ML20234C463
| ML20234C463 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/24/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 2NRC-7-166, TAC-62935, NUDOCS 8707060484 | |
| Download: ML20234C463 (11) | |
Text
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2NRC-7-166 20 Beav Vall
- o. 2 Unit Project Organization P.O. Box 328 June 24, 1987 Shippingport, PA 15077 United States Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555
SUBJECT:
Beaver Valley Power Station Unit.No. 2 Docket No. 50-412 DLC Comments on the Low Power License for BVPS-2 (Facility Operating License No. NPF-54)
REFERENCE:
NRC letter dated May 28, 1987, Mr. Steven A. Varga to Mr. J. J.
Carey Gentlemen:
Attached are Duquesne Light Company's (DLC) comments on the low power license for Beaver Valley Power Station Unit No. 2 (BVPS-2) which was transmitted to DLC in the above-noted reference.
DLC will work with the NRC Project Manager for BVPS-2 to appropriately resolve these comments.
DUQUESNE LIGHT COMPANY n
\\/yJ.. Careyc7 Senior vice President JD0/ijr NR/JD0/LP/LICN Attachment AR/NAR cc:
Mr. P. Tam, Projet.i Manager
- w/ attachment Mr. W. T. Russell, NRC Region I Administrator
- w/ attachment Mr. J. Beall, NRC Sr. Resident Inspector
- w/ attachment g
Mr. L. Prividy, NRC Resident Inspector
- w/ attachment INP0 Records Center
- w/ attachment i
i 8707060484 870624 j
PDR ADOCK 05000412 p
United States Nuclear Regulatory Commission DLC Comments on the Low Power License for BVPS-2 (Facility Operating License No. NPF-64)
Page 2 COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF BEAVER
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On this [h[ day of
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/ f [ [, before me, a Notary Public in and for said [ommonwealth and County, personally appeared J.
J. Carey, who being duly sworn, deposed and said that (1) he is Senior Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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Notary Public tMitLA 5. FATIDM, N01A8. 7 PultllC SKIPPl!!GP08T BOLO, BEAtfEB COULTF ST COGrilSSICA EXPlcIS 00T. 23,1989 wa.e. %eevsw euant+.# ueries i
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DLC Comments on Low Power License for BVPS-2 (Facility Operating License No.
NPF-64) 1.
Section 2.C.(G): Fire Protection
References:
(1) DLC Letter 2NRC-7-130, dated May 18, 1987, Mr. J. J.
Carey to United States Nuclear Regulatory Commission (2) DLC Letter 2NRC-7-134, dated May 20, 1987, Mr. J. J.
Carey to United States Nuclear Regulatory Commission (3) DLC Letter 2NRC-7-143, dated May 25, 1987, Mr. J. J.
Carey to United States Nuclear Regulatory Commission
( a)
Section 2.C.(6)(a) states that, prior to exceeding 5 percent power, DLC shall identify all unsupervised fire alarm circuits and develop and implement a test procedure to confirm the operability of these circuits.
The test shall be performed on a frequency not to exceed once per 31 days.
In Reference (1), DLC identified the unsupervised fire alarm cir-cuits an.d Figures 1 through 4 of Reference (1) are att ached.
Subsequent to the issuing of Reference (1),
the following revisions have been made to Figures 2, 3, and 4 to more clearly define the circuits associated with the gaseous (Carbon Dioxide (C0 ) and Halon) and water suppression systems:
2 Figure 2 (007 Suppression System)
- The circuits associated with the heat detectors in the Diesel Generator Building (Zones 5 and 6) are tied directly from the local control panels to the Information Handling System Annunciator (IHA) cabinet.
l
- The footnote (marked with an asterisk) has been revised to indicate that it applies only to the circuits tied from the local control panels to the IHA cabinet.
- The circuit from the XL-3 panel to the IHA cabinet is now f..
defined as a supervised trouble circuit, which would indicate a trouble signal associated with the XL-3 panel.
