ML19351D530
| ML19351D530 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/02/1980 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TAC-46068, NUDOCS 8010100351 | |
| Download: ML19351D530 (14) | |
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pg,*p' October 2, 1980 swe United States Nuclear Regulatory Connaission Atta: Mr. Darrell G. Eisenhut, Director Division of Licensing Waahington, D.C.
20555
Reference:
Beaver Valley Pewer Station, Unit No. 1
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Docket No. 50-334, License No. DPR-66 Design of Beaver Vdley Emergency Response Facilities Det.r Mr. Eisenhut; _
Shortly after.he accident at TML-2, the desirability and need for adequate Emergency Response Facilities (ERF) was identified ~and was made a requirement for nuclear power facilities (NUREG-0578). From the outset, Duquesne Light. Company endorsed both the desirability and need for these a
facilities and promptly began a 3ood faith design, procurement and con-struction effort geared to meetig as cloisely as practical the originally required completion date of January 1 1981. Durias the intervening period, however, the details of the conceptual design requirements for ERF were evolving, as was recently evidenced by the issuance of proposed NUREG-0696.
At this point in time, we have erected foundations and structural steel-for an emergency center which includes tha Emergency Operations Facility
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(EOF),ra Technical Support Center (TSC) and analytical facilities for i
radiochemical analysis.
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These facilities deviate in some details from the requirements as q
are presently set forth in proposed NUREG-0696.' These deviations arise h
from two sources, namely: 1) site characteristics which render strict i
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implementation of the requirements impractical and 2) the increasing number of new requirements and newly definet? details which are evolving.
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While we have made some design changes to'our facilities to attempt to
' meet these recently defined details, we are ccacerned that there are q'
other characteristics of our design with which the NRC staff should' become familiar ana which will require some latitude __in determining acceptability.
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Beaver Valley Power Station, Unit No. 1 c
Docket No. 50-334 License No. DPR-66 I
Design of Beaver Valley Emerge.acy Response Facilities 0
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,., gw sj_1 Substantial. funds and engineering effort have already been expended on this project and, in considering the questions which remain unresolved with regard to theJacceptability of our dpaign, further work on this project has
_.~~been suspended until our deyign approach has been reviewed and approved by the NRC eraff.
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' Attached hereto is a dihcussion of the.iesign concepts of the Emergency Response Facilities at Beaver Valley. This attachment includes a discussion of the areat.lwhere our desig.t is not in corplate agreement with a strict interpretation of the proposed.NUREG-0696. Your review and approval or identification of any areas where. our design is unacceptable is requested.
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j Very truly yours r
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C. N. Dunn~
Vice President, Operations 1
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Attachment.
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U.S. Nuclear Regulatory Commissian c/o' Doc'ticoat Management Branch '
t k*echington, D.C.
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[ s.i f A. Beckr.ta
\\ /8.S.NuclearRegulatoryCommission
' Beaver Valley Power Station.
Shippingport, PA 15077 l
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(CORPORATE SEAL) f Attest:
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Thomas Wolfer, Jr.
Secretary
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COMMONWEALTH OF PENNSYLVANIA) r
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COUNTY OF ALLEEENY On this d'
day of _CS M s 1980, before i
me, HENRY G. ST0ECKER 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 cf Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said t
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company, and (3) the statements set forth in the submittal are true and i
correct to the best of his knowledge, information and belief.
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(dNRY a STO(CKER Notary N
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Pit:s::urg't. Allegt.eny County, Pa......
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Feruary 20,1982 1
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DUQUESNE LIGHT COMPANY ww ; '"
Power Stations Department Design Description of the Beaver Valley Power Station
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Emergency Response Facilities r,
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,f Design' Description of the Beaver Valley Power Station 1
i Emergency Response Facilities i
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_s The*6fficemf2NuclearReactorRegulationoftheU.S. Nuclear-_\\
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Regulatory Commission'es't'ab11 shad =the-TMI-2-Lessons-Learned' Task Force shortly after the TMI-2 accident in the spring of 1979. The purpose of the Task Force was to identify and evaluate those safety concerns i
raised by the THI-2 accident that require generic licensing actions.1 In July,1979, the Task Force issued its first report, NUREG-0578, i'ThI-2 Lessons Learned' Task Force Status Report and Short-Term Recommendations."
