ML20106D632
| ML20106D632 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/21/1984 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Harold Denton, Schwencer A NRC, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20106D597 | List: |
| References | |
| NUDOCS 8410260083 | |
| Download: ML20106D632 (2) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101
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'2'5884' 45
50-352 Office of Nuclear Reactor Regulation 50-353 U. S. Nuclear Regulatory Ca mission Washington, D.C. 20555 a
Subject:
Limerick Generating Station, Units 1 and 2 -
Request for Exenption frun 10CFR50, Appendix A, GDC-61
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References:
(1) Ietter, J. S. Kenper to A. Schwencer, dated 7/26/84.
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(2) Ietter, J. S. Kenper to A. Schwencer, dated 8/13/84.
File:
GOVT l-1 (NBC)
Dear Mr. Schwencer:
Pursuant to 10CFR50.12, Philadelphia Electric Ccrnpany hereby requests an exenption frca the requirement of 10CFR50, Appendix A,
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General' Design' Criterion (GDC) ' 61 as' it 'relhtes 'to 'the filtering of
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radioactive gases in the refueling area under postulated accident 7
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The standby gas treatment system (SGTS) reduces halogen and particulate concentrations in gases potentially present in the refueling p,*p area following a postulated fuel handling accident before the gases are 'j
", r discharged to the environment. The SGrs will not be connected to the refueling area prior to fuel load.
FSAR Section 6.5.1(a) notes our hj [}
ccrmitment to connect the refueling area to the SGTS prior to the first ',)g o,
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refueling outage.
, ' id Wp In accordance with our reference (1) letter, the following ocamitments are made until such time as the SGTS is connected to the
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refueling area:
Operations involving removal of the primary contaiment and a.
RPV bands after initial criticality are prohibited without specific, prior,NRC approval.
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'Ihc handling of any loads (other than the RPV head, dryer or separator) over irradiated fuel will be carried out in j
accordance with the single failure criteria of NUREG-0612.
As stated in the Limerick heavy loads report, transnitted by Reference (2), a drt:p of the RPV head, dryer, or separator will not cause any fuel damage, Operations involving handling and storage of irradiated fuel c.
will not be undertaken.
These ocmnitments effectively preclude the release of radioactivity to the refueling area envirorment prior to the time that the SGTS has been cxxtW. Therefore, the "....a;propriate containment, confinement, and filtering systems..." called for by GDC-61 will not
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be required to be available by plant conditions until the SGTS has beeA connected.
Based upon the foregoing, we have concluded that granting the requested exernption will not endanger l' MrW the ommon
- 4 defense and security and is otherwise the public intere
- Further, f/
delaying the operation of Limerick un
- W SGIS servi the refueling
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area is unwarranted, unnecessary, and not in -
public interest. For these reasons, Philadelphia Electric Capany requests that the Ccumission issue an exmption to GDC-61 that would allow the SGTS to be connected to the refueling area prior to the first refueling outage. An affidavit in support of this request is attached heretd.
Sincerely,
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7 JHA/gra/09188401
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cc: See Attached Service List h
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