ML20006B440

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Advises That Licensee 890223 & 0317 Responses to Generic Ltr 88-17 Re Programmed Enhancements for Loss of DHR Appears to Meet Intent of Ltr But Lacks Detail.Util Suggested to Consider Listed Items to Assure Required Actions Addressed
ML20006B440
Person / Time
Site: Beaver Valley
Issue date: 01/24/1990
From: Tam P
Office of Nuclear Reactor Regulation
To: Sieber J
DUQUESNE LIGHT CO.
References
GL-88-17, TAC-69723, TAC-69724, NUDOCS 9002020174
Download: ML20006B440 (3)


Text

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(p>* **%q'o UNITED STATES

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i January 24, 1990 Docket No. 50-334 and 50-412 Mr. J. D. Sieber, Vice President Nuclear Group Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077

Dear Mr. Sieber:

SUBJECT:

BEAVER VALLEY POWER STATION - RESPONSE TO GENERIC LETTER 88-171 i

WITH RESPECT TO PROGRAMMED ENHANCEMENTS FOR LOSS OF DECAY HEAT REMOVAL FOR BEAVER VALLEY POWER STATION, UNITS 1 AND 2 (TACNOS. 69723,69724)

Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential for loss of decay heat removal (DHR) during nonpower operation.

In the GL, we requested (1) a description of your efforts to implement the eight recommended expeditious actions of.the GL, and (2) a description of the enhancements, specific plans and a schedule for implementation of the six recommended program enhancements. Our review of your efforts on the eight expeditious actions was transmitted by-letter dated April 26. 1989.

We have reviewed your response to Generic Letter 88-17 on programmed

' enhancements in the letters of February 23, 1989 and March 17, 1989. We find that it appears to meet the intent of GL 88-17 but lacks some of the details.

Your response to some items is brief and therefore does not allow us to fully-l understand your actions taken. Therefore, you may wish to consider several observations in order to assure yourselves that the required actions are adequately addressed:

1 1.

You stated that " modifications will-be completed at'each unit to provide two independent RCS level indications." You'further stated that

" visible and audible indications of abnormal conditions will be included in any modifications." From these brief and general statements we cannot tell what your two independent level systems consist of or what their accuracies are.

In your previous brief description of the level i

measuring' system for expeditious actions, it appeared that in addition to leve1~ transmitters you were including a tygon tube for level reading outside the control room. The tygon tube-type of level instrument does not qualify as one of the independent level measurement systems for use.

j under programmed enhancements.

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i 2.

You briefly discussed monitoring of the RHR system when at a reduced inventory or mid-loop condition. You indicated the recording of RHR pump amps, flow and temperature. However, you did not rention that visible and audible indications of abnormal conditions will be included as described in Enclosure 2, Section 3.1.2.4 of GL 88 17.

3.

You stated that you are revising procedures addressing normal and off. normal plant operations when entering a reduced inventory condition.

c In your list of procedures being modified, you included a " containment integrity check list for refueling to verify and maintain containment closure prior to entering a reduced RCS inventory or mid-loop condition."

This should be a concern not only for refueling but for any operation while at reduced inventory in order to keep treck of and control of the many potential containment openings which may have to be closed simultaneously.

There is no need to respond to the above observations, j

As you are aware, the expeditious actions you previously described were an interim measure to achieve an immediate reduction in risk associated with l

reduced inventory operation, and these are to be supplemented and in some cases replaced by programmed enhancements.

In your discussion on modifications for instrumentation you have indicated that the programmed enhancements will be in place for a " target date" that satisfies the time frame stated in the attachment to the GL 88 17. However, although the dates for hardware installation are in agreement with the GL 88-17, it is not apparent that changes not dependent on hardware changes will be performed-within the period stipulated (18 months from receipt of the GL 88-17).

We intend to audit your response to the programmed enhancement program. The i

areas where we do not fully understand your responses as indicated above may be covered in that audit.

This view was performed by Mr. H. Balukjian. As stated before, no response to this letter is needed.

1 Sincerely, i

/s/

Peter S. Tam, Senior Project Manager Project Directorate I-4 Division of Reactor Projects > I/II-Office of Nuclear Reactor Regulation I

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Mr. J. Sieber Beaver Valley Power Station Duquesne Light Company Units 1 & 2 cc:

Jay E. Silberg, Esquire Bureau of Radiation Protection Shaw, Pittman, Potts and Trowbridge Pennsylvania Department of 2300 N Street, N.W.

Environmental Resources Washington, DC 20037 ATTN:

R. Janati Post Office Box 2063 Kenny Grada, Manager Harrisburg, Pennsylvania 17120 Nuclear Safety Duquesne Light Company Mayor of the Borrough of P. O. Box 4 shippingport Shippingport,' Pennsylvania 15077 Post Office Box 3 Shippingport, Pennsylvania 15077 John A. Lee, Esquire Ashley C. Schannauer Duquesne Light Company Assistant City Solicitor Ons Oxford Centre City of Pittsburgh 301 Grant Street 313 City-County Building Pittsburgh, Pennsylvania 15279 Pittsburgh, Pennsylvania 15219 Commissioner Roy M. Smith Regional Administrator, Region I West Virginia Department of Labor U.S. Nuclear Regulatory Commission Building 3, Room 319 475 Allendale Road Capitol Complex King of Prussia Pennsylvania 19406 Charleston, WV 25305 John D. Borrows Resident Inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public Utilities Commission Post Office Box 181-180 East Broad Street Shippingport, Pennsylvania 15077 Columbus, Ohio 43266-0573 Director, Pennsylvania Emergency Management Agency Post Office Box 3321 Harrisburg, Pennsylvania 17105-3321 l

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