ML081760068

Request for Additional Information, License Amendment Request to Revise Completion Times, Bypass Test Times, and Surveillance Test Intervals (TAC Nos. MD7531 and MD7532)

ML081760068
Person / Time
Site:	Beaver Valley
Issue date:	06/27/2008
From:	Nadiyah Morgan NRC/NRR/ADRO/DORL/LPLI-1
To:	Sena P FirstEnergy Nuclear Operating Co
tsw1
References
TAC MD7531, TAC MD7532
Download: ML081760068 (9)

Text

June 27, 2008 Mr. Peter P. Sena III 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, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO REVISE COMPLETION TIMES, BYPASS TEST TIMES AND SURVEILLANCE TEST INTERVALS (TAC NOS. MD7531 AND MD7532)

Dear Mr. Sena:

By letter dated December 21, 2007, FirstEnergy Nuclear Operating Company submitted an application to amend the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2)

Technical Specifications (TSs). The proposed license amendment request (LAR) adopts changes as described in Westinghouse Commercial Atomic Power (WCAP) Topical Report WCAP-14333-P-A, Revision 1, Probabilistic Risk Analysis of the RPS [reactor protection system] and ESFAS [engineered safety features actuation system] Test Times and Completion Times, and changes as described in WCAP-15376-P-A, Revision 1, Risk-Informed Assessment of the RTS [reactor trip system] and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, The Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). The NRC staff is requesting a response to the RAI within 30 days of receipt.

P. Sena Please contact me at (301) 415-1016, if you have any questions regarding this issue.

Sincerely,

/ra/

Nadiyah S. Morgan, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

RAI cc w/encls: See next page

ML081760068 *See dated memo OFFICE LPLI-1/PM LPLI-1/LA DRA/APLA/BC DE/EICB/BC DORL/LPLI-1/BC NAME NMorgan SLittle MRubin* WKemper* MKowal DATE 6/20/08 6/26/08 05/29/2008 05/28/2008 6/27/08

Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Joseph J. Hagan Ohio EPA-DERR President and Chief Operating Officer ATTN: Zack A. Clayton FirstEnergy Nuclear Operating Company P.O. Box 1049 Mail Stop A-GO-14 Columbus, OH 43266-0149 76 South Main Street Director, Fleet Regulatory Affairs Akron, OH 44308 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 James H. Lash 76 South Main Street Senior Vice President of Operations Akron, Ohio 44333 and Chief Operating Officer FirstEnergy Nuclear Operating Company Manager, Site Regulatory Compliance Mail Stop A-GO-14 FirstEnergy Nuclear Operating Company 76 South Main Street Beaver Valley Power Station Akron, OH 44308 Mail Stop A-BV-A P.O. Box 4, Route 168 Danny L. Pace Shippingport, PA 15077 Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Commissioner James R. Lewis Mail Stop A-GO-14 West Virginia Division of Labor 76 South Main Street 749-B, Building No. 6 Akron, OH 44308 Capitol Complex Charleston, WV 25305 Jeannie M. Rinckel Vice President, Fleet Oversight Director, Utilities Department FirstEnergy Nuclear Operating Company Public Utilities Commission Mail Stop A-GO-14 180 East Broad Street 76 South Main Street Columbus, OH 43266-0573 Akron, OH 44308 Director, Pennsylvania Emergency David W. Jenkins, Attorney Management Agency FirstEnergy Corporation 2605 Interstate Dr.

Mail Stop A-GO-18 Harrisburg, PA 17110-9364 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44333

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 150

REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE COMPLETION TIMES, BYPASS TEST TIMES AND SURVEILLANCE TEST INTERVALS BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412 By letter dated December 21, 2007 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML0703601008), FirstEnergy Nuclear Operating Company (licensee) submitted an application to amend the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) Technical Specifications (TSs). The proposed license amendment request (LAR) adopts changes as described in Westinghouse Commercial Atomic Power (WCAP) Topical Report WCAP-14333-P-A, Revision 1, Probabilistic Risk Analysis of the RPS [reactor protection system] and ESFAS [engineered safety features actuation system] Test Times and Completion Times, issued October 1998 and approved by the Nuclear Regulatory Commission (NRC) by letter dated July 15, 1998. Implementation of the proposed changes is in accordance with approved TS Task Force (TSTF) Traveler TSTF-418, Revision 2, RPS and ESFAS Test Times and Completion Times (WCAP-14333).

The proposed LAR also adopts changes as described in WCAP-15376-P-A, Revision 1, Risk-Informed Assessment of the RTS [reactor trip system] and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, issued March 2003, as approved by the NRC by letter dated December 20, 2002. Implementation of the proposed changes is in accordance with approved TSTF-411, Revision 1, Surveillance Test Interval Extension for Components of the Reactor Protection System (WCAP-15376).

In order to complete the review, the NRC staff requests further information on the following items:

1. Attachment A states that, FENOC will review applicable BVPS programs and revise them as necessary to ensure that the intent of the RTS and ESFAS equipment unavailability and component failure modeling assumptions in WCAP-14333 and WCAP-15376 are met at BVPS. In addition, confirm that the following conditions and limitations from WCAP-14333 and WCAP-15376 are to be included in the above licensee commitment. Please provide your commitment to meet the topical report conditions and limitations, i.e.:

For WCAP-14333, See Enclosure 1, Page 21 of the LAR:

a. To preserve anticipated transient without scram (ATWS) mitigation capability, activities that degrade the ability of the auxiliary feedwater (AFW) system, reactor coolant system (RCS) pressure relief systems (pressurizer power operated relief valves (PORVs) and safety valves), ATWS mitigating system actuation circuitry (AMSAC), or turbine trip should not be scheduled when a logic train is inoperable.

