ML20133F355
| ML20133F355 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/02/1985 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20133F359 | List: |
| References | |
| 0295A, 295A, 4410-85-L-0159, 4410-85-L-159, NUDOCS 8508080254 | |
| Download: ML20133F355 (4) | |
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GPU Nuclear Corporation NggIgf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
(717) 948-8461 4410-85-L-0159 Document ID 0295A August 2, 1985 TMI Program Office Attn: Dr. B. J. Snyder Program Director US Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Snyder:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 General Project Design Criteria - NRC Comment Resolution Attached are the GPU Nuclear responses to the NRC comments on the General Project Design Criteria (GPDC) requested in your letter dated December 11, 1984. Also attached is Revision 6 of the GPDC.
If you have questions concerning this information, please contact Mr. J. J. Byrne, of my staff, at TMI Extension 8461.
Sincerely, L L.6 :6 F. R. Standerfer Vice President / Director, TMI-2 FRS/CJD/eml Attachment c.c: Deputy Program Director - TMI Program Office, Dr. W. D. Travers
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$0j gDR ADOCK 05000320 PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
ATTACHMENT 1 (4410-85-L-0159)
NRC Item 1 - Section 2.5 Safety Related The definition of " safety related" is not current and only allows this classification for equipment needed after/during a safe shutdown earthquake.
The more recent staff definition, which can more generally be applied, is stated in 10 CFR'50.49(b)(1). The fact that this definition is contained in a section on electrical equipment is not controlling. It states as follows:
"This equipment is that relied upon to remain functional during and following design basis events to ensure (1) the integrity of the reactor coolant pressure boundary, (ii) the capability t.
shutdown the reactor and maintain it in a safe shutdown condition, (a.iC (iii) the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the 10 CFR Part 100 guidelines. Design basis events are defined as conditions of normal (peration (or in abnormal operating conditions for TMI-2), including Enticipated operational occurrences, design basis accidents, external even'.s, and natural phenomenon for which plant must be designed to ensure functions (i) through (iii) of this paragraph."
GPU Nuclear Response The definition of " safety related" as used in the General Project Design Criteria (GPDC) is the same as the definition used in the TMI-2 Recovery Quality Assurance (QA) Plan. The Recovery QA Plan is the Licensing Basis document for QA requirements at TMI-2 and has been reviewed and accepted by the NRC. The purpose of changing the safety related definition in the GPDC was to eliminate an inconsistency between the GPDC and the Recovery QA Plan.
Therefore, use of the 10 CFR 50.49(b)(1) definition in the GPDC is not appropriate.
NRC Item 2 - Section 3.2.4 Basic Criteria As previously stated in NRC correspondence dated August 10, 1984; NovemDer 5, 1984; and November 28, 1984, this section is invalid unless proper exemptions or exceptions to the Code of Federal Regulations have been granted.
GPU Nuclear Response As stated in your letter of November 28, 1984, temporary recovery modifications do not have to meet design basis severe natural phenomena so long as:
1.
the structure is temporary; 2.
a breach of the component by natural phenomena will not cause a radiological release in excess of 10 CFR 100 limits; 3.
or a failure of the component will not compromise the ability to maintain the reactor in a safe shutdown condition.
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o ATTACHMENT 1 (4410-85-L-0159)
Based on the above, Section 3.2.4 will be revised to read:
Facilities and systems constructed to support the recovery effort shall not have as part of their design basis the severe natural phenomena for which the plant was originally designed. However, facilities and systems constructed to support the recovery shall be evaluated to ensure that there will be no loss of the required safety function of existing safety-related structures, equipment, or systems needed during the recovery should these events cccur. Where there would be a loss of safety function, the facility or system shall have as part of its design basis the severe natural phenomena to the extent that the safety function can be maintained.
Included under " severe natural phenomena" are:
a.
Tornado and tornado missile c.
Maximum flood NRC Item 3 - Section 3.4 Regulatory Requirements This section is misleading. Recovery activities and facilities shall satisfy the requirements of all of Title 10 of Code of Federal Regulations unless a specific exemption to certain sections has been granted. Section (1) should be updated to reflect the Appendix R exemption granted by the staff.
GPU Nuclear Response GPU Nuclear agrees that recovery activities and facilities shall satisfy all applicable requirements of Title 10 of the Code of Federal Regulations unless a specific exemption has been granted. This section of the design criteria is intended to highlight those sections of Title 10 which are more likely to be involved in the recovery activity or facility.
Section 3.4.1 will be revised to read:
The facilities and activities associated with the recovery shall satisfy all applicable requirements of Title 10 of the Code of Federal Regulations unless a specific exemption has been granted. Listed below are specific sections which are likely to be more frequently applicable:
Section 3.4.1 L will be revised to read:
... to January 1, 1979. An exemption to Sections III.G and III.0 has been granted by the MlC (NRC letter Snyder to Kanga, May 18, 1984). An exemption to Section III.J has been requested (GPUNC letter 4400-82-L-0102, dated June 15, 1982, J. J. Barton to Dr. B. J. Snyder).
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ATTACHMENT 1 (4410-85-L-0159) f NRC Item 4 - Note on Page 13 A discussion on many of these guides has been incorporated in the GPU Recovery QA Plan. Therefore, the reference to the Bechtel Nuclear Quality Assurance Manual (NQAM) should be deleted for those cases.
GPU Nuclear Response In your letter of August 10, 1984, your staff accepted the reference to the Bechtel NQAM in the GPDC as long as it remained consistent with the Recovery QA Plan.
The discussions contained in the Bechtel Nuclear Quality Assurance Manual (NQAM) regarding regulatory guides are consistent with the TMI-2 Recovery QA Plan. The NQAM is revised, as required, to remain consistent with the TMI-2 Recovery QA Plan. Therefore, it is GPU Nuclear's opinion that it is proper to reference the Bechtel NQAM in the GPDC.
i NRC Item 5 - Table 4 It appears that the " Access Description" for zones V, VI, and VII should state "normally inaccessible (except) during emergency".
I GPU Nuclear Response Table 4 will be revised to state "normally inaccessible (except) during emergency".
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