ML20076G575
| ML20076G575 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/09/1983 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20076G579 | List: |
| References | |
| 5211-83-151, NUDOCS 8306140732 | |
| Download: ML20076G575 (3) | |
Text
GPU Nuclear Corporation ENuclear
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Middletown. Pennsylvania 17057-0191 717 944-7621 TELEX 84 2386 Writer's Direct Dial Number:
June 9,1983 5211-83-151 Office of Nuclear Reactor Regulation Attn:
D. G. Eisenhut 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 Fire Protection Modification Schedule This document is being provided to keep the NRC informed of the status of our efforts to comply with Appendix R to 10CFR50.
The attached document " Fire Protection Modifications to Three Mile Island Nuclear Station Unit-1 Since the Browns Ferry Incident" serves three (3) major purposes:
(1)
It documents the extensive efforts completed to date to upgrade fire protection at 1MI-1; (2)
It lists the planned modifications and when they are scheduled for completion; and (3)
It reiterates the total fire protection capabilities which exist or will exist for each fire area / zone at TMI-1.
As part of the second purpose of the attached document, each of the specific modifications to comply with Appendix R have been categorized in accordance with the schedule of 10CFR50.48 as modified by NRC correspondence dated May 10, 1982 and March 9, 1983.
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As can be readily seen from a review of the attached, there is one oo modification and a portion of another which according to your March 9,1983
$8 letter should have been implemented by April 1, 1983 (Category 1 o
Modifications). As defined in the attached Category 1 is: Shutdown Not gnx Required /NRC Approval Not Required and Category 2 is:
Shutdown Required /NRC o[j Approval Not Required.
We had not been working to the April 1, 1983 schedule prior to your letter and thus, were not able to complete the modification by 4
April 1, 1983. We have however, accelerated our efforts to complete the Sma$
Category 1 modification (s) by September 30, 1983.
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GPU Nuclear Corporatron is a subsidiary of the General Public Utilities Corporation
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D. G. Eisenhut Based on the above, we hereby request a schedular exemption to permit the completion of the Category 1 modification (s) during plant operation, by September 30, 1983.
Schedular relief should be granted since:
(1)
We were not working to the April 1, 1983 schedule until your March 9, 1983 letter which resulted in inadequate time to complete the modification (s) in April 1983; and (2)
The modification (s) which currently are in this category will provide only a marginal increase in safety. Therefore, a minor delay in implementation during operation is reasonable.
It should be noted that when we filed our original schedular exemption requests (July 1, 1982 & December 2, 1982) the Category I modifications included fire barrier wraps for a large number of safe shutdown cable raceways. However, more detailed engineering has revealed that the current cable raceways could not be wrapped and still maintain their structural adequacy for all design basis accidents without extensive structural analysis and resultant support modifications. As a consequence, the safe shutdown circuits will De re-routed in new conduit to the maximum extent possible which will require plant shutdown for full implementation (terminations). This resulted in the current scope for Category I modifications.
The exemption request mentioned above is being requested pursuant to 10CFR50:12(a) and is considered to be a Class III exemption request. A check in the amount of $4,000.00 is enclosed.
As a matter of information, GPUN plans to complete the modifications remaining in Category 2 during the Cycle 6 Refueling Outage, in accordance with 10CFR50.48 c(3). During our current outage GPUN:
l.
Completed modifications implementing eight items from the TMI-l Fire Protection Safety Evaluation Report (FPSER).
This results in all TMI-l FPSER items being completed except those which were re-evaluated in light of the requirements of 10CFR50 Appendix R.
2.
Performed an updating of the TMI-l Fire Hazard Report and a detailed study to identify the scope of modifications required for compliance with 10CFR50 Appendix R.
Due to the vintage of the TMI-1 plant and the differences in the Appendix R criteria from the criteria of the original plant design, this evaluation required approximately five man-years (10,000 man-hours) of effort.
The magnitude of engineering and construction for the Category 2 modifications is estimated to be 61,100 man-hours or approximately 30 man-years of effort.
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j D. G. Eisenhut In view of the large effort needed to implement the remaining modifications in Category 2, GPUN initiated an accelerated engineering effort last year (which is continuing) to ensure that these modifications are completed on a schedule consistant with the requirements of 10CFR50.48 c(3).
Sincerely, f
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. D. Hukill HDH/klk Director, TMI-1 cc:
T. Wambach J. Van Vliet R. Conte J. Stoltz i
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