ML20107M543

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Requests That Proposed Requirement Re Communication Sys Be Submitted to NRC Mgt & CRGR for Approval,In Accordance W/Nrr Procedure for Mgt of plant-specific Backfitting Prior to Transmittal as Licensing Requirement
ML20107M543
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-4-186, GL-84-08, GL-84-8, NUDOCS 8411140191
Download: ML20107M543 (2)


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'Af 4 ) 78 -5141 Nuclear Construction Division Telecon Robinson Plaza, Building 2. Suite 210 Pittsburgh, PA 15205 November 8, 1984 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation SUBJFCT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Identification of Backfit Requirement Number 24 Gentlemen:

On September 13 and 14, 1984, a neeting was held between Duquesne Light Company (DLC) and the Power Systems Branch, Mechenical Section.

This meeting was intended to resolve Duquesne Light Company responses to requests for information provided earlier in the review process. At that meeting, the following outstanding issue which has not been formally provided to DLC was discussed:

"...the information submitted by the applicant in Amendment 4 to the FSAR indicates that the communication systems, in parcicular the page party system, the radio system, the mircowave system, and telephone systems are shared, interconnected in some manner or can be connected to their counterpart systems in Beaver Valley Unit 1.

From the information submitted, the staff can not determine if the communication systems are designed to meet the requirements of General Design Criterion (GDC) 5."

Standard Review Plan (SRP) 9.5.2 states: "There are no 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 trans ient cond i t io ns. "

Since the Power Systems Branch requires that communications systems meet GDC 5, in contradiction 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 9514 identify the requirement as a backfit.

DLC requests that the proposed requirement be submitted to NRC management for approval, in accordance with the Office of Nuclear Reactor Regulation (NRR) procedure for management of plant specific backfitting, f

8411140191 841108 PDR ADOCK 05000412 A

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Unitsd States Nuclect RIgulatory Connaission

.Mr. Darrell G. Eisenhut, Director

'Page 2 prior to transmittal as a licensing requirement.

It also appears that this requirement is'being imposed on a generic basis and should be brought to the

- attention of CRGR.

DUQUPSNE LIGHT COMPANY Ey y.

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Vice President V

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 d