ML19343C511
| ML19343C511 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/18/1981 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TAC-11111, NUDOCS 8103240408 | |
| Download: ML19343C511 (5) | |
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7" March 18, 1981 yfIG Director of Nuclear Reactor Regulation Q
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United States Nuclear Regulatory Commission j LV Attn: Harold R. Denton, Director Office of Nuclear Reactor Regulation
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Reference:
Beaver Valley Power Station, Unit No. 1 Y
Docket No. 50-334, License No. DPR-66
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/@7 Exemption to Appendix R Requirements 4
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Dear Mr. Denton:
This letter is to request, pursuant to 10 CFR 50.12, extension of certain of the schedule dates in paragrach (c) of the newly enacted fire protection regulations in 10 CFR 50.48 for Beave.r Valley Unit No. 1.
In particular, we request:
(1) that the date in paragraph (c)(5) for submitting plans and schedules for meeting the provisions of paragraphs (c)(2),
(c)(3) and (c)(4) with respect to certain requirements of Sections III.G of Appendix R to Part 50 be extended from March 19, 1981 to December 1, 1981; (2) that the date in paragraph (c)(5) for submitting design descriptions of modifications needed to satisfy Section III.G.3 of Appendix R be extended from March 19, 1981 to Dece=ber 1, 1931; (3) that the imple=entation date in paragraph (c)(2) for installation of modifications required by Section III.G.2 of Appendix R, that do not require prior NRC approval or plant shutdown, be extended from nine months after February 17, 1981 to nine months after December 1, 1981; (4) that the implementation date in paragraph (c)(3) for the installation of modifications required by Section III.G.2 of Appendix R, that do not require prior NRC approval, but
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require plant shutdown, be extended from before startup fi after the earliest of the specified events cocmencing 180 days or more after February 17, 1981, e before startup after the earliest of the specified evo s cor=encing 180
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days or more after December 1, 1981.
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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, Lic.ense No. DPR-66 Exemption to Appendix R Requirements Page i The plans and schedules now available for implementing modifications required by, Appendix R are being submitted in a separate letter dated March 19, 1981 to.the Director of Nuclear Reactor Regulation. The schedule 4
extensions requested herein relate to those modifications which may be required to satisfy'Section III.G and which cannot be specifically iden-Leified by March 19, 1981.
Section 50.48 requires that fire protection features required by
'Section III.G of Appendix R be installed irrespective of previous ongoing discussions with the NRC staff.or NRC staff. approvals for alternative fire
- protection' features tailored to the specific nuclear facility and appro-priate for protection of the public health and safety. Generic Letter 81-12, dated February 20, 1981, from Darrel G. Eisenhut stated that, in
- implementation of Section III.G,-the licensee is required to reassess all relevant. areas of the plant to determine'whether the requirements of
-Section III.G.2 are satisfied. - The letter went on to say that if the reassessment shows =that Section III.G.2 is not satisfied, the licensee must"either provide alternative shutdown capability in accordance with Section III.G.3, ' or request an exemption.
With the publication of the new rule and your letter of November 24, 1980, Duquesne Light Company initiated a. review of the requirements of the new - rule, especially - those of Section III-G by mid-Dece=ber,1980. The analysis' defines all those associated circuits, specifically non-safety related asso-lated circuits, for those systems required for safe shutdown.
~ An extensive computer search is then initiated to compare each cable with all cables in each of 30 fire are s to demonstrate whether or not redundant and-diverse functions are vulnere,le
- .o a fire in any given fire area.
Within a vulnerable fire area, the location and functional relationship
- of cab *1es is' identified in order ~to' evaluate existing separation, fire-suppression and detection.
1 lit'is estimated that an additional.six (6) weeks will be required to completely define all circuits involved; an additional twenty-four (24) weeks is necessary to compitae the computer search, with the remaining six (6)Lweeks needed:co review ths data and make recommendations and propose
- any. required modifications.
The. requested. extension will not be detrimental to health and safety.
There are no urgent considerations.which would mandate the immediate.imple-mentation of the Appendix R r'equirements. LIn promulating the rule-the-Commission-indicatea no sense or. urgency and provided no basis or expla-nation of any safety need for the implementation schedule in Section 50 48
- Indeed,'the Commission has.made.it clear on the public record that all
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operating nuclear plants may continue to operate safely pending compliance with the new requirements.
