ML20033C783

Requests Extension of Submittal & Implementation Schedule Dates for Newly Enacted Fire Protection Regulations in 10CFR50.48,per 10CFR50.12.Scheduled Extension Relates to Mods Which May Be Required to Satisfy Section Iii.G

ML20033C783
Person / Time
Site:	Beaver Valley
Issue date:	12/01/1981
From:	Carey J DUQUESNE LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TAC-11111, NUDOCS 8112040224
Download: ML20033C783 (4)

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December 1, 1981 l

P, Director of Nuclear Reactor Regulation United States-Nuclear Regulatory Commission gg},.7 At tn : Harold R. Denton, Director

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Beaver Valley Power Station, Unit No. 1 DEC3 1981n- -'

Docket No. 50-334, License No. DPR-66 Exemption to Appendix R Requirements E,

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Dear Mr. Denton:

f This letter is to request, pursuant to 10 CFR 50.12, extension of certain of the schedule dates in paragraph (c) of the newly enacted fire protection regulations in 10 CFR 50.48 for Beaver 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 to March 31, 1982.

(2) that the date in paragraph (c) (5) for submitting design descriptions of modifications needed to safisfy Section III.G.3 of Appendix R be extended to March 31, 1982.

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(3) that the implementation date in paragraph (c) (2) for installation of modifications required by Section III.G.2 of Appendix R, that do require prior NRC approval or plant' shutdown,.be extended to nine not months after March 31, 1982.

(4) that the implementation date in paragraph (c) (3) for the installation i

of modifications required by Section III.G.2 of Appendix R, that do not require prior NRC approval, but require plant shutdown, be extended to the third scheduled refueling outage.

The plans and schedules now available for implementing modifications required by Appendix R are being submitted in a separate letter dated December 1, 1981 to the l

Director of Nuclear Reactor Regulation. The schedule extensions requested herein relate to those modifications which may be required to satisfy Section III.G and which cannot be specifically identified until March 31, 1982.

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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 2 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 appropriate 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 No'rember 24, 1980, Duquesne Light Company initiated a review of the requirements of the new rule, especially those of Ss. tion III-G.

The analysis defines all those associated circuits, specifically non-safety related associated 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 areas to demonstrate whether or not redundant and diverse functions are vulnerable to a fire in any given fire-a rea. Within a vulnerable fire area, the location and functional relationship of cables is identified in order to evaluate existing separation, fire suppression and detection.

Additional time will be necessary to completely define all circuits involved and to complete the computer search.

Upon completion, a thorough review of the data-will be required in order to make recommendations and propose any required modifi-cations.

The requested extension will not be detrimental to health and safety.

There are no urgent considerations which would mandate the immediate implementation of the Appendix R requirements. In the case of Beaver Valley, those measures required to be completed in accordance with the dates specified in the SER have been completed.

The completion of these items as identified in the SER provide adequate fire pro-tection for the equipment to reasonably assure their continued operation. Additionally, Beaver Valley has alternate shutdown capability that will enable the plant to reach and maintain a h0T STANDBY mode.

Accordingly, we are at this time requesting the foregoing extensions of the schedule requirements specified in paragraphs 50.48 (c) (2), (3) and-(5).

Very truly yours, J. J. Carey Vice President, Nuclear Enclosure

9 Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 Exemption to Appendix R Requirements Page 3 cc:

D. A. Beckman, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:

R. C. Haynes, Regional Director Region I 631 Park Avenue King of Prussia, Fennsylvania 19406 e

COMMONWEALTH OF PENNSYLVANIA)

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me, e andAodnty, personally appeared J. J. Carey, 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 in the Submittal are true and correct to the best of his knowledge, information and belief.

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