ML20113F993
| ML20113F993 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/16/1985 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0800, RTR-NUREG-800, RTR-REGGD-01.070, RTR-REGGD-1.070 2NRC-5-008, 2NRC-5-8, NUDOCS 8501240201 | |
| Download: ML20113F993 (2) | |
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'Af Dugesre @t jEg8 Nuclear Construction Division Telecopy (412) 787 2629 Robinson Plaza. Building 2, Suite 210 Pittsburgh. PA 15205 January 16, 1985 United States Nuclear Regulatory Commission i
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 Docket No. 50-412 Identification of Backfit Requirement Number 33 Gentlemen:
The NRC provided the first section of the Beaver Valley Power Station Unit 2 (BVPS-2) Draft Safe ty Evaluttion Repo rt (DSER) to Duque sne Light Company (DLC) on March 1, 1984.
Open Item Number 115 of that partial DSER identified a staf f position that the Category I structures at BVPS-2 must be designed to accommodate sucwloads of 100 psf.
The 100 psf requirement of the DSER was based on a staf f estimate of a 100 year return snowpack weight of 30 psf added to a 48-hour probable maximum winter precipitation (PMWP) weight of 70 psf.
In a letter dated July 30, 1984, DLC explained that the design roof load was consistent with Regulatory Guide 1.70 (RG 1.70) Sect ion 2.3.1.2 and NUREG-0800 (SRP) Sect ion 2.3.1.
The methods endorsed by RG 1.70 and the SRP, including ANSI A58.1-1972, were used to determine the 100-ye ar return snow-load and the PMWP.
The res po ns e further detailed how the BVPS-2 design was in accord with the acceptance criteria of SRP Section 2.3.1.
The SRP accep-tance criteria are described as acceptable demonstrations of compliance with the Commission's relevant regulations including the General Design Criteria of Appendix A to 10CFR50.
In a meeting with the staff reviewer on December 6, 1984, DLC was informed that DLC's justification of the methodology used was not respons ive to the question in that it did not demonstrate the ability to withstand 100 psf loads.
The NRC reviewer is apparently establishing a 100 psf load design as a new requirement.
Neither the 100 psf design load nor the methods used to determine those loads have a basis either in existing regulation or in existing guidance documents (i.e. SRP, NUREG's, or Regulatory Guides):
1.
The 100 psf load was calculated using ANSI 58.1-1982 rather than ANSI A58.1-1972 which is endorsed by the SRP.
2.
The 100 psf load was de termined by adding the 100 year return snowload and the PMWP. The NRC ataf f internally promulgated this 8501240201 850116 DR ADOCK 05000 gl ll0
r Unitsd Sectcs Nuclear Raguictory Commission Mr. Darro11 G. Eiccnhut, Director Page 2 methodology as an " interim position" in an internal NRC memoran-dum, dated March 24, 1975.
This memo stated:
"This interim position ~ will be replaced by a Regulatory Guide on ex treme meteorological conditions." Although this memo was titled " SITE ANALYSIS BRANCH POSITION - WINTER PRECIPITATION LOADS," it would
'be inappropriate to classify it as a Branch Technical Position (BTP).
NUREG - 0800 states that BTP's are included in the SRP.
i This document was not incorporated into or referenced by the SRP, even in the total rewrite issued in 1981.
The March 24, 1975, memo has not been issued to the industry as guidance. DLC learned of this memo at a meeting with the NRC (December,1984) and first received a copy of the memo on December 19, 1984. During a tele-phone conference between the NRC and DLC on January 4,1985, the Division of Licensing Branch Chief indicated that there had been s imilar problems in the review of the snowloading for other licensees.
Apparently, the others had also been unaware of this unpublished guidance document.
In this sase phone cove rs at ion,
the NRC staff confirmed that the March 1, 1984, branch position is not. referenced by the SRP.
The BVPS-2 Final ~ Safety Analysis Report describes the basis for concluding that the BVPS-2 Category I Structures comply with the Commission's regulations - in a manner recommended by the SRP and those documents which it references.. The NRC staf f is reviewing the BVPS-2 FSAR to criteria which are not based in either the Commission's regulations or in approved guidance documents.
Since there appe ars to be no regulatory hasis for this new requirement, the controls of 10CFR50.59, GNLR 84-08, r...d NRC Manual Chapter 0514 identify the requirement as a backfit.
-DLC requests that the proposed requirement-be submi tted to NRC
-management for approval, in accordance with the Of fice of Nuclear Reactor Regulation (NRR) procedure for ' management of plant specific backfitting, 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 E
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By E.J.~
oletedf '
Vic resident
~RW/wjs cc:
Mr. H. R. Denton, Director'(NRR)
Mr. G. W. Knighton, Chief Mr.. B. K. Singh, Project Manager Mr. V. Stello, Jr., DEDROGR
!?
_ Mr. J. Tourte11otte, Chairman RRTF -
Mr. G. Walton, NRC Resident Inspector Mr..SP Chestnut, Techdical Assistant Mr.-W. Dircks, Executive Director for Operations "Mr. D. Eisenhut, Director
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