ML20099G533

Forwards Positions on Backfit Requirements.Further Clarification & Justification to Facilitate Meaningful Appeal Meetings for Evaluating Postulated Increase in Plant Safety Requested

ML20099G533
Person / Time
Site:	Beaver Valley
Issue date:	11/20/1984
From:	Woolever E DUQUESNE LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML20099G536	List: ML20099G533
References
RTR-NUREG-0800, RTR-NUREG-800 2NRC-4-195, NUDOCS 8411270332
Download: ML20099G533 (14)

Text

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'Af 4 ) 78 -5141 Nuclear Construction Division Mecon Robinson Plaza. Building 2, Suite 210 Pittsburgh, PA 15?05 November 20, 1984 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. Darrell G. Eisenhut, Director Division of Licensing Of fice of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Duquesne Light Company Backfit Status Gentlemen:

In a recent letter (Mr. T. Novak to E. J. Woolever, dated November 6, 1984), the NRC transmitted to Duquesne Light Company (DLC) a brief discussion of nine backfit requirements which the NRC staff intends to impose on Beaver Valley Power Station - Unit 2 (BVPS-2).

Attachments one through nine provide the DLC positiv s with respect to the staf f's written positions or requirements.

DLC, as evidenced in the individual attachments, perceives the need for further clarification, cf the requirements and their justification, in order to facilitate meaningful appeal meetings.

In many of the attachments there is no precise statement of the requirements that the reviewers wish to impose. Further, since some of the implied requirements are not consistent with the most recent positions of the staf f reviewers, DLC is not certain that the requirement has been sufficiently stabilized to ensure productive discussion of the merits of the issues.

DLC believes that NRR has developed a very workable procedure (Enclo-sure 2 of GNLR 84-08) to implement the requirements of NRC Manual Chapter 0514.

We believe NRR's procedure intends that the appeal meetings provide a forum for evaluating the pos tulated increase in plant safety to determine whether the new requirement should be impos ed.

Without a clearly stated requirement and without an outline of the rationale by which the staff concluded that the proposed requirement provides a needed increase in safety, beyond that provided by existing regulations, DLC is unable to formulate and submit the well-defined position which is requisite to productive discussion of these issues.

My staf f is available, as required, to expedite the completion of the preparatory steps which will lay the fo,undat ion for meaningful discussion of the merits of the staf f's proposed requirements.

DUQUESNE LIGHT COMPANY

\\.

l By E. 4) Woolever Vice President 8411270332 841120 PDR ADOCK 05000412 A

PDR Boo t

.U2ited.Stcts3 Nucladr.RIgulctcry Commicsien Mr.'.D:rrall G. Eis:nhut, Dirsctor Page 2

'RW/wjs At tachments cc:

Mr. M. Clausen, Technical Assistant (w/a)

Mr. S. Chesnut, Technical Assistant (w/a)

Mr. H. Denton, Director NRR (w/a)

Mr. T. Novak, Assistant Director (w/a)

Mr.'B. K. Singh, Project Manager (w/a)

Mr. V. Stello, DEDROGR (w/a)

Mr. J. Tourtellotte, Chairman RRTF_(w/a)

Mr. G. Walton, NRC Resident -Inspector (w/a)

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ATTACHMENT 1 PACE 1 0F 2 ISSUE: Review Criteria for Probable Maximum Precipitati.on (PMP)__

BACKFIT ISSUE NO.: L-84-16 TO DLC RESPONSE TO NEC LETTER DATED 11/06/84 DLC.BACKFIT NO.

1 05/30/84 11/06/84 Bac k t it IRC Rqen t s Appeal Position Meeting First Minutes ; 'Second Meeting Second Minutes &

Formal Identified Letter Filed Statement Agenda Appeal Decision Appeal Agenda Appe al Dec is ion Appeal Submitted lasued Meeting issued Requested Issued Meeting lasued Req ue s t to Dir, NRR NRC POSITION DLC POSITION COMMENTS PROPOSED In FSAR questions dated August 31,1983, and in The NRC's acceptance REQUIREMENTS Draft SER received March 1,1984, the NRC stated review found the BVPS-2 f t is ene state catutten test me $1/s2 are the aest runtir avaliente that DLC should evaluate PHP using HMR 51 and HMR 1icense application pubitCatteas en the subject of PMP east of the 10$th serldtaa. There ere.

