ML20214A759

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Forwards Request for Addl Info Re 870402 Tech Spec Amend Request 126,Rev 2 in Order to Complete Review
ML20214A759
Person / Time
Site: Beaver Valley
Issue date: 05/12/1987
From: Tam P
Office of Nuclear Reactor Regulation
To: Carey J
DUQUESNE LIGHT CO.
References
TAC-63184, NUDOCS 8705190580
Download: ML20214A759 (5)


Text

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Docket No. 50-334 May 12,1987 L ,Q Mr. J. J. Carey, SenioE Vice President Duquesne Light Company Nuclear Group Post Office Box 4 Shippingport, PA 15077

Dear Mr. Carey:

SUBJECT:

BEAVER VALLEY UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION (TAC 63184)

Enclosed please find a request for additional information concerning your Technical Specification Amendment Request No.126. Revision 2 dated April 2, 1987. It is our understanding that this amendment is needed prior to the restart of Unit I which is currently scheduled for May 16, 1987. Resolution l to the issues in the enclosure are necessary for us to complete our review; therefore, a prompt response to this request is vital to mer your schedule.

The reporting requirements contained in this letter affect Nor than ten respondents; therefore, OMB clearance is not reouired under P.L.96-511.

Sincerely,

/s/

Peter S. Tam, Project Manager Project Directorate I-4 Division of Reactor Projects I/II

Enclosure:

As stated cc w/ enclosure:

See next page Docket File NRC & Local PDRs PD # I-4 Reading SVarga BBoger SNorris PTam OGC-Bethesda E. Jordan J. Partlow ACRS (10)

P PDI-4 a M I-4 S PTam;e J to z  %?edersed S/II/87 [/[{/f] $f/(f] q jy 8705190580 870512 4 DR ADOCK 0500

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Mr. J. J. Carey Duquesne Light Company Beaver Valley 1 Power Station cc:

Mr. W. S. Lacey Pennsylvania Power Company Station Superintendent James R. Edgerly Duquesne Light Company Post Office Ecx 891 Beaver Valley Power Station New Castle, Pennsylvania 16103 Post Office Box 4 Shippingport, Pennsylvania 15007 Mr. Jess T. Shumate, Commissioner State of West Virginia Department Mr. S. Sovick, Acting Supervisor of Labor of Licensing 1800 Washington Street, East Duquesne Light Company Charleston, West Virginia 25305 Post Office Box 4 Shippingport, Pennsylvania 15077 David K. Heydinger, M.D.

State Director of Health Mr. John A. Levin State Department of Health Public Utility Commission 1800 Washington Street, East Post Office Box 3265 Charleston, West Virginia 25305 Harrisburg, Pennsylvania 17120 Regional Administrator, Region I Gerald Charnoff, Esquire U.S. Nuclear Regulatory Commission Jay E. Silberg, Esquire 631 Park Avenue Shaw, Pittman, Potts and Trowbridge King of Prussia, Pennsylvania 19406 2300 N Street, N.W.

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Washington, DC 20037 Mr. R. Janati Bureau of Radiation Protection Charles E. Thomas, Esquire Pennysivania Department of Thomas and Thomas Environmental Resources 212 Locust Street P.O. Box 2063 Box 999 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17108 John D. Burrows, P.E.

Marvin Fein Director of Utilities Utility Counsel State of Ohio City of Pittsburgh Public Utilities Commission 313 City-County Building 180 East Broad Street Pittsburg, Pennsylvania 15219 Columbus, Ohio 43266-0573 Resident Inspector Pennsylvania Office of Consumer U.S. Nuclear Regulatory Commission Advocate Post Office Box 298 ATTN: Michael Bardee Shippingport, Pennsylvania 15077 1425 Strawberry Square Harrisburg, Pennsylvania 17120

Enclosure RE00EST FOR ADDITIONAL INFORMATION BEAVER VALLEY UNIT 1 T5 CHANGE REQUEST NO. 176, REV.2 The purpose of the requested clarifications primarily relates to the deter-rination that the as-modified shared control room habitability system for Peaver Valley Units 1 and 2 is acceptable based on the licensing criteria '

applicable to Unit 2. This determination is required even though the requested technical specification changes concern only Unit 1 because the system serves Unit 2 as well.

