ML20128G871

Summary of 850509 Meeting W/Util in Bethesda,Md to Hear Appeal on Steam Generator Channel Level Requirements.Meeting Notice & Transcript,W/Attendance Roster,Encl

ML20128G871
Person / Time
Site:	Beaver Valley
Issue date:	06/25/1985
From:	Nerses V Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20128G874	List: ML20128G871 ML20128G903
References
NUDOCS 8507090344
Download: ML20128G871 (5)

Text

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/$ 'g UNITED STATES '

NUCLEAR REGULATORY COMMISSION y ) )g#,/c. y WASHINGTON, D. C. 20555 r,S'gf

% ..... / JUN 2 51985 Docket No.: 50-412

, APPLICANT: Duquesne Light Company (DLC)

FACILITY: Beaver Valley Power Station, Unit 2

SUBJECT:

MEETING

SUMMARY

On May 9,1985, NRC and applicant representatives met in Bethesda, Maryland to hear the applicant's appeal on the stearn generator channel level require-ments for Beaver Valley Power Station, Unit 2 (BVPS-2). A meeting notice is provided as Enclosure 1. A transcript with an attendance roster of this meeting is provided as Enclosure 2.

The affected parties at this meeting presented their cases and participated in discussions regarding the steam generator channel level requirements. After hearing the presentations and discussions, the Director, Division of Licensing, (DL), considered there were two aspects to this issue.

One aspect was technical - specifically identifying hardware changes, such as a fourth steam generator channel level, to the facility that might be needed to meet the requirements. From the information presented at this meeting, the Director, DL, was convinced that there is no undue risk to the public health and safety without the addition of a fourth steam generator channel level for the interim period it will take to resolve and implement an appropriate resolution of the A-47 " Safety Implications of Control Systems" generic issue. The Director, DL, further recognized the following in support of his position: ,

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1. The event of concern, a failure in the control channel leading to l a steam generator overfill, should be a relatively small probability because at least two failures in the control channels must occur before the event can occur. Given that the feedwater centrol system is in automatic, the first failure must be in the steam generator water level channel that is providing input to the control system.

It must fail low. The second failure must be on the same steam generator in one of the other two remaining channels and the failure l must be a fail-as-is. A third failure may be involved because the operator is not credited with taking any action. Actually, at 100% l power, analysis indicates that. there are 10 minutes for operator action and this meets the staff position.

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2. Prior experience on Unit 1 has shown that an operator has been trained to be quite sensitive to steam generator feedwater control problems and is expected to be prompt in correcting any feedwater mismatch because the actions an operator would need of take to intervene and stop this event are quick and easy.

8507090344 050625 UB 05 2

3. Based on the history of overfill events of Westinghouse steam generators, no overfill events occurred due to control system failures.

i. In the intentediate power le'ic! range, the range in which operators have shortest time to act to prevent a steam generatotr overfill, the applicant noted that the plant will operate less than 2% of the time at these intermediate power levels. During this period, the applicant's present mode of operation requires at least one operator at the.feedwater control panel.

5. The applicant agreed to meet any requirements that evolved from the resolution of A-47 to allay steam generator overfill concerns.

Another aspect of this issue was administrative - specifically whether or not 50.55a(h) applies to the BVPS-2 high steam generator level system. The staff noted that this is germane to the issue since the source for the staff authority to establish steam generator channel level requirements is in 50.55a(h). The applicant stated 50.55a(h) did not apply because the steam generator hioh level trip system is not considered a protection system. The listing in the BVPS-2 FSAR of the feedwater isolation on high steam generator level as an Engineered Safeguards Feature (ESF) appears to be inconsistent with the DLC stated position. DLC has noted that the FSAR incorrectly listed it as an ESF, and the FSAR will be revisied to correct this inconsistency.

The Director, DL, stated that the question of whether or not the BVPS-2 system falls within the rules and regulations would require a legal analysis which he would persue.

Victor Verses, Project Manager Licensing Branch No. 3 l Division of Licensing  ;

Enclosures:

As stated i cc: See next page I l

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Agenda for the Beaver Valley 2 Bac'kfit Appeal Meeting on Steam Generator Level Channel

1. Discuss safety significance of steam generator overfill.

2. Discussion of NRC and applicant written position and any additional clarification on.

a. staff requirements

b. how staff requirements, which can be met by the addition of a fourth steam genertor level channel or alternative, should achieve and maintain an acceptable level of safety

c. relation of staff requirements to existing regulations

d. schedule for implementing requirements 6

s e

Mr. E. F. Kurtz, Jr., Manager Regulatory Affairs  ;

Beaver Valley Two Project '

Duquense Light Company Robinson Plaza Buidling No. 2 Suite #210 PA Route 60 Pittsburgh, Pennsylvania 15205 l

NN 2 519e5 MEETING

SUMMARY

DISTRIBUTION s..... . - . . - ,

Docket'No(s): 50-412:-

NRC POR Local PDR NSIC PRC System LB3 Reading Attorney, OELD GWKnighton Project Manager V. Nerses JLee NRC PARTICIPANTS H. Thompson R. Bernero W. Houston G'. W.Knighton V. Nerses t

bec: Applicant & Service List '