The wording associated with Figure 2 on Pages 1 and 2 of Reference (1) should accordingly be revised to delete the statement that the heat detectors are interconnected with the Pyrotronics XL-3 panel, and to state that the fire, trouble, and lockout circuits are supervised from the local control panels to the IHA cabinet.
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~a Figure 3 (Halon' Suppression _ System)
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,E' The fire and discharge cfrcuits are tied directly from the loc & control panels to the IHA cabinet.
- Suoervised troub'le' circuits exist from both the local control panels and the XL-3 panel to the IHA cabinet.
f)
A note has been added to indicate that OLC is currently con-sidering a modification to make the fire and discharge circuits supervised circuits.
The wording associated,with Figure 3 on Page 2 of Reference (1) should tecordingly 2.a 'evised to state that the trouble cir-cuits are supervised from the local control panels to the IHA cabinet.
Figure 4 (Water Sgoressio_n System)
I
- A note has been added to indicate that DLC is currently con-sidering a modification to make the fire, discharge, and trouble circuits supervised circuits.
Prdsently, the unsupervised circuits and the associated testing require-ments are as follows:
(i)
Water _ Suppression System (Figure 4_)
The dire, discharge, and trouble circuits are unsupervised from 1
thi local control panels to the IHA cabinet.
As stated in Reference (1), these circuits will be tested montnly to confirm their operability as' specified in Site Administrative Procedure 90, " Fire Protection".
The associated test procedure will be developed and implenented prior to exceeding 5 percent power.
sAs stated previously, DLC is currently considering a modification a<hich would make the fire, discharge, and trouble circuits super-vised circuits.
The monthly testing requirement for these circuits will remain in effect until such a modification is completed.
The circuits from the IHA cabinet to the Control Room need not be supervised since they have multiple pathways to the Control Room -
one from the IHA cabinet to the annunciator windows on the Build-ine Service Panel, and one from the IHA cabinet to the plant computer.
I L
(ii) Gaseous Suppression Systems (007 and Halon)
C0p Suppression System (Figure 2)
The discharge circuit is unsupervised from the local control panels to the IHA cabinet.
l Halon Suppression System (Figure 3).
]
I j
The fire and discharge circuits are unsupervised from the local control panels to the IHA cabinet.
The unsupervised fire circuit associated with the Halon Suppression System will be tested monthly.to confirm its operability.
The associated test procedure will be developed and implemented prior to exceeding 5 percent power.
As stated previously, DLC is currently considering making the
-Halon Suppression System fire and discharge circuits super-vised circuits. The monthly testing requirement for the fire l
circuit will remain in effect until such a modification is completed.
The unsupervised discharge circuits associated with the gaseous suppression systems need not be tested monthly since these systems have alternate means of detecting a system i
discharge for all areas associated with the gaseous suppres-l sion systems.
System discharge or actual fires would not go undetected due to the fire detection system (Early-warning detection system-L Refer to Figure 1) which is a Class A system as defined in i
NFPA 72D 1978) from the detectors to the Control Room.
Therefore, identification of system discharge or fires through suppression system alarms is not a safety concern.
The circuits from the IHA cabinet to the Control Room need I
not be supervised since they are contained in multiple patn-ways to the Control Room - one from the IHA cabinet to the annunciator windows on the Building Service Panel, and one from the IHA cabinet to the plant computer.
f (b)
Section 2.C.(6)(b) states that, prior to exceeding 5 percent
[
power, DLC shall complete the installation of all fire protection provisions.
Until that time, DLC shall maintain fire watches in those areas in accordance with its commitments made in letters dated May 20 and 21,1987.
l The compensatory measures (use of fire watches)o specified in this license condition are outlined in DLC's May 20 and 25, 1987, letters (References (2) and (3), respectively).
