ML19345E132

Responds to Re Confirmation of Commitment to Meet Implementation Dates Contained in NUREG-0737.Requests Extension for Proposed Mods Re Auto Trip of Reactor Coolant Pumps

ML19345E132
Person / Time
Site:	Beaver Valley
Issue date:	12/17/1980
From:	Dunn C DUQUESNE LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 TAC-45275, NUDOCS 8012230299
Download: ML19345E132 (4)

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December 17, 1980 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn:

Mr. Daniel G. Eisenhut, Director Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No.1 Docket No. 50-334 D. G. Eisenhut's letter dated October 31, 1980 Gentlemen:

Mr. Eisenhut's letter requested that we furnish confirmation of our commitment to meet the implementation dates contained in NUREG-0737,

" Clarification of TMI Action Plan Requirements." We have reviewed of NUREG-0737 and the implementation dates contained therein and have determined that we are able to commit to all the implementation dates except for the following action items.

II.K.3.2 Report On Overall Safety Effect On Power Operated Relief Valve Isolation System Duquesne Light Company is participating in the Westinghouse Owners Group which is in the process of developing a report which includes his-torical valve failure rate and documentation of actions t.tken since the TMI-2 event to decrease the probability of a stuck open power operated relief valve (PORV). Due to the time consuming process of gathering, breakdown and evaluation of data, this report will not be submitted by the required date.

The Owners Group will submit the required report on March 1, 1981. This report will be used to support a decision on the necessity of an automatic PORV isolation system.

II.K.3.7 Auto Trip Of Reactor Coolant Pumps The Westinghouse Owners Group resolution of this issue has been to perform analyses using the Westinghouse small break evaluation model (WFLASH) to show ample time is available for the operator to trip the reactor coolant pumps following certain size small breaks (ref.

WCAP-9584). In addition, the Owners Group is supporting a best estimate study using the NOTRUMP computer code to demonstrate that tripping the reactor coolant pump at the worst trip time following a small break will lead to acceptable results. For both of these analyses efforts, the Owners Group is performing blind post-test predictions of LOFT experiment O

L3-6.

The input data and model to be used with WFLASH on LOFT L3-6 was S

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Beaver Valley Power Station, Unit No.1 Docket No. 50-334 D. G. Eisenhut's letter dated October 31, 1980 Page 2 previously submitted to the NRC staff on December 1, 1980 by Westinghouse for the Owners Group. The information to be used with NOTRUMP on LOFT L3-6 will be submitted to the NRC staf f prior to the performance of the L3-6 test.

The LOFT prediction from both models will be submitted to the NRC staff on February 15, 1980 given that the LOFT test is performed by the schedule provided in NUREG-0737. The best estimate study is scheduled for completion by April 1, 1981. Based on these studies, the Westinghouse Owners Group believes the resolution of this issue will be achieved without any design modifications.

In the event that this is not the case, a schedule will be provided for potential modifications.

We believe that the extended dates proposed are justified since both reports are to be used to identify proposed modifications which are due to be submitted by July 1,1981.

The short extensions will allow Owners Group members to better evaluate report results and propose modifications, if necessary, that will be acceptable to both the NRC staff and utility members.

We would like to point out, at this time, action items for which we presently believe the commitment dates are attainable but would like to further expand our position.

II.F.2 Instrumentation For Detection Of Inadequate Core Cooling In our letter of June 26, 1980, we indicated that we had purchased the generic Westinghouse Reactor Vessel Level Instrumentation System as additional instrumentation to provide more positive indication of inade-quate core cooling. We are proceeding in the engineering and design for the installation of this system and we expect to meet the commitment date of January 1, 1982 contained in NUREG-0737. However, Duquesne Light Company is aware of the ongoing research and development of additional reactor vessel level systems which at the present time are not sufficiently developed te be commercially available. We expect to monitor the progress and developuent of these systems, and would retain the option of selecting a system different than the one we presently propose. This may, at the time, require additional discussions with the NRC staff and revised commitment dates. We believe that in our efforts to meet the requirements of the TMI action plan and provide the equipment necessary to operate the plant as safely as is achievable this option must be made available.

II.K.3.30 Small Break LOCA Methods II.K.3.31 Compliance With 10 CFR 50.46 The present Westinghouse small-break model used to analyze Beaver Valley is in conformance with 10 CFR 50 Appendix K.

However, Westinghouse has indi-cated that they will address the schedule for completion by January 1,1982.

Westinghouse provided a detailed outline of the scope and schedule for this effort was submitted to the NBC staff on September 26, 1980.

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Beaver Valley Power Station, Unit No. 1 I

Docket No. 50-334 l

D. G. Eisenhut's letter dated October 31, 1980 Page 3 i

l If the results of the new Westinghouse model and subsequent NRC staff review and approval indicate the present small-break 1,0CA analyses for Beaver Valley are not in conformance with 10 CFR 50.46, a new analysis l

utilizing the new and approved Westinghouse model will be submitted in

- accordance with the schedule contained in NUREG-0737 provided the NRC j

staff review and. approval supports the schedule.

If you have any questions, please contact my office.

Very truly yours, l

o C. N. Dunn Vice President, Operations cc:

Mr. D. A. Beckman, Resident Inspector U.S. Nuclear Regulatory Commission j

Beaver Valley Pov-er Station Shippingport, PA 15077 U.S. Nuclear Regulatory Commission i

c/o Document Management Branch Washington, DC 20555 j

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Secretary COMMONWEALTH OF PENNSYLVANIA)

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COUNTY OF ALLEGHENY On this

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1980, before me, Tnmnw etnewn,

, a Notary Public in and for said Commonwealth and' County'," personally appeared E. J. Woolever, who being duly sworn, deposed, and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said company, and (3) the state-ments set forth in the Submittal are true and co'rrect to the best of his knowledge, information and belief.

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