ML20054F193

Provides Status of Listed NUREG-0737 Items in Response to Generic Ltr 82-10, Post-TMI Requirements

ML20054F193
Person / Time
Site:	Beaver Valley
Issue date:	06/08/1982
From:	Carey J DUQUESNE LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-1.C.1, TASK-2.D.1, TASK-2.K.3.30, TASK-2.K.3.31, TASK-3.A.1.2, TASK-3.A.2.2, TASK-3.D.3.4, TASK-TM GL-82-02, GL-82-10, GL-82-2, TAC-48146, NUDOCS 8206150298
Download: ML20054F193 (11)

Text

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"*F Telephone (412) 4564000 Nuclear Division P.O. Box 4 Shippingport, PA 150774004 June 8, 1982 Lirector of Nuclear Reactor Regulation United States Nuclear Pegulatory Commission Attn: Mr. Darrell G. Eisenhut, Director Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-10 (NUREG-0737)

Lentlemen:

This is in response to your letter of May 5, 1982, Generic Letter No. 82-10, Post-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 item:

1.A.l.3.1 Shift Manning: Limit overtime The NRC policy statement issued by Generic i.etter 82-02, as amended in the Federal Register on June 1, 1982 (Volume 47, No. l')S), has been reviewed to determine the impact en existing guidelines which schedule overtime. We acknowledge the NRC's objective to have operating personnel work a normal 8-hour day, 40-hour week and to only schedule overtime when neces sa ry.

With regard to our licensed operating staf f, we will be unable to meet this objective for the following reasons:

- a large attrition rate of licensed personnel resulting in a small licensed staff

- the need for work schedules which support the minimum shift crew during periods of time when retraining or vacations are scheduled

- the need for overtime to support shift coverage when an employee reports off sick This condition is expected to continue through 1962 and 1983. We expect to have additional licensed personnel late in 1983 such that a five shift schedule may be implemented which will provide the relief needed to support the common objective of an 8-hour day, 40-hour week.

8206150298 820608 x 8 PDR ADOCK 05000334 P PDR Y

. Basvar Vallsy Powar Ststion, Unit No.1 -

Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-10 (NUREG-0737)

June 8, 1982 Page 2 We will implement the four enumerated overtime scheduling guide-lines as set forth in FR 23836 dated June 1,1982 by the recommended implementation date of October 1, 1982. For this purpose, we interpret the title " health physicists" to mean " Radiation Control Technicians" and we believe that the term " key maintenance personnel" to correspond to " Meter and Control Repairmen" at our facility. It will be our policy to extend these guidelines to all personnel actually performing work on safety related equipment.

I.A.1.3.2 Shift Manning: Minimum Shift Crew Action on this item is complete. Our letter of October 29, 1980 addressed the Staff concerns for minimum shift crew and documented how compliance would be achieved. On September 17, 1980, we submitted pro-posed changes to our Technical Specifications specifying the minimum shif t crew in accordance with NUREG-0737. This change request was ap-proved and issued by the NRC as Amendment 39 on February 11, 1981.

I.C.1 Revise Emergency Procedures The Westinghouse Owners' Group (WOG) has been developing the emer-gency guidelines which are to be used for the development of plant specific procedures. At the present time, we are reviewing the emergency response guidelines which have been received from the WOG. The recommended schedule,.

as published in Generic Letter 82-10, of the first refueling af ter October 1, 1982, is our present goal for completing this effort; however, we understand.

that the Commissioners are presently considering a revised implementation schedule for this item under the topic of SECY 82-111, " Requirements For Emergency Response Capability". It is also our understanding that Commission action on this document is expected in the near future. We will provide additional information on our ability to meet the implementation schedule when the results of the Commission action has been published.

II.D.l.2 Relief Valve and Safety Valve Test Program This item requires plant-specific submittals by April 1, 1982, con-firming adequacy of safety and relief valves based on licensee preliminary review of generic test program results. We provided our submittal on March 29,1982 confirming that the valves tested adequately represent the safety and relief valve designs and the conditions for Beaver Valley Power Station, Unit No. 1 II.D.1.3 Block Valve Test Program The block valve test program was discussed with the NRC Staff and representatives of the PWR utilities on July 17, 1981, and documented in a letter to Mr. Harold Denton from Mr. R. C. Youngdahl of Consumers Power Company, representing the utilities, on July 24, 1981. A test program position stating that additional block valve testing would not be necessary was presented based on the relief valve test program results and the results of block valve tests performed at the Marshall facility. The test data accumulated from this program contains information applicable to our block valves and will be provided as required to satisfy this NUREG-0737 item by July 1, 1982.

