ML20107B560

Requests Exemption from Requirements of 10CFR50,App A,Gdc 19 Re Capability to Achieve Hot & Cold Shutdown from Outside Control Room.Redundant Remote Shutdown Capability Will Be Provided by Making Procedural & Hardware Changes

ML20107B560
Person / Time
Site:	Limerick
Issue date:	10/25/1984
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0800, RTR-NUREG-800 NUDOCS 8411020241
Download: ML20107B560 (4)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101

.OHN S. KEMPER.

V IC E-PR ESID E N T 0CT 2 51984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccmnission Washington, D.C. 20555

Subject:

Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Request for Exemptton from 10CFR50, Appendix A, GDC 19

Reference:

J. S. Kemper (PECO) letter to A. Schwencer (NRC) dated July 18, 1984.

File:

GOVT 1-1 (NRC)

Dear Mr. Denton:

Pursuant to 10CFR50.12, Philadelphia Electric Company hereby requests an exemption frcm the requirement of 10CFR50, Appendix A, General Design Criterion 19 as it relates to the provision of a capability to achieve hot and subsequent cold shutdown from outside the control rocm.

A remote safe shutdown panel room is provided outside the control room in order to achieve the objectives of GDC 19. As interpreted in Standard Review Plan (NUREG-0800) Section 7.4, this GDC requires that the capability to achieve _such shutdown conditions remotely should also be redundant.

PECO has ccmnitted, via the reference letter, to provide this redundant remote shutdown capability by making procedural and hardware changes (which allow for the single failure of systems or ccmponents controlled from the Remote Shutdown Panel without the need for 'Jtsnpering or rewiring circuits). This capability will be provided prior to starting up the plant at the conclusion of the first refueling outage.

Information on the changes to be made at the first refueling outage will be provided to the NRC staff prior to exceeding 5% pover.

PECO additionally comnits to providing a redundant remote shutdown capabllity using procedures and existing equipment as detailed below prior to exceeding 5% power.

The absence of this redundant remote shutdown capability will not endanger life or property for the following reasons:

1.

A remote shutdown capability is needed only in the event l

that the main control rocm becomes either inoperative or p(

0 uninhabitable.

8411020241 841025 dg t

PDR ADOCK 05000352

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. '.2~

The provision of redundant safe shutdown capabilities within the control room makes'It highly unlikely that all such available methods in the control room will be simultaneously unavailable. The Ilkelihood that this unevallability would' occur during operation before exceedirg 54 power is even

~

more unlikely.

3..

- The Ilkelihood that either internal or external events will render the control room uninhabitable is very small, given the presence of systems and procedures to detect and protect the

. control room against such events.

4.

The existing Remote Shutdown Panel room is located on a separate floor from the main control room and separated by barriers which protect '.the remote room from the hazards which would affect the main control room. The !!kelihood that the Remote Shutdown Systems would not function as designed is small. When ccmbined with the Ilkelihoods discussed in 2 and 3 above, the likelihood that these 3 events would conbine prior to exceeding 5% power is even more remote.

5.

Procedures will be available to provide this redundant remote shutdown capabi11ty using equipment presently installed at the plant in conjunction with temporary Jtmpers. These procedures will be reviewed, approved and in place prior to exceeding 5% power. Prior to exceeding 5%

power, only minimal decay heat requiring removal will

. exist. As a result substantial time will be available to

.take'mltigatIve measures.

The requested exemption does not impact the cormon defense and security. Only the potential impact on pubilc health and safety is at issue.

The requested exemption is in the public interest in that any delay in conmencement of low power testing and power ascension would

- cause a delay in the attainment of conmercial operation (and subsequent increase in ratepayer's cost) and since, as shown above, the health and safety of the public will be adequately protected.

l l-Based upon the foregoing, we have concluded that granting the requested exemption will not endanger life or property or the ccmmon defense and security and is otherwise in the public interest.

. Therefore, Philadelphia Electric Company requests that the Ccmmission issue an exemption to GDC 19. An affidavit in support of this request is attached hereto.

(

Sincerely,-

L 4 i /C JTR/gra/10258407 l

- cc: See Attached Service List m

u

COPNONWEALTH OF PEM4SYLVANIA ss.

COUNTY OF PHILADELPHIA J. S. Kenper, 'being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company, the applicant herein; that he has reviewed the foregoing request, pursuant to 10CFR50.12 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, Infonnation and belief.

I I

0] f /LL

[ Vice Presicisint

Subscribed and sworn to before me on the 25th day of October 1984.

f-

' Notary PubtIc; PATRI'd1A D. SCHOLl! '

Notary Pubrd Phibdefphia, Philadelphia Co.

2 Aly Comm$sMn Espires february J0.1366

2. *'

y-sot.

T cc: Judge Helen F. Hoyt

'dudge derry Harbour-idudge Richard F.. Cole

oudge Christine N. Kohl Judge Gary ~J..Edles Judge.Reginald L. Gotchy Troy B. Conner, dr., Esq.

JAnn P..Hodgdon, Esq.

Mr.-Frank R.~ Romano

'Mr. Robert.L.-Anthony

'Ms. Phyllis Zitzer

~

Charles W. Elliot,-Esq.

l-Zori G.;Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.

David Wersan, csq.

' Robert J. Sugarman, Esq.

Martha W. Bush, Esq..

-Spence W. Perry, Esq.

Jay M. Gutierrez, Esq.

Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section Mr. James Wiggins Mr. Timothy R. S. Campbell