ML20207F996

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Discusses Requirements of Radiological Control Program,Per App I of 10CFR50.Relaxation from Requirement to Impose RM-50-2 Radiological Criteria Requested.Response Requested within 30 Days
ML20207F996
Person / Time
Site: Beaver Valley
Issue date: 12/31/1986
From: Carey J
DUQUESNE LIGHT CO.
To: Harold Denton, Tam P
Office of Nuclear Reactor Regulation
References
2NRC-6-132, TAC-63996, NUDOCS 8701060276
Download: ML20207F996 (2)


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2NRC-6-132 Beaver Valley No. L Unit Project Organization S.E.G. Building Te6ecopy 2)64 5 Ext.160 P.o. Box 328 Dec. 31, 1986 Shippingport, P A 15077 Mr. Harold R. Denton, Director Office Of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Peter Tam, Project Manager Division of PWR Licensing - A Office of Nuclear Reactor Regulation

Subject:

Beaver Valley Unit No. 2 Docket No. 50-412 Appendix I Operating Program

References:

A) 2NRC-4-144, dated September 14, 1984 B) NRC letter dated November 6, 1986 from Mr. L. Rubenstein C) 40 Federal Register 40816, published September 4, 1975 D) 2NRC-5-034, dated March 1, 1985 Gentlemen:

Duquesne Light Company (DLC) has committed to develop the Technical Specifications for Beaver Valley Power Station Unit No. 2 (BVPS-2) to be as much like the RVPS-1 Technical Specifications as possible (per Reference A) and agreed to by the Nuclear Regulatory Commission in Reference B. In addition, DLC has developed plant procedures and structured numerous programs for both plants to be executed as similarly as possible to promote effective human factors considerations for maximum safe operation for both plants.

Since the Technical Specifications for BVPS-2 were modeled to be as much like the BVPS-1 Technical Specifications as possible, the BVPS-2 offsite dose calculation manual (00CM) was written to comply with the BVPS-2 Technical Specifications and to be similar to the BVPS-1 ODCM. DLC also believes that the BVPS-2 ODCM meets Appendix I because the plant was designed to meet the more restrictive criteria of RM-50-2. This criteria was imposed for construc-tion permit holders which filed after January 2, 1971 as per Section V of 10CFR50, Appendix I. BVPS-2 construction perinit application was docketed in October, 1972. Also per Reference C, cost-benefit analyses were not required of applicants in accordance with II.D of Appendix I, if the radioactive waste systems and equipment described in the Final Safety Analysis Report satisfied the Guides on Design Objectives proposed in RM-50-2. DLC believes that the design for BVPS-2 is acceptable per Appendix I requirements because it was shown in the Final Safety Analysis Report and Environmental Report that BVPS-2 was designed to be able to meet the more restrictive pre-Appendix I criteria of RM-50-2.

BO Y 8701060276 861231 (' s PDR A

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  • United States Nuclear Regulatory Canmission Mr. Harold R. Denton Appendix I Operating Program Page 2 l

Plant design evaluation findings in the SER and FES written by the NRC reference the pre-Appendix I criteria of RM-50-2. However, DLC is in the pro-cess of conpleting the full implementation of an Appendix I-designed radiolog-ical controls progran for BVPS-2. DLC had notified the NRC of its intentions to operate in accordance with Appendix I through conments on the BVPS-2 Draft Environnental Statenent (Reference D) and through its Technical Specifications and ODCM submittals provided over a year ago without any NRC notification of non acceptance. At DLC's request, a conference call was conducted on October 28, 1986 during which DLC was notified that developing a radiological controls progran to meet the requirenents of 10CFR50 Appendix I at BVPS-2 was not accep-table to the NRC. In contrast to DLC's belief that 10CFR50 Appendix I itself shows that Appendix I criteria should be applied to BVPS-2, Mr. Robert Fell of the Nuclear Regulatory Conmission stated that his interpretation of Appendix I requires him to apply RM-50-2 criteria for BVPS-2.

DLC hereby requests relaxation fran Mr. Fell's perceived requirenent to impose RM-50-2 radiological criteria on BVPS-2. DLC will conmit to operate BVPS-2 in accordance with Appendix I radiological criteria which has been the design for the BVPS-1 radiological progran and is also the sane standard that other recently licensed nuclear power plants are using at multi-unit sites, such as Millstone Unit No. 3 and the River Bend Units.

Because fuel loading for BVPS-2 is scheduled in less than six months, DLC requests notification of acceptance of this proposed use of Appendix I for BVPS-2 within 30 days of this transnittal.

If you have any questions regarding this subject, please contact Mr. K.

D. Grada at (412) 393-5211 as soon as possible.

DUQUESNE LIGHT COMPANY l

By J.J.Wa(eJ (/ '

Sr. Vice President RWF/ijr NR/0PER/PROGRM AR/NAR cc: Mr. Peter Tam, Project Manager Mr. W. Troskoski, Sr. Resident Inspector Mr. J. Beall, Sr. Resident Inspector

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