ML20137C558

Requests Postponement of Generic Requirement for Extensive Pressure Isolation Valve Leak Testing Until Net Safety Benefit Determined by Crgr.Ser Open Item Should Be Closed Until CRGR Analyses Complete

ML20137C558
Person / Time
Site:	Beaver Valley
Issue date:	01/09/1986
From:	Carey J DUQUESNE LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
2NRC-6-005, 2NRC-6-5, TAC-62871, NUDOCS 8601160348
Download: ML20137C558 (2)

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'Af Duquesne Lisfit Jagtsos Nuclear Construction DMeeon y ,i. copy $hf $

Na u* g"[P $525 January 9, 1986 United States Nuclear Regulatory Conunission Washington, DC 20555 ATTENTION: Mr. Harold R. Denton Office of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Pressure Isolation Valve Leak Testing

REFERENCES:

(1) Letter fran Mr. V. Stello, Chainnan CRGR, to Mr. E. F.

Kurtz, Duquesne Light Conpany, dated Novunber 15, 1985 (2) Letter fron Mr. E. F. Kurtz, Duquesne Light Conpany, to Mr.

V. Stello, Chainnan CRGR, dated October 31, 1985 (3) Minutes of CRGR Meeting No. 79 held July 24, 1985 (4) Letter fron Mr. H. Denton, Director, Office of Nuclear Reac-tor Regulation, to Mr. V. Stello, Chainnan CRGR, dated June 20, 1985 (5) Memorandun fron Mr. V. Stello, Chainnan CRGR, to Mr. H.

Denton, Director, Office of Nuclear Reactor Regulation, dateo March 1,1985 (6) Menorandun fron Mr. V. Stello, Chainnan CRGR, to Mr. H.

Denton, Director, Office of Nuclear Reactor Regulation, dated February 25, 1985 Gentionen:

The purpose of this letter is to bring the subject of pressure isola-tien valve (P!V) !cak testing for Scaver V:lley Pc,4cr Station Unit Mc. 2 (BVPS-2) to your attention. Duquesne Light Canpany (DLC) has been infonned on several occasions that additional Plv leak testing requirenents must be applied to BVPS-2 based upon a newly approved generic requironent.

Although DLC understands and agrees with the basic safety rationale for requiring testing of certain P!Vs, the basis for the staff position which requires an extensive nunber of P!Vs to be periodically tested is not evident. The Canmittee to Review Generic Requirunents (CRGR) menbers have stated that they have similar concerns and they have expressed the need for NRR to conduct analyses to better establish the overall safety rationale (References 1, 3, 5, and 6),

in the attachnent to your June 20, 1985 letter to Mr. V. Stello (Reference 4), the NRR staf f acknowledges that there is a need to perfonn these analyses. However, it proposes to continue the practice of imposing the staf f position untti the analyses are conpleted. To the contrary, DLC '

believes that detailed net safety benefit analyses should be conpleted before linploaentation of this position on an applicant. We are concerned that the i

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United States Nuclear Regulatory Conunission Mr. Harold R. Denton Pressure Isolation Valve Leak Testing Page 2 staff may be requiring more PlV testing than is justifiable. Consideration -

of the negative safety aspects, such as occupational radiation exposure, might show that the staff position would result in decreased safety.

DLC believes this is a generic issue because the sa1e staff position is being applied to other plants, in addition, we do not knod of any feature unique to BVPS-2 that woul d warrait a plant specific analysis on this subject. Whether this issue is treated as a generic issue or a plant specific issue, 10CFR50.109(d) indicates that no licensing action will be withheld until the issue is resolved. Accordingly, it is requested that you close the BVPS-2 Safety Evaluation Report open iton until the analyses hwe been completed and CRGR approval has been obtained.

As sudV<!sted by Mr. V. Stello's response to our letter (References 1 and 2), we are bringing this matter to your attention to ensure pronpt reso-lution. Please infona us of the schedule you will be following for submittal to CRGR and the actions you will be taking to assure no isnpact on the BVPS-2 licensing schedule.

DUQUESNE LIGHT COMPANY By _ _

ent GLB/wjs cc: Mr. L. Rubenstein iir. V. Stellu ,

i Mr. P. Tan

{ Mr. G. Walton i e

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