52. On May 30, 1984 DLC identifled this issue acceptable for docketing r

en y sneeld be used as the ents tw reste= to accordance =tta precedures as a backfit requirement.

with the PMP evaluation ceed to sap 2.4.r and 2.4.3.

1,ased on HMR-33.

In a letter dated October 12, 1984, the NRC tt ts ruegattee that the value of for cannet ne uterstaes prenant1tsticaty requested that DLC answer questions using the 6anse of tantric *pt nea. Me nw. a deter =taistic memi cu to used.

FSAR data which had been developed using HMR 33.

On November 8,1984, DLC answered the NRC ques-tions of October 12, 1984, using the HMR 33 data.

The NRC position of November 6,1984, states that HMR 51/ 52 should be used as the basis for review. This appears to conflict with the Octo-ber 12, 1984, letter. Further, DLC is not cer-tain whether the NRC. intends to require DLC to re perform the PMP analysis using HMR 51/52 or.

whether the staff intends to use the methodology N

of HMR 51/52 to review the HMR 33 evaluatic,n.

Floodtag of safety-related factittles as a result of fatease local practpitatten designed to support water accumuletion at the

.rael cu ector to two ways: First. by accumulatten of retafall en reefs of Parapet overflow level. Postulating a greater PMP

.afety-reisted structures nech eueeds the ante ind aad ent,a Imt. m event results in increased overflow rather than' IMPROVE oe of m ruf a f

of m utela increased accumulatlon. Therefore, no increase in SAFETY

,,,,,,,,q,,,,,,,,,,,,,,,,,,,,,,,,,,i,,,,,,,,,,,,,

safety can be demonstrated with respect to roof reef matenes and reef vettietws. tatertw fleedia, can rewit sa the less ey loading, and plant safety as not compromised.

ufety-related eintrical eat,= eat.

Probable Maximum Precipitation is described in.

HMR 33 as " synonymous with ' maximum possible pre-ine swend fleestae esta, es site fieedia,.nten can ruelt 6e water imis cepitation'."- Since this is a rainf all which, by definition, cannot be exceeded, increased safety as plaat grade unten eueed the dose st11s of safety-retated structures. The ta tuaap from ents patn.sy, as in ene case of esensive reef peastag. caa cannot be desunstrated for the use of a higher vitimately ind to ins a niatist electrical eatet.

rainfall intensity. The highest actual rainf all for the Pittsburgh area was 2.09 inches in I hour (during 1876). The HMR 33 analysis uses a I hour intensity of 9.3 inches / hour. Unless the staff can demonstrate that a storm vore severe than the HMR 33 PMP has a probability greater than zero, no increase in safety can be demonstrated for the use of a more severe projection.

1

ATTACHM NT I.. PACE 2 OP 2-

~'i ISSUE Review Criteria for Probable Maxiupas Precipitation (FMP)

BACKPIT ISOE Nol:

L-84 -TO DLC RESPONSE-TO M C LETTER DAfED 11/06/84 DLC BACKPIT NO.: 1

+

NRC POSITION DLC POSITION C09MENTS RELATION OP MMR 33 methodology, as suggested by the SRP,- was NEW REQUIRE-seneret nest,a cettwton 2 (soc-tI. Ecestga bases fw protectie avatast astural used to demonstrate that BVPS-2 meets CDC 2.

MENT TO

,> nomeaa.* er to cFe so. Appades a. reevices, ta part, that a cieer e er EXISTING etent structens, syntes and compoasts te destened to ettnstead the e fects BVPS-2 was designed prf or to the issuatice of HMR r

REGULATORY er fie ds without less of caesetitty to awfor= taete safety feacticas.

51 and 52.

POSITIONS cuidaace is aise esatataed la segetatory Goldes 1.59. *oestga seats Fleeds for Construction of the BVPS-2 safety related struc-wieer to er piants". end 1.102. *Flead Protection for nuclear Power Plaats' tures reached a significant percentage of com-n.ese dec aeats state anat ene enroectate dest,a tests for pew pitettea taduced pletion prior to the issuance of HMR 52.

s fie dtag ts the Probatte poetave F1eed (PW) as developed by the Corps of fagineers.

Ytts Pm cetterten has been esed by the staff stace at least 1970 for res"t"*

No regulations provide for the use of HMR 51/52.

eents ee tatense local proctattatten. This restew was tacorporated late the steadard Review Plaa (5RP) 2.4.2 and f.4.3.

