ML20093M813
| ML20093M813 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/19/1984 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| CON-#484-708 OL, NUDOCS 8410230306 | |
| Download: ML20093M813 (5) | |
Text
W PHILADELPHIA ELECTRIC COMPANY 5-2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215)841-4500 V. S. BO Y ER SR. VICE PRESIDENT NUOLE AR POWER Dockets:
50-352 50-353 October 19, 1984 Mr.. Harold Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Limerick Generating Station Units 1 & 2 Request for Exemption from 10 CFR 50 Appendix A, GDC 2 & 4
Dear Mr. Denton:
Pursuant to 10 CFR 50.12, Philadelphia Electric Company hereby requests an exemption from the requirement of 10 CFR
'50, Appendix A, General ~ Design Criteria (GDC) 2 and 4 as they relate to the protection of the ultimate heat sink (UHS) from the effects of tornado missiles.
This exemption is requested for power levels not exceeding 5 percent of full power.
Loss of the UHS (spray pond) due to to nado missiles for power levels not exceeding 5% power will not endanger life or property for the following reasons:
1.
Even if the heat removal capability of the cooling tow!rs and spray networks were compromised by tornado. missile effects, use of the cooling tower basins and/ or UHS in a " cooling pond type" mode
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would allow substantial time for spray network repair.
Under design meteorology, it would take apgroximately 5 days for the pond to reach its 95 F limit.
8410230306 841019 PDR ADOCK 05000352 A
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In the remote possibility that the heat removal capability of the spray pond networks-and the cooling towers is compromised, and that repairs cannot be completed before the design temperature of the spray pond is reached, a once-through mode of cooling can can be implemented.
In this mode of operation, cool water from the cooling tower basins is supplied to the spray pond pumphouse wet pits, ESWLand RHRSW will pump this water through the plant, the water is returned to the spray pond and is allowed to discharge over the blowdown weir and storm spillway.
Sufficient makeup water can be supplied to the cooling tower basins to sustain continuous operation in this mode from the Schuylkill River or a number of other sources.
3.
During the period of operation before exceeding 5%
90wer, it is extremely unlikely that tornado missile damage to the networks would occur.
But in the event that this should occur, there is sufficien~t time to effect the repairs on any one oof the four networks such that sufficient heat removal' capability can be restored without the existence of specific procedures.
Specific procedures for such repairs will be completed prior to exceeding 5% power.
4.
As indicated in the above discussions, substar.tial time is available for corrective operator actions.
If UHS capability should be lost for such a long period of time that conditions degraded cansiderably, the existing plant emergency procedures would direct the use of equipment which would achieve a safe stable state regardless of UHS capability.
The requested exemption does not impact the common defense and security.
Only.the potential impact on public health and safety is at issue.
The' requested exemption is in the public interest in that any delay in commencement of low power testingoand power ascension would cause a delay in the attainment of commercial operation (and subsequent increase in ratepayers' cost) and since', as shown above, the health and safety of the public will be adequately protected.
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' Based'upon the foregoing, we have concluded that granting
-the. requested exemption will not endanger-life-or property or the common defense and security and is otherwise in the puulic interest.
Therefore, Philadelphia Electric Company requests that the' Commission issue an exemption to GDC 2 and
-4:for power. levels not exceeding 5 percent of full power.
An affidavit in support of this request is attached hereto.
Sincerely, t
V. S.Boyer See attached Service List 6
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cc: Judge Helen F.-Hoyt Judge Jerry Harbour
-Judge Richard F. Cole Judge Christine N. Kohl
. Judge Gary J.'Edles Judge Reginald L. Gotchy Troy B. Comer, Jr., Eso Ann P. Hodgdon, Esq.
Mr. Frank'R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitzer Char %s W. Elliot, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence W. Perry,.Esq.
day M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board
. Atomic Safety & Licensing Board Panel Docket & Service Section Mr. James Wiggins Mr. Timothy R. S. Campbell
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l STATE OF. MARYLAND-;
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- MONTG0MERY COUNTY :
V. S. Boyer, being first duly sworn, deposes and says:
That he is Senior-Vice President of Philadelphia Electric Company, the applicant herein; that he.has reviewed the
' foregoing request pursuant to.10 CFR 50.12 for certain specific exemptions to^ the requirements of Appendix A and knows the contents thereof; and that the matters and
- statements, set forth therein are true and correct to the best of his knowledge, information and belief.
V Senior Vice President Subscribed and sworn to before me on the 19th day of October 1984.
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. Nctary PubMc
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1 D. LYNN NEAL -
NOTARY PUBUC STATE OF MARYLAND Hy Comndulon Espires July 1,1986
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