NUREG-0578 contains 23 specific recomunendations in 12 areas which aresto be implemented in two stages over the 18 month period following publica-tion. One of the recommendations of NUREG-0578 is the establishment of q
an onsite Technical Support Center (Section 2'.2.2(b)).
Since that time, requirements for other, more comprehensive, emergency facilities were
' developed. Tle recently issued proposed NUREG-0696 formalizes require-i ments for Emergen g Response facilities which were initially identified-as being both iesirabia and necessary shortly-after the TMI event.
We endorsed both the desirability and need for these facilities.
We immediately undertook the design of these facilities and presently have erccted the structural steel for an emergency complex that includes :
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an EOF, a TSC and analytical facilities for radioactive samples.
1 These functions will be carried out in completely isolated portions
_of this complex. Spaces for conferences and press brieffags have been incorporated into the design.-~ Adequate communication equipment, emergency, power supplies and sufficient shielding are provided to assure that all necessary functions can continue to be performed under conditions which
. - - - - - " ~ - -:~aii more severe than the Design Basis Accidents which are included in the Final Safety Analysis Report.
We have presently conunitted a large amount of engineering effort as well as a significant sum of money to this project in order to have these facilities available as rapidly as possibly.
l We are concerned that the increasing number of new requirements and newly defined details will result in major redesigns, schedule slippage, and unreasonably large additional expenditures prior to completing this project un) tas some. flexibility is provided in the NUREG to accommodate the site specific conditions which exist at all facilities. These site specific conditions include such things as the space available in exist-ing plant' structures, the size and shape of the existing plant protected area and the. size, shape and topography of the site.
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Design Description of the Beaver Valley Power Station Emergency Response Facilities II.
'The Beaver Valley Site Chara'eteristics The site is located on the south bank of the Ohio River and comprises 6
approximately 449 acres of which 21.5 acres is' utilized for the protected area of Beaver Valley Unit No. 1.
Immediately contiguous to Beaver Valley Unit No. 1 to the west is Shippingport Atomic Power Statioh and to the east is Beaver Valley Unit No. 2.
All three units, including natural draft cooling towers and switchyard, are located on terraces at elevations of 735 ft. (units) and 707 ft. (transformers). With the exception of the northeast corner of the site where these three units and supporting faci-4 lities are located, the remainder of the site is very hilly with valley walls rising to 1160 ft. above MSL. The site is traversed east and west by a branch line of the Consolidated Railroad Corporation and the easterly i
portion of the site is traversed in a north-south direction by state highway Route 168. Because of the terrain, facilities layout on the suitable areas of the sita have been kept very compact making the addition of any sizable facility within or close to the protected area impractical.
The lowest terrace (elevation 675 ft.) located along the northern shore line is unsuitable for construction due to flood considerations. Figure 1, attache _d_herero,2provides an= elevated = view _of..mche site and the layout m
- of~ facilities. Examination of Figure 1 will show that sites-for_ con-struction of new facilities are limited and suitable sites close to'Ehe=~~
control room are virtually non-existent.
Existing plant structures were examir.ed for suitability for use as a Technical Support Center. All areas of the plant, with the exception of the control room and the rooms beneath the control room, were con-sidered unsatisfactory because either shielding or ventilation or both failed to meet requirements and modification of existing structures to meet these ' requirements was not considered feasible. The areas beneath the control room are too small and contain a substantial amount of equip-ment making these areas likewise unsuitable for a Technical Support Center.
2 Examination of existing facilities indicated that a new structure must be built for ERF and examination of site arcas reasonably contiguous to the control room did not reveal any practical location which meets the control room accessibility requirements as set forth in NUREG-0696.
