ML20054D638
| ML20054D638 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/16/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.3.1, TASK-2.B.2, TASK-2.B.3, TASK-2.B.4, TASK-2.E.1.2, TASK-2.E.4.2, TASK-2.F.1, TASK-TM GL-82-05, GL-82-5, TAC-44830, NUDOCS 8204230221 | |
| Download: ML20054D638 (4) | |
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Telephone (412) 456 6000 O
Nuclear Division P.O. Box 4 Shippingpod, PA 150 4 0004
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Apr11 16, 1982 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn:
Mr. Darrell G. Eisenhut, Director Division of Licensing Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. l Docket No. 50-334, License No. DPR-66 Ceneric Letter Nr. 82-05 (NUREC-0737)
Gentlemen:
This is in response to your letter of March 17, 1982, Generic Letter No. 82-05, Pos t - TMI Requirements whereby you requested a firm schedule or a reconfirmation of scheduled dates for selected NUREG-0737 items.
The following describes the present status of each selected item.
Item I.A.3.1 Simulator Exams We have satisfied the requirements of this item by scheduling simulator time for license applicants.
Your Generic Letter No. 81-29 of August 7, 1981 requested our schedule for exams and reiterated the requirement that simulator exams should be scheduled consecutively with the balance of the NRC examination but that an allowance of up to two weeks is acceptabic for any scheduling dif fer-ences.
Our response of October 1,1981 indicated the difficulty with committing to scheduling blocks of simulator time coordinated to end within two weeks of the written exam.
You replied to our letter on October 13, 1981 and deleted the NUREG-0737 requirements of the two-week provision for scheduling simulator exams with the written exam.
On November 6, 198], we provided our schedule for simulator exams for 1982 and 1983 thus demonstrating our compliance with this item.
II.B.2 Plan t Shielding The schedule for completing this item was included in our December 30, 1981 submittal wherein we stated the plant modifications would be completed prior to start-up from our second refueling outage.
On March 12, 1982 the modification satisfying this NUREG item was completed.
II.B.3 Post Accident Sampling The schedule for completing this item was included in our December 30, 1981 submittal wherein we stated the plant modifications would be completed prior to start-up from our second refueling outage.
This item and others which were to be implemented by January 1, 1982 were scheduled for installation during the second refueling outage originally scheduled to begin December 31, 1981.
Our justification for this schedule provided for continued operation until the refueling outage, at which time, the refueling and TMI modifications would be j
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o Beaver Valley Power Station Unit No. l o
Docket No. 50-334, License No. DPR-66 Ceneric Letter No. 82-05 (NUREG-0737)
Page 2 worked concurrently. Our compensatory measures for items of this type was to have the plant in a shutdown condition as of January l, 1982.
This plant modification is currently in progress with completion expected prior to plant start-up with the exception of the Boron and Chloride analyzers.
Due to equipment delivery problems, we do not expect to install these analyzers prior to plant start-up.
As an interium method of determining boron and chloride concentrations, samples collected from the Post Accident Sampling System will be analyzed in the Chemistry Laboratory. The on line analyzers will be installed upon their arrival.
II.B.4 Training for Mitigating Core Damage The training for Mitigating Core Damage was completed on November 27, 1981.
Additionally, the NRC Office of Inspection and Enforcement inspected this item as documented in Inspection Reports 8l-18 and 82-05.
Report 81-18 verified course content and attendance as of that inspection period and Report 82-05 confirmed the completion of this training and closed this item.
II.E.L.2 Auxiliary Feedwater Initiation and Flow Indicator The plant modification to upgrade auxiliary feedwater system initiation and flow indication was completed on June 30,198L.
II.E.4.2 Containment Isolation Dependability - Part 5 In our December 31, L980 submittal, we provided justification for retaining our present containment pressure setpoint thereby eliminating the need for plant modifications.
Your letter of December 11, l981 documented the NRC review of the above submittal and the determination that our containment isolation pressure setpoint meets the criteria of NUREG-0737 and the additional limiting guidelines
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provided by the NRC staff. Additionally, this item was inspected by the NRC Of fice of Inspection and Enforcement and is documented in Inspection Report 82-01.
We therefore consider this item closed as of Decembar 11, 1981.
