ML20040D951

Requests Extension of Schedule Dates in Paragraph (C) of Fire Protection Regulations in 10CFR50.48,per 10CFR50.12

ML20040D951
Person / Time
Site:	Beaver Valley
Issue date:	01/20/1982
From:	Carey J DUQUESNE LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20040D947	List: ML20040D946 ML20040D951
References
TAC-11111, NUDOCS 8202020427
Download: ML20040D951 (4)

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~%5 ouquesneuet 435 Santh Avenue pyon.ea-January 20, 1982 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn: Harold R.-Denton, Director Office of Nuclear Reactor Regulation Washington, DC 20555

Reference:

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

Dear Mr. Denton:

This letter is to request, pursuant to 10 CFR 50.12, extension of the schedule dates in paragraph (c) of the fire protection regulations in-10 CFR 50.48 for Beaver Valley Unit No. 1 that were previously submitted to you in our letter of December 1, 1981.

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 July 1, 1982.

(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 to July 1, 1982.

(3) that the implementation 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 to nine months after July 1, 1982.

(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 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 January 20, 1982 to the Division of Licensing.

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 July 1, 1982. We are currently reviewing drawings associated with equipment necessary for safe shutdown in anticipation of identifying any necessary plant modifications and developing a procedure that will address alternative methods for operating equipment and limit maloperation by isolating associated circuits of safe shutdown equipment in the event of a fire within designated areas.

8202020427 820120 hDRADOCK 05000334 PDR

o 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 November 24, 1980, Duquesne Light Company initiated a review of the requirements of the new rule, especially those of Section 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 being conducted to compare each cable with all cables in each of the fire areas to demonstrate whether or not redundant and diverse functions are vulnerable to a fire in any given fire area. Within a vulnerable fire area, the location and functional relationship of cables is identified in order to evaluate existing separation, fire suppression and detection. This computer search is presently approximately 70% complete.

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 sodifica tions.

This 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 protection 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 HOT 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 trul yours, k

J. J. Carey Vice President, Nuclear Enclosure

- Beaver Valley Power Station, Unit No. 1 Docket No.~50-334,JLicense 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, Pennsylvania 19406 t

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