ML20032B835
| ML20032B835 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/02/1981 |
| From: | J. J. Barton METROPOLITAN EDISON CO. |
| To: | Barrett L Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20032B836 | List: |
| References | |
| LL2-81-0245, LL2-81-245, NUDOCS 8111060427 | |
| Download: ML20032B835 (4) | |
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Metropolitan Edison Company
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Middletown, Pennsyhania 17057
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Novenber 2, 1981
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Attn:
Mr. L. H. Barrett, Deputy Program Director g
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Ern c/o Three Mile Island Nuclear Station NE Middletown, Pennsylvania 17057 S
Dcar Sir:
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sn Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Design Criteria for Recovery Facilities Enclosed is our response to your comments on the General Project Design Criteria and the Containment Recovery Service Building (CRSB) Design Criteria provided in your letter of August 24, 1981 (NRC/TMI-81-047).
Also attached is a copy of Revision 2 of the CRSB Design Criteria. As stated in our response to your comment on the CRSB Design Criteria further justification of our response will be provided in the CRSB Technical Evaluation Report (TER) which will be submitted in the near future. Therefore, an early review and approval of any remaining areas of concern with the CRSB Design Criteria after we submit the CRSB TER is requested.
If you have any further questions, please contact Mr.
J. J. Byrne at (717) 948-8461.
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Rincerely,_
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J' darton A
g Director, TMI-2 JJB:JJB:djb Enclosure s
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Dr. B. J. Snyder, Program Director, TMI Program Office
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Metropostan Ecson Company is a Member of the Genera! Pubbc Utd t:es System
a RESPONSE TO COMbENTS
- 1. COMLENT Reactor Building Integrity:
The recovery technical specifications specify that " Primary containmen,t integrity shall be maintained...". Without analyzirg each proposed evolution inside the reactor building (RB), it should not be assumed that a temporary equipment hatch cover designed to withstand a 1 psi differential pressure (item 5.4.6.2 of your submittal) will provide adequate primary containment integrity for the full spectrum of recovery operations inside the RB.
Each proposed evolution inside the RB should be reviewed on a case by case basis to evaluate the potential for causing an inadvertant RB pressurization and an appropriate level of containment integrity will be assigned to each operation. We do not concur with the statement that "the CRSB serves no nuclear safety func-tions" (item 5.1 of your submittal).
After removal of the equipment hatch the containment recovery service building (CRSB) will serve as a RB contamination barrier.
Prior to removing the equipment hatch, Section 3.6.1 of the Technical Specifications requires modification to permit operations without an operable containment airlock.
RESPONSE
The of fsite radiological consequences will be determined for each proposed evolution inside the containment and an appropriate level of containment integrity will be provided.
Additionally an evaluation of various postu-lated accidents will also be performed. The Containment Recovery Service Building (CRSB) will provide for contamination control when the equipment hatch is removed. Evaluations indicate that, while provisions must be made to prevent uncontrolled releases, it is not necessary to define the structure as safety related.
These evaluations will be addressed in the Technical Evaluation Report (TER) for Containment Recovery Service Building and. other TER's as required.
Safety related features are those plant features necessary to assure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in offsite expasure comparable to the guideline exposures of 10 CFR Part 100.
The only area where the CRSB would be considered to l
serve as a safety related feature would be in the prevention of offsite exposure comparable to the guideline exposures of 10 CFR Part 100.
Considering the present snutdown status of TMI-2, it is extremely unlikely that any event will occur which would result in the release of radio-activity in quantities that would approach the guideline exposures of 10 CFR Part 100.
l It is correct that the containment air control envelope (CACE), an integral part of the CRSB, will serve as an extension of the containment boundary when the equipment hatch is removed. However, with the present l
4 shutdown status of the reactor, the containment boundary is needed to I
serve only as a contamination control boundaiy to satisfy the requirements of 10 CFR Part 50, Appendix A, Criterion 16 (GDC-16). Specifically, the lP containment boundary serves to prevent"...the uncontrolled release of radioactivity to the environment..." as Iequired by GDC-16.
l-t Based on the discussion above, it is concluded that the WSB does not serve a nuclear safety related function.
Prior to removal of the equipment hatch, changes to the Recovery Techinical Specifications will be requested.
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- 2. CDMhENT Water used for flushing the reactor coolant system (RCS) should be of equal (or better) quality as that used for RCS makeup water (table 4.3 of your submittal).
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RESPONSE
The water quality for flushing the RCS was established based on recom-mendations from Babcock & Wilcox, our vendor, and are consistant with their Grade 1 water quality specification.
Specifics concerning flushing of the RCS will be discussed in future submittals detu.l'ng our plans for
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i clean-up of the Reactor Coolant System.
- 3. CDMbENT The upper limit on baron concentration for primary water and standby pressure control tank water may be increased to the technical speci-fication limit of 4500 ppm (table 4.3 of ~your subnittal).
RESPONSE
i The upper limit on the boron concentration will be revised in the next f
revision of tne General Project Design Criteria to the technical syi-fication limit.
- 4. WMhENT Specifications for water used in the mini decay heat removal system should be supplied and the criteria for this water should be the same as for RCS water (table 4.3 of your submittal):
RESPONSE
The specification for water used during operation of the mJni decay heat removal system are as specified for RCS water and are specified in the Mini Decay. Heat Removal Doerating Procedure (OP 2104-1.15) which has been approved by the NRC. This information is not within the scope of the General Project Design Criteria, however, and thus will not be included.
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- 5. C0f4ENT The dissolved gas concentration for water in the SPC surge tanks should be limited to less than 15 scc /kg (table 4.3 of your submittal).
RESPONSE
l The dissolved gas concentration for water in the SPC surge tanks are controlled to less than 15 scc /kg as specified in the Recovery Operations Plan (Section 4.1.1.1). This information is not within the scope of the General Project Design Criteria, however, and thus will not be included.
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