ML12264A407

Request for Additional Information Regarding National Fire Protection Association Standard 805 License Amendment Extension Request

ML12264A407
Person / Time
Site:	Beaver Valley
Issue date:	10/18/2012
From:	Peter Bamford Plant Licensing Branch 1
To:	Harden P FirstEnergy Nuclear Operating Co
Bamford P
References
Download: ML12264A407 (6)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 October 18, 2012 Mr. Paul A. Harden 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 BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 -REQUEST FOR ADDITIONAL INFORMATION REGARDING NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LICENSE AMENDMENT EXTENSION REQUEST (TAC NOS. ME9015 AND ME9016)

Dear Mr. Harden:

By letter dated August 29, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12243A245), FirstEnergy Nuclear Operating Company (FENOC, the licensee) notified the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff that a previous commitment to submit a license amendment request (LAR) for Beaver Valley Power Station, Unit Nos.1 and 2, to transition to National Fire Protection Association Standard (NFPA) 805 in accordance with Title 10 of the Code of Federal Regulations 50.48(c), would not be met. The previous committed due date of September 30,2012, was submitted by letter dated June 29, 2011, (ADAMS Accession No. ML111800765).

The August 29, 2012, letter also requested that the NRC staff extend enforcement discretion for certain fire protection issues to correspond with the revised projected LAR submittal date of December 31,2013. The NRC staff has been reviewing the August 29,2012, letter 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 questions were sent via electronic transmission on September 19, 2012, to Mr. Henry Hegrat, of your staff. The draft questions were sent to ensure that the questions were understandable, the regulatory basis was clear, and to determine if the information was previously docketed.

The draft questions were discussed in a public meeting via teleconference with your staff on October 18, 2012. It was agreed that a response to this RAI would be submitted by November 2, 2012.

P. Harden -2 Should you have any questions regarding this letter, please contact me at 301-415-2833, or via email at peter.bamford@nrc.gov.

Sincerely, Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and Request for Additional cc w/encl: Distribution via REQUEST FOR ADDITIONAL INFORMATION REGARDING REVISION OF REGULATORY COMMITMENT RELATING TO SUBMITTAL OF 10 CFR 50.48{c} LICENSE AMENDMENT REQUEST FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-334 and 50-412 By letter dated August 29,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12243A245), First Energy Nuclear Operating Company (FENOC, the licensee) submitted a notification of a change in a regulatory commitment for the submission of a license amendment request (LAR) for a transition to National Fire Protection Association Standard (NFPA) 805 at Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2. The projected LAR submission date and the associated commitment were changed from September 30, 2012, to December 31, 2013. Consistent with the revised commitment date, FENOC also requested continuation of the current enforcement discretion for certain fire protection issues for BVPS, Units Nos. 1 and 2, until an acceptable application for license amendment is submitted, through the revised commitment date of December 31,2013. The U.S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal.

The NRC staff has determined that the additional information requested below is needed to complete its review. General/Plant Configuration and Modifications In Attachment 3 of the letter dated August 29, 2012, for each task or milestone with an incomplete or "Not Started" status, provide an explanation and justification of why that item is not complete. Attachment 2 of the letter dated August 29, 2012, contains a list of ongoing and conceptual design modifications.

Within this listing, six modifications indicate that the conceptual design package is not to be completed until various dates beyond the date for which the Fire Probabilistic Risk Assessment (Fire PRA) evaluation is complete, in September 2013. The LAR must provide a detailed, proposed configuration, including a description of all proposed modifications sufficient for risk analysis purposes.

According to the FENOC definition provided in Attachment 2, a conceptual design package is a documented analysis of one or more alternative solutions, with an identified preferred solution.

To evaluate the feasibility of FENOC providing an acceptable LAR by December 31, 2013, the NRC staff needs assurance that the LAR, as supported by the PRA, will contain the details necessary to evaluate the request fully. Accordingly, the LAR and PRA should include the particular design features of the plant, not a set of alternatives.

Enclosure Therefore, provide an explanation as to how the proposed schedule for ongoing and conceptual design modifications supports the submission of a complete and acceptable LAR on December 31,2013, or modify the August 29, 2012, request accordingly. In accordance with SECY-12-0031, "Enforcement Alternatives for Sites That Indicate Additional Time Required to Submit Their License Amendment Requests to Transition to 10 CFR 50.48(c) National Fire Protection Association Standard 805," the NRC's evaluation of the justification provided by the licensee for the issuance of a confirmatory order that would extend enforcement discretion will consider, but not be limited by, the status of plant modifications.

Attachment 2 describes an extended timeline for installing certain modifications.

In order to determine whether the scheduled modifications are being installed in a timely manner, the NRC staff requests that FENOC provide an explanation of how the current schedule demonstrates that modifications will be installed in a timely manner, through any enforcement discretion extension period. Alternatively, if further review of the modification schedule indicates that the timeline does not reflect timely installation of each of the necessary modifications, provide a revised modification milestone schedule.

Probabilistic Risk Assessment According to the licensee's letter dated August 29,2012, the BVPS, Unit No.1, Fire PRA had a full-scope peer review in April 2011. BVPS, Unit No.2, had their review in April 2012. These are significant milestones to complete, but completion of the resolution of the Finding and Observations (F&Os) is needed prior to submitting the LAR. Based on the information provided by the licensee, the fire models have been updated and the F&Os are 80% resolved and will be considered complete in May 2013. What is the justification for another 7 to 8 months to complete the last 20% of the F&Os and another 4-5 months for final closure? If developing the Fire PRA is considered complete in September 2013, how can it be useful for the NFPA 805 LAR and Transition Report, which must be completed at the same time? Provide a more detailed timeline for completing the Fire PRA and the Fire Risk Evaluation effort. Classical Fire Protection According to their letter dated August 29,2012, the licensee indicated that they had not developed all their additional existing engineering equivalencies evaluations (EEEEs) for BVPS, Unit No.1 and had not started to develop the additional EEEEs for BVPS, Unit NO.2. Please provide more detail on how FENOC will finish this work and update the B-1 Table by June 2013.

-3 Completion of LAR and Transition Report According to the licensee's letter dated August 29,2012, the LAR preparation will be complete in September 2013. Once the LAR is completed, what is the justification for another 3 to 4 months final review and concurrence?

P. Harden -2 Should you have any questions regarding this letter, please contact me at 301-415-2833, or via email at peter.bamford@nrc.gov.

Sincerely, /raj Peter Bamford, 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/encl: Distribution via Listserv DISTRIBUTION:

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