 8052017-01-30030 January 2017 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Response to RAI L-17-197, Response to Request for Additional Information and Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 8052017-06-23023 June 2017 Response to Request for Additional Information and Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Supplement ML17220A2342017-08-0808 August 2017 E-mail Regarding Request for Additional Information for NFPA 805 License Amendment Request Project stage: RAI ML17313A6422017-11-0909 November 2017 Transmittal of Draft Safety Evaluation for Proposed Amendments Transition to NFPA 805 (CAC Nos. MF3301 and MF3302; EPID L-2013-LLF-0001) Project stage: Draft Approval ML17335A0962017-11-27027 November 2017 NRR E-mail Capture - Beaver Valley: NFPA 805 LAR: License Condition: Fire Protection Program Changes That Have More than Minimal Risk Impact (CAC Nos. MF3301 and MF3302; EPID L-2013-LLF-0001) Project stage: Other ML18058A9422017-12-11011 December 2017 NFPA 805 Amendment Application Transition License Condition Project stage: Other ML17291A0812018-01-22022 January 2018 Issuance of Amendments Transition to NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (CAC Nos. MF3301 and MF3302; EPID L-2013-LLF-0001) Project stage: Approval ML18058B0722018-02-23023 February 2018 BVPS NFPA 805 License Amendment Change Requested, and Other SE Comments Project stage: Other ML18059A7982018-02-26026 February 2018 BVPS NFPA 805 License Amendment Change Requested, and Other SE Comments Project stage: Other ML18058A9852018-02-27027 February 2018 BVPS-1 License Condition Page Project stage: Other ML18058A9532018-02-27027 February 2018 Comments on BVPS SE Project stage: Other ML18065A4032018-04-0505 April 2018 Correction of Errors in Safety Evaluation Associated with License Amendment Nos. 301 and 190 Project stage: Approval ML18099A2322018-04-18018 April 2018 Correction of an Error in the Renewed Facility Operating License No. DPR-66 Associated with License Amendment No. 301 CAC No. MF3301; EPID L-2013-LLF-0001) Project stage: Other 2016-06-01
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Category:Letter
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Nonproprietary IR 05000334/20234022023-09-29029 September 2023 Security Baseline Inspection Report 05000334/2023402 and 05000412/2023402 (Cover Letter Only) ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure IR 05000334/20234012023-09-21021 September 2023 Cybersecurity Inspection Report 05000334/2023401 and 05000412/2023401 (Cover Letter Only) ML23263A0192023-09-20020 September 2023 Operator Licensing Examination Approval ML23243A9272023-09-19019 September 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23249A1842023-09-18018 September 2023 Authorization and Safety Evaluation for Alternative Request No. 2-TYP-4-RV-06 L-23-208, Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA00256152023-09-14014 September 2023 Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA0025615 L-23-167, Twenty-Third Refueling Outage Inservice Inspection Summary Report2023-09-13013 September 2023 Twenty-Third Refueling Outage Inservice Inspection Summary Report L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments IR 05000334/20230052023-08-31031 August 2023 Updated Inspection Plan for Beaver Valley Power Station Units 1 and 2 (Report 05000334/2023005 and 05000412/2023005) L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual ML23129A1722023-08-25025 August 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2; Davis Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 IR 05000334/20230022023-08-0909 August 2023 Integrated Inspection Report 05000334/2023002 and 05000412/2023002 ML23219A0592023-08-0707 August 2023 Steam Generator Inspection Reports - Spring 2023 Spring Refueling Outrage L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-179, Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA00256152023-07-18018 July 2023 Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA0025615 ML23188A0982023-07-17017 July 2023 Correction to the Safety Evaluation Issued Related to Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time ML23188A0672023-07-10010 July 2023 Project Manager Assignment L-23-165, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-06-26026 June 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-139, Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report2023-06-13013 June 2023 Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report ML23157A1072023-06-0707 June 2023 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000334/2023011 and 05000412/2023011 ML23143A0272023-05-23023 May 2023 Licensed Operator Positive Fitness-For-Duty Test L-23-055, Submittal of the Updated Final Safety Analysis Report, Revision 342023-05-23023 May 2023 Submittal of the Updated Final Safety Analysis Report, Revision 34 ML23102A1472023-05-22022 May 2023 Issuance of Amendment Nos. 321 and 211 Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23135A7872023-05-19019 