ML20112H557
| ML20112H557 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/11/1985 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 5211-85-2008, NUDOCS 8501170199 | |
| Download: ML20112H557 (2) | |
Text
e GPU Nuclear Corporation Nuclear
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Middletown, Pennsylvania 17057-0191 717 944-7621 TELEX 84-2386 Writer's Direct Dial Nurnber:
5211-85-2008 January 11, 1985 Office of Nuclear Reactor Regulation Attn: John F. Stolz, Chief Operating Reactors Branch No. 4 U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Stolz:
Three Mile Island Nuclear Station Unit I (TMI-1)
Operating License Nol DPR-50 Docket No. 50-289 Reactor Building Purging, Summary Report Your letter of December 5,1984, regarding containment purging, requested that GPUN provide a summary report after the first cycle of operation after restart that contains (1) the actual number of hours of purging for each of the operations or combination of operations listed in T.S. 3.6.9, (2) an analysis of the benefits of purging in terms of reduction in rMiation exposure to plant personnel, and (3) the actions taken to minimize personnel entries. We agree with your conclusion that our proposed Technical Specification requirements combined with other actions to limit off-site doses are adequate. Since these specifications and actions are deemed adequate, we do not agree that our proposed Technical Specification (T.S.) purging restrictions (3.6.10) need to be compared with future operating experience.
GPUN had previously been allowed to conduct unrestricted containment purging during operation. To date, in addressing the generic concern of purging and venting containments, GPUN Las (1) adopted more restrictive T.S. primary 0
coolant activity limits, (2) limited containment purge valves to a nominal 30 open while purging is conducted during STARTUP, HOT STANDBY and POWER OPERATION, these modes to the seven activities listed (3) agreed to limit purging during(4) added a specification requiring these in proposed specification 3.6.10, activities be scheduled to coincide to minimize instances of purging, (5) enhanced T.S. actions associated with an inoperable purge isolation valve, (6) specified purge valve seat replacement intervals in the T.S., (7) provided analysis which demonstrates the protection of safety related equipment down stream of the purge valves from adverse environment during a LOCA, (8) committed to installing debris screens on the purge lines, (9) provided an analysis which demonstrated the negligible effect of purge valve closure time on ECCS containment pressure response, (10) adopted purge valve test frequency and acceptance criteria in the proposed specification, (11) shown that the valves 8501170199 850111 PDR ADOCK 05000209
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Mr. J. F. Stolz 5211-85-2008 will close from the nominal 30 open angle against the buildup of contain-ment pressure in the event of a LOCA. These actions, analyses and Technical Specifications provide sufficient assurance that TMI-1 containment purging activities will be managed in a prudent manner and will not endanger the public health and safety.
Additionally, your request for a summary report of purging activities is not consistent with the proposed rulemaking on "Backfitting" 10 CFR 50.109.
The staff has not provided either an analysis of any substantial increase in the protection of the public health and safety to be derived from this report or an analysis of the monetary cost considerations (i.e., manhours) incurred in providing this report. Standard Review Plan, Standardized Technical Specifications, and other NRC guidelines have been adopted by GPUt! which adequately address the generic concern of containment purging and venting.
There are currently no NRC guidelines (e.g. Reg Gu'ies, NUREG's, SRP's) which either endorse or provide any basis for the subject report. GPUN has adopted the ALARA concept and maintains sufficient records, reporting requirements and Technical Specifications to validate our management goals and techniques. The ALARA concept is utilized in conducting many activities which do not have the additional, excessive reporting requirements you propose for purging activities. The requested summary report represents a significant administrative effort with no apparent benefit. Appropriate records of activities in this area are available on-site for NRC inspection.
Sincerely, t
. D.
k 11 Director, THI-1 HDH: RAS:che cc:
R. Corte J. V6n Vliet
- 0. Thompson
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