ML22321A239

NRR E-mail Capture - (External_Sender) Beaver Valley Power Station, Units 1&2 - Clarification on LAR to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time

ML22321A239
Person / Time
Site:	Beaver Valley
Issue date:	11/17/2022
From:	Ballard B NRC/NRR/DORL/LPL1
To:	Goodman J, Lashley P Energy Harbor Nuclear Corp
Ballard B
References
L-2022-LLA-0071
Download: ML22321A239 (4)

Text

From: Morgan, Jeffrey D <jdmorgan@energyharbor.com>

Sent: Thursday, November 17, 2022 10:12 AM To: Brent Ballard Cc: Lashley, Phil H; Goodman, Josh

Subject:

[External_Sender] Clarification on Beaver Valley Decay Time LAR (EPID L-2022-LLA-0071)

Brent,

I have reviewed the document that you provided (ML22137A049) and I concur that the statements on pages 9 and 26 are referring to Supplemental Leak Collection and Release System (SLCRS) requirements that were previously retained in the Tech Specs following adoption of Amendments 278 and 161.

Furthermore, the statements on pages 9 and 26 are not SLCRS requirements that will be retained in the Tech Specs following implementation of the LAR to consolidate fuel decay time requirements. Please contact me if you have additional questions.

Sincerely,

Jeffrey D. Morgan Energy Harbor Nuclear Corp.

Fleet Licensing PNPP (A-PY-A210) jdmorgan@energyharbor.com 440-280-5336

As we discussed today during our call, will you please confirm the staffs understanding of the following sections of Energy Harbors license amendment request to consolidate fuel decay time requirements into a new LCO titled, Decay Time (ML22137A049):

On PDF page 9 of 129, starting in the second paragraph, the application states:

Therefore, the SLCRS requirements contained in LCO 3.7.12 are only applicable during refueling operations involving recently irradiated fuel. Although movement of recently irradiated fuel is not currently permitted, the requirements for SLCRS have been retained in the TS in the event these requirements are necessary to support fuel movement involving recently irradiated fuel at some point in the future.

When required in accordance with LCO 3.9.3.c.3, for Unit 1, one train of SLCRS is required to be operable and in operation to reduce the consequences of a fuel handling accident inside containment. This applicability applies only to Unit 1 in accordance with the provisions of LCO 3.9.3, "Containment Penetrations" when the containment purge and exhaust system penetrations are open coincident with fuel movement involving recently irradiated fuel assemblies within containment.

On PDF page 26 of 129, in the Basis section of the table for TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS), the application states:

The SLCRS function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiation fuel at some point in the future and would represent the primary success path for an FHA involving recently irradiated fuel.

Both of these sections state requirements for SLCRS have been retained in the TS, however, TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS) and TS 3.9.3, Containment Penetrations, to include TS 3.9.3.c.3, are deleted in their entirety (PDF page 56 of 129 and page 67 of 129, respectively).

Please confirm that the statements made regarding SLCRS functions retained in the TS on the pages above are in reference to the discussion on PDF pages 4-5 of 129, which states:

BVPS does not have an FHA analysis to support movement of recently irradiated fuel and currently has a Licensing Requirements Manual (LRM) licensing requirement (LR), titled Decay Time, which prohibits fuel movement involving recently irradiated fuel. In the NRC Safety Evaluation for Amendments 278 and 161, dated February 21, 2007, (Accession No. ML070160593) the NRC staff stated the following:

Although BVPS-1 and 2 do not currently have safety analyses that support moving recently irradiated fuel assemblies, TS requirements have been retained to address the condition of moving recently irradiated fuel assemblies. These TS requirements are retained because decay time limits for moving irradiated fuel are in the LRM and the NRC staff has determined that fuel handling limits should be retained in the TSs should the licensee develop future capability to move recently irradiated fuel.

Adding an LCO, titled Decay Time, which prohibits fuel movements involving recently irradiated fuel obviates the need for the individual requirements in the affected TS LCOs, applicability statements, conditions, and notes. Specific changes to TS LCOs, and the bases for those changes, are discussed in Section 3 of this attachment.

It is the staffs understanding that the statements on PDF pages 9 and 26 are referring to SLCRS requirements that were previously retained in the TS following Beaver Valleys adoption of the Improved Standard TS (amendments 278 and 161), and not referring to SLCRS requirements that will be retained in the TS following implementation of the LAR to consolidate fuel decay time requirements, if approved.

Thank you,

Brent Ballard Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-0680

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Hearing Identifier: NRR_DRMA Email Number: 1830

Mail Envelope Properties (SA1P110MB1518C4ACFB92F09C7C2300E3A5069)

Subject:

[External_Sender] Clarification on Beaver Valley Decay Time LAR (EPID L-2022-LLA-0071)

Sent Date: 11/17/2022 10:11:56 AM Received Date: 11/17/2022 10:12:21 AM From: Morgan, Jeffrey D

Created By: jdmorgan@energyharbor.com

Recipients:

"Lashley, Phil H" <phlashley@energyharbor.com>

Tracking Status: None "Goodman, Josh" <joshgoodman@energyharbor.com>

Tracking Status: None "Brent Ballard" <Brent.Ballard@nrc.gov>

Tracking Status: None

Post Office: SA1P110MB1518.NAMP110.PROD.OUTLOOK.COM

Files Size Date & Time MESSAGE 5810 11/17/2022 10:12:21 AM

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