May 2023 Summary of Conference Calls Regarding the Spring 2023 Steam Generator Tube Inspections L-23-137, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-05-18018 May 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 L-23-125, Cycle 24 Core Operating Limits Report2023-05-17017 May 2023 Cycle 24 Core Operating Limits Report ML23124A3882023-05-16016 May 2023 Summary of Regulatory Audit in Support of License Amendment Request to Revise Technical Specification 5.6.3, Core Operating Limits Reports (COLR) and TS 4.2.1 Fuel Assemblies ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) L-23-132, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-10010 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations IR 05000334/20230012023-05-0808 May 2023 Integrated Inspection Report 05000334/2023001 and 05000412/2023001 L-23-129, Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations2023-05-0505 May 2023 Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations ML23118A3812023-04-28028 April 2023 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations L-23-115, Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological2023-04-27027 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological L-23-126, Discharge Monitoring Report (Npdes), Permit No. PA00256152023-04-22022 April 2023 Discharge Monitoring Report (Npdes), Permit No. PA0025615 CP-202300181, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-20020 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML23107A2502023-04-18018 April 2023 Requalification Program Inspection 2024-01-25
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23143A0272023-05-23023 May 2023 Licensed Operator Positive Fitness-For-Duty Test ML23125A1462023-05-0505 May 2023 NRR E-mail Capture - Beaver Valley - RAI Regarding Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations ML23125A1602023-05-0505 May 2023 NRR E-mail Capture - Correction to Beaver Valley - RAI Regarding Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations ML23122A0342023-05-0202 May 2023 NRR E-mail Capture - Beaver Valley - Request for Additional Information Regarding Unit 1 - 180 Day Steam Generator Tube Inspection Report ML22312A5912022-11-0808 November 2022 NRR E-mail Capture - Beaver Valley Power Station, Units 1&2 - Request for Additional Information LAR to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time ML22278A0972022-10-0606 October 2022 Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment Request for Fire Protection Program Changes ML22178A1322022-06-24024 June 2022 Request for Additional Information for Beaver Valley Unit 2 Steam Generator Inspection Report - Fall 2021 Refueling Outage ML22068A1822022-03-0909 March 2022 NRR E-mail Capture - Beaver Valley Power Station, Units 1 & 2 - Request for Additional Information for License Amendment Request to Revise Technical Specification 3.3.5 ML22013A7512022-01-13013 January 2022 Information Request to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000334/2022010 and 05000412/2022010 ML21292A0482021-10-19019 October 2021 Ti 2515/194 Inspection Documentation Request ML21259A1642021-09-16016 September 2021 NRR E-mail Capture - Request for Additional Information Regarding the LAR for Core Operating Limits ML21124A1322021-05-0404 May 2021 Notification of Conduct of a Fire Protection Team Inspection ML21102A1542021-04-0909 April 2021 Request for Additional Information (2nd Round) - Steam Generator Tube Sleeve LAR ML21082A4942021-03-23023 March 2021 Final RAIs for GL 04-02 Closure (Email) ML21068A3502021-03-0909 March 2021 Final Request for Additional Information for Reactor Coolant System (RCS) and Pressure and Tempature Limits Report(Ptlr) TS LAR ML21053A0252021-02-20020 February 2021 NRR E-mail Capture - Request for Additional Information (Rais) - LaSalle Request for Exemption from Pre-Access Drug and Alcohol Testing ML21015A5762021-01-14014 January 2021 Final RAIs for Steam Generator 180 Day Tube Inspection Report ML21007A3732021-01-0707 January 2021 NRR E-mail Capture - (External_Sender) (External) Request for Additional Information Regarding License Amendment Request to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff, ML21004A1442020-12-30030 December 2020 NRR E-mail Capture - Request for Additional Information Regarding License Amendment Request to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff ML20290B0082020-10-0808 October 2020 Draft Request for Additional Information - Steam Generator Letter ML20127H8672020-05-0606 May 2020 NRR E-mail Capture - Beaver Valley, Davis-Besse, and Perry - Request for Additional Information Regarding Request for Exemptions from Part 73 Security Requalification Requirements ML20072N0402020-03-12012 March 2020 Request for Additional Information - Control Envelope Habitability LAR ML19192A2222019-07-18018 July 2019 Request for Additional Information Regarding Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML19143A0732019-05-29029 