ML20039H258
| ML20039H258 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/22/1981 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Carey J DUQUESNE LIGHT CO. |
| References | |
| TAC-6714, NUDOCS 8201190790 | |
| Download: ML20039H258 (6) | |
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NTC PD'R DEC 2 21981 L PDR TERA NSIC ORB #1 Rdg DEisenhut Docket flo. 50-334 OELD IE-4 ACRS-10 CParrish Mr. J. J. Carey, Vice President DChaney Duquesne Light Company SDiab fluclear Division Gray File Post Office Pox 4 Shippingport, Pennsylvania 15077
Dear l'r. Carey:
The staff review of your report on the Reactor Vessel Overpressure Protection System !?odification for Beaver Valley Power Station, Unit flo.1 has resulted in the generation of questions that need to be resolved before the review can be completed.
It is requested that you provide answers to the enclosed list of questions by February 15, 1981, to facilitate the timely resolution of this subject.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore OMB clearance is not required unit P.L.-96-511.
Sincerely, Original signed by Stev'en A. Varga, Chief Operating Reactors Branch #1 Division of Licensing
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ll Mr. J. J. Carey Duquesne Light Company cc: Mr. H. P. Williams Mr. J. D. Sieber, Manager Station Superintendent Nuclear Safety and Licensing Duquesne Light Company Duquesne Light Company Beaver Valley Power Station Nuclear Division Post Office Box 4 Post Office Box 4 Shippingport, Pennsylvania 15077 Shippingpart, Pennsylvania 15077 Mr. T. D. Jones, Manager Resident Inspector Nuclear Operations U. S. Nuclear Regulatory Commission Duquesne Light Company Post Office Box 298 Post Office Box 4 Shippingport, Pennsylvania 15077 shippingport, Pennsylvania 15077 B. F. Jones Memorial Library 663 Franklin Avenue Aliquippa, Pennsylvania 15001 Gerald Charnoff, Esquire Jay E. Silberg, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Karin Carter, Esquire Special Assistant Attorney General Bureau of Administrative Enforcement Sth Floor, Executive House Harrisburg, Pennsylvania 17120 Marvin Fein Utility Counsel City of Pittsburgh 313 City-County Building Pittsburgh, Pennsylvania 15219 Mr. John A. Levin Public Utility Commission P.O. Box 3265 Harrisburg, Pennsylvania 17120 1
Irwin A. Popowsky, Esquire Office of Consumer Advocate 1425 Strawberry Square Harrisburg, Pennsylvania 17120 Charles A. Thomas, Esquire Thomas and Thomas 212 Locust Street dox 999 Harrisburg, Pennsylvania 17108 e
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i ENCLOSURE I QUESTIONS 1.
The Branch Technical Position R$B 5-2 requires the Reactor Vessel Overpressuri-zation Protection System (RV0PS) to meet single active failure analysis when the initiating cause of the event is not considered as the single active failure.
In your failure made analysis submitted in your letter dated November 23, 1977, there were several failures of power supplies or power sources that would result in one of the PORV trains being disabled. Could the loss of any power source result in isolation of the letdown flow path,(considered the initiating eventh and also results in disabling one of the PORVs.
- If the above scenario is possible, discuss your plant's provisions to mitigate an over-pressurization transient without PORVs.
2.
The branch position requires an alarm to alert the operator to enable the OMS at the correct plant condition during cooldown.
(a) You rely on a pressure actuated alarm to perform this function. How do you ensure that the Reactor Coolant System temperature does not fall below the allowable temperature corresponding to the above alarm pressure setpoint, thus violating Appendix G limits?, (b) What assurance do you have that once the enable alarm is received, the OMS is, functional and properly lined up?
3.
Please respond to the following:
q a.
When are the RV0PS functional tests performed?
b.
How are the PORVs functionally tested?
c.
How do you ensure that these valves actually open during testing?
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The Branch Technical Position requires the RV0PS to be functional through. an Operating Basis Earthquake (OBE).
In your November 23, 1977 submittal, you identified eight valves as interim valves because they lacked seismic quali-fication and you stated that they would be replaced by appropriate Seismic Category I valves during a subsequent refueling outage.
In your followup letter of December 14, 1978, you state that the relief valves had received their seismic certification and that the RV0PS as it then existed was consi-dered the pennanent modification.
a.
How was the seismic classification resolved on the interim valves other than the relief valves mentioned in the December 14, 1978 letter?
b.
If a pipe rupture occurred in the non-seismic portion of the nitrogen supply (as shown in figure 3 of your November 23, 1977 submittal),
what would prevent the nitrogen discharge?
c.
Are the PORV operators qualified to operate through an OBE?
5.
In your March 1,1977 letter, you provided some infonnation on the training that you conducted on the overpressurization incidents; provide the following additional training infonnation.
a.
What overpressure training have you performed since 1977?
b.
How do you ensure that a continued emphasis is placed on possible over-4
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pressurization situations in your licensing and retraining programs?
c.
How is this training and LER review documented?
6.
What is the present status of the Beaver Valley, Unit 1, RV0PS?
a.
Have all permanent RV0PS installations and modifications been completed?
b.
Have warnings and caution notes been included in all affected procedures?
c.
Have all necessary administrative documentation changes been made?
7.
List all the administrative procedures and controls used to minimize the probability of an overpressure transient (i.e., solid-water operation limited to certain RCS pressure, Pressurizer heater and HPI oumps disabled at certain l
RCS pressure and temperature, etc.).
Indicate which of the above procedures
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and controls appears in your pl3nt's Technical Specifications.
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8.
If the Westinghouse generic analysis aoplies to your plant, reactor coolant pumps should not be started when water-solid and with a temperature difference of 2 50 F between the RCS and the steam generator secondary siaes. Wnat means are available at Beaver Valley to determine the representative temperature difference
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between the RCS and the steam generators?
9.
Provide current P& ids of the RV0PS including air and nitrogen systems associated with it.
- 10. What pracautions are taken when testing the RV0PS during low temperature operations in order to avoid an inadvertent pressurization event?
11.
In your November 23, 1977 letter, you state that you do not consider the safety I
injection accumulators as a credible mass input mechanism and you, therefore, did not analyze for adequacy of the RV0PS based on inadvertent accumulator injec-tion to the RCS. There have been sbveral overpressure events at plants of the same NSSS as Beaver Valley 1 where the initiating event was an inadvertent accumulator discharge to the RCS.
Explain why an inadvertent accumulator dis-charge is not credible at Beaver Valley 1.
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a.
Explain all of the procedural and administrative controls used to prevent accumulator discharge to the RCS at low temperatures, b.
How do you verify that these controls are in place and how often is this verification perfonned?
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- 12. What is the reactor pressure vessel age in effective full-power years (EEPYs) for which yotr Appendix G limits are calculated?
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