No regulations require update of PMP evaluation methodology.

saw t.s.: refers to ser secston 2.s.3 for par estt=stes. time distettette.

etc.

SRP 2.4.3 states the follawlag:

Sectlen vg m.fere.ces "la adottien to the felle= tag specific references. Destga Ms=ornada.

Civil Works lowestigettens sad researen and develapsent reports of the Crees of tagtavers and reports of ether federal and state ageactes releveat to f'.000 esti=stes et a speCtf tt site util be used en aa "as-availa41e* Dasts..

• wyeremeteorolosteel aeports Deel $1 ead 52.ere lis.ed Josetty ty matteet Ocesale and 4teospherte Adatetstrettea (Ratleast weather Service) and the

s. 5. Army Corps of tagtaeers la Jwae 1978 ead August isst, respectively.

SUCCESTED DLC is unable to establish a position since no

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TIME FOR time has been proposed.

IMPLEMENTn*

TION d

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ATTACHMENT 2

. PACE.1 OF 2 ISSUE:

Fire Suppression in the Cable Spreading Room BACKFIT ISSUE NO.

L-84-10 TO DLC RESPONSE TO MRC LETTER DATED 11/06/84 DLC BACKFIT NO.: 17 05/30/84 11/06/84 Backfit NRC Rqents Appe al Position Meeting First Minutes &

Second Meeting

.Second Minutes &

Formal Identified Letter Filed Statement Agenda Appe al Decision Appeat

' Agenda.

Appeal Decision Appeal Submitted issued Meeting lesued Reque s ted issued Meeting is sued Request to.

Dir. NRR 4

NRC POSITION DLC POSITION-COP 9 TENTS PROPOSED

1. The NRC staf f's proposed requirement is not it' appears that the NRC REQUIREMENTS readily apparent in the November 6.1984 staf f may intend to letter.

elevate the status of SRP 9.5.1 and BTP 9.5-1,

2. The fire suppression design for the BVPS-2 which it incorporates by cable spreading room meets the requirements reference. to the level of a requirement. '10CFR of 10CFR50.

50.34(g) states that compliance with the SRP is not a requirement.

HOW PROPOSFD CO2 is a imre appropriate suppression medium for REQUIREMENT ghe gypg.2 cable spreading room than is water.

DLC does not consider the selection of 0)2 to M LD r,,, pr t ct s,,,.,,,y g.wg,

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be a weak Iink in the defense-in-depth chain.

IMPROVE sigi it t tw prey as c w i.e.ty,,

tw. o

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Further, it s k id be noted that the strength of SAFETY

,..,,,3.,n ti. y nn t wn t,

tw.,iit, u,.tig.i.n nn, nig a defense-in-depth progras is based on the tatal 4

t.,orce8"****'*""*'**'""'"""-

"""'. '"' *. i g it y,,

t Protection of the program rather than on a single cc, t..ccogiin emis. cts e

.di e.

ttas. cert.i. o c tr.tsen of ce,

" weak. link."

for.,.etoe of ti auen.cy to ter.i te ene str...e er.w.t nipitt.

rw n..e ter

. nm ente nnetati.

2 and water can effec-DLC agree.s that both CO tively extinguish fires.

Both water and CO2 have design requirements which must be considered in the suppression system design. The staf f has chosen to label these design requirements as limitations. Water sup-pression systems have there own set of design reqairements which can also be labeled as limitations.

SVPS-2 uses covered cable trays and has electri-cat switchgear located in the fire area in which the cable spreading-room is located.

OLC will test the cable spreading room CO2 system prior to fuel load to ensure that system per for-maned is consistent with specification require-ments. The NRC is welcome to witness the system testing.

s Cables from boti safety trains are located in the Fire t. en. ca1. serudig e

, e, ca' er 6etn uvery trei.,.nic.

cable spreading room regardless of choice of sup-s

.r. ese 11,.we t samt eava the cent.,.ae

+ t.ia +t ta. u e mtseva Press (on medium.

.ad t i. a signific..t ver.

