ML20107M765

Requests That Proposed Backfit Requirement 25 Re Operable Lighting Sys Be Submitted to NRC Mgt for Approval Prior to Transmittal as Licensing Requirement,Per Procedure for Mgt of plant-specific Backfitting

ML20107M765
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-4-188, NUDOCS 8411140256
Download: ML20107M765 (2)

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412 787 si i Nuclear Construction Division Telecopy 4 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

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Do cke t No. 50-412 Identification of Backfit Requirement Number 25 Gentlemen:

In a letter to Duquesne Light Company (DLC) dated September 19, 1983, the NRC transmitted the Power Systems Branch, Mechanical Section ques-tions resulting from review of the Beaver Valley Power Station Unit 2 (BVPS-

2) FSAR. Question 430.64 requested a discussion of protective measures which assure a functionally operable lighting system under conditions such as acci-dents and fires.

The response provided by DLC was rejected.

During a meeting with Power Systems Branch on September 13 and 14,1984, the following outstanding is' sue which has not been formally provided to DLC was discussed at that meeting:

"The applicant was requested to provide a discussion on the protec-t ion measures taken to assure a functionally operable lighting system, including considerations given to component failures, loss of ac power, and the severing of li hting cables 2

as a result of an accident or fire.

He has not adequately responded to this request."

Standard Review Plan (SRP)

9.5.3 states

"There are no general design criteria or regulatory guides that directly apply to the safety-related performance requirements for the lighting system."

Since the Power System Branch requires that lighting systems be designed to withstand conditions such as those spe cified in General Design Criterion 4, which is contrary to the SRP and in excess of 10CFR50 Appendix A, this is a new interpretatior. of the SRP, and the controls of 10CFR50.109, GNLR 84-08, ar.d NRC Manual Chapter 0514 identify the requirement as a backfit.

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

8411140256 841108 PDR ADOCK 05000412 A

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s' United States Nuciscr Ragulatory Commission 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.

DUQUESNE LIGHT COMPANY rQf By e,

a E. Jj/ ool0MMf y

W Vice President GLB/nul 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 u_t