ML19325C206
| ML19325C206 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/03/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19325C208 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 8910130053 | |
| Download: ML19325C206 (4) | |
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October 3, 1989 U-.
S. Nuclear Regulatory Commission i
e Attn:
Document Control Desk j,
Washington, DC-20555
Reference:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No.~50-412, License No. NPF-73
Response
to Generic letter 89-04, Guidance On Developing i
Acceptable Inservice Testing Programs.
I i
Gentlemen:
]
This submittal provides the Beaver Valley Power Stations response to Generic Letter 89-04.
Beaver Valley Unit No. I was listed on l
Table 1
of.the generic letter and as such does not need to cespond with the confirmation letter requested by the NRC.
However, we have revised the Unit No.
1 Inservice Test (IST)
Program (Isnue 2, Revision 5) in part as a result of this generic letter.
We have, therefore, included the Unit No. 1 IST Program for your infortation as Enclosure 1.
Beaver Valley Unit No. 2 was not listed on either Table 1 or 2.
We have confirmed that the revisions to the Unit No. 2 IST Program either:
1) are in conformance with the stated positions of Generic H
Letter 89-04, or l
2) require prior NRC approval in accordance with 10 CFR 50.55a(g).
We have revised the Unit No. 2 IST Program (Revision 4) in part as a result of this generic letter and attached it as Enclosure 2 for your information and review.
We have not identified any Unit No. 2 plant modifict. ions which would be needed to conform to the NRC's stated positions.
This submittal does not contain any future commitments and, therefore, it completes our reporting requirements associated with Generic Letter 89-04.
As indicated
- above, we have attached Issue 2, Revision 5 of the l
Unit No. 1.IST Program.
Since Unit No. 1 was included on Table 1, we expect' to receive an SER in the near future.
The NRC had Issue 2 revision 3
for their review which generated six specific questions regarding the Unit No.
1 IST Program.
Our response to those questions was submitted on April 27,
- 1989, and included program 8910130053 spioo3 pod PDR ADOCK 05000334 P
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Be2v r Vallcy Pow r St;tiCn, Unit N:3. 1&2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to Generic Letter 89-04; Guidance On Developing Acceptable Inservice Testing Programs Page 2 changes-resulting from the NRC questions.
As a result, the current NPC copy of the program of record for. Unit No.
1 is Issue 2, Revision 3
as modified with Revision 4 (pages 4 and 11 and relief requests 6,
17, 18, and 36).
It is understood that upon receipt of the SER for the Unit No. 1 IST Program, that all relief requests will have been reviewed. by the NRC against the guidelines delineated in Generic Letter 89-04, and those that are denied should be resolved in accordance with the guidance in the SER.
The attached Revision 5 (Enclosure 1) has incorporated editorial changes and technical changes permitted by Generic Letter 89-04 and does not require NRC approval prior to implementation.
A summary of the Unit No.
1 IST Program changes is included in Enclosure 1 as.
The revised Unit No.
2 IST Program (Revision 4) is attached as Enclosure 2.
This revision incorporates editorial changes, changes permitted by Generic Letter 89-04 and changes which will require NRC approval prior to implementation.
It contains all revisions proposed since the NRC's review of Revisions 0 and 1 was documented in their SER dated March 18, 1988.
Program changes-in Revisions 2 and 3 were forwarded to the NRC on January 31, 1989 and Revision 3A was submitted on September 19, 1989.
All Revision 4 changes to the Unit No.
2
- program, including proposed changes requiring prior approval, are summarized in Attachment 1 to Enclosure 2.
We hereby request NRC approval pursuant to 10CFR50.55a(g) to incorporate these specific relief requests identified in Revision 4
into the Unit No. 2 IST Program.
We have also included as Attachment 2 in Enclosure 2 an overview describing how the Unit No. 2 IST Program conforms to Attachment 1 of Generic Letter 89-04.
There are three exceptions defined in Enclosure 2
Attachment 2 where our Unit No. 2 IST Program is not in i
complete agreement with the generic letter.
Full stroke exercising of accumulator discharge check valves (Enclosure 2,, item 3)
Full stroke-exercising of check valves in parallel flow paths (Enclosure 2, Attachment 2, item 4)
Including control room chilled water system pumps and valves in the IST Program (Enclosure 2, Attachment 2, item 5)
i i
Be;v;r VJllcy Pow r StCticn, Unit NCa. 1 &2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to Generic Letter 89-04; Guidance On Developing Acceptable Inservice Testing Programs Page 3 The full stroke exercising of the check valves in the first two ballets above are the subject of NRC review on the Unit No. 1 IST Program.
As prev 3ously stated, we will adopt for Unit No. 2 the same position approved for Unit No. 1 in the forthcoming Unit No. 1 SER.
We have also provided in Enclosure 3 copies of certain submittals previously made to the NRC on both the Unit No. 1 and No. 2 IST Programs.
Various references to these submittals have been made; we
- are, therefore, providing them for completeness to aid the NRC in performing their review.
If you have any questions regarding this submittal, please contact me or members of my staff.
Very truly yours, D. Sieber Vice President Nuclear Group Attachments cc:
Mr. J.
Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr.
P. Tain, Sr. Project Manager Mr. R. Saunders (VEPCO) (w/o Attachments)
._4' ENCLOSURE 1 1
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