ML20107M072
| ML20107M072 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/09/1984 |
| From: | Sugarman R SUGARMAN & ASSOCIATES |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20107M061 | List: |
| References | |
| OL, NUDOCS 8411140014 | |
| Download: ML20107M072 (7) | |
Text
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7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cggg M:
ATOMIC SAFETY AND LICENSING APPEAL BOARD N O/13 lin :;5 In the Matter of Philadelphia Electric Company Docket No. 5 0- 3 5 2-OL 50-353-OL; (Limerick Generating Station, Units I and II)
REPLY RE: STAY l
The staff has opposed the requested stay, inter alia,
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on the grounds that the supplemental cooling water system is not P
safety related.
The staff f ails to mention the letter from J.
L Kemper to A.
Schwencer, referenced in the Petition for Stay, which asserted that the supplemental cooling water system is safety related, and is a basis for exemption or waiver of the inadequacy of the cooling towers.
On October 19,
- 1984, applicant filed Request for l'
Exemption from Appendix A under the 10 CFR Section 50.12, on the
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f ground that a f ailure of the cooling towers would be covered by L
the "other water sources". Copy attached as Exhibit A.
l Despite applicant's attempts to obscure the issue by its elliptical reference, and its inconsistent letter of the same s
date, it is clear that the "other Water sources" in mind, must be the only other supplemental cooling water source mentioned by the L
applicant in all of its filings with this Commission, namely, the Perkiomen-Point Pleasant diversion (dependent on Point Pleasant 96% of the tim a).
The other alternative is that the applicant has misrepresented the f acts all along as to unavailability of consumptive cooling water.
The staff did not refer to this letter in its November 8411140014 841109
{DRADOCK 05000352 1
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2 filing.
This filing, along and in concert with the other grounds asserted in the request for stay, require that the stay be granted as sought, or as recharacterized as a motion to set aside.
Respectfully submitted, t
CounselforIntbrven\\r ROBERT J. SQA$AN o
Of Counsel Sugarman,.Denworth & Hellegers 16th Floor, Center Plaza 101 North Broad Street Philadelphia, PA 19107 215-751-9733 DatedNovemberf,1984 p09.rjs 2
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.s RECEIVEO PHILADELPHI A ELECTRIC COM PANY
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OCT 251984 2301 M ARKET STREET P.O. DOX 8699 7
- 18. N PHILADELPHI A. PA.19101 mM * *
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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 1.imerick Generating Station Units 1 & 2 S ub*j e c t :
Request for Exemption from 10 CFR 50 Appendix A, h
GDC 2 & 4
Dear Mr. Denton:
pursuant to 10 CFR 50.12, Philadelphia Electric Company phereby requests an exemption from the requirement of 10 CFR L
i 50, Appendix A General Desian Criteria (GDC) 2"and 4 as they) relate tv Tne protecn of the ultimate heat sink This exemption (UHS from the effects of tornado missiles.
is requested for power levels not exceeding 5 percent of 1+
full power.
Loss of the UHS (spray pond) due to tornado missiles for power levels not exceeding 5% power will not endanger life j
or property for the following reasons:
I Even if the heat removal capability of the cooling 1.
towers and spray networks were compromised by
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tornado missile effects, use of the cooling tower basins and/ or UHS in a " cooling pond type" mode n
h would allow substantial time for spray network Under design meteorology, it would take
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apgroximately 5 days for the pond to reach its j
95 F limit.
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en.
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s 2.
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 l
of the spray pond is reached, a once-through mode of cooling can can be implemented.
In this mode of operation, cool water on the cooling tower basins is suppli_td-tn' e spray pond bumphouse wet
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L pits, ESWj nd'R'HRSW will pump this water through s
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the t,
the water is returned to the spray pond'ws s allowed to discharge over the blowdown weir f
d storm spillway.
Sufficient makeup water can N
h be supplied to the cooling tower basins to sustain I
continuous operation in this mode from the Schuylkill River or a number of other sources.
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I l 3.
D u r i n g - t h e_p e r i o d ol o p e r a t i o n - b e f o rmxc~e e~diiii~S %
power, it is extremely unlikely that tornado missile damage to the networks would occur.
But in the event that this should occur, there is y
Sufficient time to effect the repairs on any one of the four networks such that sufficient heat 0
removal capability can be restored without the existence of specific procedures.
Specific procedures l
for such repairs will be conpleted prior to exceeding 3
5% power.
4.
As indicated in the above discussions, substantial time is available for corrective operator actions, If UHS capability should be lost for such a long o
period of time that conditions degraded considerably, the existing plant emergency procedures would l;
direct the use of equipment which would achieve a i
safe stable state rd4ots of UHS capability.
'f T h,g-re qu e s t exemption does not impact the common defent j;:
frnd security.
Only the potential impact on public healt (a
we.
j The requested exemption is in the public interest in that any delay in commencement of low power testing and power 8
ascension would cause a delay in the attainment of commercial operation (and subsequent increase in ratopayers' cost) and j','
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 public 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.
Ao affidavit in support of this request is attached hereto.
Sincer,ely, t
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4 V. S.Boyer
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- See attached Service List r
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cc: Judge Helen F. tbyt Judge Jerry Harbour 3
d;dge Richard F. Cole Judge Christine N. Kohl Judge Gary J. Edles Judge Reginald L. Gotchy Troy'B. Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
j Mr. Frank R. Romano Mr. Robert L. Anthony p
Ms. Phy111s Zitzer g
usar ses W. Elliot, Esq.
Zort G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Managcment Agency ll Angus R. Love, Esq.
David Wersan, Esq.
i Robert J. Suganmn, Esq.
f Martha W. Bush, Esq.
Spence W. Perry, Esq.
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Jay M. Gutierrez, Esq.
ll Atcmic Safety & Licensing Appeal Board Atcmic Safety & Licensing Board Panci i
Docket & Service Section Mr. James Wiggins
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Mr. Timathy R. S. Canpbell t.
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, STATE Of MARYLAND {
NONTGO!!ERY 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 e
foregoing request pursuant to 10 CFR 50.12 for certain specific exemptions to the requirements of Appendix A and L
knows the' contents thereof; and that the matters and l
stat'ements set forth therein are true and correct to the best of his knowledge, information-and belief.
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Senior Vice President 1
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Subscribed and sworn to before me on the 19th
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day of October 1984.
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