ML20196C306

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Provides History Leading to & Justification for Deleting Pumps Control Room Refrigeration Pumps from Rev 2 to Inservice Testing Program
ML20196C306
Person / Time
Site: Beaver Valley
Issue date: 06/20/1988
From: Sieber J
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-62870, NUDOCS 8807010060
Download: ML20196C306 (2)


Text

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f v Waey Power Station Shippengport. PA 15077 @ 04 Y Nwco Gos tua 643 52%

June 20, 1988 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 2 Docket No. 50-412, License No. NPF-73 BV-2 Inservice Testing (IST) Program, Revision 2

. Gentlemen:

During our investigations to resolve the concerns raised by the NRC in the Technical Evaluation Report (TER) to the BV-2 IST Program (revisions 0 and 1), it was noted that revision 2 was not submitted to the NRC for review. Revision 2 to the BV-2 IST Program incorporated several editorial changes and deleted the Control Room Refrigeration Pumps (2SWS*P25A,B] and the Fuel Pool Cooling Pumps i

[2FNC*P21A,B] from the IST Program effective January 28, 1988. A statement was made in the letter from the NRC (dated March 18, 1988) l attached to the Safety Evaluation Report (SER) for the BV-2 IST Program stating that, "Program changes such as revisions to additional relief requests or deletion of any components from the IST program should be submitted for our review, but should not be implemented prior to review and approval."

In a telephone conference call with the NRC (Peter Tam - et. al.)

on Friday, June 3, 1988, while discussing Anomaly No. 5 in Appendix C l to the TER on the BV-2 IST Program, the NRC was notified that these pumps had been deleted in revision 2 to the BV-2 IST Program. We l were directed to provide a letter of justification for deleting these pumps and a discussion on Anomaly No. 5 to document the changes which were made. They also stated that revision 3 to the BV-2 IST Program, which will include more editorial changes and any program changes required as a result of our resolutions to the NRC's concerns in the TER, should be submitted for NRC review with sidebars in the page margins indicating any changes made since revision 1 to the BV-2 IST Program.

The BV-2 IST Program is currently operating under revision 2.

The following discussion will p2 ovide the history leading to this revision, and the justification for deleting these pumps.

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\heaverValleyPowerStation,UnitNo. 2 Docket No. 50-412, License No. NPF-73 l Page 2 Anomaly No. 5 discussed two Service Water Valves (2SWS*TCV101A) and (2SWS*TCV101B] which were under consideration for inclusion in the IST Program as Category B valves to be tested to the code requirements. Question / Reply 0 - 11 of the BV-2 Trip Report for the February 11 and 12, 1987 working meeting stated that these valves had been included in the IST Program as Category B valves. These valves were to be included in revision 1 to the BV-2 IST Program issued on April 15, 1987, but were not. A decision not to include these valves was made because the Control Room' Refrigeration Pumps [2SWS*P25A,B]

were going to be deleted in revision 2 to the IST Program. There was insufficient time to delete them from revision 1 prior to submittal of the program to the NRC. Unit 1 was in the process of deleting similar pumps and valves from their IST Program. Both the pumps and valves were determined not to have a safety related function as defined in ASME XI, Section IWP-1100. Unit 1 was also in the process of deleting their Fuel Pool Cooling Pumps [2FNC*P21A,B) from their IST Program. BV-2 decided to do the same, and deleted these pumps in revision 2 to the BV-2 IST Program.

The Control Room Refrigeration Pumps and Fuel Pool Cooling Pumps were determined not to be required to perform a specific function in shutting down the reactor or in mitigating the consequences of an accident. A redundant means of cooling the Control Room to permit occupancy under accident conditions has been provided by two service water cooling coils located in the Control Room Air Conditioning Units. There are no postulated accidents associated with failure of the Fuel Pool Cooling Pumps. Redundant means for hookup of temporary pumps and supplemental water supplies have been provided. Neither pump was required to meet the ASME XI Code, so they were deleted from the BV-2 IST Program in revision 2.

The BV-2 IST Program is also currently being reviewed to make the Unit 1 and Unit 2 IST Programs more consistent. Revision 3 to the BV-2 IST Program is expected to be approved and forwarded to the NRC in the fall of 1988.

If you have any questions, contact me or members of my staff.

Very truly yours, dA D. Sieber ice President, Nuclear Group cc: Mr. J. Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr. P. Tam, Project Manager Director, Safety Evaluation & Control (VEPCO)

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