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.., n.iic., strat.cn v.t.e,

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ATTACMMENT 2-PACE 2 0F 2 ISSUE:

Fire Suppress. ion in the Cable Spreading Room BACKPIT.1SSUE No.:

L-84-10,_

TO DLC RESPONSE TO MC LETTER DATED 11/06/84-

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DLC BACKPIT NO.: 17 NBC POSITION DLC POSITION COMENTS -

RELATION OF Mone of the regulations pertaining to fire pro-The SRP identifies an -

• • I"'5"******'"'*""****'*"'35""'*'*8'I**9"

tection for nuclear power plants specify the acceptable means for Meld REQUIRE-MENT TO M'd'*d""*****'"'I"F""'"'""'

suppression mediums to be used.

meeting the requiremente

""' "' '*' " irs *at s of %50 88. Coc 3 ead S.

la 'r8'r te a'** **e which underlie the SRP.

EXISTING

• • • • "9"'""8=*"*""i""'**"**""

Altt.ough the BTP 9.5-1 paragrsph eited in the Nowever, 10CPR50.34(g)<

RECutATORY POSITIONS November 6, 1984, MRC letter expresses a prefer-states. "The SRP is not a ereace Tecn. net enitie. asvei cus,.s.i u.t reietn te tne ence for water, oths r parts of the same BTP substitute for the regu-eesig. pre iste.s,ie te te,ie e eme rire protect s

,regre.-

address design considerations for gas suppression lations, and compliance

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The eTP cms 9.5-1 et eeregreen c.f.c toe,e 9.s.i-4sl states:

At least 14 operating plants along with several ~

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cenie s,rnes., see.

NTOL's use ;se systems as the primary fire sup-Pression systems in cable spreading rooms. Since The prise y fire svoeresste. in the cette spreedia, res.

these plants have not been requried to obtain should be se este= sue water system sect es stes.4-nne exemptions to Title 10, DLC must conclude that seriamiers.==+ 4 eetage syste.. er dienttoa.1 water suppression is not required by existing ter spie.

regulations.

i o

DLC is unable to establish a position since no SUCCESTED TIE FOR t ime has been proposed, IMPLEMENTA-TION

l ATTAOIM IT 3 ISSUE: Steam Cenerator Level BACKFIT ISSUE NO.

L-84-13 TO DLC RESPONSE.

11/06/84 To letC I2TTER DATED DLC BACKFIT NO.: 1 05/30/s4 11/06/84 Backfit NRC Rgents. Appeal Pos it ion Meeting First Minutes &

Second Meeting

Second Minutes &

Formal Identified Letter Filed Statement Agenda Appeal Decision Appeal

^ Agenda Appeal Decision Appeal.

Submitted issued Meeting les6ed Requested leeued

Meeting, lesued -

Req ue s t to -

Dir, NRR NRC POSITION DLC FOSITION CotMENTS '

PROPOSED A large number of plants are currently operating N 8" Y

• P""("'a 875"* '" '"8"*

i"18 t i" '* * '9" St"*

with the standard Westinghouse 3 channel SG level REQUIREMENTS peerstw lewt sne.ie ne sectated to confer eace ith sectka e,7 af :tt5-570' control / protection system. Many of these plants 279 as reg tree e la cra so.55athL otherwise. the ufety eaaiysts ornated received CP's af ter January 1,1971, and are, in $ ction is er ene tsaa sne.14 se ce.iue te semeastrate taae ene ceawowen therefore, subject to 10CFR50.55(h). Since these of sens caerate e.wetii ere aet u et, siciticut e=4 that eversaw rneense plants have not been required to obtein exemp-r te s.cn acts.: say, ewe tewi is aet ce + red ta iess in a u 6a tes.

tions to 10CFR50.55(h). DLC must conclude that 10CFR50.55(h) does not require a fourth SG 1evel channel.

The hi-hi level trip is not required for protec-tion from'the excessive feedwater transient. The hi-hi-steam generator level function is assumed in FSAR Chapter 15 only for the analysis of, "feedwater system malfunctions causing an -

increase in feedwater flow.

This analysis satisfies all applicable safety criteria, as the minimum DNBR remains above the protect ion limit and the minimum DNBR occurs prior to turbine trip (see FSAR Figure 15.1-2 and Table 15.1-1).

NOW PROPOSED The event postulated by the staf f is extremely REQUIREMENT improbable.' Additionally, DLC has provided

1. it" *** 8'""t 8"?'" e sia,te f ati re of a stna esaerstae inet capael responses teilch demonstrate that the operator has M LD

• ** 'd ( **" '** d"'.caat**1 ' F5t** ** 8'**ad 4'd""' ' * *"8 '

sufficlent information and time to respond. The IMPROVE

'""*5'"*"""'"**"****'"'*"**'""""**"

etaf f has not demonstrsted that the' postulated SAFETY

=t ene stagie fattere critwie.

