ML20126C781

Requests Exemption from 10CFR70.24(a) to Maintain Criticality Alarm Sys in Each Area in Which SNM Handled, Used or Stored.Exemption Based on NRC Granting Same Request for Unit 1 in Sser 22 (NUREG-0797)

ML20126C781
Person / Time
Site:	Comanche Peak
Issue date:	12/18/1992
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0797, RTR-NUREG-797 TXX-92618, NUDOCS 9212230213
Download: ML20126C781 (2)

Text

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6 5~~, ~~M Log # TXX 92618

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file # 10003 L - 901.8 C

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Ref. # 10CFR50.12 10CFR70.24

\ TUELECTRIC 10CFR70.14 December 18, 1992 M INm J. Cubill, .f r.

Gwap he Pmsar f U. S. Nuclear Regulatory Commission Attention: Document Control Des)

(

Washington, DC 20555

) _

l SUBJECT. COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)- UNIT 2 DOCKET NO. 50-446 l REQUEST FOR EXEMPTION FROM 10CFR'^ '4(a)

REF: 1) TV Electric Letter from W GHILL Jr.. to NRC 1r :

TXX-89438 and dated Jur.e 3 1$e9 e

2) Environmental Asses ment and finding of No Impact for Unit 1 (54 FR 47432), November

3) Safety Evaluation Report Related to the Operation of 3manche Peak Steam Electric Station, Units 1 ard 2 3 .Nureg-0797), Supplement No. 22 Gentlemen:

r TV Elet'ric requests an exemption, on the facility operating license for CPSES Unit 2 from the requirament of 10CFR70.24(a) to maintain a e criticality alarm system in each area in which special nuclear material is

[ ,_

handled, used. or stored. Unit 2 currently has an exemption f rom the criticality monitoring requirements in Special Nuclear Material Licensc Ho.

L S'4M - 181' TU Electric requests the exemption remain effective and be )

incorporated into the facility operating license on conversion of the Unit 2 Construction Permit, CPPR-127, to a Unit 2 facility operating licanse under 10CFR50.

The exemption is authorized by 10CFR50.12(a), 10CFR70.24(d), and 10CFR70.14(a) which provide that an e.<emption may be granted if:

1) Special circumstances and good cause are present in that implementation of the regult. tion, at CPSES Unit 2, is not necessary to achieve the underlying purpose of the rule.

2) The exemption is aPthorized by law; it will not present an undue risk to the public health and safety: it is consistant with the common defense and security; and it is in the public interest, is discusssd below, these elements are present in the requested exemption.

t 9212230213 921218 PDR- ADOCK 05000446 A ppr' p - - -

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TJX- 92618 Page 2 of 2 TU Electric's CPSES Unit I currently has an exemption from the criticality monitoring requirements of 10CFR70.24. The Unit 1 exemption was granted on the basis that the fuel storage system, the fuel handling system, the administrative controls, and refueling procedures are such that, under both normal and accident conditions and while moving 'or storing new or spent fuel, sub criticality is maintained, accidental criticality is precluded, and accidental personnel exposures are thereby prevented.

The CPSES fuel handling system and storage racks are common equipment and the refueling procedures are dual unit procedures. The design and administrative controls applicable to Unit 1 to p.eclude inadvertent criticality also apply to Unit 2. A criticality monitoring system for Unit

2. like in Unit 1, will not serve the intent of the rule which is to prevent personnel f rom exposure in the event of accidental criticality.

The Unit 2 exemption request is authorized by 10CFR70.24(d) in that the commission may grant exemptions on a showing of a good cause. The Environmental Assessment and Finding f No Significant Impact for Unit I was published in 54 FR 47432 on November 14, 1989. In it the NRC documented its finding of no environmental impacts and no radiological effects associated with the Unit 1 exemption. Unit 2 utilizes the same facilities, systems, and controls as Unit 1 in storing and handling fuel. 'The Unit 2 exemption will, like Unit 1, not present a risk to the public health and safety.

Approval 'or exemption of Unit 1 from the criticality monitoring requirements was published in the Safety Evaluation Report related to the operation of Comanche Peak Steam Electric Station. Units 1 and 2 -

(NUREG-0797), Supplement No. 22. In SSER 22, the NRC determined that the Unit 1 exemption would not endanger the common defense and security and was otherwise in the public interest. The requested Unit 2 exemption like the Unit 1 exemption is consistent with the common defense and security and in the public interest.

Sincerely, Qfy 0 '

William J. ahill, Jr.

JOR/

c- Mr. J. L. Milhoan, Region IV Resident Insnarts,s, CPSES (2)

Mr. B. L. Holian, hRR n-