May 2019 FENOC Fleet - Beaver Valley, Units 1 and 2; Davis-Besse, Unit 1, Perry, Unit 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action; Application for Order Consenting to License Transfer and Conforming Amendments ML18242A3642018-08-29029 August 2018 Request for Additional Information (Final) -Steam Generator Technical Specification LAR ML18102B0852018-04-12012 April 2018 NRR E-mail Capture - Follow-up Request for Additional Information (RAI) FENOC FLEET-- Exemption Request for a Physical Barrier Requirement for Beaver ML18043A0102018-02-0909 February 2018 NRR E-mail Capture - FENOC--MG0010-MG0011, MG-0012, MG0013-- Request for Additional Information (RAI) - Exemption Request Security Barrier in Physical Plans ML18024B3642018-01-24024 January 2018 NRR E-mail Capture - Beaver Valley 10 CFR 50.54(f) - NTTF 2.1 SPRA Review ML18019A0722018-01-18018 January 2018 NRR E-mail Capture - Beaver Valley Unit No. 1: Request for Additional Information - Modified Rtpts Values and Reactor Vessel Surveillance Capsule Withdrawal Schedule ML17353A1582017-12-19019 December 2017 NRR E-mail Capture - Request for Additional Information: Beaver Valley Unit No. 1 - Proposed Alternative Request, 1-TYP-4-BA-01 ML17352B2612017-12-18018 December 2017 NRR E-mail Capture - Request for Additional Information: Beaver Valley Unit No. 1 - Proposed Alternative Request, 1-TYP-4-BA-01 ML17303B1582017-11-0707 November 2017 FENOC-Beaver Valley Power Station, Units 1 and 2, Davis-Besse Nuclear Power Station, Unit 1, Perry Nuclear Power Plant Unit 1 - Generic Letter 2016-01, Request for Supplemental Information ML17256A2502017-09-13013 September 2017 NRR E-mail Capture - Beaver Valley Power Station Units 1&2: Request for Additional Information for Emergency Plan EAL Change to Adopt NEI 99-01, Rev. 6, ML17220A2342017-08-0808 August 2017 E-mail Regarding Request for Additional Information for NFPA 805 License Amendment Request ML17093A7622017-04-10010 April 2017 Request for Additional Information Regarding Emergency Action Level Scheme Change License Amendment Request ML17031A0362017-02-0303 February 2017 Request for Additional Information Regarding Relief Request Numbers PR6 and PR7 ML16333A0162016-12-0202 December 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 ML16147A2842016-06-14014 June 2016 Request for Additional Infomation Regarding Fall 2015 Refueling Steam Generator Tube Inspections ML16071A1222016-04-0707 April 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 ML16084A8442016-03-30030 March 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 ML16060A0122016-02-29029 February 2016 FENOC - Email RAI to Licensee Regarding LAR for Changes to TS 5.3.1 CAC Nos. MF7118, MF7119, and MF7120 ML15320A4132015-11-24024 November 2015 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 ML15280A0742015-10-0909 October 2015 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 ML15279A1252015-10-0505 October 2015 Licensed Operator Positive for Fitness-for-Duty-Test ML15181A2142015-07-14014 July 2015 Request for Additional Information Regarding License Amendment Request to Revise Steam Generator Technical Specifications to Reflect TSTF-510 and to Revise Alloy 800 Sleeve Technical Specifications (TAC Nos. MF6054 & MF6055) ML15125A4162015-05-11011 May 2015 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC Nos. MF3301 & MF3302) ML15016A4392015-01-20020 January 2015 Draft Request for Additional Information ML15007A5582015-01-15015 January 2015 Request for Additional Information Steam Generator Inspection Reports ML14218A7622014-12-11011 December 2014 RAI Request to Implement 10 CFR 50.61a Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events ML14316A3902014-11-14014 November 2014 Request for Additional Information Review of Licensee Security Plans 2023-05-05
[Table view] |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 7, 2016 Mr. Marty L. Richey Site Vice President FirstEnergyNuclear 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 REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (CAC NOS. MF3301 AND MF3302)
Dear Mr. Richey:
By letter dated December 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14002A086), as supplemented by letters dated February 14, 2014; April 27, 2015; May 27, 2015; June 26, 2015; November 6, 2015; December 21, 2015; and February 24, 2016 (ADAMS Accession Nos. ML14051A499, ML15118A484, ML15147A372, ML15177A110, ML15313A306, ML15356A136, and ML16055A160, respectively), FirstEnergy Nuclear Operating Company submitted a license amendment request to change the Beaver Valley Power Station, Units 1 and 2, fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated in Title 10 of the Code of Federal Regulations, Section 50.48(c). To complete its review, the U.S. Nuclear Regulatory Commission staff requests a response to the enclosed Request for Additional Information.
The draft questions were sent to Mr. Phil Lashley 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 by May 14, 2015.