III.
Location of Beaver Valley Emergency Response Facilities The Technical Support Center is being constructed at a location 1200 feet from the Beaver Valley Power Station control room. This site is illustrated on the Property Development Plan attached as Figure 1.
This site was chosen to take advantage of the natural shielding from containment " shine" afforded by the existing north-south highway embank-ment immediately adjacent to the proposed building site. Also, the distance from the plant is such that the postulated accident dose is reduced at this site. This site allows good access from offsite and has ample parking space for emergency vehicles and trailers. Direct _.
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Design Description of the Beaver Valley Power Station Emergency Response Facilities site roads exist between this site and the control room allowing trans-
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port by auto between the two points in less than 3 minutes. This
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travel time is comparable to the walking time from the' control room to the other possible sites within the plant security boundary.
The Technical Support Center location has been selected to assure that it is easily accessible to the emergency staff including employees of the NSS vendor, A/E and NRC representatives who might not be totally familiar with the site. Ongoing activities in the TSC or the Control Room should not be interrupted to provide guide services for late arrivals. We believe that the specified two-minute walking time between the TSC and the Control Room is unnecessarily restrictive. A slightly longer travel time would reduce unnecessary trips between the two loca-tions, which was one of the original goals of the TSC concept.
In addition, when such a visit is made, even if only to provide a manage-ment presence, the individuals involved will probably spend at least fifteen minutes in the Control Room. No single individual is indis-pensable to the functioning of the TSC since a multidisciplined group is expected to be in place at this location. These facts make the rigid defining of tha travel time between these locations unnecessary. The method of travel should not be restricted to walking since individuals may prefer to drive, particularly in inclement weather.
The two-minute walking time requirement set forth in NUREG-0696 should be modified to state that "the technical support center shall be located sufficiently close to the Control Room that the distance can be traveled in a few minutes under all weather conditions."
% '4 The i ocation and distances between the Control Room, the TSC and x,'(
the EOT
" tid not be defined so precisely that site specific variations N
cannot ce commodated. The only important requirement is that each sactivity ne rhysically isolated from the ott r to avoid unnecessary x
interference and yet be within reasonably'short travel distance to expedite face-to-face interaction when necessary. The best logistical location for each facility musc be selected considering the unique characteristics of'each site.
IV.
Architectural Features The Emergency Response Facilities building has been designad to satisfy the functional requirements of the Technical Support Center, the Emergency Operaticus Facility and a Communication Center. The design of the building enhances the proper control and coordination of the principle activities of emergency operations. The establishment, as soon as is reasonably possible after an accident, of the Emergency Operations Facility in this building will allow close coordination of all offsire emergency activities without interfering with plant emergency operations.
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l Design Description of the Beaver Valley Power Station Eaergency Response Facilities l
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The building will be equipped to process personal dosimetry devices and will have facilities to analyze reactor coolant system and containment atmosphere staples after an accident.
Figure 2 is a conceptual floor plan of the Technical Support Center building illustrating the functional areas described above. Appendix A contains a functional description of each of the significant areas of the building.
Building electrical service will be provided by underground primary service to a 3 phase, 4 wire 277/480 volt pad mounted transformer in the 300 to 500 KVA range, supplied from the Duquesne Light Company distribution system. A Diesal Emergency Generator (approximately 300 to 500 KVA) with i
a 1500 gallon steel underground fuel tank (48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> supply) will be installed l
to provide backup power for the full building requirement. UPS and battery
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systems will be incorporated into the design with a 480V delta, 120/208V wye dry type transformer provided to bypass the UPS equipment via'a static switch.
Architectural Features he building will be constructed of reinforced concrete / concrete block a vill contain provision for the following functions:
1.
Emergency Operations Facility 3.
Emergency Communications Center 4.
Dosimetry Facilities 5.
Sample Preparation Room and Counting Room 6.
Mobile Counting Equipment 7.
