ML20195H208
| ML20195H208 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/06/1988 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801190105 | |
| Download: ML20195H208 (2) | |
Text
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Te.pnon. i412> 3916000 w.,
Sh ppogport PA 15077 4004 January 6, 1988 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 10CFR50.72(b)(2)(ii) and 50.73(a)(2)(iv)
Genticmen:
The referenced sections of Title 10 of the Code of Federal Regulations both contain requirements for telephone and written reporting of "any event or condition that results in manual or automatic actuation of any Engincerod Safety Feature (ESP), including the Reactor Protection System (RPS)".
Our historic interpretation, for reporting under those sub-sections, was to utilize the ESF Actuating Circuits listed in the Technical Specification Table 4.3-2.
We had taken this position because a
broader interpretation could virtually defino all components with dicscl-backed power supplies as an "ESF" and any change in the operational status of these components could similarly be construed as an "Actuation".
At Beaver Valley Unit 1, a number of radiation monitor circuits will cause a
diversion of ventilation flow through the filter banks installed in the Supplementary Leak Collection and Release System (SLCRS).
The setpoints for these monitors were deliberately set lower than required to minimize any potential releases through these flow paths.
Under LOCA conditions, the same diversion of ventilation flow is accomplished on a
Containment Isolation Phase "A"
(CIA) signal.
Based on our previous position for reporting, only the SLCRS actuations initiated by a CIA signal would be reported, provided that the initiating event would not otherwisc be reportable under the other 50.72 and SC 73 sub-sections.
We believe this position is in concert with the original intent of the rule, in capturing events which could lead to significant releases of radioactivity (FR 39045),
and further believe that this rationale was the bases for increasing the reporting criteria for releases from 25% MPC to the current 2X MPC values.
Since the reporting critoria for reporting releases was increased to climinate reporting of insignificant events, then it would seem to follow that automatic actuations taken to limit those k
releases should not be reportable either, p
8801190105 880106 PDR ASUCK 05000334 S
DCD L
~
E; Ecavar Valley-Powar Station, Unit No. 1
- Dock 0t No. 50-334, Licanse No. DPR-66 10CFR50.72(b)(2)(ii) and 50.73(a)(2)(iv)
-Page 2~
We believe, that ESF' actuations_ should only be reported if the actuating circuit was an ESF actuating circuit and the equipment affected was similarly an ESF component.
These components are described in the FSAR and the actuating circuits are identified in the Technical Specifications.
We understand that there is some on-going work in refining the reporting requirements generically but request that our use of the ESF Actuating
- Circuits, as defined in the Technical Specifications, be accepted for interim use for reporting pursuant to 50.72 and 50.73.
Please contact my office for any further information on this matter.
Very t uly yours,
$h Q
J J. D. Sieber Vice President, Nuclear cc:
Mr. J. Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr.
P. Tam, Project Manager Director, Safety Evaluation & Control (VEPCO)