Bexver Valley Power Station, Unit No.1

. Docket No. 50-334. Licenna No. DPR-66 Generic Letter ho. 82-10 (NUREG-0737)

June 8, 1982 Page 3 II.K.3.30 and 31 Small-Break LOCA Analysis This item requires that the analysis methods used by NSSS vendors for small-break LOCA analysis for compliance with Appendix K to 10 CFR part 50 and 10 CFR 50.46 be revised, documented and submitted for NRC approval.

The plant specific analysis is to be submitted to the NRC one year af ter the Staff's approval of the revised SB-LOCA model. Our understanding is that on March 31, 1982, the Westinghouse Electric Corporation submitted their new small-break model under the title WCAP 10054, and they are presently awaiting the Staff's review and approval. It is expected that we can support the recommended schedule following the NRC Staff approval of the new small-break LOCA analysis model.

III.A.l.2 Staffing Levels for Emergency Situations Our response to Generic Letter 81-10 dated April 8,1981, indicated that the staffing requirements of Table III.A.1.2-1 would be achieved. We amended this commitment on August 25, 1981, indicating that implementation of the staffing requirements within the specified time periods is not physically achievable at the Beaver Valley Power Station. During the period of October 4-16, 1981, the Office of Inspection and Enforcement conducted an appraisal of our emergency preparedness program. Subsequently, a con-firmatory action letter dated November 2,1981 was issued requesting a study be performed to determine how the augmentation of the onshif t staff could be attained within the time constraints identified in Generic Letter 81-10. The results of this study were provided to the NRC on January 5,1982, and indicated that the on-shift personnel could be augmented with called-in personnel in about 30 minutes, with complete activation within about 60 minutes. This represents a best time estimate and does not take into account f ailures of the paging devices to alert personnel and the subsequent delays in sequentially locating designated alternates. As stated in our August 25 letter, we do not feel we can realistically commit to 100% activation within 30 minutes for every occasion. The results of this evaluation are attached to this letter as Attachment 1. This report identifies the various emergency organization functions, the on-shift and augmentation personnel who would perform those functions, and the expected low, mean and high travel times for these personnel. This evaluation indicated that the BVPS Emergency Organization is responsive to the criteria of Table III.A.1.2-1. In addition to this study, Duquesne Light has increased the on-duty shift complement to ten individuals with the addition of an Administrative Aide to the Shif t Supervisor. In an emergency situation, this individual is assigned the responsibility for notifications and communications until relieved by the designated Communica-tions and Records personnel.

On April 28, 1982, IE Inspection Report 81-27 (Emergency Preparedness Appraisal was issued which reiterated the concerns identified in the con-firmatory action letter. Our response of May 28, 1982 addressed each of the NRC concerns for staf fing levels for emergency situations which repre-sents our formal position on staffing levels and is consistent with state-ment contained herein.

Beaver Valley Powar Station, Unit No.1

. Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-10 (NUREG-0737)

June 8, 1982

.Page 4 III. A.l.2 Upgrade Emergency Support Facilities In our letter dated June 15, 1981 we had stated that the Emergency l Response Facility (ERF) would be operational by June 1, 1983. Currently, eight separate Design Change Packages have been issued in support of the ERF and its ancillary functions.- They are:

DCP 400 Meteorological Systems Upgrade DCP 296/366 ERF Communications / Instrumentation DCP 398 Technical Support Center Substation DCP 331 ERF Structure DCP 529 ERF Domestic Water System DCP 394 Backup Instrumentation for the Meteorological System DCP 509 Fire Protection for the ERF The current projected cost for completing the ERF exceeds 50 million dolla rs . Over one third of this money has been expended in support of this activity as of the first quarter of this year.

Based on receipt of all electrical and communications equipment by February,1983, we will complete construction of the ERF structures prior to start-up from the third refueling in 1983. At this time, we will have sufficient information input to the computer systems, to enable the Tech-nical Support Center personnel to assist the Control Room Operator in evaluating the status of the plant under emergency conditions. This schedule is necessary since the tie in and testing of the majority of the circuits between the plant and the ERF can only be performed during an extended outage.