Improvement to safety warrants this new requirement.

RELATION OF This position has not been provided by the NRC, therefore, DLC is unable to formulate a complete NEW REQUIRE-PENT To po s it ion.

EXISTING REGULATORY POSITIONS SUCCESTED DLC is unable to establish a position since no TIME FOR t ime has been proposed.

IMPLEMENTA-TION 1

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ATTACNINr.T 4 PAGE 1 OF 2 ISSUE: - Air Drytra ist Emerstney DisM1 Cenerrtor BACKF1T ISSUE No.: L-84-12

~ TO DLC RESPONSE :

'1-TO NRC LETTER DATED 11/06/84 DLC BACKFIT NO.: i 06/15/e4 11/06/84 Bac k f it NRC Rqmnts Appe al Position Meeting First Minutes &

Second Meeting Second

. Minutes &. Formal-identified Letter Filed Statement Agenda Appeal Decision Appeal

. Agenda Appeal Decision Appeat Submitted Issued.

Meeting.

Issued Reques t ed Is sued Meeting Issued '

Request-to Dir NRR e

NRC POSITION DLC POSITION '

. C0petENTS PROPOSED The Standard Review Plan is not a requirement, semserd m.ete. tw (sarl sectta 9.5.4 rewires (10CPR50.34 states, "The SRP ie not a substitute tut iiettu of sie errors to praeat seistere acces=1etten to the emergency f r the regulations, and compliance is *ot a eies.i,s.oretw s sie ntert irstem.

req ui reme nt. )

9 HOW PROPOSED Operating history of diesel generators at BVPS-1 REQUIREMENT has shown that proper maintenance and operating.

Pract ices will allay the corrosion concern. the WOULD IMPROVE ne att stat system mitoned tw seeeer valier 2. natch sees we heee ser dryers.

NUREC/CR 0660 study evaluated licensee event S AFF.TY

.til est prectees corresta sad toileep of ewreste preesets witnie the syste.

reporte issued from 1969 through 1977 when the.

ne preentw of correstee preemets is necesswy necesse teth esporteace sad industry was less experienced with the operation st ft steer susts/cs-osso sus identitles esitwo to air etwt systees as tne of diesel generators, This aspect of the report staete erwent cases of tes waretteettity, nos cavie e, rata ine ses is outdated and current industry data and prac-esetta, its safety fenettoa.

tices must now be considered.

A more recent study by the Institute for Nuclear Power Operations used 450 diesel-related LER's 1

issue / since Jannuary 1980 to analyse f ailure i

data.

Ihis study shows that only 5 perc ent of the more recent failures were due to seisture.

At BVPS-1, there have been no moisture-related 1

f ailures. resulting in LER's for the eight years since the implementation of revised operating and maintenance practices. Moisture in air start sys-tems is clearly not the single greatest cause of EDC unreliability at BVPS or in the. industry as a whole. The staff has f ailed to demonstrate that addition of air dryers will provide a substantial increase in overall plant safety.

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ATTACHMENT 4 PACE 2 0F 2 ISSUE: ~~ Air Dryers for Emergency Diesel Generator BACKFIT ISSUE NO.*

L-84-12 TO DLC RESPONSE

. TO NRC LETTER DATED 11/06/84 DLC BACKFIT NO.: 1 MRC POSITION Dif POSITION.

(DteENTS RELATION OF CDC 17 requires that onsite elect ric power. sup-NEW REQt!!RE*

pli*e have suf ficient Inde pendence, redundancy, MENT TO ne design of the tservacy onesel tastae starttas ystee (totsst is acceptatie and testability to perform their safety functions s

EXISTING if the tetepeted desty of the syste is to accordance ettn Gst 17. De Peer assuming a single failure. This is accomptished' RECULATORY systems treact reeten of the tatss includes these system features necessary to at BVPS-2 by providing independent and redundant POSITIONS assure retteste starttas of the emergency diesel eagine to confere with the ggegeg g,ngragot,. - BVPS-2 exceeds CDC 17 and the reentre==ts of Esc 17.

SRP acceptance criteria by providing two air starting systems for each diesel.

DLC has determined that at least two operating plants do not use air, dryers in the diesel air start systems. Since DLC is not aware that those plante have been required to obtain exemptions to Title 10, we must conclude that this is further evidence that no basis exists in regulation for requiring air dyers.