Note that the Reference (2) date is May 25, 1987, instead of May 21,1987, as stated in the license condition.
These compensatory measures are j
(
part of the BVPS-2 Fire Protection Program as specified in Site Administrative Procedure 90 and are consistent with those used during normal operations to compensate for work activities which may result in temporary inoperability of fire-rated assemblies.
In References (2) and (3), we stated our intentions to complete all fire protection system installation and testing prior to i
exceeding 5 percent power.
However, it has become evident that f
certain fire protection items may not be completed in accordance with that schedule and the compensatory measures discussed above I
will need to be utilized in lieu of these items.
Items which may not be complete prior to exceeding 5 percent power are the follow-ing:
- Installation of fire wrap on certain cables within the Primary Auxiliary Building due to the amount of work associ-ated with qualified fire wrap installation and the physical restraints in the areas.
- Successful acceptance testing of the C02 Suppression System for some of the areas serviced by this system.
Recent test-ing of the CO2 Suppression System has shown overpressuriza-tion to be a problem in these areas, along with maintaining the required concentration for the specified amount of time.
)
Corrective ac'tions are being taken to resolve these problems l
and the areas will be re-tested when the modifications are l
complete.
{
- Successful acceptance testing of fire dampers in three I
safety-related areas of the plant due to the failure of the
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dampers to latch properly.
Modifications to these dampers are being performed and re-testing will occur when they are complete.
In the interim, the use of compensatory measures in lieu of the completion of any of these items will have no adverse effects on personnel or plant safety.
(
2.
Section 2.C.(7): Plant Safety Monitoring System (PSMS)
References:
(1) DLC Letter 2NRC-7-101, dated April 30, 1987, Mr. J. D.
l l
Sieber to United States Nuclear Regulatory Commission (2) NRC Letter dated June 4,1987, Mr. Peter S. Tam to Mr.
J. J. Carey In this section, the staff has imposed a license condition which requires submittal of a plan for performing a verification and validation of PSMS software.
The condition requires that the approved plan be implemented prior to startup following the first refueling outage.
In Reference (1), DLC responded to a previous staff request and indicated that confirmation of PSMS software adequacy was in process and was planned for completion prior to exceeding 5. percent power. ' DLC pointed out that the generic review criterion chosen by the staff was stated by Regulatory Guide 1.152 to be not applicable to plants such as BVPS-2 and DLC request-ed CRGR approval -if the proposed criterion was to be applied at BVPS-2.
DLC also requested that further requests by the staff clearly specify the regulatory basis so that DLC may adequately address the staff's concerns.
Subsequent to issuing the license, the staff provided a letter (Reference (2)) describing its current position.
The letter does not describe the l
regulatory basis for its position nor does it provide any indication of what an adequate program for confirmation of PSMS sof tware should address.
I The lack of a described regulatory basis and review criteria make address-ing of actual staff concerns difficult and inefficient.
DLC will fully address the perceived staff concern through the methods briefly described in Reference (1).
The plca which was used to confirm PSMS sof tware will be described in further detail to the staff.
- 3. (Item 1)
This section states that 6 unresolved items related to emergency prepared-ness are to be resolved prior to criticality.
The items listed are Unresolved Items 87-14-09, 87-14-17, 87-14-18, 87-14-19, 87-14-20, and 87-14-21.
These items were described by NRC Region I in their Inspection Report No. 50-412/87-14, which - documented their Emergency Preparedness Implementation Appraisal conducted March 2-6, 1987.
Based on a follow-up visit conducted by NRC Region I on May 18-20, 1987, and recent telephone conversations with Region I, DLC agrees that Unresolved Items 87-14-09 and 87-14-20 will be resolved prior to criticality.
However,.it is our under-standing with Region I that Unresolved Items 87-14-17, 87-14-18, 87-14-19, and 87-14-21 need not be resolved until prior to issuance of the full power license.
This section of the low power license should be revised j
accordingly, i
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