This is necessary to insure that protective and control functions are not l affected, and will limit the amount of construction activities in the control '

room and safety related areas during operation. The remainder of the com-puter interfacing and testing will be completed during the fourth refueling outage, presently anticipated to occur in early 1985.

Our Electrical Engineering Department had set early goals to provide ,

design outputs to our Construction Department such that 95% of the para- '

meters listed in Regulatory Cuide 1.97 would be available for display, stored or printed for retrieval purposes at the locations required by NUREG 0696.

The remaining 5% require a significant amount of additional evaluation and engineering per parameter as compared to the 95% which were readily available.

With the issuance of each additional regulatory document, including new criteria contained in NUREG 0814, " Methodology for Evaluation of Emergency l Response Facilities", it became increasingly difficult to determine exactly what the final requirements for the ERF would be.

Your letter dated November 9,1981 requested information you required to evaluate and approve conceptual designs for our ERF. Although this letter was later withdrawn, it created a redirection of engineering and licensing activities that ultimately raised numerous questions with regard to the overall schedule of the ERF, which could not be considered in a con-ceptual stage at this late date. The more significant engineering delays j encountered have been due to the following problems: l i

Braver Vell:y Power Station, Unit No.1

. Dock t No. 50-334, Licensa No. DPR-66 Generic Letter No. 82-10 (NUREG-0737)

June 8, 1982 Page 5

- Backfitting several highly reliable computer data acquisition systems to interface with a large portion of existing station equipment;

- Lack of detailed engineering information on equipment from suppliers which is required to complete engineering design.

- Regulatory requirements on modifications which have been established since the initial licensing of the plant are much more restrictive than those to which the original plant was designed, built, and licensed;

- The final NUREG-0696 and Reg. Guide 1.97 are more stringent than original drafts;

- Delays in delivery dates from suppliers; We have placed separate orders to Westinghouse (April 1980) and Bailey Control Companies (March 1980) for a SPDS Computer and a 1.97 Plant Variable Computer System respectively.

The NRC Staff extended the completion date, but also increased the reliability and qualification requirements of these computer systems and their respective interfaces. We were already financially tied with the above suppliers, requested proposals and schedules for these additions and redirected our engineering efforts per the revised requirements.

Even though these systems were originally promised to be shipped for installation prior to 1981, neither supplier is ready to ship a system today which will meet the revised NUREG's and Regulatory Guides. The SPDS Computer supplier will not commit to a firm date to provide the system drawings re-quired for the preparation of detailed installation drawings. The PVS Computer supplier has not yet responded with a quotation for the Historical Data Storage and Retrieval Function which was discussed in mid 1981. The same type of pro-blem exists with other equipment suppliers as well as qualification problems for Category I isolation equipment. The equipment suppliers have not yet supplied the necessary engineering information required to provide design outputs such as wiring diagrams, etc.

BVPS No. I was designed and constructed in the late 1960's - early 1970's and licensed per the applicable standards and regulations at that time. The primary process electrical equipment is Westinghouse 7100 series equipment which cannot be qualified to the present standards for Category I equipment (Ref. IEEE Std. 384). Design and installation of additional raceway and cable is extremely difficult due to the congested trays, conduit, and areas where new raceway would have to be installed to interface with existing equipment (Ref. IEEE Std. 384; 10 CFR 50 - App. R). Installation of additional equipment and cabinets is dif ficult due to the same reasons. Much of this space has been filled by various plant modifications made since the original licensing of the plant.

Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-10 (NUREG-0737)

June 8, 1982 Page 6 With the limited amount of space available in the existing process rack room, detailed raceway and conduit schedules could not be developed prior to the completion of the NUREG-0737 required modifications which have been installed during the present refueling outage.

Justification for interim operation is based on the design adequacy of our interim Technical Support Center and Emergency Operation Facility in that it:

- provides all requisite information necessary to assist the operator in determining plant safety status;

- relieves control room personnel of peripheral duties and communications not directly related to plant operations;

- prevents congestion in the control room;

- provides assistance to operations by technical personnel who have comprehensive data acquisition capabilities at their disposal;

- provides a co-ordinated means for management and technical personnel to communicate and manage an event at a central location with of fsite agencies.

