ML052030162

(BVPS-1 and 2), RAI, Steam Generator (SG) Level Allowable Value Set Points (TAC Nos. MC4649 and MC4650)

ML052030162
Person / Time
Site:	Beaver Valley
Issue date:	08/01/2005
From:	Colburn T NRC/NRR/DLPM/LPD1
To:	Pearce L FirstEnergy Nuclear Operating Co
Colburn T, NRR/DLPM, 415-1402
References
TAC MC4649, TAC MC4650
Download: ML052030162 (5)

Text

August 1, 2005 Mr. L. William Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 (BVPS-1 AND 2) -

REQUEST FOR ADDITIONAL INFORMATION (RAI) - STEAM GENERATOR (SG) LEVEL ALLOWABLE VALUE SETPOINTS (TAC NOS. MC4649 AND MC4650)

Dear Mr. Pearce:

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your October 5, 2004, license amendment request (LAR) to revise the SG level allowable value setpoints. The NRC staff has determined that the additional information contained in the enclosure to this letter is needed to complete its review. As discussed with your staff, we request your response within 30 days of receipt of this letter, in order for the NRC staff to complete its scheduled review of your LAR. If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

RAI cc w/encl: See next page

August 1, 2005 Mr. L. William Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 (BVPS-1 AND 2) -

REQUEST FOR ADDITIONAL INFORMATION (RAI) - STEAM GENERATOR (SG) LEVEL ALLOWABLE VALUE SETPOINTS (TAC NOS. MC4649 AND MC4650)

Dear Mr. Pearce:

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your October 5, 2004, license amendment request (LAR) to revise the SG level allowable value setpoints. The NRC staff has determined that the additional information contained in the enclosure to this letter is needed to complete its review. As discussed with your staff, we request your response within 30 days of receipt of this letter, in order for the NRC staff to complete its scheduled review of your LAR. If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION:

PUBLIC MO'Brien ACRS PDI-1 R/F TColburn OGC RLaufer RBellamy, RGN-I AHowe SRhow DLPM/DPR CGratton ACCESSION NO.: ML052030162 OFFICE PDI-1/PM PDI-2/LA PD2-I/PM EEIB/SC PDI-1/SC NAME TColburn MOBrien CGratton HGarg for AHowe RLaufer DATE 7/27/05 7/28/05 7/28/05 7/28/05 8/1/05 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 (BVPS-1 AND 2)

STEAM GENERATOR (SG) LEVEL ALLOWABLE VALUE (AV) SETPOINTS METHOD 3 CONCERNS During reviews of proposed license amendment requests (LARs) that contain changes to limiting safety system settings (LSSSs) setpoints, the Nuclear Regulatory Commission (NRC) staff identified concerns regarding the method used by some licensees to determine the AVs identified in the technical specifications (TSs). AVs are typically identified in the TSs as LSSSs to provide acceptance criteria for determination of instrument channel operability during periodic surveillance testing. The NRC staffs concern relates to one of the three methods for determining the AV as described in the ISAs (Instrument Society of Americas) recommended practice, ISA-RP67.04-1994, Part II, Methodologies for Determination of Setpoints for Nuclear Safety-Related Instrumentation.

The NRC staff has determined that to ensure a plant will operate in accordance with the assumptions upon which the plant safety analyses have been based, additional information is required regardless of the methodology used to establish LSSS values in the TSs. Details about the NRC staff's concerns are available on the NRC's public website under Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML041690604, ML041810346, and ML0506700251.

In order for the NRC staff to assess the acceptability of your LAR for SG level AV setpoints related to this issue, the NRC staff requests the following additional information:

1. Discuss the setpoint methodology used at BVPS-1 and 2 to establish AVs associated with LSSS setpoints.

2. Regardless of the methodology used, the NRC staff has the following questions regarding the use of the methodology at BVPS-1 and 2:

a. Discuss how the methodology and controls you have in place ensure that the analytical limit (AL) associated with an LSSS will not be exceeded (the AL is a surrogate that ensures the safety limits will not be exceeded). Include in your discussion information describing the controls you employ to ensure the trip setpoint established after completing periodic surveillances satisfies your methodology. If the controls are located in a document other than the TSs, discuss how those controls satisfy the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.36, as they apply to LSSSs.

1 To access the document, go to www.nrc.gov, click on Electronic Reading Room, then Documents in ADAMS, then Web-Based Access, then "Begin ADAMS Search," then Advanced Search, and enter the Accession number into the Accession Number box near the top of the page. Click on the Search button near the bottom of the page. You will need to select Image File on the search results page to view the document. NOTE:

You will need Adobe Acrobat Reader to open this file.

The NRC staff requests the licensee discuss current requirements or procedures for returning the as-left instrument settings to settings within the tolerance band for the trip setpoint established to protect the applicable safety limits.

b. Discuss how the TS surveillances ensure the operability of the instrument channel. This should include a discussion on how the surveillance test results relate to the TS AV and describe how these are used to determine the operability of the instrument channel. If the requirements for determining operability of the LSSS instrument being tested are in a document other than the TSs (e.g., plant test procedure), discuss how this meets the requirements of 10 CFR 50.36 as they relate to LSSSs.

Additionally, the NRC staff requests the licensees response to include a discussion of the requirements and methods the licensee has in place to assess the operability of tested instrumentation giving consideration to the previous as-left setting and accounting for uncertainties associated with the testing and calibration of the instruments.

In answering the above questions, as part of the discussion on the setpoint methodology used to establish AVs, the NRC staff requests that the licensee discuss consideration of the Technical Specification Task Force (TSTF) traveler being developed on this subject and to what extent the licensee would consider adopting the TSTF when issued.

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

Mary OReilly, Attorney Rich Janati, Chief FirstEnergy Nuclear Operating Company Division of Nuclear Safety FirstEnergy Corporation Bureau of Radiation Protection 76 South Main Street Department of Environmental Protection Akron, OH 44308 Rachel Carson State Office Building P.O. Box 8469 FirstEnergy Nuclear Operating Company Harrisburg, PA 17105-8469 Regulatory Affairs/Performance Improvement Mayor of the Borough of Shippingport Larry R. Freeland, Manager P O Box 3 Beaver Valley Power Station Shippingport, PA 15077 Post Office Box 4, BV-A Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Commissioner James R. Lewis 475 Allendale Road West Virginia Division of Labor King of Prussia, PA 19406 749-B, Building No. 6 Capitol Complex Resident Inspector Charleston, WV 25305 U.S. Nuclear Regulatory Commission Post Office Box 298 Director, Utilities Department Shippingport, PA 15077 Public Utilities Commission 180 East Broad Street FirstEnergy Nuclear Operating Company Columbus, OH 43266-0573 Beaver Valley Power Station ATTN: R. G. Mende, Director Director, Pennsylvania Emergency Work Management (BV-IPAB)

Management Agency Post Office Box 4 2605 Interstate Dr. Shippingport, PA 15077 Harrisburg, PA 17110-9364 FirstEnergy Nuclear Operating Company Ohio EPA-DERR Beaver Valley Power Station ATTN: Zack A. Clayton Mr. B. F. Sepelak Post Office Box 1049 Post Office Box 4, BV-A Columbus, OH 43266-0149 Shippingport, PA 15077 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 J. H. Lash, Plant Manager (BV-IPAB)

FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077