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((s., . gk UNITED STkTES n NUCLEAR REGULATORY COMMISSION

- .; WASHINGTON, D. C. 20555 Enclosure 1 APR 2 61985

% ..... /

Docket No.: 50-412 MEMORANDUM FOR: Cavac '.l. Knighton, Chief Licensing Branch No. 3 Division of Licensing , _ ,

FROM: Victor Nerses, Project Manager Licensing Branch No. 3 Division of Licensing

SUBJECT:

FORTHCOMING BEAVER VALLEY 2 MEETING BETWEEN THE NRC AND DUQUESNE LIGHT COMPANY DATE & TIME: Thursday, May 9, 1985 10:30 am b0 CATION: P-110 Phillips Building Bethesda, Maryland PURPOSE: Appeal of the requirements on steam generator level channel (refer to enclosed agenda).

PARTICIPANTS: NRC H. Thompson, R. Bernero, W. Houston, G. Knighton, V. Nerses, et al.

Duouesne Light Company J. J. Carey, E. Kurtz, et al .

Victor Nerses, Project Manager Licensing Branch No. 3 Division of Licensing

Enclosure:

As stated cc: See next page

• Meetings between NRC technical staff and applicants for licenses are open for interested members of the public, petitioners, intervenors, or other parties to attend as observers pursuant to "Open Meeting Statement of the NRC Staff Policy",

43 Federal Register 28058, 6/28/78. Those interested in attending this meeting should make tiseir intentions known to the Project Manager, V. Nerses, at (301) 492-7238, by no later than noon, May 8,1985.

45459fesr1-Sp.-

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• Reaver Valley Mr. John J. Carey Vice President, Nuclear Duquesne Light Company Robinson Plaza Building, No. 2, Suite 110 PA Route 60 Pittsburgh, Pennsylvania 15205 Gerald Charnoff, Esq. ,,- i4r. R. E. Martin, Manager Engineering Jay E. Silberg, Esq. Beaver Valley Two Pro,iect Shaw, Pittman, Potts & Trowbridge Duquesne Light Company 1800 M Street, N.W. Robinson Plaza Building No. 2, Suite 110 Washington, DC 20036 PA Route 60 Pittsburgh, Pennsylvania 15205

. Mr. C. W. Ewing, Quality Assurance Zori Ferkin Manager _

Assistant Counsel Quality Assurance Department Governor Energy Council Duquense Light Company 1625 N. Front Street P. O. Box 186 Harrisburg, PA 15105 Shippingport, Pennsylvania 15077 Mr. John J. Carey Vice President, Nuclear Duquense Light Company Director, Pennsylvania Emergency P. O. Box 4 Management Agency Shippingport, Pennsylvania 15077 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 A Webster Engineering Corporation BVPS-2 Records Manaaement Supervisor P. O. Box 23?5 Duquesne Light Company Boston, Massachusetts .0?l07 Post Office Box 4 Shippingport, Pennsylvania 15077 Mr. Glenn Walton U. S. NRC John A. Lee, Esc.

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 r King of Prussia, Pennsylvania 15229 l

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3. Based on the history of overfill events of Westinghouse steam generators, no overfill events occurred due to control system failures.

4. In the intermediate power level range, the range in which operators have shortest time to act to prevent a steam generatotr overfill, the applicant noted that the plant will operate less than 2% of the time at these intermediate power levels. During this period, the applicant's present mode of operation requires at least one operator at the feedwater control panel.

5. The applicant agreed to meet any requirements that evolved from the resolution of A-47 to allay steam generator overfill concerns.

Another . aspect of this issue was administrative - specifically whether or not

~

50.55a(h) applies to the BVPS-2 high steam generator level system. The staff noted that this is germane to the issue since the source for the staff authority to establish steam generator channel level requirements is in 50.55a(h). The applicant stated 50.55a(h) did not apply because the steam generator high level trip system is not considered a protection system. The listing in the BVPS-2

.FSAR of the .feedwater isolation on high steam generator level as an Engineered Safeguards Feature (ESF) appears to be inconsistent with the DLC stated position. .DLC has noted that the FSAR incorrectly listed it as an ESF, and the FSAR will be'revisied to correct this inconsistency.

The Director, DL, stated that the question of whether or not the BVPS-2 system falls'within the rules and regulations would require a legal analysis which he would persue.

U/

Victor Verses, Project Manager Licensing Branch No. 3 Division of Licensing

Enclosures:

As stated cc: See next page D-(Bf3 D/DL g rses HThoripson 6/y/85 6/1) /85

ORENAL- -

Enclosure 2

' UNITED STATES NUCIEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:

BEAVER VALLEY - UNIT 2 BACKFIT APPEAL MEETING ON STEAM GENERATED WATER LEVEL CHANNEL INSTRUMENTATION ISSUE i

LOCATION: BETHESDA, MARYLAND PAGES: 1- 35 DATE: THURSDAY, MAY 9, 1985

(

ACE-FEDERAL REPORTERS, INC.

Oficial Reporters 444 North Capitol Street Washington, D.C. 20001 (202) 347-3700 NATIONWIDE COVERACE