Other Ancillary Functions s
Shieldina - Normally habitated areas of the building will be designed to meet General Design Criteria 19 for a DBA.
In addition, extra shielding will be provided for the dosimetry facility, the sample preparation room and the counting room to assure the availability of'those facilities during accident. conditions and to protect building occupants from the effects of a sample handling accident, should one occur within the laboratory' area.
The Emergency Operations Facility portion of the building vill be designed to achieve a protection factor of 50.
Ventilation - The ventilation system will be arranged so that the building is isolable from the outside air. Ventilating air will pass through HEPA both on normal outside air and on' recirculation. Charcoal filters will be available for insertion into the ventilation path.
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Design Description of the Beaver Valley Power Station Emergency Response Facilities V.
, Data and Acquisition System Data acquisition and display is planned to be accomplished through the use of a separate data acquisition computer.
Input to this computer will be obtained from isolated output of the reactor control racks, the reactor protection racks, the environmental monitor racks and other transducers and switch contacts. Regulatory Guide 1.97, Revision 2, was used as a guide in determining the parameters to be acquired. The-l digital and analog information associated with these inputs will be multiplexed and transmitted to the Technical Support Center for display.
At the Technical Support Center, a console will be provided con-i sisting of a CRT, printer and keyboard. The computer will also provide output to 10-2 pen strip chart recorders. These recorders will be capable of trending any variable available to the computer.
l Effluent radioactivity, area monitoring and meteorological data will be acquired using a separate Nuclear Data Model 6650 dual computer system.
Terminals served by this computer will be located in the plant control room, the Technical Support Center room and the Emergency Oper:tions Facility room.
e The computer facilities design criteria availability goal as set forth in paragraphs II D and F of NUREG-0696 should be adjusted by at least an order of magnitude to be consistent with the reliability achieve-ment of commercial equipment performing similar function. Unrealistic availability goals will probably not be achieved during the lifetime of existing plants and will probably be counter-productive by increasing equipment down time for maintenance and modification and extended delivery time of replacement parts.
The requirement set forth in Paragraph III H of NUREG-0696 should be revised to state the "TSC display shall'be of sufficient accuracy to permit assessment of the operating condition of plant systems." Detailed technical analysis, when required, shou 1d be performed utilizing direct readings from installed station instruments thereby eliminating a source i
of potential additional inaccuracies.
The previous comments on revising the unavailability goal also apply here.
l VI.
General The building is planned to be used during non-emergency periods as quarters for engineering personnel. This non-emergency use of the facility has the advantages of providing for the assurance of continuing
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t Design Descriptica of the Beaver Valley Power Station l
Emergency Response Facilities t
operability of building support systems and for the maintenance of up-to-date drawings and records for emergency use. The facility will also 1
be used to train plant operations and emergency personnel where the Technical Support Center data acquisition system and displays will be part.icularly useful. In no way will these alternate uses of the facility interfere with the primary purpose.of the building.
Our construction plans have been to proceed as rapidly as is possible to complete the ERF by the dates required. Because of our inability to meet the strict interpretation of the NRC requirements, we cannot cen-tinue construction under our present design until the NRC staff revr.ews and approves our design concept. We are further concerned that new-details of requirements as set forth in NUREG-0696 could add substantially 1
to the total' design.and construction time for,ERF. For example, paragraph j
I D of NUEEG-0696 requires independent verification of the design, develop-ment, qualification and-installation of the SPDS, TSC, EOF and NDL. This requirement vill extend design and construction time by at least five i
years. Similarly, unusually optimistic goals for availability beyond i
the state of commercial practice for data systems will necessarily extend construction time for these systems substantially. SPDS seismic require-ments will also increase construction time.
In our situation, requiring strict compliance with the two-minute walking distance will require aban-donment or present plans and total redesign of the TSC if, in fact, any suitable alternate location can be found.
