L-24-038, License Amendment Request to Remove the Expired One-Time Action for Valve Leak Repair in Technical Specification (TS) 3.5.2 and to Correct Core Operating Limits Rep Ort (COLR) References

License Amendment Request to Remove the Expired One-Time Action for Valve Leak Repair in Technical Specification (TS) 3.5.2 and to Correct Core Operating Limits Rep Ort (COLR) References

ML24261B850
Person / Time
Site:	Beaver Valley
Issue date:	09/17/2024
From:	Blair B Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-24-038
Download: ML24261B850 (1)

Text

L-24-038 September 17, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License NPF-73 Beaver Valley Power Station Barry N. Blair Site Vice President P.O. Box4 200 State Route 3016 Shippingport. PA 15077 724-682-5234 10 CFR50.90 License Amendment Request to Remove the Expired One-Time Action for Valve Leak Repair in Technical Specification (TS) 3.5.2 and to Correct Core Operating Limits Report (COLR} References Pursuant to 10 CFR 50.90, Vistra Operations Company LLC hereby requests an amendment to the facility operating license for Beaver Valley Power Station, Unit No. 1 (BVPS-1) and Beaver Valley Power Station, Unit No.

2 (BVPS-2). The proposed change would revise TS 3.5.2, "ECCS - Operating," Limiting Condition for Operation (LCO) 3.5.2, to remove Note 4, which allowed a one-time use of an alternate manual flow path to support repair of a leak. Additionally, the proposed change would correct three titles of references cited in TS 5.6.3, "CORE OPERATING LIMITS REPORT (COLR)."

An evaluation of the proposed change is provided in Attachment 1. A copy of the TS pages marked with the proposed changes is provided in Attachment 2. A re-typed copy of the TS pages with the proposed changes incorporated is provided in Attachment 3 for information only. The applicable TS Bases page marked to reflect the proposed change is provided in Attachment 4 for information only.

Approval of the proposed amendment is requested by April 20, 2025. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Jack Hicks, Senior Manager - Fleet Licensing, at (254) 897-6725.

der penalty of perjury that the foregoing is true and correct. Executed on September.!.1_, 2024.

VI fl oRr COM

Beaver Valley Power Station, Unit Nos. 1 and 2 L-24-038 Page 2 Attachment(s):

1. Evaluation of the Proposed Change

2. Proposed Technical Specification Page Markups

3. Proposed Technical Specification Pages Re-typed (for information only)

4. Proposed TS Bases Page Markups (for information only) cc:

NRC Region I Administrator NRC Resident Inspector NRR Project Manager Director BRP/DEP Site BRP/DEP Representative L-24-038 Evaluation of the Proposed Change Page 1 of 6

Subject:

License Amendment Request to Remove the Expired One-Time Action for Valve Leak Repair in Technical Specification (TS) 3.5.2 and Correct COLR References 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements I Criteria 4.2 No Significant Hazards Consideration Analysis 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

L-24-038 Page 2 of 6 1.0

SUMMARY

DESCRIPTION This evaluation supports a license amendment request to amend Renewed Facility Operating License No. DPR-66 for Beaver Valley Power Station, Unit No. 1 (BVPS-1) and Renewed Facility Operating License No. NPF-73 for Beaver Valley Power Station, Unit No. 2 (BVPS-2).

The proposed change revises Technical Specification (TS) 3.5.2, ECCS - Operating, Limiting Condition for Operation (LCO) 3.5.2, to remove Note 4, which allowed a one-time use of an alternate manual flow path to support repair of a leak. The use of the note expired on April 7, 2023.

Additionally, the proposed change corrects three titles of references cited in Technical Specification (TS) 5.6.3, CORE OPERATING LIMITS REPORT (COLR).

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The proposed change is administrative in nature and makes no physical changes to plant systems or plant operation.

2.2 Current Technical Specification Requirements TS LCO 3.5.2 requires that two ECCS trains shall be operable. Note 4, which is for BVPS-1 only, states that one ECCS train may use an alternate manual flow path on a one-time basis not to exceed 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> while the compensatory measures described in Section 3.3 of Energy Harbor Nuclear Corp. letter L-23-073, dated March 1, 2023, are implemented, if not otherwise inoperable. This allowance expires on April 7, 2023.