Enclosure

b. To preserve loss-of-coolant accident (LOCA) mitigation capability, one complete emergency core cooling system (ECCS) train that can be actuated automatically must be maintained when a logic train is inoperable.

c. To preserve reactor trip and safeguards actuation capability, activities that cause master relays or slave relays in the available train to be unavailable and activities that cause analog channels to be unavailable should not be scheduled when a logic train is inoperable.

d. Activities in electrical systems (e.g., AC and DC power) and cooling systems (e.g., service water and component cooling water) that support the systems or functions listed in the first three bullets should not be scheduled when a logic train is inoperable. That is, one complete train of a function that supports a complete train of a function noted above must be available.

For WCAP-15376, See Enclosure 1, Page 23 of the LAR:

e. The probability of failing to trip the reactor on demand will increase when an RTB train is removed from service; therefore, systems designed for mitigating an ATWS event should be maintained and available. RCS pressure relief PORVs and safety valves, AFW flow (for RCS heat removal), AMSAC, and turbine trip are important to ATWS mitigation. Therefore, activities that degrade the availability of the AFW, RCS pressure relief system (pressurizer PORVs and safety valves),

AMSAC, or turbine trip should not be scheduled when an RTB is inoperable.

f. Due to the increased dependence on the available reactor trip train when one logic train is unavailable, activities that degrade other components of the RTS, including master relays or slave relays, and activities that cause analog channels to be unavailable, should not be scheduled when a logic train is inoperable.

g. Activities in electrical systems (e.g., AC and DC power) that support the systems or functions listed in e and f should not be scheduled when an RTB is inoperable.

2. Identify the latest revision of the probabilistic risk assessment (PRA) and the PRA revision used for this LAR. Identify BVPS-1 and 2 plant LARs, plant modifications, or plant procedure changes not reflected in the PRA revision referenced for this LAR. See Section 3.1.7.3 of the LAR. Verify that the proposed WCAP-14333 and WCAP-15376 extended completion times and surveillance test intervals are not impacted by changes not incorporated into the BVPS PRA.

3. A high winds, floods and other (HFOs) external event risk evaluation was not provided in the LAR. Confirm that the conclusions stated in the IPEEE continue to represent the HFO risk at BVPS-1 and 2 (HFO events screened out).

4. In the Loss of Power (LOP) Diesel Generator (DG) Start and Bus Separation Instrumentation TS 3.3.5 Functional Units 1, 2, 3, and 4, Condition B completion time is revised to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on WCAP-14333 implementation for BVPS-1 and 2. Also in TS 3.3.2, ESFAS Functional Unit 7.b, Refueling Water Storage Tank Level Extreme Low, Condition J completion time is revised to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on WCAP-14333 implementation for BVPS-1 and 2.

The justification for the completion time change referenced on Page 31 of Enclosure 1 is based on the applicability to WCAP-10271, as approved by the NRC in Amendment Nos.

267 and 149 for BVPS-1 and 2, respectively. As stated in the original submittal, the application of the proposed completion time, bypass test times, and surveillance intervals to functional units not specifically covered by WCAP-14333 and WCAP-15376 may be applicable, if previously accepted under the plant-specific implementation of WCAP-10271. The BVPS-1 and 2 WCAP-10271 LARs for the above functional units increased the surveillance interval from monthly to quarterly, but did not discuss a revised completion time per WCAP-10271. Clarify the LAR justifying a change to completion times based on WCAP-10271 implementation.

5. The LAR states that 10 CFR 50.65 Maintenance Rule program at BVPS-1 and 2 includes condition monitoring requirements. The LAR also states that BVPS-1 and 2 will review applicable BVPS-1 and 2 programs and revise them as needed to ensure the intent of the RTS and ESFAS equipment unavailability and component failure modeling assumptions in WCAP-14333 and WCAP-15376 continue to be met. Describe the implementation and monitoring program per Regulatory Guide (RG) 1.74, Section 3.4, Implementation Plan and Performance Monitoring Documentation including procedures to include applicable RTS and ESFAS equipment related to WCAP-14333 and WCAP-15376 in the implementation and monitoring program. Discuss component level criteria under 10 CFR 50.65 that reflect the assumptions in the topical reports. Identify any additional regulatory commitments. See Attachment A of the LAR.

6. The configuration risk management program (CRMP) is stated in the LAR to use a PRA-based model to assess configuration risk prior to a maintenance activity being performed consistent with 10 CFR 50.65(a)(4). Tier 3 guidance can be satisfied by the Maintenance Rule Section (a)(4), subject to the guidance provided in RG 1.177, Section 2.3.7.1, and the adequacy of the licensees program and PRA model for the application. Discuss the BVPS-1 and 2 CRMP implementation (including Tier 2 conditions, TS, grid or weather) for WCAP-14333 and WCAP-5376 including revision, quality and verification of the BVPS-1 and 2 PRA applicable completion and bypass test times CRMP for this LAR.