ML20081C074
| ML20081C074 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/26/1983 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8310310089 | |
| Download: ML20081C074 (3) | |
Text
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i 2NRC-3-078 M12) 787-5141 Telecopy
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Nuclear Construction Division Robinson Plaza, Building 2, Suite 210 Pittsburgh, PA 15205 United States Nuclear Piegulatory Commission Washington, DC 20555 ATTENTION:
Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 BVPS-2 Technical Specifications Gen t lem'e n:
A meeting was hald with Duquesne Light Company (DLC) on Tuesday, August 23, 1983, at NRC Headquarters in Bethesda, MD.
The NRC was rep r e-s ent ed by members of the Division of Licensing and the Division of Human Factors.
The purpose of the meeting was to discuss DLC's development of the Technical Specifications (Tech. S pe cs. ) for Beaver Valley Power Station -
Unit No. 2 (BVPS-2).
DLC opened the meeting with a discussion explaining the BVPS-2 Tech. S pe c, preparation policy, implementat ion statu s and sub-mittal sch ed ule.
DLC has be en following the guidance of 10CFR50.36 which i nd ica t es that the applicant 's proposed Tech. Specs. should be derived from the analyses and evalua t ions inc luded in the ap plicant 's Final Safety Analysis Report.
In addition, the BVPS-2 Tech. Specs. are being written to be cotisistent with the BVPS-1 Tech. Sp3cs.
EVPS-2 is similar, although not ide nt ical, to BVPS-1, which was licensed in 1976.
The two uni t s will be ope ra ted from a common control room under the direction of a single Shif t Su;ervisor.
l BVPS-1 utilized the original vers ion (Rev. 0) of the Wes tinghouse Standard Technical Specifications (WSTS) for the operating li ce ns e.
These l
tech. specs. have been revised over the years to reflect ch anges in regula-tory, requirement a, plant modifications, and, in some ins t ance s, to clarify the intent of the speci fica t ion.
The la t es t issue of the USTS has always been ut ilized as a model in the preparation of proposed revi s io ns.
Dif believes that the existing BVPS-1 tech. s pe cs, are extreicely ef fect ive in j
accomplishing their intended purpose; which is to assure that the plant and its equipment are operated and maintained as described in the Final Safety Analysis Report (FSAR) and within the assumptions utilized in the accident analyses.
A comprehensive set of ope ra t ing, maint enance, tes t ir.z, surve il-lance, and training procedures and programs have been developed based upon implementing the requirements of exieting tech. s pe cs.
DLC es timates that over 40 man years of ef fort has been expended in the development, review and revision of these procedures, 8310310089 831026 M
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- United States Nuclear Construction Division Mr. Hxrold R. Denton Page 2 DLC has been informed that the staf f has an int ernal po licy wh ich requires NTOL's to develop tech. specs. based upon the la tes t issue of the Standard Tech. Specs.
It is DLC's understaMing that the major purposes of revising Stan-dard Tech. S pec s. is to cla ri fy the int ent of specifications to pr ec lude inadve rt ent non-compliances that mignt result fr om individual li c ens ee int erpret at ions and to ad dr es s ge ne ric req ui rement s imposed to reso lve various safety issues.
BVPS-1 programs, and in many cases, the tech.
specs, have been revised to address these issues.
In ce rt ain instances, some minor addit ional conservat ism has be en sometimes introduced into the S taMard Tech. Specs. by the NRC; e.g., the t ime pe rmi t ted to restore a piece of equipment to se rvice might be changed from 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
We have never been able to ascertain the bases for the exi s t ing pe rmi s sab le times for a piece of equipment to be out-o f-service, but we believe that they were based on an attempt to balance the best ava ilab le estimates of the occurrence of an event that might req ui r e that piece of equipment.
We can also conclude that the sho rt enir.g of the permissible time by six hours would decrease the probability of that equip-ment be ing unava ilab le wh en called upon by 6/8760 or.075% on an annual basis.
DLC is also concerned ab out the human factors as pe ct of attempt ing to operate two essentially ident ical units fr om a common control rom with significally dif ferent tech. s pe c s.
These dif ferences on the same systems will lead to operator confusion and possible operator error.
It is not c le ar to us that the marginal improvement s in calculated probabilit ies of equipment un ava ilabili ty of one of these un it s impr oves the safety posture of the s tat ion suf ficiently to justify the, pr edict ab le di sru pt ions that are bound to occur as a result of inad ve rt ent application of the wrong out-of-set < ice time to one of the units.
The staf f informed DLC that there will be no backfit req ui r ed on BVPS-2 to meet the S t anda rd Tech. S pe c s.
The staf f reque s ted that DLC s ubmit a marked-up copy of Rev. 4 to the S t andard Tech. Specs. to ind ica te proposed BVPS-2 Tech. S pe cs.
A justification fo r each pr oposed devi a t ion from Rev. 4 of the Standard Tech. Specs. was also requested.
DLC indica t ed that the req ue s ted conformity evaluation would be a s igni ficant ef fort and would advise the staf f when the req ues t ed info rma-tion would be submitted.
DUQUESNE LIGHT COMPANY By E.UJ. Wooleve r Vice President
4 N United States Nuclear Regulatory Commission
~ #
Mr. Harold R. Denton.
Page 3 4
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- cc: - Mr.'G. W. Knighton,-NRC Licensing Branch Chief, Region 3 Ms. L. Lazo, NRC Project Manager
. Mr..F. Anderson, Standardization and Special Projects Branch 8
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