ML20107M403
| ML20107M403 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/08/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-4-187, GL-84-08, GL-84-8, NUDOCS 8411140141 | |
| Download: ML20107M403 (2) | |
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'Af Ducluestie Udit s t4-iy 412)923 6 0 Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plaza. Building 2. Suite 210 Pittsburgh, PA 15205 November 8, 1984 Unite'd States Nuclear Regulatory Connission Washington, DC 20555 ATTENTION:
Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Ur it No. 2 Docke t No. 50-412 Identification of Backfit Requirement Number 23 Gentlemen:
In a letter to Duquesne Light Company (DLC) dated September 19, 1983, the NRC transmitted the Power Systems Branch, Pechanical Section ques-tions resulting from review of the Beaver Valley Power Station Unit 2 (BVPS-
- 2) FSAR. Question 430.57 requested a discussion of how communication systems are protected against failures resulting from accidents or fires.
The DLC response was rejected.
On September 13 and 14, 19 84, a meeting was held in which the following outstanding issue which has not been formally provided to DLC was discussed:
"The information submitted by the applicant is insufficient to evaluate the capabilities of the onsite communication systems.
In addition to the above, the applicant was requested to evaluate his system and discuss the protective measures taken to assure a func-tionally operable onsite and offsite communicat ion system.
The discussion was to include the cons ide rat ions given to component failures, loss of power, the severing of communication lines or trunks as a result of an accident or fire, and any sharing with the Unit I communication systems and their power sources. His response was inadequate in that the staff cannot determine that the system /
compo nent failures will not result in a total loss of communica-t ions at BVPS-2.
Frora information submitted on the intraplant communication system, the staf f concludes that under seismic condit ion with a loss of offsite powe r all communic at ions within the plant will be lost.
This is not acceptable."
Standard Review Plan (SRP) 9.5.2 states: "There are not general design criteria or regulatory guides that directly apply to the safety-related performance requirements for the design and use of the communication system during normal plant operations and transient conditions." Since Power Systems Branch requires that commun icat ions systems be designed to meet cond it ions such as identified in General Design Criterion 2 and General 8411140141 841108 PDR ADOCK 05000412 F
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l United States NuElear*Ragulatory Commission Mr. Darrell G. Eisenhut, Director Page 2 Design Criterion 4, in contrad ict ion to the SRP and in excess of 10CFR50 Appendix A, this is a new interpretation of the SRP, and the controls of 10CFR50.109, GNLR 84-08, and NRC Manual Chapter 0514 identify the requirement as a backfit.
DLC requests that the proposed requirrment be submitted to NRC management for ap proval, in accordance with the Of fice of Nuclear Reactor Regulation (NRR) procedure fo r management of plant specific backfitting, licensing requirement.
It also appears that this prior to transmittal as a requirement is being imposed on a generic basis and should be brought to the attention of CRGR.
DUQUESNE LIGHT COMPANY By.,[f /A -
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E. J GWoolgye/
Vic# President GLB/nml cc:
Mr. H. R. Denton, Director (NRR)
- Mr. G. W. Knighton, Chief Mr. B. K. Singh, Project Manager Mr. V. Stello, Jr., DEDROGR
.Mr. G. Walton, NRC Resident Inspector
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