ML19330B754

Informs of Intentions to Withdraw Commitment to Adopt Guidance of IE Circular 80-02,due to Wording of IE Circular 80-02 & Application of Circular Re Work Situations

ML19330B754
Person / Time
Site:	Beaver Valley
Issue date:	07/31/1980
From:	Dunn C DUQUESNE LIGHT CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
TAC-44070, NUDOCS 8008050453
Download: ML19330B754 (2)

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July 31. 1980 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn:

Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 i

Five Additional D11 Related Items Gentlemen:

My letter dated June 9, 1980, related to the above referenced subject indicated that "we will commit to adopt the guidance of IE Circular 80-02 by August 1, 1980, to the extent that the guidance of that Circular is en-compassed by the requirements of this item" (l. A.1.3 - Shif t Manning). We i

have further considered this item and we now find it necessary to withdraw our cornnitment to adopt the guidance of Circular 80-02 for the following reasons:

1.

The wording of Circular 80-02 is sufficiently vague so as to allow interpretation of the scope of applicability to extend well beyond the scope which we had intended to apply under the item " Shift Manning."

2c Application of Circular 80-02 to certain work situations which could arise from time to time in our facilities will result in a direct conflict with the existing Labor Contract between the j

Company and union represented employees.

We point out that the Nuclear Regulatory Commission hrs not yet, to our knowledge, clarified its requirements with regard to Item 1.A.l.3.

For clarity, our response to Item II.K.3.3 is restated as follows:

Future' failures of relief and safety valves to close at Beaver Valley will

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be promptly reported-to the NRC, and future challenges to relief and safety valves will be documented at least annually.

3 Very truly yours,

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Lsm C. N. Dunn Vice President, Operations b

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'e Beaver _ Valley Power. Station, Unit-No. 1 Docket No._50-334, License No. DPR-66 Five Additional IMI Related Items Page 2

~cc: 'Mr. D. A. Beckman, Resident Inspector U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, Pennsylvania - 15077

/ U.S. Nuclear Regulatory Commission c/o Document Management Branch

- Washington, D.C.

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