ML20206Q836
| ML20206Q836 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/30/1986 |
| From: | Tam P Office of Nuclear Reactor Regulation |
| To: | Carey J DUQUESNE LIGHT CO. |
| References | |
| TAC-62881, NUDOCS 8607030392 | |
| Download: ML20206Q836 (4) | |
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. June 30,1986 Docket No. 50-412 DISTRIBUTION g6 P.-Tam j
NRC PDR D. Miller i
Mr. J. J. Carey, Vice President -
PAD #2 Rdg Tech Branch i
Duquesne Light Company T. Novak Gray File j
Nuclear Group OELD F. Burrows
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Post Office Box 4 E. Jordan A. Gilbert Shippingport, PA 15077 B. Grimes J. Partlow l
Dear Mr. Carey:
N. Thompson, DHFT l
Subject:
Beaver Valley Unit 2 - SER Backfit. Issue 4, Steam Generator-j Level Control and Protection 1'
In a letter to you dated November 22, 1985, we requested Beaver Valley Unit 2 Final Safety Analysis Report (FSAR) you to revise the i
to eliminate the inconsistency of representing main feedwater isolation on a generator high level as part of ESFAS and the plant's protection systems. This revision was necessary to support your position relative to the backfit appeal issue (SER Section 7.3.3.12).
In a December 20, 1985 letter, you responded and stated that the requested FSAR revision would be forthcoming in Amendment No. 11.
I We have now reviewed your response and Amendment No.11 to the plant's FSAR and find they do not totally eliminate the. inconsistency of representing main feedwater isolation on high steam generator level ~as a requirement for protection of the plant. We believe that a more comprehensive FSAR revision is needed and have enclosed a discussion of other FSAR sections which we feel 4
j should also be revised.
We request your response within 45 days of your receipt of this letter. 'This information request affects fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, s
)
j Peter S. Tam, Project Manager PWR Project Directorate #2 Division of PWR Licensing-A Office of Nuclear Reactor Regulation
Enclosure:
j As stated 1
j cc: See next page 1
P #2 PM: PAD #
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1 8607030392 860630 l
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.x Mr. J. J. Ca rey Duquesne Light Company Beaver Valley 2 Power Station cc:
Gerald Charnoff, Esq.
Mr. R. E. Martin, Manager Jay E. Silberg, Esq.
Regulatory Affairs Shaw, Pittman, Potts & Trowbridge Duquesne Light Company 1800 M Street, N.W.
Beaver Valley Two Project Washington, DC 20036 P. O. Box 328 Shippingport, Pennsylvania 15077 Mr. C. W. Ewing, Quality Assurance Zori Ferkin Manager Assistant Counsel Quality Assurance Department Governor Energy Council Duquesne Light Company Harrisburg, PA 15105 1625 N. Front Street P. O. Box 186 Shippingport, Pennsylvania 15077 Director, Pennsylvania Emergency Management Agency Room B-151 Transportation & Safety Building Harrisburg, Pennsylvania 17120 Mr. T. J. Lex Mr. Thomas Gerusky Westinghouse Electric Corporation Bureau of Radiation Protection Power Systems PA Department of Environmental P. O. Box 355 Resources Pittsburgh, Pennsylvania 15230 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Mr. P. RaySircar Stone & Webster Engineering Corporation BVPS-2 Records Management Supervisor P. O. Box 2325 Duquesne Light Company Boston, Massachusetts 02107 Post Office Box 4 Shippingport, Pennsylvania 15077 Mr. W. Troskoski U. S. NRC John A. Lee, Esq.
P. O. 181 Duquesne Light Company Shippingport, Pennsylvania 15077 1 0xford Centre 301 Grant Street Mr. Thomas E. Murley, Regional Admin.
Pittsburgh, Pennsylvania 15279 U. S. NRC, Region I 631 Park Avenue King of Prussia, Pennsylvania 15229 I
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9 ENCLOSURE 4
REQUEST FOR ADDITIONAL INFORMATION i
In a letter dated November 22, 1985, we requested DLC to revise the Beaver Valley Unit 2 Final Safety Analysis Report (FSAR) to eliminate the representation of main feedwater isolation on high steam generator level as part of ESFAS and the Protection System. This revision was necessary to support the applicant's position relative to the steam generator level backfit appeal issue.
In a December 20, 1985 letter, the applicant stated that the requested FSAR revision would be forthcoming in Amendment No. 11. We have reviewed the FSAR (including Amendment No.11) and find that the following sections of the FSAR should also be revised to fully support the position that main feedwater isolation on a high steam generator level signal is not required for protection of the plant and is not part of the plant's ESFAS.
j 1.
Table 15.0-4 includes the high steam generator level as a trip function assumed in the accident analyses. This should be removed from this table j
and the appropriate accidents reanalyzed.
P.
In Section 15.0.8 on page 15.0-11 the following statement is made:
... the nomally operating systems and components listed in Table 15.0-6 will be available for mitigation of the events discussed in Chapter 15."
Table 15.0-6 includes the high steam generator level as available for transient and accident conditions related to a feedwater system malfunction causing an increase in feedwater flow. The high steam generator level actuation should be completely removed from Table 15.0-6 or it should be footnoted that no credit is taken for this trip in the accident analysis.
If credit is taken, these accidents j
should be reanalyzed without this trip.
j 3.
Section 15.1.2, "Feedwater System Malfunctions Causing an Increase in Feedwater Flow," contains statements such as: " Continuous addition of excessive feedwater is prevented by the steam generator hi-hi level trip..." and "The feedwater flow resulting from a fully open control valve is teminated by a steam generator hi-hi level trip signal...."
l Statements referring to the steam generator hi-hi level trip signal should be removed from the FSAR, and the analysis performed under il Section 15.1.2.2, which currently assumes that the high steam generator level signal teminates this transient, should be replaced by a new l
analysis that accurately describes the assumptions used including those relating to Lemination of the transient. The analysis should state j
explicitly which safety-related equipment is taken credit for in the mitigation of this transient. If termination of the transient is not required for safety, this should be so stated and bases provided. Also, the time sequence of events contained in Table 15.1-1 and all related FSAR figures must also be revised accordingly for the new analysis, t
4.
Section 7.3.1.1 provides the system description for ESFAS and refers (see page 7.3-2) to Table 7.3-1 and 7.3-2 for additional information pertaining to ESFAS logic and function.
In Table 7.3-2 under feedwater isolation, the logic for steam generator high-high water level is discussed. This functional unit should be removed from Table 7.3-7.
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5.
Section 7.3.1.1 also refers (see page 7.3-2) to Table 7.3-3 for interlocks associated with ESFAS.
In Table 7.3-3 high steam generator level is included as "P-14."
This interlock should be removed from this table.
6.
A functional description of the main feedwater isolation on steam generator high-high water level should be included in the appropriate Chapter 7 section of the FSAR following the guidance of Standard Review Plan, NUREG-0800, and Regulatory Guide 1.70.
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