In the case of ~ Beaver Valley, those measures required 'to' be completed 'in' accordance with the dates specified in t'se SER d
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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Exemption to Appendix R Requirements Page 3 have been completed. Our letter to you dated October 30, 1980, referenced in Ericlosure 2 of your letter cf November 24, 1980, described the status of the remaining SER items to be completed.
Those areas wh.'ch were available
-to be worked during plant operation (i.e., PT-1A, PT-lF) hav been completed.
The completion of these items as identified in the SER provide adequate fire protection for the equipment to reasonably assure their continued operation.
Additionally, Beaver Valley has alternate shutdown capability : hat will enable the plant to reach and maintain a HOT STANDBY mode.
Were we to attempt to formulate and submit plans and schedules for modifications or design descriptions for alternative shutdown capability prior to completion of the plant reassessment, we would not be certain of having developed the most effective means of implementing the required modifications. More importantly, vithout being able to complete the necessary work in a carefully considered and thorough fashion, we could not be certain that hastily developed plans would enhance health and safety or that they would not be detrimental to public health and safety.
We anticipate that the reassessment will indicate the need to request exemptions from certain requirements of Section III.G.2 for certain treas of the plant as suggested in Generic Letter 81-12.
The new rule, by generically imposing the requirements of Appendix R on all p,lants operating prior to January l, 1979, ignores the unique and widely varying design features of individual facilities and the intensive efforts undertaken by the licensee and the staff in developing fire protection features which may be better suited to those individual facilities than the generic requirements of Appendix R.
Compliance with the new regulation will not
.necessarily result in better prctection of the_public health and safety.
In fact, unnecessarily increasing the complexity of power plant design features, particularly those involving circuitry and instrumentation or containment. penetration, may even be detrimental to safety.
The new Section 50.48 will impose restrictive amendments of operating licenses, and will require backfitting of operating nuclear plants.
- Yet, the Commission is unilaterally imposing backfit requirements without regard to its own backfitting standards specified in 10 CFR 50.109.
It is already apparent to us that many of the modifications required by Appendix R will not provide " substantial, additional protection...," [particularly when viewed against alternative methods of fire protection which we have pre-viously proposed and intend to implement for Beaver Valley].
In fact, we
-find little or no basis of any sort in the record for the specific require-ments articulated in Appendix R.
The new regulation also ignores the practical aspects of cost and-feasibility or possibility of compliance.
In many respects, the appli-cation of the new requirements to the Beaver Valley facilities is econo-mically impracticable, without regard to whether it offers compense. ting
. benefit necessary for the protection of the public health and 'sefety.
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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Exemption to Appendix R Requirements Page 4 For example, the costs of designing and implementing alternative shutdown
- capability, or modifications for compliance with Section III.G.2, could be substantial, without necessarily having met the Section 50.109 standard for requiring backfitting.
If additional down time were needed to implement the modifications, replacement power costs could be enormous.
Accordingly, we'are at this time requasting the foregoing extensions of the schedule requirements specified in paragraphs 50.48 (c)(2), (3) and (5).
Very truly yours, f
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Dunn Vice President, Operations Enclosure
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D. A. Beckman, Resident Inspector U.f.. Nuclear Regulatory Commission Beaver Valley Power Station
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5'.tippingport, PA 15001 U.S. Nuclear Regulatory Co= mission c/o1 Document Management Branch
. Washington, DC -20555-tg,
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{ CORPORATE SEAL)
Attest:
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Thomas Welig, Jr '.
r Secretary COMMONWEALTH OF PENNSYLVANIA)
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COUNTY OF ALLEGIENY
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On this M
day of A/'7 C M 1981, before
'me, 150NATM W. RNANNnY
, a Notary Public in and for said Commonwealth and County, personally appeared C. N. Dunn, who being duly sworn, deposed, and said that (1) he is 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 ie. '.he Submittal are true and correct to the best of his knowledge, inforn.ation and belief.
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DONALD W. SHANNON. NOTARY PUBLIC PITTSSURGH. ALLEGHENY COUNTY MY COMMISSION EXPIRE 3 J'JNE 7,1983 Wember Pennsylvania Assocaton of Notanes I
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