II.E.4.2 Containment Isolation Dependability - Part 7 This item was the subject of a related NRC review ef fort documented as "The Override and Reset of Control Circuitry in the Ventilation / Purge Isolation and Other Engineered Safety Feature Systems" and was issued to Duquesne Light on April 29, 198L. We reported in our submittal of July 1,198L that the requirement for purge and vent valves to close on a high radiation signal during operation was not applicable to Beaver Valley Power Station due to the subatmospheric containment design. This requirement was reviewed and determined as not ap-plicabic by the NRC via your letter of April 29, L98L.
Additionally, this item was inspected by the NRC Of fice of Inspection and Enforcement and is documented in Inspection Report 82-01.
We therefore consider this item closed as of April 29, 1981.
o Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-05 (NUREG-0737)
Page 3 II.F.1 Accident Monitoring, (1) Noble Gas Effluent Monitor Our submittal of November 9, 1981, in response to your letter of October 7, 1981 requested permission to defer installation of this equipment until our second refueling and modification outage.
Our justification for this schedule and the in compensatory measures being taken are the same as indicated in our response item II.B.3.
This plant modification is currently in progress with completion expected prior to plant start-up.
II.F.1 Accident Monitoring, (2) Ef fluent }bnitoring of Iodine Our response to this item is the same as for item II.F.1 part (1)
Noble Gas Effluent }bnitor.
II.F.1 Accident Monitoring, (3) In-Containment Radiation Monitor The schedule for completing this item was included in our December 30, 1981 submittal wherein we stated the plant modifications would be completed prior to start-up from our second refueling outage.
Our justification for this schedule and the compensatory measures being taken are the same as indicated in our response in item II.B.3.
On March 19, 1982 we provided a submittal documenting a deviation to your stated position regarding equip-ment qualification. The qualification of the containment penetration / cable termination is still in progress, and the schedule as stated at that time has not changed. This plant modification is currently in progress with com-pletion expected prior to plant start-up.
II.F.1 Accident Monitoring, (4) Containment Pressure Ibnitor As reported in our submittal of December 30, 1981, the plant modifica-tions have been completed for this item.
However, the pressure transmitters which were installed were qualified to IEEE Standard 323-1971, rather than the 1974 edition, and as such they do not meet the staffs requirements re-lated to qualification as stated in NUREG-0737. We have met the implementa-tion date by installing the best available equipment in accordance with your clarification provided in NUREG-0737, Appendix B.
We plan to replace these pressure transmitters when fully qualified and suitable equipment becomes available.
Since qualified equipment suitable for this application has not yet been located by us, no schedule for replacement can be submitted. We are presently developing a program which will provide a means of identifying and tracking equipment which has qualification deficiencies and which must be replaced and a method for following the industry progress for supplying qual-ified equipment and a method for developing replacement schedules for this equipment.
This is being accomplished as part of our equipment qualification ef fort and as such, all installed equipment of this type will be handled in accordance with this program.
11.F.1 Accident Monitoring, (5) Containment Water Level Our submittal of December 30, 1981 indicated the plant modification to support this item would be completed prior to start-up from this second refueling outage. However, all modifications had been completed at that time.
' Beaver Valley Power Station Docket No.- 50-334, License No. DPR-66 Generic Letter No. 82-05 (NUREG-0737)
Page 4 The level transmitters installed were qualified to IEEE standard 323-1971 rather than the 1974 edition and as such do not meet the staffs require-ments related to qualification as stated in NUREG-0737.
The level instru-ments installed were the best available at the time of purchase. We have been unable to locate a supplier who manufactures instruments, suitable for this application, which meets the qualification. requirements of IEEE 323-1974 and therefore, we cannot supply a schedule for replacement of this instrument at this time.
Our handling of this equipment will be accomplished in the same manner as indicated in our response to item II.F.1, Part (4) 4 above.
4 II.F.1 Accident Monitoring, (6) Hydrogen Concentration in Containment Our response to this item is the same as for item II.B.3 1
l We are presently performing an in-depth technical review of the degree of compliance of all NUREG-0737 design changes with the technical require-ments of NUREG-0737.
We shall inform you of all deviations identified by this review and provide a schedule for resolution of these deviations upon the completion of our review of this ef fort.
Our present schedule for completing our second refueling / modification outage is May 21, 1982. The above status should satisfy your request for information concerning completion of these' specific NUREG-0737 items.
If you have any questions, please contact my office.
i Very truly yours, J
J. J. Carey Vice President, Nuclear cc:
Mr. D. A. Beckman, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport,-PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 i
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