We therefcre encourage a flexible review by the NRC staff. We believe that recognition of individual circumstances prevailing at specific sites and of the state of the art within the. industry will produce operable facilities in a reasonably short time frame. We further believe that imposing of unnecessarily rigid requirements will impede design, procure-ment and construction progress co the extent that the facilitus could not be placed in operation for a number of years. We believe that the former approach has the greater benefit to the. safety of the public.
VII.
Summarv
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This report has described the results of planning and design activities for the Emergency Response Facilities building, plant monitoring equipment and communications equipment for the; Beaver Valley Power Station.
While every specific recommendation related to the construction and equip--
ping of the ERF cannot be embodied -in a design suitable to this site, every reasonable effort has been made to incorporate into the design those features which will satisfy the intent of the requirements set forth for this ites.
j Special consideration hss been'given to habitability and usefulness of the facility'during acciden.: conditions.
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APPENDIX A-Design Description of the Beaver Valley Power Station Emergency Response Facilities i
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1.
Technical Support Center Room This room will be sized to' accommodate approximately fcrty (40) persons. The room will contain approximately ten (10) wall mounted 2 pen recoruers. Parameter display will be through a CRT console with a printer-for hard copy print. There will be desk space for approxi-mataly twenty-five (25) persons and sufficient flat work space to hold 4 or 5 full size drawings. Spcce will be included for microfilm viewer or projector.
2.
- Computer Roon This room 'till contain suffeient room for computer and process racks, programmer's desk and fi
.s communications and tone equipment, also computer and recorder par., supplies and a t. trk table.
3.
Emergency Operations Facility 2
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This room will contain site and area maps and will have desk space for approximately 25 to 35 persons. This at ta will contain ona
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CRT terminal and printer, teletype and a telecopie. This room will be located adjacent to the Technical Support Center Room, and will be shielded to a protection factor of 50.
4.' ' Emeraency Commiunications Center Room This room will contain working space for a minimum af five persons and should have two CRT' terminals and will house the radio communication control equipment. Each work position will have space for several telephones. This room will be shielded to a protection factor of 50.
5.
Emergency Director's Office
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This office will have direct access to the Technical Support Center a
and the Emergency Operations Facility Room. This roca should be large l
enough to seat twelve (12) persons for briefings.
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6.
Near-Site Emergency Coordination li An area will be provided which is sized to contain 10 %o-man office cubicles which can be used for government liaison offic his plus one office cubicle for the Duquesne Light Company liaista representative.
This area will be fully equipped with telephone service, teletype and telecopies service. This room will be in r;asonably close proximity to the Emergency Director's Office, the Technical 'upport Center Room and' the~ Emergency Control Center Room.
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Appendix A Design Description of the.
J 5eaver Valley Power Station Emergency P.asponse Facilities 1
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Auxilisry Facilities Rooms a.
Kitchen This room will contain a sink, two small microwaves, one 2-4 burner
- range and one freezer / refrigerator combination.
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b.
Records' Room i.
This room will contain a set of as-built station drawings, a complete set of station manuals, the FSAR, a comprehencive set of vendors manuals and in(.truction books will also be available.
c.
Sleepina-~0uarters For 8-10 persons (fold-up cots acceptable).
,1 d.
Medical Facilities One bed, one first-aid cabinet and sink.
j e.
Garane tor monitorina Van f.
Reception Room and Security Room i
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Mechanical Equipment Room HVAC. etc.
i 8.
_ Laboratory Area I
a..
Dosimetry Lab A shielded dosimetry laboratory will be pcovided with body = counting = s=== "
facilities and TLD processing equipment of sufficient capacity to serve the needs of all station personnel.
b.
Sample Preparation and Counting Facilities Shielded sample preparation and counting facilities utilizing a Nuclear Data Model 4420 gamma spectrometry system with intrinsic germanium detector will be available in~the building. ~We plan to provide a liquid scintillation system and gas ini:ernal propor-4 tional counters. It.is also planned to maintain a reserve supply of various types of survey instruments.
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