TS 5.6.3 CORE OPERATING LIMITS REPORT (COLR) requires that core operating limits be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR. Part b of TS 5.6.3 lists the analytical methods used to determine the core operating limits as previously reviewed and approved by the NRC, specifically those described in the listed documents. The following three documents are included in the list:

WCAP-8745-P-A, "Design Bases for the Thermal Overtemperature T and Thermal Overpower T Trip Functions" WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification" WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicating Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids" L-24-038 Page 3 of 6 2.3 Reason for the Proposed Change The proposed amendment incorporates administrative changes to remove an expired Note and correct titles of referenced documents.

2.4 Description of the Proposed Change The allowance provided by TS LCO 3.5.2 Note 4 expired on April 7, 2023. Therefore, Note 4 is removed from TS 3.5.2. The applicable TS Bases page will be changed to reflect that there are three Notes associated with TS 3.5.2.

The titles of three of the references cited in TS 5.6.3.b are incorrect. The following changes are made to the titles:

WCAP-8745-P-A, "Design Bases for the Thermal Overtemperature T and Thermal Overpower T Trip Functions," is changed to WCAP-8745-P-A, "Design Bases for the Thermal Overpower T and Thermal Overtemperature T Trip Functions,"

WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification," is changed to WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control-FQ Surveillance Technical Specification,"

WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicating Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"

is changed to WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicting Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"

3.0 TECHNICAL EVALUATION

Note 4 was added to TS 3.5.2 by Amendment 319 to Renewed Facility Operating License No. DPR-66 (BVPS-1). The allowance provided by Note 4 was a one-time allowance, which expired on April 7, 2023.

Removal of Note 4 is administrative. No physical changes are made to plant systems, structures, or components. No changes are made to plant operation.

The titles of three references in TS 5.6.3.b were found to have editorial errors:

WCAP-8745-P-A, "Design Bases for the Thermal Overpower T and Thermal Overtemperature T Trip Functions,"

o The words Overtemperature and Overpower are swapped.

WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control-FQ Surveillance Technical Specification,"

o The / between Control and FQ is replaced with a -.

L-24-038 Page 4 of 6 WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicting Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"

o The word Predicating is replaced by the word Predicting.

Correction of the titles is administrative. No changes are requested to the analytical methods used.

Therefore, the proposed change is administrative.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 10 CFR 50.36, Technical specifications This part of the Code of Federal Regulations (CFR) contains regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(2) states, in part, Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

The proposed license amendment does not delete requirements associated with the system and LCO 3.5.2 continues to maintain requirements associated with structures, systems, and components that are part of the primary success path and actuate to mitigate the related design-basis accidents and transients. The proposed change does not affect compliance with this regulation.

Additionally, 10 CFR 50.36(c)(5) states, in part, Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

The proposed license amendment does not change administrative controls. The proposed change does not affect compliance with this regulation.

4.2 No Significant Hazards Consideration Analysis Vistra Operations Company LLC is proposing to amend the Renewed Facility Operating License No. DPR-66 for Beaver Valley Power Station, Unit No. 1 (BVPS-1) and Renewed Facility Operating License No. NPF-73 for Beaver Valley Power Station, Unit No. 2 (BVPS-2). The amendment would revise Technical Specification (TS) 3.5.2, ECCS - Operating, Limiting Condition for Operation (LCO) 3.5.2, to remove Note 4, which had allowed a one-time use of an alternate manual flow path to support repair of a leak. The use of the note expired on April 7, 2023.

Additionally, the proposed change corrects three titles of references cited in TS 5.6.3, CORE OPERATING LIMITS REPORT (COLR).

