ML20134P927

Forwards RAI Re Gpu Nuclear Corp 960816 & 28 Requests for Exemption from 10CFR50,App R for Plant Unit 1

ML20134P927
Person / Time
Site:	Three Mile Island
Issue date:	11/20/1996
From:	Norris J NRC (Affiliation Not Assigned)
To:	James Knubel GENERAL PUBLIC UTILITIES CORP.
References
TAC-M96473, NUDOCS 9611290383
Download: ML20134P927 (6)

Text

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! November 20, 1996 s ,

Mr. James Knubel i Vice President and Director, TMI l GPU Nuclear Corporation Three Mile Island Nuclear Station j Post Office Box 480

, Middletown, Pennsylvania 17057-0191 i

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION (RAI) RELATED TO REQUEST FOR EXEMPTION FROM 10 CFR 50

APPENDIX R (TAC NO. M96473)

)-

Dear Mr. Knubel:

\ .

j- By letters dated August 16 and August 28, 1996, GPU Nuclear Corporation l submitted a request for exemption from 10 CFR 50 Appendix R for Three Mile

-Island, Unit 1. The staff has completed the preliminary review of-your request and has identified the need for additional information. The Enclosure gives details of this RAI. We request that you furnish your response within 45 days of the date of receipt of this letter.

Sincerely, (Original Signed By)

Jan A. Norris, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated  !

cc w/ enclosure: See next page t

Distribution Docket File JStolz ,Oj I PUBLIC EDunnington PDI-3 RF JNorris SVarga JZwolinski DOCU n MENT NAME:.. G:\NORRIS\.96473.TMI

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• al November 20, 1996 Mr. James Knubel Vice President and Director, TMI GPU Nuclear Corporation Three Mile Island Nuclear Station 4 Post Office Box 480 4

Middletown, Pennsylvania 17057-0191

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION (RAI) RELATED TO REQUEST FOR EXEMPTION FROM 10 CFR 50 APPENDIX R (TAC NO. M96473)

Dear Mr. Knubel:

a By letters dated August 16 and August 28, 1996, GPU Nuclear Corporation I submitted a request for exemption from 10 CFR 50 Appendix R for Three Mile 4 Island, Unit 1. The staff has completed the preliminary review of your request and has identified the need for additional information. The Enclosure l

gives details of this RAI. We request that you furnish your response within 45 days of the date of receipt of this letter.

Sincerely, ,

a- >

aa Jan A. Norris, Senior Project Manager hoject Directorate I-2 j Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/ enclosure: See next page 1

9

i ,

Three Mile Island Nuclear Station, Unit No. I j cc

l Michael Ross Robert B. Borsum 2

Director, O&M, TMI B&W Nuclear Technologies i GPU Nuclear Corporation Suite 525 4 P.O. Box 480 1700 Rockville Pike

- Middletown, PA 17057 Rockville, MD 20852 1

! John C. Fornicola William Dornsife, Acting Director i Director, Planning and Bureau of Radiation Protection Regulatory Affairs Pennsylvania Department of

GPU Nuclear Corporation Environmental Resources

100 Interpace Parkway P.O. Box 2063 l Parsippany, NJ 07054 Harrisburg, PA 17120 i ' Jack S. Wetmore Dr. Judith Johnsrud

Manager, TMI Regulatory Affairs National Energy Committee GPU Nuclear Corporation Sierra Club i P.O. Box 480 L33 Orlando Avenue l Middletown, PA 17057 State College, PA 16803 l Ernest L. Blake, Jr., Esquire i

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

j Washington, DC 20037

! Chairman

Board of County Commissioners of Dauphin County j Dauphin County Courthouse

Harrisburg, PA 17120 l Chairman i Board of Supervisors

( of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 i

j Michele G. Evans Senior Resident Inspector (TMI-1)

U.S. Nuclear Regulatory Commission P.O. Box 311 Middletown, PA 17057 Regional Administrator, Region I i U.S. Nuclear Regulatory Commission i

475 Allendale Road j King of Prussia, PA 19406

}

I l

i

i REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR EXEMPTION FROM SECTION III.G.2.c 0F APPENDIX R TO 10 CFR PART 50 THREE MILE ISLAND NUCLEAR GENERATING STATION, UNIT 1 DOCKET NO. 50-289 i

j 1. Topical Report #094, Rev.1, page 7 states:

To establish the barrier rating (ACTUAL RATING) of a test assembly, GPU Nuclear reviewed the temperature data for the test and identified the point in time when the first j individual temperature reading... exceeded 325 deg F above the initial temperature. Note that this method establishes a rating for all the elements of a particular raceway size based upon the weakest link in the raceway. ...it is conservative to establish a common rating for all elements i

of a raceway based upon the single high reading for the entire raceway.