DLC is unable to establish a position since no SUCCESTED TIME FOR t ime has been proposed.

IMPLEMENTA-TION 3

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e ATTACHMENT 5 ISSUF.: ^ Noter Orerated Accumulator isolation Valve BACKFIT ISSUE NO.

L-84-14 To DLC RESPONSE TO NRC LETTER DATED 11/06/84 DLC BACKFIT NO.t 1 06/15/84 11/06/84 Backfit MRC Rqunts Appeal Pos it ion Meeting First Minutes &

Second Meeting Second Minutes &- ' Formal identified Letter Filed Statement Agenda Appeal Decision Appe al Agenda Appeal Decision Appeal l

Submitted Is eued Meeting iesued Requested issued Meeting

_1esued Request'to I

Dir, NRR NRC POSITION DLC POSITION CO M NTS PROPOSED No requirement is evident in the NRC letter dated REQUIREMENTS November 6, 1984. D14 is, consequently, unable to establish a position on the proposed require-ment.

HOW PROPOSED No improvement to safety is evident in the NRC

,, w

,,,, w,,,,,,,,, gw,w,,,,i,,,,w, position of November 6,1984, REQUIREMENT te meet the stagle failure CFttertoe of 10 CFs $0 Apesadts A and what

!MPROVE

,,,,,,,,,,,,,,,,,,,u,,,,%,

SAFY.TY RELATION OF DLC letters 2NRC-4-082, dated June 15,1984, and NEW REQUIRE-2NRC-4-076, dated June 8, 1984, describe BVPS-2 MENT TO design and administrative controls. These festures meet the requiremente of 10CFR50 and EXISTING

,,,,,,y,,,,,,,,,,,,,,,,,,,,3,,,,3,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,

through the guldance of NTP-18 meet those of RECULATORY

,,,,,,,,,,,,,,,,,,,,,,,,,,i,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,g, IEEE-279.

POSITIONS uttwatten end less of taete system fonetten.

SUCCESTED DLC is unable to establish a position since no TIME FOR t ime has been proposed.

IMPLEMENTA -

TION 6-

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ATTACHECT 6 ISSUE: Spent Fuel Fool Heat Load BACKFIT ISSUE NO.*

'L-84-11 TO DLC RESPONSE TO NRC 12TTER DATED 11/06/84 DLC BACKF1T NO.: 1 06/15/84 11/06/e4 Backfit NRC Rqmnts Appe al Position Ef tg First Minutes &

Second Meeting Second Miriutes &

Forma l Identified Letter Filed Statement Agenda Appeal Decision Appeal Agenda Appeal Decision Appeal Submitted Issued Meeting Issued Reques ted issued Neeting Is sued Req ue s t to Dir, NRR NRC POSITION DLd POSITION COMMENTS PROPOSED The BVPS-2 fuel pool cooling system satisfies the requiremente of CDC-44. This has been established REQUIREMENTS

,,,,,,,,,,,,,,g,,,,,,,,,,,,,,,,,yg,,,,

by Providing the evaluation which SRP 9.1.3 should prestee the results of en onlysts yhtch shows the cepenflity of the recomraends for demonstrating compliance with CDC-enitag systee for loss esseeltes usustag successive refueltas desenerves.

44, HOW PROPOSED DLC agrees that ove-heating of the fuel pool is unde s irable.

This statement, however, provides REQUIREMENT onennstas of sne peel could ruett la the release of redtesettetty from t#e WOULD stwed fuel asseneites and possitiy to the site eavtreas.

has not demonstrated that the acceptance criteria IMPROVE of SRP 9.1.3 does not reasonably preclude undue SAFETY risk to the health and safety of the public.

RELATION OF The new staf f request is a change of interprete-tion of the following:

NEW REQUIRE

• ENT To

.a. speat fuel peel cnita, systee avet settsfy the requirments of saaerst

1. 10CFR50. 34( g): The SRP was issued to establish EXISTING

,,,,,, g,,,,,,, 44,,,ct states in part 'The system ufety twet ten snell se criteria that the NRC statf intends to use in REGULATORY to treasfer the centud hnt 1.e4 et thne structern, systems. and casepets POSITIONS D.e.. these iseertet to safety) mader aernet operettag and accideat conditteas.*

evaluating whether an applicant / licensee meets the Cossaission's regulations.