L-24-038 Page 5 of 6 Vistra Operations Company LLC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment is an administrative change that removes an expired Note and corrects editorial errors in titles of references. No physical changes are made to plant systems, structures, or components. There is no change to plant operation.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment is an administrative change that removes an expired Note and corrects editorial errors in titles of references. No physical changes are made to plant systems, structures, or components. There is no change to plant operation.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment is an administrative change that removes an expired Note and corrects editorial errors in titles of references. No physical changes are made to plant systems, structures, or components. There is no change to plant operation.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, Vistra Operations Company LLC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

L-24-038 Page 6 of 6 4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to editorial, corrective or other minor revisions to the license, including updating of NRC approved references. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

L-24-038 Proposed Technical Specification Page Markups (3 pages follow)

ECCS - Operating 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

- NOTES -

1.

In MODE 3, both low head safety injection pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform pressure isolation valve testing per SR 3.4.14.1.

2.

In MODE 3, one of the required charging pumps may be made incapable of injecting to support transition into or from the Applicability of LCO 3.4.12, "Overpressure Protection System (OPPS)," for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or until the temperature of all RCS cold legs exceeds the OPPS enable temperature specified in the PTLR plus 25F, whichever comes first.

3.

For Unit 1 only. In MODE 3, the ECCS automatic high head safety injection (HHSI) flow path may be isolated to support transition into or from the Applicability of LCO 3.4.12, "Overpressure Protection System (OPPS)" for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or until the temperature of all RCS cold legs exceeds the OPPS enable temperature specified in the PTLR plus 25F, whichever comes first.

4.

For Unit 1 only. One ECCS train may use an alternate manual flow path on a one-time basis not to exceed 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> while the compensatory measures described in Section 3.3 of Energy Harbor Nuclear Corp. letter L-23-073, dated March 1, 2023, are implemented, if not otherwise inoperable. This allowance expires at 2400 EDT on April 7, 2023.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more trains inoperable.

A.1 Restore train(s) to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Beaver Valley Units 1 and 2 3.5.2 - 1 Amendments 319 / 161

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR) (continued)

LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limits" LCO 3.1.5.2, Unit 2 Shutdown Bank Insertion Limits LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits" LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))"

LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (

N H

F)"

LCO 3.2.3, "Axial Flux Difference (AFD)"

LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation" - Overtemperature and Overpower T Allowable Value parameter values LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits" LCO 3.9.1, "Boron Concentration"

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

WCAP-9272-P-A, "Westinghouse Reload Safety Evaluation Methodology,"

WCAP-8745-P-A, "Design Bases for the Thermal OvertemperatureOverpower T and Thermal OverpowerOvertemperature T Trip Functions,"

WCAP-16996-P-A, Revision 1, Realistic LOCA Evaluation Methodology Applied to the Full Spectrum of Break Sizes (FULL SPECTRUM LOCA Methodology), November 2016, WCAP-12945-P-A, Volumes 1 through 5, "Code Qualification Document for Best Estimate LOCA Analysis," [Shall not be used to determine core operating limits after December 2024]

(For Unit 1 only) WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using Automated Statistical Treatment of Uncertainty Method (ASTRUM)," [Shall not be used to determine core operating limits after December 2024]

WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control/-

FQ Surveillance Technical Specification,"

WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis,"

WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report,"

WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicating Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"

Beaver Valley Units 1 and 2 5.6 - 2 Amendments 322 / 212 L-24-038 Proposed Technical Specification Pages Re-Typed (for information only)

(2 pages follow)

ECCS - Operating 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

- NOTES -

1.

In MODE 3, both low head safety injection pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform pressure isolation valve testing per SR 3.4.14.1.

2.

In MODE 3, one of the required charging pumps may be made incapable of injecting to support transition into or from the Applicability of LCO 3.4.12, "Overpressure Protection System (OPPS)," for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or until the temperature of all RCS cold legs exceeds the OPPS enable temperature specified in the PTLR plus 25F, whichever comes first.

3.

For Unit 1 only. In MODE 3, the ECCS automatic high head safety injection (HHSI) flow path may be isolated to support transition into or from the Applicability of LCO 3.4.12, "Overpressure Protection System (OPPS)" for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or until the temperature of all RCS cold legs exceeds the OPPS enable temperature specified in the PTLR plus 25F, whichever comes first.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more trains inoperable.