This implies that the average temperature of the raceway (or cable tray) is not taken into account when making the determination of the fire rating of the assembly. Provide technical justification for this deviation from Generic Letter 86-10, Supplement 1.

i

2. For each fire barrier element, describe how consideration of the average temperatures will affect the fire rating analysis.

The following questions relate to Attachment I to Topical Report #094:

3. Attachment 1 to Topical Report #094 describes 2.5-inch straight and j radial bend conduits and condulets which are qualified by the test of a 3/4 inch conduit /condulet. Provide a bounding analysis of the 2.5 inch conduits and condulets with respect to the test results of both the 3 inch conduits and condulets and the 3/4 inch conduit and j condulets.

! 4. The analysis of elements nos.159 and 160, states that "... depth of the cable tray does not effect the out come of the test as the width does." This statement is made without any supporting rationale.

Justify this statement.

4

5. Define the relationship.between the fire barrier elements that are evaluated in Attachment 1 to Topical Report #094 and the

corresponding fire barrier configurations installed in the various fire envelopes in individual plant fire areas, as described in Enclosure A to your letter dated August 16, 1996.

6. Some Thermo-Lag assemblies mentioned in Enclosure A of your August

16, 1996 submittal, are not reviewed in Attachment 1 to Topical 1

Report #094. For example, there are evaluations for 31 elements, yet there are over 40 individual elements listed in the exemption.

Please resolve this discrepancy.

7. The following elements are listed as penetrations in Attachment 1 to Topical Report #094: 31, 573, 574, 582, 577, 578, 545, 605, and 606.

The Nuclear Energy Institute (NEI) program did not test penetrations, and it is not clear from the evaluation of these elements how they are bounded by the fire tests that were discussed. Please clearly describe the configurations of these individual elements, as they are installed in the plant. Detailed drawings should be provided for further clarification. In addition, describe how these elements are bounded by the fire tests discussed in the evaluation.

8. For elements 542 and 34 specific condulet dimensions are not given.

Elements 352, 300, 314, and 30 are described as condulets with specific dimensions of height, length, and width provided. Please clarify this inconsistency.

9. Elements 578 and 350 do not have the band spacing specified and the evaluations state that " Additional inspection is required to determine the band spacing requirement." Provide results of these inspections and justify how these elements are bounded by the NEI tests to which these assemblies are being compared.

w-

r f .

i LIST OF ACRONYMS USED CFH Certified Fuel Handler CLUP Cask Loading / Unloading Port l CPM Counts Per Minute  ;

CSU Colorado State University l DOE Department of Energy DPM Disintegrations Per Minute DTS Decommissioning Technical Specification EML Environmental Measurements Laboratory FSP Final Survey Plan FSV Fort Saint Vrain GE Germanium l HTDN Hard To Detect Nuclides IFl Inspection Followup Item ISFSI Independent Spent Fuel Storage Installation MDA Minimum Detectable Activity MVDS Modular Vault Dry Storage System Nat Sodium lodide NRC Nuclear Regulatory Commission ORISE Oak Ridge Institute for Science and Education PCRV Prestressed Concrete Reactor Vessel PDR Public Document Room RCA Radiologically Controlled Area RSO Radiation Safety Officer QA Quality Assurance SEG Scientific Ecology Group SNM Special Nuclear Material TBD Technical Basis Document TCM Tool Contamination Monitor TLD Thermolurninescent Dosimeter TS Technical Specification Final Survey Area Packages Reviewed During inspection:

1. Final Survey Area No. A0007 (Buildings 1019,107,110,1001,1002)

2. Final Survey Area No. B0006 (Buildings 15,16,17,1003)

3. Final Survey Area No. B0012 (Building 1)

4. Final Survey Area No. C0004 (Level 5 Northwest Office Areas / electric shop)

5. Final Survey Area No. C0009 (Level 5 Turbine Lube Oil Storage Tank Room)

6. Final Survey Area No. C0030(Level 7 Turbine Deck Northwest General Area)

7. Final Survey Area No. C0031 (Level 7 Turbine Deck Southwest General Area)

8. Final Survey Area No. D4800 (Alternate Cooling System)