ML19256G069

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Responds to 791218 Request Re Procedures for Small Break Loca.Westinghouse Owners Group Procedures Adequate for facility.Site-specific Procedures Do Not Deviate Significantly from Ref Procedure
ML19256G069
Person / Time
Site: Beaver Valley
Issue date: 12/21/1979
From: Dunn C
DUQUESNE LIGHT CO.
To: Harold Denton, Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 7912270370
Download: ML19256G069 (3)


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'Af (412) 456-6000 435 S.xth Avenue Pittsburgh, Pennsylvania 15219 Decerber 21, 1979 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attention: A. Schwencer, Chief Operating Reactors Branch No. 1 Division of Operating Reactors Washington, D.C. 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Small Break LOCA Procedures

Dear Sir:

We have reviewed your telephone request of December 18, 1979 concerning the Westinghouse Owner's Group Reference Procedures for a small break LOCA and the Beaver Valley Power Station, Unit No. 1 specific procedures for this particular accident.

Duquesne Light Company believes that the procedures developed by the Owner's Group were adequate to allow the Beaver Valley Power Station to develop more site-specific procedures to deal with a Reactor Coolant System small break accident. Members of the station staf f have attended the Owner's Group meetings held to discuss these reference procedures and were aware of some of the basic differences between the systems of the reference plant (Westinghouse Standard 412) and the Beaver Valley Power Station.

In regard to your second question, the station staff does not believe that the site-specific procedures developed for a Reactor Coolant System small break accident deviate substantially from the reference procedure de. : loped by the Owner's Group. Deviations which do occur are basically due to phraseology, differences in pit nt-specific systems and some dif ferences in the order of presentation of the action steps in the plant procedure as deemed appropriate by the plant operatieng personnel.

Examples of the typical deviations are listed below:

a. Since our station utilizes the charging pumps as the "high head safety injection pumps" with low pressure, high flow low head safety injection pumps", whereas the reference procedure was written for a plant with an " intermediate head safety injection pump' cur procedure is written to address our particultr system. MO39 s

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 Small Break LOCA Procedures Page 2

b. The site-developed procedure included specific procedure steps to address the need to relieve steam from the steam generators for certain accident conditions whereas the reference procedure was more general.
c. The site-developed procedure requires establishment of both hot and cold leg recirculation at the appropriate time into the accident whereas the reference procedure utilized only one injection path for recirculation.
d. In a number of cases, the emergency procedure actions / steps in the reference procedure have been included in the " Abnormal Operating Procedure" at the site and, hence, vere not rewritten into the

" Emergency Operating Procedures" for the site.

e. The reference procedure provided a separate section to address the necessar'.' operator action required
  1. sc failure of various pieces whereas the site electec to include these operator actions in the individual procedures.
f. The site-developed procedures include applicabl2 symptoms in each accicent procedure which was not done in the reference procedure. This was done to keep all of the site Emergency Operating Procedures in the same format.

To reiterate, it is not believed that the variations between the site-specific procedures and the reference procedure as exampled above constitute substantial deviation.

The Beaver Valley Power Station Training Program has always used the most currently approved procedures in the Station Operating Manual for training of new operators or requalification training of licensed operators. The operators are trained to adhere to the written procedures, as approved, unless a situation occurs which mandates, in his or the on-duty supervisor's opinion, immediat e deviation from the procedure. For situations which develop slowly, it is expected that necessary revisions to the applicable procedure would be made and approved in accordance with existing station administrative practices, should such a need arise.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 Small Break LOCA Procedures Page 3 If you have any questions regarding this response, please notify my office.

Very truly yours,

)

C. N. Dunn Vice President, Operations cc: United Stater Nuclear Regulatory Cor: mission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D. C. 20555 1643 266