2. lutroduction to NUREC 0800 (SRP): Each section is written to provide the complete procedure and all acceptance criteria for all of the areas of review pertinent to that section.

3. NRR Office Letter No. 2: The Standard Review See Attachment #10 (NRR Plan represents the most definitive basis Of fice Letter No. 2).

available for spec,ifying NRC's design criteria and design guidelines for an " acceptable level of safety" for light water reactor f acility reviews.

SUCGESTED DLC is unable to establish a position since no time has been proposed.

TIME FOR IMPLEMENTA-T10N

ATTACHMENT 7 Class 1E Power far Lighting End ISSUE: Communications Systems BACKFIT ISSUE NO.*

L-84-15 TO DLC RESP 08tSE TO NRC 1ETTER DATED 11/06/84 DLC BACKFIT No.-

15 06/25/84 11/06/84 Backfit MRC Rqmnts Appe al Position Meeting First Minutes &

Second Meeting Second

' Minutes &

Fo risal Identified Letter Filed Statement Agenda Appe al Decision Appeal Agenda Appeal Decision Appeal Submitted Issued Meeting issued Requested Issued Meeting Issued Request to Dir, NRR NRC POSITION DLC POSITION COMMENTS PROPOSED dequate" coussunications and lighting are not n

euf ficutly defined to support preparation of a REQUIREMENTS ne staff reatres that weer a destga bests sets =4 mat, the 16 eat's destga sneeld pentee adewate cesansatcettens between the centret rees ead DLC positlon.

ascessary plant safety reisted erees and edewate Itgnttas to enese areas to emette operater to perform the aecessary safety fvacties.

l Since the requirement is anbiguous, it cannot be HOW PROPOsw demonstrated how os rall plant safety would be REQUIREMENT g,,,

I* Proved.

carry at steer duties durtas emergeactes. These duties tmtw meay acttens M 0 The Standard Review Plan is not a requirement.

RELATION OF in addition, the StaMad Review Plan acceptance NEW REQUIRE-3,,,,,,,,,,,,,,,,gg,,,,,,,,,,,,,,,,,,,,,,3,,,,,,,,p,,,,,,,,,,,g,,

criterla seetion atstes,,There are no general f

MENT TO deeign criteria or regulatory guides that EXIST 1NG

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,i,,,,,,,,,,,,,,,,,,,,,,

directly apply to the eafety-related performance REGULATORY

,,,,,,,,,,y,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,i,,,,y,yy,,,,,,,,,,

requirementa for the lighting sy s ttem."

POSITIONS The sep fortner stetes 'the cementeette systes is acceptatie if the tate.reted l

destys of t7 system et11 provide effective commeateetten between plaat persennel to all vital erees ductag aerust plaat operettee and durtag the ' ell spectrus of ecctdeat er facteent cenetttees (lacludtag fire) under mash potetta17tse iml.*

$f* g.5.3 *}tghttag $ystems' remtres the Itghttag systems te meet the fellewtag!

'sil e capab'Itty of the aeraal Itghttag systeests) te preetde adewate Itchttag durtag all plaat operettag coasttleas. and (t) e apettlity of the suergsacy Itghttag system te provide see9pete Itghttag dUrtag oli plaat operettag condittens. tac 1.dtag fire. treastats sad accident conetttens.

ead the effect of less of-effstte power a the eergeacy itshtias system".

DLC is unable to estahlish a position since no SUGCESTED t ime has been proposed.

TIME FOR IMPLEMENTA-

, TION

n

-ATTAOIMENT 8 ISSUE: Alarm for Rocker Arm tube Oil reservoir BACKFIT 4SSUE NO.:

L-84-17 M DLC RESPONSE TO NRC LETTER D4TED 11/06/84

A DLC EACKFIT NO.: 1 06/25/P 11/06/s4 Backfit ~ NRC Aqants Appeal Position Meeting Pirst Minutes &

Second Meeting Second Minutes &

Firmal Identified Letter Filed Statement Agenda Appeal Decision

' Appeal Agenda Appeal Cecision f.ppeal Submitted issued Meeting issued Reque s ted Is sued Meeting issued Request to Dir, NSR MRC POSITION' DLC POSITION COPetENTS PROPOSED

1. Low pressure alarm warns aperator.

REQUIREMENTS

2. System desigi provides a reliable means of To uttsfy tats. tu steff reest**s==attet e of Ide ett imi a to.

automatic make-up to rocker are reservoir.

