ML20054C465
| ML20054C465 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/15/1982 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 5211-82-094, 5211-82-94, NUDOCS 8204210129 | |
| Download: ML20054C465 (3) | |
Text
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9 GPU Nuclear
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P.O. Box 480 Middletown, Pennsylvania 17057
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717-944-7621 Writer's Direct Dial Number:
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April 15, 1982 Y
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sQ5d K3 1p Office of Nuclear Reactor Regulation s\\
Attn:
D. G.
Eisenhut, Director G; / j Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 10 CFR 50 Appendix R Exemptions Based on a tele) hone discussion on April 12, 1982 betwecn R. Jacobs (NRC) and members of my staff, GPU Nuclear is clarifing some of the previously submitted exemptions to 10 CFR 50 Appendix R as outlined in the enclosure.
Sincerely, IK D. I' kill Director, TMI-l ifDil:LWH:vj f cc:
J. F. Stolz R. Jacobs R. C. Ilaynes cob 1
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i 8204210129 820415 DR ADOCK 05000209 PDR GPU Nuclear is a part of the General Pubhc Utibties System
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a-Exemption 1 Exempt from the III.G.3 requirement for additional fire suppression system protection where redundant safe shutdown equipment is located in the same fire area / zone.
Alternate Method Where redundant safe shutdown equipment is located in the same fire area or zone a one hour fire barrier is/will be required including cable trays, tray supports exposed structural steel and rerouting of any cables within the alternate shutdown facility.
3 Justification Our basis for exemption to having additional fixed fire suppression system for redundant safe shutdown equipment is outlined in our letter of December 15, 1981.
Specifically, the equipment and circuits required for safe shutdown identified in the safe shutdown Evaluation will not be subjected to a theoretical design basis fire in excess of one hour. This fire rating is based on the combustible loading in each fire arca/ zone of the unit.
For the proposed modifications listed above GPU Nuclear requests NRC approval 4
prior to proceeding with the' int.tallation.
Exemption 2 1
Extend from March 19, 1981 to October 1, 1982, the date for filing additional exemptions from III.G. pursuant to 50.12(a) and 50.48(c)(6).
4 Justification TMI Unit 1 has developed and implemented a significant number of fire pro-tection modifications based on the TMI-l Fire Hazards Analysis to resolved lessons learned from the fire at Browns Ferry Nuclear Plant. With the issuance of Appendix R to 10 CFR 50, an extensive reanalysis of the Fire Hazards Analysis for TMI-l was undertaken and is still in progress. GPU j
l Nuclear with contractor support is applying a significant effort to complete the reassessment of remaining modifications which may be necessary for
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i conformance with Section III.G.
The additional time requested will allow time co quantify in detail the differences between what has been approved and the specific requirements of III.G.
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j Since TMI-l is presently in a shutdown condition and will remain as such until at least October 1,1982, and because of the existing fire protection installed; there is no undue risk to the health and safety of the public involved in activities at TMI-1 until completion of this reassessment.
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Exemption 3 Extend from February 17, 1981 to October 1, 1982, the date from which the installation schedules established in 50.48(c)(2) and (3) are calculated.
Justification When the Fire Protection Rule was approved by the Commission, it was understood that the time required for us to re-examine previously approved configurations at TMI-l to determine whether we met the requirements of Section III.G of Appendix R to 10 CFR 50 was not well known. A revised fire hazards analysis for TMI-l which is in progress needs to be developed to provide in detail the basis of compliance and the need for exemption as necessary.
By necessity " time clocks" of Appendix R must be reset in order to allow IMI-l to come into compliance pending the outcome of this reassess-ment.
Since TMI-l is currently in a shutdown condition and will remain shutdown until at least October 1,1982, and because of the existing fire protection installed, there is no undue risk to the health and safety of the public involved in activities at TMI-l until completion of this reassess-ment.
l l