ML19343B931
| ML19343B931 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/09/1981 |
| From: | Johnson W Maine Yankee |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| FMY-81-17, IMS.2.C.2.1, NUDOCS 8102180299 | |
| Download: ML19343B931 (2) | |
Text
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MAIRE HARHEE ~
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ENGINEERING OFFICE V.E STB CR O, '.t AE S A Cm s E T * ; : :
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Februa ry 9, 1981 i
IMS.2 4.2.1 FMY 81-17 r.
i United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter dated November 24, 1980,
Subject:
Revised Section 10CFR50.48 and New Appendix R to 10CFR50.
Subject:
Request for Exemption
Dear Sir:
Maine Yankee Atomic Power Company has reviewed the new Section 50.48 and Appendix R to 10CFR50, dealing with fire protection. During that review, it became apparent that there is one section that Maine Yankee is unable to meet.
It is, therefore, necessary to request an exemption.
The section for which we request an exemption is Section 50.48 (c)(5), the third sentence, which states " Licensees shall submit design descriptions of modifications needed to satisfy Section III.G.3 of Appendix R to this part within 30 days af ter the e ffective date of this section and Appendix R to this part".
Maine Yankee Atomic Power Company cannot meet that date for submittal of a design description suitable for NRC staff review; and we must ask for an exemption.
The basis for the exemption is:
l First, on September 20, 1979, Maine Yankee submitted a description of its safe l
shutdown capability, addressing the criteria expressed in a generic staff position similar to that expressed in Appendix R, Sections III.G. and III.L.
Five months later, in early March of 1980, Maine Yankee received a telephone call from the NRC staff indicating that they had some problems with the Maine Yankee method of cafe shutdown. At that time, Maine Yankee was asked to prepare for a meeting with the NRC to discuss the issue. That meeting was then cancelled by the NRC staf f, and Maine Yankee was told that a letter would S
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U. S. Nuclear Regulatory Commission February 9, 1981 Attention:
- 11. R. Denton, Director Page 2 l
be forthcoming delineating the NRC staff's conunents. An of ficial letter j
documenting accepted portions and open items has not been received to date.
I Until Maine Yankee receive = ? fnrmal letter, we can only speculate on what problems the NRC had with the original submittal and what changes would have l
to be made to it.
Therefore, we are unable at this time to submit the " design description" called for in 50.48(c)(5).
Second, if ar.d when the above letter is received describing the NRC staff's concerns, Maine Yankee is presented with a further complication. As you are j
aware, the question of the effect upon overall plant safety of every system change must be analyzed. One cannot simply decide to use a piece of equipment l
or a system in a manner for which it was not originally designed without a j
thorough, careful review of all the potential affects this use could have on j
the plant.
I Therefore, any concerns expressed by the NRC staff and required modifications will have to receive this careful review. For the NRC to require a rushed and perhaps incomplete analysis because of arbitrary schedule considerations and for Maine Yankee to agree to do such an analysis, would leave'both organizations open to just and severe criticism.
We, therefore, request an exemption from the submittal schedule for Maine Yankee's alternate shutdown capability design description to a date six months af ter receipt of NRC staff comments on our September 20, 1979 submittal.
We trust that this request will receive your swif t consideration and approval.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY leem W.
Johnson Vice President WPJ/cjp i