ML19260A011

Responds to 790913 Ltr & NUREG-0578 Re TMI Followup Actions. Outlines Status of Each NUREG-identified Item.Although Implementation Schedule Is Probably Unachievable,Util Proceeding as Rapidly as Possible W/All Required Actions

ML19260A011
Person / Time
Site:	Beaver Valley
Issue date:	10/22/1979
From:	Dunn C DUQUESNE LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 7910260290
Download: ML19260A011 (6)

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15219 October 22, 1979 Director of Nuclear Regulation United States Nuclear Regulatory Commission Attn: Darrell G. Eisenhut, Acting Director Division of Operating Reactors Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Followup Actions Regarding TMI Gentlemen:

We have reviewed your letter of September 13, 1979, the accompanying ten (10) enclosures and the referenced NUREG 0578.

We have also attended the regional meeting which was held in King of Prussia, Pennsylvania, and the series of topical meetings that took place in Bethesda, Maryland, to clarifv several of the NUREG requirements.

In addition, we are a member of the Westinghouse TMI Operating Plant Owners Group that has been working closely with the NRC Bulletin and Orders Task Force in performing analyses and developing guidelines which will serve as the basis for upgraded emergency and abnormal operating procedures and for improved operator training programs. Through the Owners Group, we are participating in the EPRI program for the testing of safety valves and power operated relief valves.

Although we believe that the implemnration schedule which is provided as Enclosure 6 of your September 13, 1979, letter is so ambitious as to be almost unachievable, we are proceeding as rapidly as possible with all actions necessary to evaluate, engineer, procure, install and test the additional equipment and instruments tequired by the NUREG. We are also engaged in the performance of additional analyses and also in the revision, review, approval and issuance of upgraded emergency procedures and the preparation of training material related to emergency and abnormal operating procedures including the detection of and recovery from occurrences of inadequate core cooling.

We are evaluating the alternatives described in Enclosure 2 of your September 13 letter to provide the accident assessment function on shift and the operating experience asses sment capability at the plant level.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Followup Actions Regarding TMI Page 2 We are also evaluating the additional instruments described in Enclosure 3 and the high point vent described in Enclosure 4 At the present time, we can project no schedule for installation until the completion of preliminary engineering and placement of the necessary purchase orders.

The unit will be shut down for refueling in December and will not be ready to return to power until late next spring due to extensive planned modifications and also due to completing the requirements of numerous IE Bulletins including 79-02 and 79-14 Since the unit will not be in operation on January 1,1980, we would like to obtain your approval to defer full compliance with the Implementation Category A items until the unit is ready to resume power operation.

If this is acceptable, we will provide you with monthly reports, beginning in January,1980, of the status of each incomplete item in Implementation Category A. We will also provide the available engineering details of the longer term Implementation Category B items in these same monthly reports and the estimated completion dates.

The status of each NUREG identified item follows:

2.1.1 Emergency Power Supply for Pressurizer Heaters, PORV's, PORV Block Valves and Pressurizer Level Indicators.

This capability already exists at Beaver Valley.

2.1.2 We are participating in the EPRI-MPR Program through the Westinghouse Owners Group. Schedular considerations will be provided on a generic basis by EPRI.

2.1.3(a) Direct Indication of PORV and SV Position.

Direct Indication of PORV position currently exists on Beaver Valley.

We are investigating the seismic and environmental qualifications of the existing equipment.

Indirect indication of the existence of a safety valve leak presently exists. This indirect indication is obtained by determining that the pressurizer relief tank temperature, pressure and level is increasing and that (through the direct indication of PORV position) the PORVs are not the source. Temperature detectors on the lines leading to the PRT also provide indication of a relief to the tank.

We are investigating a means to provide direct indication of SV valve position.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Followup Actions Regarding TMI Page 3 2.1.3(b) Instrumentation for Detection of Iaadequate Core Cooling.

Adequate instrumentation for the detection of the existence of inadequate core cooling presently exists at the Beaver Valley Power Station. The Westinghouse Owners Group is presently developing abnormal procedures related to the decection of and recovery from occurrence of inadequate core cooling. All licensed operators and all licensed supervisory personnel will receive training in the use of these procedures.

We are also engaged in the engineering evaluation necessary to engineer, purchase, install and test a direct reading subcooling meter. This meter will be installed prior to resuming power operation subsequent to the refueling outage.

2.1.4 Diverse and More Selective Containment Isolations Provisions.

Beaver Valley containment isolation is actuated from two diverse signals. These signals are:

1. Safety Injection Initiation and

2. Containment Pressure.

We are therefore presently in full compliance with this requirement.

2.1.5(a) Dedicated Penetrations for External Hydrogen Recombiners and Capability and (c) to Install Hydrogen Recombiner.

Beaver Valley presently has a permanently installed external hydrogen recombiner and is in compliance with this requirement.

2.1.6(a) Integrity of Systems outside Containment Likely to Contain Radioactive Fluids.

We are precently preparing a program to verify the integrity of these systems. This program will be implemented prior to station start up after the refueling.