r,,,,ete tad er othe seems to esen the presence of a saffletent e63,1y ue 14 accept a stint glass Ie.e1 welcater fw this repose.

ef 5.n ett,

3. BV-2 des ign is similar to other plants where this c.anuf acturer's design has proven reli able.

HOW PROPOSED Ede ett imi to amatted tocan less of ide ett 1ew1 to tne emrwir Staff has not demonstrated that low pressure REQUIREMENT taan usu14 sdject see recew era esseely to smee new and/or to pesstele alarm in conjunction with auto make-up valve does WDULD eastae fetim dite operettag unsw teed er to e dry start when stwitag not provide sufIICient reIImbEIIty of that le*GI IMPROVE from e steaer sede, sad thus caserests the tes mitettitty to amet its switches or sight glasses increase safety.

SAFETY safety fonetten.

RELATION OF Proposed requirement exceeds the scope of SRP See Attachment #10 (NRR which:

Office letter #2).

steadyd me,te. Ptee (sitel 9.5.7 *tser,saer teset Eastae tubricettee System

• s regneres that the etent eattae te Preete d wits a dedicated Ide ett EilSTING

,y,,,,,,,,,, eg.n % i.ees aseses to yre,tde luneteettee to the diesel I. Is guidance not requirement

2. does not aussest a level switch R V. m TORY

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,f,,,,,,,i,,d_,,e,,acy POSITIONS At least eight other plants have the smee diesel.

A survey is still in progrees but it appears that the results will demonstrate that other plants, both operating and NTOL:

1. have the same diesel

2. do not have low level switches / alarms

3. did not require exemptions to Title 10 Therefore, DLC expects to conclude that there is no basis in regulation for this request.

SUCCESTEC DLC is unable to establish a position since no TIME FOR time has been proposed.

IMPLEMENTA-TION e

r I

l t

Not ATTACHMENT 9 ISSUE: Diesel L.O. Fill Procedure BACKFIT ISSUE NO.: Aw-itabla TO DLC RESPONSE TO IstC LETTER DATED !!/06/04 DLC BACKFIT No..

32 09/14/84 11/06/84 Bac k f it NRC Rqent s Appeal Position Meeting First Minutes &

Second Meeting Second.

Minutes &

Formal Identified Letter Filed Statement Agenda Appeal Decision Appeal Agenda Appeal Decision Appe al Submitted Issued Meeting Issued Requested Issued Meeting Issued Req ue s t to Dir, NRR -

l NRC POSITION DLC POSITION COMMENTS l

This requirement has no basis in regulation. This PROPOSED REQUIREMENTS requiremert is not consistent with the method of n steer re,tres enet werett.,,,wesere, w eittee twetes w ented ta the handting procedures for other safety related evolutions.

en ca.

This requirement would not be consistent with DLC attainistrative controls which ensure the use of controlled copies of approved procedures.

HOW PROPOSED The NRC staf f has neither demonstrated that REQUIREMENT locating procedures in the D/C toon improves WOULD I' **mt'a, precedures we aet iecoted er posted in ene sa ress. tertuttas plant safety nor that posting increases the prob-

+99 eigns w tacerrutty eeded to the 94 eitteet censutstag tne procesures and ability of using a current approved procedure.

IMPROVE

'***P'**'*"7"*"*****""*""F'd""*"'"*""*

SAFETY RELATION OF IE Circular 80-05 recommends that the procedure be available in the D/C room.

l NEW REQUIRE-l IENT TO l

EXISTING ste

,q pe.w rien tssel t.lJ 'teensacF 9**I E*9'"' '*""" I" The SRP recommends that diesel tube oil be kept

,,,e, one system to > eesigned to seu1*** *** 'F d'""

f ree of foreign material. Neither the SRP not l

REGULATORY POSITIONS set,qei t te the system due to e****** "'" " "*"'" ***""

IEC 80-05 require posting of procedures.

,,,,,,,,,.,,.e,.e i,,,e t w. (see eine It ctreetetw so-sll At least two operating plants do not keep thia procedure in the D/C room. Since no exemption to l

Title 10 requirements was required of these plants DLC must conclude that no basis exists in e

regulation for this requirement.

t i

1 l

SUCCESTED DLC is unable.to establish a position since no TIME FOR t ime has been proposed.

l IMPLEMENTA-(

TION t

.