ML19345G507
| ML19345G507 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/01/1981 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM TAC-47267, NUDOCS 8104070406 | |
| Download: ML19345G507 (2) | |
Text
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'Af (412) 456-6000 435 S.am Ave %e u gft. Pa r
April 1, 198 f.),.1 di},,,
El Director of Nuclear Reactor Regulation V
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p0 United SMtes Nuclear Regulatory Commission
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Attn:
Mr. Steven A. Varga, Chief 7
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Operating Reactors Branch No. 1 c
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Division of Licensing Dh
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Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 NUREG-0737 - Action Item I.C.6 Gentlemen:
In our letter to Mr. Eisenhut dated December 17, 1980, we indicoted that we would be able to meet the implementation date of January 1,1981 for NUREG-0737 action item I.C.6 - Guidance On Procedure For Verifying Correct Performance Of Operating Activities. The purpose of this letter is to inform you that with the present station manpower complement we have had extreme difficulty in implementing the requirements of this action item and we would like to request an exemption to delay the implementation date until July 1, 1982.
The requirements of item I.C.6, when issued as a new action item in Mr. Eisenhut's letter of October 31, 1980, were reviewed and determined to be achievable.
It has become apparent that to meet the requirements of item I.C.6 in its entirety, additional qualified manpower must be made available to the station operating staff.
We have reviewed the station administrative controlc that are presently in effect and have determined that the following controls help assure opera-bility of ESF equipment, which we believe is the ultimate intent of item I.C.6.
1.
The key in line flow path manual valves in the Emergency Core Cooling Systems (ECCS) and Auxiliary Feedwater System (AFS) are visually checked for proper system alignment once per shift.
2.
The AFS system flow path alignment is verified by two independent operators af ter performance of surveillance testing.
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1 Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 NUREG-0737 - Action Item I.C.6 Page 2 3.
The ESF clearance checklist requires independent verification of the correct clearance points before placing ESF equipment on clearance, and two independent signatures to authorize the removal of the equipment from service.
The checklist also requires two independent signatures for the operability of the standby system.
4.
The shift turnover logs for the Nuclear Control Operators and Shift Foremen require review s.
the ESF system status board.
The shif t foremen are also required to perform a comprehensive review of all ESF control room control switches to ensure equipment is in the proper alignment and standby availability for the existing plant mode is met.
5.
The Shif t Supervisor's turnover checklist requires that he review the control and vertical boards to check the general status of equipment and look for deviations. The Shift Supervisor also maintains an ESF status board of all ECCS flow paths for updating during maintenance or off-normal conditions.
We-believe that the aforementioned controls are adequate interim measures and to be consistent with the requirements of NUREG-0737 action
' item I.A.l.3,' Shift Manning, we request that we be granted an exemption to, delay the implementation date of item I.C.6 until such time as a sufficient number of trained, etalified operating persornel are available to perform these activities. We are presently adding personnel to'our operating staff. We expect these new employees to be fully trained and
- qualified by. July 1, 1982.
Very truly yours, 6
J. J. Carey-Vice President, Nuclear cc:
D. A. Beckman, Resident Inspector U.S. Nuclear Regulatory Commission Beaver ValJay Power Station
.Shippingport, PA 15077 U.S.-Nuclear Regulatory. Commission' c/o Document Management Branch Washington, DC 20555
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