ML20213E067
| ML20213E067 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/28/1986 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | Tam P Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8611130003 | |
| Download: ML20213E067 (4) | |
Text
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Telephone (412) JS3-6000 Nuclear Group P.O. Box 4 Shippingport, PA 15077-0004 October 28, 1986 1
Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn:
Mr. Peter S. Tam, Project Manager Project Directorate No. 2 Division of PWR Licensing - A Washington, DC 20555
- Mail Stop 340 -
Reference:
(a) Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 (b) Appendix R - Additional Exemption Requests, Letter to NRC (Mr.
S. A. Varga), dated January 14, 1985 Gentlemen:
By letter dated January 14, 1985 [ Reference (b)], Duquesne Light Company requested five (5) exemptions from the provisions of 10CFR50, Appendix R,
Section III.G.2.
Per your request, we are providing l
additional information in support of these exemptions as a result of l
the newly revised 10CFR50.12 rule which clarified the standards to be l
applied for considering exemptions.
Specifically, information is being provided on the estimated costs associated with modifications which would be necessary to fully meet the technical requirements of Appendix R,Section III.G.2.
Section 50.12(a)(2)(iii) states " Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted or that are significantly in excess of those incurred by others similarly situated".
Implementing additional modifications would require the
(
expenditure of engineering and construction resources, capital costs associated with additional equipment and future maintenance and l
upkeep expenses associated with maintaining the equipment.
A summary and cost estimate savings for each exemption request identified in our previous January 14, 1985 submittal is provided in Table I.
The potential effects on plant operation are also factored into the estimated costs.
8611130003 861028 PDR ADOCK G5000334 F
PDR I
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n Benvar Valley Pownr Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Appendix R - Additional Exemption Requests Page 2 DLC has determined that special circumstances, as defined in 10CFR50.12, exist for the requested exemptions based on the supporting technical documentation provided in our January 14, 1985 submittal and the information provided in this letter which responds to the cost estimate savings.
Granting these exemptions would achieve the Commission's purpose in providing safety benefits with minimal cost impact for these situations by crediting alternative measurcs and equivalent capabilities.
If there are any questions or clarifications, please contact my staff.
Very truly yours, b, ' $1,
. D. Sieber Vice President Nuclear Operations cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261
Table I - Appendix R ExSmptions/ Cost Savings Cost Estimate i
Exemption Savings (Range)
Summary of Tasks Associated with Modifications
- 18. Fire Doors / Frames 757,000
- Engineering and Construction resources (Security modified doors,
- Material (6 new fire doors and frames) unlabeled frames, etc.)
- Security modifications (19 existing alarm doors) and rerouting of cables, and associated conduit and equipment supports
- Conduct fire tests to qualify 19 modified fire door / frame configurations
- Increased congestion complicating plant operations
- Establishing fire watches (during inoperable fire barrier situations)
- 19. Fire Dampers
$1,723,000
- Engineering and Construction resources (unlabeled 1 1/2 hour
- Material fire rated dampers)
. Replace 42 fire dampers with new 3-hour rated fire dampers
. Fire wrap material (where dampers could not be physically installed at barriers)
- Ventilation ductwork modifications and associated seismic supports
- Conduct fire tests to qualify modified fire damper configurations
- Establishing fire watches (during inoperable fire barrier situations)
- 20. PAB/ Charging Pump Cubicles
$7,707,000
- Engineering and Construction resources (redefined fire area
- Material boundary due to common vent 17 new 3-hour rated fire dampers shaft thru PAB with lack
. Fire wrap material of fire dampers separating 3 new fire doors / frames (to maintain vent each floor level.
- Also, shaft barrier) lack of full area coverage
. Automatic suppression system (4 floors) automatic suppression and Automatic detection system (4 floors) detection for all 4 floors
- Ventilation ductwork modifications and in the PAB and charging pump associated seismic supports cubicles)
- Significant additions and routing of power and control cables, associated conduit, piping and seismic supports.
- Increased congestion complicating plant operations.
- Establishing fire watches
Table I - Appendix R Ex?mptions/ Cost Savings (Cont.)
s Cost Estimate Exemption Savings (Range)
Summary of Tasks Associated with Modifications
- 21.
Control Room /HVAC 976,000
- Engineering and Construction resources Equipment Room
- Material (redefined fire area
. 7 new 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated dampers boundary due to common
. Fire wrap material (where dampers vent shaft traversing to could not physically be installed control room from HVAC at barrier) equipment room below with
. Automatic suppression system for control lack of fire dampers room.
separating floor levels.
- Ventilation ductwork mods and associated Also, lack of automatic seismic supports suppression in the fire
- Routing of power and control cable, area),
associated conduit, piping and seismic supports
- Increased congestion
- Establishing fire watches 422.
Main Steam Valve Room
$1,268,000
- Engineering and Construction resources (redefined fire area
- Material and installation of seismically boundary, and lack of supported barriers between main steam lines, separation between decay
- Suppression and detection for entire fire areac heat removal capability
- Relocating equipment, piping etc. to and main steam isolation accommodate barriers and reroute conduit.
valves)
- Rerouting ventilation ductwork Significant impact on plant operations.
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