Our interim Technical Support Center and Emergency Operations Facility will continue to provide these capabilities until such time that the Emergency Response Facility is operational. We have successfully demonstrated the func-tional capability of our alternate Technical Support Center and Emergency Operations Facility during our full scale EPP drill. This drill was performed on February 17, 1982 and documented in Inspection Report 82-04 dated March 24, 1982. This report contained no significant findings attributable to the use of the interim facility.

III.A.2.2 Meteorological Data This item requires plant modifications to be completed by October 1,1982, which will provide meterological data for use in evaluating the offsite con-sequences of a radiological emergency condition. We have recently placed a nurchase order to obtain the equipment necessary to provide this monitoring capability. Several months were spent reviewing proposals for this equipment and evaluating it against our needs to determine which will best satisfy our design philosophy. Our schedule for procuring, installing and testing this equipment remains consistent with out earlier commitment of December 1983, as documented in our letter of July 2, 1981. In the interim, we vill continue to assess the offsite consequences of a radiological emergency condition through the use of our dose projection implementing procedures contained in our Emergency Preparedness Plan.

Seaver Valley Power Station, Unit No. 1

. Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-10 (NUREG-0737)

June 8, 1982 Page 7 III.D.3.4 Control Room Habitability C

t This item required that we perform an evaluation and recommend appropriate modifications to meet control room habitability requirements. On December 31, 1980 we provided the results of our evaluation with the modifications believed to be necessary at that time. On December 28, 1981, we submitted an additional study which represented the results of an intensive engineering review to identify which toxic gasses would require monitoring and to fully define the extent of the changes required to our ventilation system. The analysis con-cluded that the only chemical requiring monitoring is chlorine for which we have an installed de tection system. The aggregate probability of all other toxic gas releases that would result in exposures greater than 10 CFR 100 guidelines was found to be lower than the design basis probability identified in the Standard Review Plan. It was determined that additional modifications would not be necessary. However, we are presently establishing firm communica-tions links with local industry and enforcement officials such that our faci-lity will receive priority notification during any spill or gas release and Control Room Ventilation isolation can be ef fected immediately. We received Staf f notification of concurrence with our analysis on February 9,1982 stating agreement that the control room habitability systems will provide safe, habit-able conditions within the control room under both toxic gas and radiological releases and the design meets the criteria identified in item III.D.3.4 of NUREG-0737.

If you have any questions, please contact my office.

Very trul yours, J. J. Carey Vice President, Nuclear cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Locument Management Branch Washington, DC 20555

DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Response to Generic Letter No. 82-10 dated May 5, 1982 Attachment #1 Emergency Organization Augmentation Times Introduction This document provides the results of the evaluation performed to determine the time required to augment the Beaver Valley Power Station emergency organization in the event of an emergency condition requiring the activation of the Technical Support Center and/or Emergency Operations Facility. This evaluation was performed in response to the Emergency Preparedness Appraisal and was based on a comparison of the BVPS emergency organization and " Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants".

Methodology-The evaluation was performed in two pbases. The first phase was to determine the travel time required by the designated personnel to arrive at the site following notification. Questionnaires were distributed to the supervisory personnel designated as primaries and alternates to each emergency position.

Each person responded with the normal travel time from their residences to the station.

The individual travel times were increased by 10 minutes each to provide for preparation time prior to departure. No adjustments were made for notification time as the primary individuals are provided personal radio paging devices which are simultaneously keyed by the paging services (2) called by the shif t personnel. -

Personnel within this group are identified by a letter "B" in the column marked "means of notification" on Table 1, which is attached to this appendix.

Table 1 tabulates the low, mean, and high adjusted travel times for these personnel.

For supplementary personnel, most of which are bargaining unit or contractor personnel, a different methodology was employed. An area map was annotated with the residence and travel time of each individual who was provided questionnaires.

The residence of each supplementary person was located on this map and travel time extrapolated from adjacent data points. In addition, the individuals responsible for initiating these call-outs have been provided personal radio paging devices. We expect that these call-outs could be completed within about 15 minutes. Since the call-out times wi:1 vary depending on the individual's position on the call-list, no adjustments were made for notification time.

However, the previously discussed 10 minute preparation time was incorporated.

These supplementary personnel are identified on Table 1, by the Letter "C" in the column marked "means of notification".