2.1.6.(b) Design Review of Plant Shielding Spaces for PA Operations.

We are performing the required design review. This review will be completed prior to resuming power operation after the refueling.

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Braver Valley Power Station, Unit No. 1 Docket No. 50-334 followup Actions Regarding TMI Page 4 2.1.7(a) Automatic Initiation of the AFW System.

The Auxiliary Feedwater System is presently automatically initiated.

We are therefore in compliance with this requirement.

2.1.7(b) AFW Flow Indications.

Beaver Valley Power Station presently has indication of auxiliary feedwater flow to each steam generator. We are investigating the qualifications of the instslied instruments to determine what will be required to achieve safety grade status.

2.1.8(a) Improved Post Accident Sampling Capability.

We are performing necessary design reviews and procedure preparation to comply with the Implementation Category A items subsequent to the refueling. The Category B item requirements will be identified, engineered and scheduled upon the completion of the ongoing review.

2.1.8(b) Increased Range of Radiation Monitors.

We are conducting an engineering study to identify the equipment necessary to comply with this requirement. The procurement and installation schedule will be established upon the completion of this study.

2.1.8(c) Improved Plant Iodine Instrumentation.

We have ordered silver zeolite cartridges for our plant air sampling equipment at this time. We will be in compliance with this ,

requirement as soon as these cartridges are received and installed.

2.1.9 Analyses of Design and Off-Normal Transients and Accidents.

We are participating in this effort through the Westinghouse Owners.

The information will be developed and submitted by the Owners Group in accordance with the schedule as submitted by Mr. Cordell Reed, Owners Group Chairman to Mr. D. F. Ross, Chairman of the NRC Bulletins and Orders Task Force. It is our understanding that the agreed upon schedule is in full compliance with this requirement.

2.2.l(a) Shift Supervisor Responsibilities.

A review of the Shift Supervisors authorities and responsibilites shall be conducted in accordance with the requirements of this item.

Clear instructions relative to the command and management function of the Senior Licensed Operators will be issued by January 1, 1980.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Followup Actions Regarding TMI Page 5 2.2.l(b) Shift Technical Advisor.

A shif t technical advisor will be provided on a shif t .iasis at all times that the reactor coolant system average temperature exceeds 2000F. These individuals will be selected and familiarized with their duties prior to assuming their tours of shif t at the time the station is returned to power operation late next spring. Provisions for instituting an operating experience assessment function by graduate engineers in the station organization will be instituted by January 1, 1980. This function will not necessarily be performed by the Shift Technical Advisor.

2.2.l(c) Shift and Relief Turnover.

For=al procedures and checklists for shift turnover will be developed and i=plemented prior to January 1, 1980.

2.2.2(a) Control Room Access.

Procedures will be instituted o limit access to the control room during both normal and accident conditions. These procedures will be instituted by January 1, 1980.

2. 2. 2 (b) Onsite Technical Support Center.

A temporary onsite technical support center will be selected and provided with direct communications to the control room by January 1, 1980. Engineering information considered necessary to provide technical support to the shif t operating personnel in the control room will be available in the technical support centet. Communications between the technical support center and offsite agencies including the NRC will be available.

We are evaluating both the specific plant parameters that are required to be available in the technical support center and the manner in which this information is to be transmitted and displayed. A schedule for implementation cannot be established until these studies are completed.

We are also performing studies to determine the habitability in a post accident situation of the location in which we plan to locate the technical support center.

A firm schedule for the installation of the permanent technical.

support center carnot be provided until these studies are completed.

2.2.2(c) Onsite Operational Support Center An onsite operational support center with adequate communications will be provided by January 1,1980.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Followup Actions Regarding TMI Page 6 Paragraph (c) of the September 13, 1979, letter - Additional Containment Parameter Instruments.

We plan to install the instruments identified in this additional requirement. A firm schedule for procurement and installation of these instruments will be established and submitted as it becomes available.

Paragraph (e) of the September 13, 1979, letter - High Point Vent.

We are performing the preliminary (t.gineering necessary to procure and install a high point vent. A firm decision to install a high point vent system on the head of the reactor vessel will be made at the time that the analyses relating to inadequate core cooling determines the need for a vent. The engineering design details and schedule for installation will be provided when we decide to install the vent.

We are proceeding to revise and upgrade our Emergency Preparedness Plan in accordance with requirements of Enclosure 7 of your September 13, 1979, letter. We believe that the schedule provided in Enclosure 8 of the same letter be met.

We wish to reemphasize that the tasks which we have undertaken in an effort to achieve full compliance with the requirements of this NUREG and your :eptember 13, 1979, letter represent a tremendously large amount of work t hat must be accomplished in what we consider to be a remarkably short period of time.

We intend to vigorously pursue each and every one of these tasks. We shall keep you informed of our progress and provide schedules for completion on a periodic basis as this information becomes available.

Very truly yours,

• f 8' C. N. Dunn Vice President, Operations 1212 330