ML20205C652
| ML20205C652 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/19/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| CON-#287-2944, RTR-NUREG-0612 OL, NUDOCS 8703300228 | |
| Download: ML20205C652 (2) | |
Text
9 PHILADELPHIA ELECTRIC COMPANY.
2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (2151 841 5001 JOSEPH W. G ALLAGHER March 19, 1987 J;*.".l".".'."."7...
Mr. W. R. Butler Project Directorate #4 Division of Boiling Water Reactor Licensing U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station - Unit 1 Removal of Primary Containment Head
Reference:
Letter, V. S. Boyer, (PECo) to H.
R. Denton, (NRC), dated September 21, 1984
Dear Mr. Butler:
Limerick Generating Station Unit 1 License Condition 2.C.14 states that until the LGS Standby Gas Treatment System (SGTS) is connected to the refueling area, the Licensee shall not remove the RPV head prior to NRC staff review and approval.
License Condition 2.C.14 references Section 6.2.3 of SSER-2 and SSER-3 which state that until the Standby Gas Treatment is connected to the refueling area, operations involving removal of the Primary Containment head, as well as the RPV head after initial criticality, are prohibited without specific prior NRC approval.
This same condition is contained in the referenced letter.
During the May 1987 LGS Unit I refueling outage we plan to remove the primary containment head in parallel with the SGTS connection to the refueling area.
A Safety Evaluation has been performed which concludes that SGTS need not be connected to the refueling area while removing the primary containment head for the following reasons:
It has been determined that handling of the primary (heavy O m, y
containment head in accordance with NUREG 0612 L
9 in fuel load handling requirements) would not result damage requiring the use of the SGTS to control the $jp6/9gyg release of radiation.
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W..R.' Butler March 19, 1987 Page 2 SGTS is not required by the Technical Specification Limiting Conditions for Operation to be operable during primary containment head removal.
There are no Technical Specification Limiting Conditions for10peration to verify the refueling area secondary containment. integrity prior to removing the primary containment. head.
The refueling area secondary containment' integrity will be verified prior to handling irradiated fuel, performing core alterations, or
-operations with the potential to drain the vessel.
The drywell will be purged in accordance with established procedures to.de-inert the primary containment.
This process will assist in the removal of airborne contamination in the drywell so that removal of the primary containment head will not result in contamination of the' refueling area.
From the time that the-Reactor Enclosure Secondary Containment integrity is rendered inoperable until the time Refueling Area Seconday Containment' integrity has been verified, no operation with the potential for draining the reactor vessel will be performed.
Based on the above considerations, it is not necessary to have the SGTS-connected to the refueling area prior to the removal of the primary containment head.
Accordingly, Philadelphia Electric Company requests NRC approval to remove the LGS primary containment head prior to the connection of SGTS to the refueling floor.
If you have any questions or require additional information on this subject, please do not hesitate to contact us.
In accordance with Section 170.12 of the Commission's regulations, enclosed is Philadelphia Electric Company's check in the amount of $150.00 to cover the filing fee.
Very truly yours, 4
0 0'y l.
Attachment cc:
E. M. Kelly, Senior Resident Site Inspector See Attached Service List J