Re:pon:c to Gansric Letter No. 82-10 i

. dated May 5,1982 ,

Page 2 l l

The second phase of this evaluation involved the comparison of the derived BVPS augmentation times with the guidance of Table B-1 of NUREG-0654. A matrix identifying emergency function, major tasks, designated shift and ncn-shif t personnel, non-shif t augmentation times derived in phase 1, and NUREG-0654 Table B-1 requirments, was prepared. This matrix is attached as Table l'to this appendix.

A Results As can be seen on Table 1, Duquesne Light has the capability to substantially augment its on-shift pesonnel within the guidance of Table B-1 of NUREG-0654 under favorable conditions. No provision has been made in this evaluation for failure of radio paging devices, or the time necessary to sequentially locate designated alternates. As we expressed in our letter of August 25, 1981, we do not feel that we can commit to 100% avgmentation within 30 minutes of personnel notification, llowever, we will continue to maintain an emergency organizatio's and a notification system which will have the objective of meeting the 30-minute response criterion.

I l

l t

' TABLE I Augment. NUREG Position Title Times * -0654 Major Functional to Mean '41 30 60 Area Major Tasks Onshift Offshift

~

?lant Operations NSS 1

& assess =ent of NSOF 1 opsrational NCO 2 NO 2 STA 1 E=srgsney dir. & NSS 1* Em. Dir. 30 50 70 3 - -

Control (3/3)

NSS 1 C & RC 30 46 70 3 1 2 Notification & Notify licensee, Co==unication state, local & Asst. (2/5) l Federal Personnel

& maintain comm- C & RC 25 41 70 C l Assts.

l 1 cations I (17) 1 E/RM 50 63 65 3 - 1 Radrological EOF Director NSS accident assess- (4/4) cent & support NSS 1 EA & DP 30 41 35 3 1 -

of ops. accident Offsite dose assessment projection NSOF 1 (2/4)

SCRT 1 RCT 20 40 75 C 2 2 Offsite surveys (17)

SCRT 1 RCT 20 49 75 C 1 1 Onsite surveys (Outside Plant) (17)

SCRT 1 RCT 20 49 75 C 1 1 Inplant surveys (17)

Chemistry SCT 1 CT 20 46 75 C -

1 (10)

Plant system Tech. support STA 1 TSC 25 50 75 B - -

eng, repair, (1/3) corr. actions Core & hydraul. STA 1 off-duty 25 40 50 C 1 -

tech. supp. STA (6)

Electrical STA 1 Elec+

tech supp. Eng. (2) 55 55 55

_-- ]

. Mechanical STA 1 Maint. 30 50 70 C -

1 tech. supp. Eng. (2) i Mech. Maint. NO 1** Maint. 35 35 35 3 --

1 l Coo:d.

(1/2)

OSC 40 40 40 3 (1/2)

Radwaste oper. '0 1** off-duty 15 40 65 C -

1 NSOF/NO

l Augnent. NUREG Major Functional Position Title Tines * -0654 Area Major Tasks Onshift Offshift to Mean Hi 30 60

=

l Electr. Maint. NO 1** OSC 45 45 45 3 1 1 (1/2)

_==

Inst. & Control NO 1** MCR 20 45 65 3 1 --

(1/4)

Protective Radiation Prot. SRCT 1 RCC 30 40 55 3 2 2 actions (onsite) (2/5)

RCT 20 49 75 C (17)

Firefighting Fireiighting Shift Local - - - Local emerg. Support Supp.

squad

______-__-- _===

Rescue & First Rescue & First Shift Local Local aid aid emerg. Support Supp.

squad Site access control in accordance with site security plan State / Local ECC Liaison with Nuclear as requested by agencies Instrs, offsite agencies Abbreviations:

NSS Nuclear Shift Supervisor NSS Asst. Nuclear Shift Supervisor Administrative Assistant NSOF Nuclear Shift Foreman NCO Nuclear Control Operator 50 Nuclear Operator STA Shift Technical Advisor SRCT Shift RadCon Technician SCT Shift Chenistry Technician RCC Radiological Controls Coordinator RCT RadCon Technician CT Chemistry Technician MCR Meter & Control Repairmen (I & C)

TSC Technical Support Coordinator OSC Operations Support Center Coordinator E/RM Energency/ Recovery Manager (EOF)

C & RC Cc=nunications and Records Coordinator C Notification by call-out 3 Notification by beeper (2) Nunber of personnel designated (1/ 2) (have beeper / designated)

• • May be provided by shift personnel assigned other functions.

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