ML20140E624

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Forwards Response to NRC 970527 RAI Re Request for Exemption from Requirements of 10CFR70.23(a), Criticality Accident Requirements
ML20140E624
Person / Time
Site: Crane Constellation icon.png
Issue date: 06/05/1997
From: Langenbach J
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
6710-97-2235, NUDOCS 9706120163
Download: ML20140E624 (5)


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GPU Nuclear,lnc.

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Route 441 South NUCLEAR Post Offico Box 480 Middletown. PA 17057-0480 Tel 717 944-7621 June 05,1997 6710-97-2235 U. S. Nuclear Regulatory Commission l

Attention: Document Control Desk l

Washington, DC 20555 Gentlemen:

Subject:

Three Mile Island Nuclear Station Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 i

Request for Additional Infonnation - Request for Exemption from 10 CFR 70.24(a)

By letter dated Febmary 7,1997, as supplemented March '26,1997, GPUN requested an exemption from the requirements of 10 CFR 70.24(a), " Criticality Accident Requirements."

l Based on NRC review of our submittal, a request for additional information (RAI) was issued by the NRC in a letter dated May 27,1997. The enclosure contains our response under oath to i

the RAI.

If you have any questions or require aw additional infonnation, please contact Adam Miller at (717) 948-8128.

l Sincerely, j

ames W. Lange ach Vice President and Director, TMJ Enclosure l

AWM cc:

Region I Administrator, w/ enclosure l

TMI-1 Senior Project Manager, w/ enclosure TMI Senior Resident Inspector, w/ enc.losure llb l

,l. l File 97035 9706120163 970605 PDR ADOCK 05000289 P

PDR 3

l GPU NUCLEAR, Inc.

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50 289 5

This letter is submitted in response to an NRC request concerning an exemption request from the requirements of 10 CFR 70.24, in a letter dated May 27,1997. All statements contained in this response have been reviewed, and all such statements made and matters set forth therein are true and correct to the best of my knowledge.

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l/ames W. Langenb c Vice President and trector, TMI i

i Signed and sworn before me this Iy

>,1997.

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/ Notary Public' Notarial Seal Suzanne C. Miklosik. Notary Public Londonderry Twp., Dauphin County My Commission 6pires Nov. 2.2,1999 Member. Pennsylvania Association of Notanes 1

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Enclosure 1

Response to NRC Request for AdditionalInformation TMI-l Criticality Accident Monitor Exemption Request Below are listed the eight criteria, specified in the NRC letter dated May 27,1997, for granting exemptions from 10 CFR 70.24. Following each criterion is a response stating how the criterion is met or why meeting the critelion is not necessary.

1.

Plant procedures do not permit more than 1 PWR fuel assembly or 3 BWR fuel assemblies to be in storage or transit between their associated shipping cask or storage rack at one time.

Response

During refueling operations, transfer of fuel assemblies between the Reactor Building (RB) and the Spent Fuel Pool (SFP) via the Fuel Transfer System is controlled by approved fuel handling procedures. Parallel movement activities can occur such that assemblies are being tmnsferred at the same time that the fuel handling bridge is moving an assembly to/from a storage rack location. Although fuel assemblies can be moving between the RB and SFP while the Fuel Handling Bridge is moving fuel within the storage racks, only one assembly at a time can be raised / lowered in a rack location since there is only one fuel mast on the bridge in the SFP. In addition, during fuel receipt operations, fuel may be moved in the SFP while an assembly is j

lifted from its shipping container and inspected in the Truck Bay, and then transported to the SFP operating floor, elevation 348 feet. All of these opemtions are bounded by the fuel l

handling accident of a dropped assembly on top of stored assemblies (reference TMI Technical l

Specification Amendment No.170).

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2.

The requirement is met that k-effective not exceed 0.95, at a 95% probability,95%

l confidence level with the fresh fuel storage racks filled with fuel of the maximum permissible U-235 enrichment and flooded with pure water.

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Response

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The requirement of k-eff < 0.95 in new fuel storage when flooded with unborated water is met as stated in Tech. Spec. 5.4.1.

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3.

The requirement is met that k-effcc tive not exceed 0.98, at a 95 oB probability, 95 %

l confidence level with the fresh fuel storage racks filled with fuel of the maximum permissible l

1 U-235 enrichment and flooded with moderator at the (low) density corresponding to optimum moderation.

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Response

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The requirement of k-eff < 0.98 in new fuel storage when flooded with optimum low moderator density condition is met as stated in Tech. Spec. 5.4.1.

4.

The requirement is met that k-effect;ve not exceed 0.95, at a 95 % probability, 95 %

confidence level with the spent fuel storago racks filled with fuel of the maximum permissible l

U-235 enrichment and flooded with pure water, l

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Response

The requirement of k-eff < 0.95 in spent fuel storage when filled with maximum 5.0 % U-235 and flooded with pure water is met as stated in Tech. Spec. 5.4.1. During fuel movements, a l

minimum of 600 ppm boron is required in the Spent Fuel Pool to ensure k-eff <0.95 based on l

the analyzed fuel handimg accident.

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5.

The quantity of forms of special nucle.ir material, other than nuclear fuel, such as sources i

or detectors, that are stored onsite in one area, is less than that necessary for a critical mass.

Response

Special Nuclear hiaterial (SNM) is reported in the semi-annual material status reports as required. The quantity of SNh1 in onsite detectors is less than 40 grams, which is less than necessary for a critical mass. For the special case of ThfI-2, SNM quantities have been l

addressed previously in the Afay 27,1988 Amendment 30 to the EfI-2 License, and the June l

15,1992 approval of 10 CFR 70.24 exemption for Thil-2. Sources are controlled onsite by procedures, which assign source custodians, track inventory, record movement and storage, and cnsure required testing. The amount of source material is less than 30 grams, much less than mquired to produce a critical mass.

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Radiation monitors, as required by GDC 63, are provide,I in fuel storage and handling areas to detect excessive radiation levels and to initiate appropriate safety actions.

Response

i Radiological Controls Procedure 6610-ADhi-4410.01, " Fuel Receipt and Handling," provides radiation monitoring requirements for handling new fuel prior to being placed into the spent fuel pool. Any handling of fuel in the spent fuel pools is monitored by Technical Specification required radiation monitors on the fuel handling bridges. These required radiation monitors i

have alarm response procedures which provide instructions to the operators upon receipt of alarms.

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o 7.

The maximum nominal U-235 enrichment is 5 wt%.

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Response

Maximum enrichment is 5.0 % U-235 as stated in Tech. Specs. 5.4.1 and 5.4.2.

8.

Training is provided to the appropriate personnel for safely handling fresh fuel.

Response

Training of Fuel Handling Bridge operators is provided through the Operator Training program.

Training of Maintenance personnel consists of crane operation certification, rigging and handling, and signaling for safe load handling. In addition, allindividuals who have access to radiologically controlled areas must complete initial training, and annual refresher training thereafter, which includes proper response to area radiation monitor alarms.

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