ML20215H482

Forwards Comments Re Preliminary Draft of Proposed Low Power License Transmitted by NRC .Util Will Work W/Nrc Project Manager to Resolve Comments

ML20215H482
Person / Time
Site:	Beaver Valley
Issue date:	04/13/1987
From:	Carey J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
2NRC-7-074, 2NRC-7-74, TAC-62942, NUDOCS 8704200341
Download: ML20215H482 (3)

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2NRC-7-074 Beaver Valley No. 2 Unit Project Organization Telecopy 1 )

88 sgaB[2Y" April 13, 1987 eo Shippingport. PA 15077 United States Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, DC 20555

SUBJECT:

Beaver Valley Power Station Unit No. 2 Docket No. 50-412 DLC Comments on the Preliminary Draft of tne Proposed Low Power License for BVPS-2

REFERENCE:

NRC letter dated March 12, 1987, Mr. Lester S. Rubenstein to Mr.

J. J. Carey Gentlemen:

Attached are Duquesne Light Company's (DLC) comments on the preliminary draft of the proposed low power license for Beaver Valley Power Station Unit No. 2 (BVPS-2) which was transmitted to DLC in the above-noted reference. DLC will work with the NRC Project Manager for BVPS-2 to appropriately resolve these coments.

DUQUESNE LIGHT COMPANY By L/ Q/ J. Care"y Senior Vice President JDU/ijr NR/JUO/LP/LICN Attachment AR/NAR cc:

Mr. P. Tam, Project Manager

- w/ attachment Dr. T. E. Murley, NRC Region 1 Administrator

- w/ attachment Mr. J. Beall, NRC Sr. Resident Inspector

- w/ attachment INP0 Records Center

- w/ attachment i

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DLC Comments on Preliminary Draft of Proposed Low Power License for BVPS-2 1.

Paragraphs 1.H, 2.C.(2), and 2.G refer to the " Environmental Protec-tion Plan." At BVPS-1, Radiological Effluent Technical Specifications and Environmental Technical Specifications have been adequately incor-parated into Appendix A of the license or have been eliminated based upon justification provided in support of license Amendments 66 and 93.

DLC has not been informed of the need to implement an " Environ-mental Protection Plan" for BVPS-2 beyond that currently in place at BVPS-1. These references should be deleted.

2.

The 5 percent core power level in Paragraph 2.C.(1) (Maximum Power Level) should be more properly shown as 132.6 megawatts thermal.

DLC understands this condition to permit 5 percent. operation at an NSSS power level of 140.6 megawatts thermal (includes 8 megawatts for RCP heat).

Likewise, the 100 percent core power level (2652) is under-stood to be equivalent to an NSSS power level of 2660 megawatts ther-mal.

3.

The license condition specified in Paragraph 2.C.(4) (Stean Generator Tube Rupture) should be eliminated since generic resolution has not yet been completed.

DLC is currently participating in Westinghouse Owners Group activities aimed at resolving the issue, but the NRC has not yet completed its review of the group's proposals.

Since the probability of a tube rupture event at BVPS-2 should be lower than plants which are already operating and which have no license condi-tion, DLC believes that an acceptable level of safety will be main-tained without this condition.

Generic requirements which result from resolution of this issue should be applied to BVPS-2 on an equal basis with the remainder of the industry.

4.

License condition 2.C.(5) (Accumulator Tank Level or Pressure Instru-mentation ) should be renoved.

To date, the NRC has not responded to a DLC letter dated March 3,1986, which laid the groundwork for show-ing that 10CFR50.109 is applicable to this issue.

Fur thermore, the NRC has not communicated knowledge of any technical basis for needing this equipment.

The NRC staff has relied upon the Regulatory Guide 1.97 recommendation for this equipment as sufficient basis for imposi-tion of this change.

Imposition of this change through a license-condition pr ior to completion of an appropriate analysis is not consistent with the commission's philosophy regarding implementation of 10CFR50.109.

5.

License Condition 2.C.(8) (Detailed Control Room Design Review) uses the anbiguous term " proposed".

This term should be replaced with the phrase " mutually agreed upon" to avoid confusion.

6.

License condition 2.C.(9) (Safety Parameter Display System) uses the ambiguous term " proposed".

This term should be replaced with the phrase " mutually agreed upon" to avoid confusion.

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l 7.

Paragraph 2. C. (10) (Natur al Circulation Test) imposes a condition which requires DLC to demonstrate that the Diablo Canyon (4-loop) test is applicable to BVPS-2 (3-loop).

This license condition should be modi fied to be directed toward a more flexible resolution of the issue.

Although DLC -is currentIy pursuing use of DiabIo Canyon data in a BVPS-2 evaluation, the evaluation is not complete and applicabi-lity to BVPS-2 is uncertain.

DLC continues to believe that the North Anna (sister 3-loop plant) test which was accepted in a staff safety evaluation report for that plant is more consistent with the purpose of an actual demonstration of specific plant design.

While the alternative of perfonning a test at BVPS-2 is a viable one, it should not be_ specified as the only alternative to a Diablo Canyon comparison.

Any alternative method which satisfies the requirement underlying BTP RSS 5-1 should be acceptable to the NRC staff.

8.

Paragraph 2.D.(4) indicates that an exemption regarding use of RM 50-2 is being developed.

Although DLC requested this exemption at the NRC staff's direction, it seems unusual that it should be necessary to obtain an exemption to 10CFR50, Appendix 1, in order to be permitted to follow Appendix 1.

The need for this exemption should be scruti-nized by NRC management.

9.

Section 2.D (Exemptions) should include the exemption from criticality alarm r equirements that is currently par t of the Special Nuc lear Material License No. Sftl-1954 (Condition 18) since this license wili expire when the Operating License becomes effective.

10.

In License Condition 2.F (Fire Protection Progran), DLC understands the phrase " implement and maintain in effect all provisions of the approved fire protection program" to mean that all provisions of the approved fire protection program which (1) pertain to NRC require-1 ments, or (2) affect plant safety or the ability to achieve and main-tain safe shutdown in the event of a fire, are required to be imple-mented and maintained.

Based on the wording of applicable NRC docu-ments (10CFR, SRP, SER) with respect to fire protection, it is clear which provisions of the BVPS-2 Fire Protection Program are included in these two categories.

The reasons for which DLC has established a fire protection program for BVPS-2 are as follows:

NRC regulations l

DLC standard practices Insurance company guidelines l

Industry codes and standards Drotection of DLC's capital investment I

Many of the provisions of the fire protection progran resulting from these reasons may go beyond areas which include the NRC's require-ments.

However, DLC believes that it is beneficial from the stand-i points of efficiency and effectiveness to include al l provisions related to fire protection in one integrated progran rather than hav-i ing several separate prograns.

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