1. Provide information to justify the conclusion that the as-rodified design complies with GDC 4 regarding its ability to maintain a suitable environ-ment, end GDC 5 concerning shared safety functions.
2. In the SER for Unit 2 (NUREG-1057), Section 6.4, it is stated that to en-sure compliance with FRC guidelines in the protection of the control room operator following a chlorine release, the staff will review the Unit 2 TS to ensure that control room isolation, response times and pressuriza-tion test flow rates are consistent with the guidance of RG 1.95, Table 1.

In this regard, provide a description of this capability and how these functions will be ensured by the proposed TS change. (See Itst 4b. below for furtner discussion . i

, 3. Confirm that the staff conclusion in the Beaver Valley Unit 2 SER INilREG-1057) that the acceptance criteria of SPP 6.4 (including GDC 19) and S9P 6.5.1 remain valid for the as-modified system design.

a. Specifically address the as-modified subsystems not addressed in NUREG-1057, h Provide analyses regarding the consequences of pos^telated radiological and non-radiological accidents.
c. Clarify exceptions taken to RG 1.5? and RG 1.95 as follows:
1. Clarify how use of artificial resistance is needed to avoid damage to installed system components.

ii. Clarify how the chlorine detection system is qualified for the severe environments that lead to or could be a result of a chlorine release.

4 Provide justification for all deviations from the Standard Technical Specifications. Specifically address the following:

a. In order to be able to credit the emergency ventilation subsystems with the capability to maintain positive pressure in the envelope and to remove radioactive materials from inceming air the STS require that each subsystem must be i

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l surveillance tested at the flow rate intended to be used for these functions i 10%.

fii Verify the intended flow rate of each of the Unit 1 and Unit ? systems, fii) Amend the proposed TSs to require each test at that flow l rate 10%. '

b. I.ikewise, for the bottled air pressuri7ation system TS 4.7.7.2 should provide a discharge flow rate range, e.g., 800 cfm 10%,

or an ecuivalent bottle pressure range for this test.

c. The meaning of footnote ** in terms of the surveillance required is not clear. Clarify the current proposal or amend the proposal and explain the change. (See Item No. 2 above).
d. To apply the full RG 1.52 radioactive iodine removal efficiency in the staff safety analysis the average residence time for charcoal filters must be no less than 0.25 sec per 2-inches of bed thickness.

(a) Verify that each of the emergency subsystems has an average residence time for charcoal filters of no less than 0.25 sec per ?-inches of bed thickness.

(b) Otherwise, provide other bases for the radiciodine removal efficiencies to be used in the NPC staff safety analysis.

(See Item 3.b above).

e. PG 1.52. Positions C.5.c and C.S.d provide that in-place testing of PFPA filters and charcoal adsorbers should confirr penetrations of 0.05%

at rated flow. The Standard Technical Specifications provide that the in-place peretration and bypass leakape testing acceptance criteria is 0.05% where a HEPA filter or charcoal adsorber e##iciency of 99%

is assumed, or 1% where a HEPA filter or a charcoal adsorber efficiency of 95% or less is assumed in the safety evaluation. (Use the value assumed for the charcoal adsorber efficiency if the value for the HEPA filter is different from the charcoal adsorber efficier.cy in the NRC staff safetyevaluation).

(a) Clarify the applicability of the acceptance criterion as in-dicated above to the BV design and TS.

(b) Otherwise, provide other bases for the removal efficiency to be used in the staff analysis. (See Item 3.b as above).

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f. Provide justification, or amend your proposal for deviations from STS regarding:
1. 31 day tests on a staggered basis for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters operating; and ii. Laboratory tests within 31 days after removal with representative samples obtained in accordance with RG 1.52 Position C.6.b and testing in accordance with Position C.6.a.
g. Provide rationale (or amend the proposed TS) for the TS not -

reouiring in Modes 5 and 6 (when irradiated fuel may moved within the contairment) isolation of normal ventilation on a CIB signal and demonstration of emergency ventilation subsystem and bottled air system operability by verifying autonatic opera-tion on a CIB signal.

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