A.1 Restore train(s) to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Beaver Valley Units 1 and 2 3.5.2 - 1 Amendments 319 / 161 For Information Only

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR) (continued)

LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limits" LCO 3.1.5.2, Unit 2 Shutdown Bank Insertion Limits LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits" LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))"

LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (

N H

F)"

LCO 3.2.3, "Axial Flux Difference (AFD)"

LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation" - Overtemperature and Overpower T Allowable Value parameter values LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits" LCO 3.9.1, "Boron Concentration"

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

WCAP-9272-P-A, "Westinghouse Reload Safety Evaluation Methodology,"

WCAP-8745-P-A, "Design Bases for the Thermal Overpower T and Thermal Overtemperature T Trip Functions,"

WCAP-16996-P-A, Revision 1, Realistic LOCA Evaluation Methodology Applied to the Full Spectrum of Break Sizes (FULL SPECTRUM LOCA Methodology), November 2016, WCAP-12945-P-A, Volumes 1 through 5, "Code Qualification Document for Best Estimate LOCA Analysis," [Shall not be used to determine core operating limits after December 2024]

(For Unit 1 only) WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using Automated Statistical Treatment of Uncertainty Method (ASTRUM)," [Shall not be used to determine core operating limits after December 2024]

WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control-FQ Surveillance Technical Specification,"

WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis,"

WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report,"

WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicting Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"

Beaver Valley Units 1 and 2 5.6 - 2 Amendments 322 / 212 For Information Only L-24-038 Proposed TS Bases Page Markups (for information only)

(1 page follows)

ECCS - Operating B 3.5.2 BASES LCO (continued)

During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers to each of the three cold leg injection nozzles. In the long term, this flow path may be switched to take its supply from the containment sump and to supply its flow simultaneously to both the RCS hot or cold legs for Unit 1. The flow path from the containment sump is cycled alternatively between the RCS cold legs or hot legs for Unit 2.

The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains.

The LCO is modified by fourthree Notes. Note 1 provides an exception allowing the LHSI flow paths to be isolated for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in MODE 3, under controlled conditions, to perform pressure isolation valve testing per SR 3.4.14.1. The flow path is readily restorable from the control room.

As indicated in Note 2, operation in MODE 3 with one required charging pump made incapable of injecting in order to facilitate entry into or exit from the Applicability of LCO 3.4.12, "Overpressure Protection System (OPPS)," is necessary when OPPS enable temperature is at or near the MODE 3 boundary temperature of 350F. LCO 3.4.12 requires that one required charging pump be rendered incapable of injecting at and below the OPPS enable temperature. When this temperature is at or near the MODE 3 boundary temperature, time is needed to make a required charging pump incapable of injecting prior to entering the OPPS Applicability, and provide time to restore the inoperable pump to OPERABLE status on exiting the OPPS Applicability.

Note 3 is only applicable to Unit 1. As indicated in Note 3, operation in MODE 3 with the Unit 1 ECCS automatic high head safety injection (HHSI) flow path isolated in order to facilitate entry into or exit from the Applicability of LCO 3.4.12, "Overpressure Protection System (OPPS)," is necessary when the OPPS enable temperature is at or near the MODE 3 boundary temperature of 350F. LCO 3.4.12 requires that the Unit 1 ECCS automatic HHSI flow path be isolated when any RCS cold leg temperature is the enable temperature specified in the PTLR. When this temperature is near the MODE 3 boundary temperature, Note 3 provides time to isolate the ECCS automatic HHSI flow path prior to entering the OPPS Applicability, and to restore the flow path on exiting the OPPS Applicability.

Note 4 is only applicable to Unit 1. As indicated in Note 4, one ECCS train may use an alternate manual flow path on a one-time basis not to exceed 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> while the compensatory measures described in Section 3.3 of Energy Harbor Nuclear Corp. letter L-23-073, dated March 1, 2023, are implemented, if not otherwise inoperable. This allowance expires in April 2023.

Beaver Valley Units 1 and 2 B 3.5.2 - 6 Revision 47 For Information Only