ML20082B358

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Request That Question 240.01 & 08 Be Rescinded from FSAR & Drainage Plan Reviewed Per NUREG-0880.Review Criteria Change Not within Nrrd Policy Outlined in 820428 Rev 2 to Ofc Ltr 2
ML20082B358
Person / Time
Site: Beaver Valley
Issue date: 11/15/1983
From: Woolever E
DUQUESNE LIGHT CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0880, RTR-NUREG-880 2NRC-3-088, 2NRC-3-88, NUDOCS 8311210150
Download: ML20082B358 (2)


Text

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2NRC-3-088 (412) 787 - 5141 Telecopy 8

November 15, 1983 Nuclear Construction Division Robinson Plua, aulldM 1, Suite 210 Pittsburgh, PA 15205 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. Darrell G. Eieenhut, Director Division of Licensing Office of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Final Safety Analysis Report - Review Ques tions Gentlemen:

As discussed in Chapter 1 of the Beaver Valley Power Station Unit 2 Final Safety Analysis Report (FSAR), the design of the station was reviewed against the Fed e ral regula t ions and the NRC St anda rd Review Plan (S RP),

NUREG-0800, dated July 1981.

A recent reque s t for additional info rma t ion on the Beaver Vall?y docket revises the SRP criteria without following NRR procedures for such revisions.

Such act ions by the staf f are contrary to NRR policy and have a destablizing ef fect on the licensing process.

On August 31, Duquesne Light Company (DLC) received seve ral que s-t ions fr om the NRR Hydrologic Engineering Branch conce rni ng the probab ic maximum precipitation and its ef feet on safety-related structures and component s at Beaver Valley Unit 2.

In reviewing these ques tions, we not ed that the staff had ch anged their reveiw cri teria fo r pr obab le maximum preci pi t at ion (PMP) from the Hydrometeorological Report (HMR) No. 3 3 and Corps of Engineers EM 1110-2-1411 to HMR's Nos. 51 anci 52 dated June 1978 and August 1982, respectively.

It is our feeling that such a ch ange ' to the rev i ew cri teri a, especi ally at this stage of the Beaver Valley Unit 2 review, is not in accordance with NRR policy as outlined in NRR Of fice Letter No. 2, Revision 2, April 28,1982. As noted on page 2 of this memorandum, " Staff reviewers should not decrease or go beyond the scope and requirements of any specific SRP section".

In accordance with 10CFR50.34(g), DLC submitted Section 1.8 of the FSAR Wich evaluated Beaver Valley Unit 2 against the SRP (NUREG-0800, July 1981) in of feet six months prior to our docket date of May 18, 19 83.

8311210150 831115 gl PDR ADOCK 05000412 A

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United States Nuclear Regulatory Commission Mr. Darrel G. Eisenhut Page 2 Therefore, it is req ues ted that que s t io ns 240.01 and 240.08 be rescinded a nd that the Beaver Valley site dra inage plan be reviewed in ac corda nce with NUREG-0800, July 1981.

DUQUEUESNE LIGHT COMPANY By

(

E.VJ. Woolever Vice President ETE/wjs cc:

Mr. G. Knighton, Chief Licensing Branch No. 3 Ms. L. Lazo, Project Manager Mr. G. Walton, NRC Resident Inspector

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