E. Larson If you have any questions regarding this matter, please contact me at (301) 415-7128 or Taylor.Lamb@nrc.gov.
Sincerely,
~~
Taylor A. Lamb, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
Request for Additional Information cc w/enclosure: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS,"
FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-334 AND 50-412 By letter dated December 23, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14002A086), as supplemented by letters dated February 14, 2014; April 27, 2015; May 27, 2015; June 26, 2015; November 6, 2015; December 21, 2015; and February 24, 2016 (ADAMS Accession Nos. ML14051A499, ML15118A484, ML15147A372, ML15177A110, ML15313A306, ML15356A136, and ML16055A160, respectively), FirstEnergy Nuclear Operating Company submitted a license amendment request to change the Beaver Valley Power Station, Units 1 and 2, fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 1O of the Code of Federal Regulations (10 CFR), Section 50.48(c). To complete its review, the U.S. Nuclear Regulatory Commission (NRC) staff requests a response to the questions below.
Probabilistic Risk Assessment (PRA) Request for Additional Information (RAI) 01.f.ii.01.01 The responses to RAI 01.f. and RAI 01.f.ii.01 did not provide information that the NRC staff can use to conclude that the quantitative fire risk estimates exclude the impact of unrealistically low joint human error probabilities (HEPs) consisting of pairs of HEPs and longer strings. Instead, the responses indicate that many thousands of joint HEPs with unrealistically low probabilities may be embedded within the logic sequences frequencies. These low probabilities may lead to significant underestimates of affected sequence fire risks and have an indeterminate impact on the NFPA-805 change-in-risk estimates.
The reference to "two" HEPs in RAI 01.f.ii.01 is only a reflection that a "joint" HEP must have at least two individual HEPs and assigns no significance to pairs of HEPs. Longer strings of HEPs can occur frequently, and the error associated with simply multiplying individual probabilities in these longer strings can be many orders of magnitude.
The response states, in part, that the RISKMAN structure itself precludes dependency concerns; however, this is not entirely clear to the staff.
Enclosure
The staff has accepted applications, which have used the following:
- 1. Minimum joint HEPs of 1E-05 within an accident sequence cutset; or
- 2. Using joint HEPs in accident sequence cutsets:
- a. Identifying the number of sequences (or the fraction of core damage frequency and large early release frequency) in which joint HEP values of less than 1E-05 contribute,
- b. Describing the range of joint HEP values in sequences where the joint HEP value is less than 1E-05, and
- c. Confirming that a justification (e.g., narrative) for each joint HEP value below 1E-05 has been documented, consistent with the scenario, and that the justification was developed by reviewing each applicable sequence and the joint HEP(s) contributing to the sequence.
Alternately, the Beaver Valley Power Station can use an alternative method to demonstrate that every joint HEP value less than 1E-05 is evaluated within the sequence that it is used, and confirm that an evaluation for each joint HEP is documented.
Please provide adequate justification that the quantitative fire risk estimates exclude the impact of unrealistically low joint HEPs. Summarize any review of dependency, in addition to a pairwise review, that is done on longer strings of HEPs to identify if a dependency exists between the full set of actions in these longer strings within the sequence.
PRA RAI 08.01.01 The response to PRA RAI 08.01 explains that confined areas behind substantial cable tray stacks are excluded from evaluation of transient fires in the fire PRA. The response states:
These spaces are not part of any normal travel path through the plant. The crowded tray spacing and configuration completely encloses the area, making it extremely difficult to enter the space. The excluded locations in this fire compartment contain no equipment, significantly minimizing or eliminating maintenance and modification activities.
This exclusion is inconsistent with guidance in NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Final Report (NUREG/CR-6850, EPRI 1011989)."
NUREG/CR-6850 states in Section 6.5.7.2 that areas not precluded by design or operation should be evaluated for transient fires, and although these areas are difficult to access, their access is not precluded. Additionally, transient combustibles placed in these areas could go unnoticed. NRC staff notes that Frequently Asked Question 12-0064, "Hot work/transient fire frequency: influence factors," provides guidance on the use of weighting factors for fire areas less likely to have transient combustibles. Include the evaluation of transient fires for these spaces in the integrated analysis in response to PRA RAI 03, dated March 4, 2015 (ADAMS Accession No. ML15049A507).
ML16071A122 OFFICE DORL/LPLl-2/PM DORL/LPLl-2/LA DRA/APLA/BC DORL/LPLl-2/BC DORL/LPLl-2/PM NAME Tlamb LRonewicz SRosenberg DBroaddus Tlamb DATE 4/7/16 4/7/16 4/6/16 4/6/16 4/7/16