ML20215C848
| ML20215C848 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/10/1986 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Travers W Office of Nuclear Reactor Regulation |
| References | |
| 0141P, 141P, 4410-86-L-0207, 4410-86-L-207, NUDOCS 8612150462 | |
| Download: ML20215C848 (4) | |
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y GPU Nuclear Corporation Nuclear
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a Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
(717) 948-8461 4410-86-L-0707 Document ID 0141P December 10, 1986 TMI-2 Cleanup Project Directorate Attn: Dr. W. D. Travers Director US Nuclear Regulatory Commission c/o Three Mile Island Nuclear Station Middletown, PA 17057
Dear Dr. Travers:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Exemption From 10 CFR 50 Appendix A, General Design Criteria 17 And 19 As discussed with members of your staff, GPU Nuclear understands that favorable NRC review of Technical Specification Change Requests (TSCRs) 49 and 51, submitted via GPU Nuclear letters 4410-85-L-0110 dated June 18,1985, and 4410-85-L-0135 dated July 31, 1985, respectively, require exemption from 10 CFR 50, Appendix A, General Design Criteria (GDC) 17, " Electric Power Systems," and GDC 19, " Control Room." A request for said exemptions is submitted herein.
Based on the justification provided in Attachments 1 and 2, GPU Nuclear has concluded that these exemptions from the GDC are warranted in accordance with 10 CFR 50.12(a)(2)(ii).
Due to the unique condition of TMI-2, compliance with the requirements of GDC 17 and 19 is not necessary to achieve the underlying intent of these criteria.
The safety evaluations submitted in support of the referenced TSCRs, as well as the analyses presented in GPU Nuclear letters 4410-86-L-0033 dated February 26, 1986, and 4410-86-L-0081 dated May 20, 1986, provide the technical bases for this request.
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation gc'c,\\ w%4/ec)L 7//$0 00
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Dr. Travers December 10, 1986 4410-86-L-0207 Per the requirements of 10 CFR 170, an application fee of $150.00 is enclosed.
Sincerely,.
. Standerfe Vi e President / Director, TMI-2 FRS/RDW/eml Attachments Enclosed: GPU Nuclear Corp. Check No. 000219 i-l I
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ATTACHMENT 1 4410-86-L-0207 JUSTIFICATION FOR EXEMPTION FROM GENERAL DESIGN CRITERION 17 General Design Criterion (GDC) 17, " Electric Power Systems," to 10 CFR 50 Appendix A requires that, "An on-site electric power system and an off-site electric power system shall be provided to permit functioning of structures, systems, and components important to safety."
Technical Specification Change Request (TSCR) 51 proposed, in part, deletion of the Class lE Diesel Generators based on demonstrating that many original safeguard system loads requiring emergency diesel generator backup are no longer required due to the current unique condition of TMI-2. The safety evaluation attached to TSCR 51 demonstrates that "most of the loads automatically or manually sequenced on emergency diesel generators are for components whose functions are no longer safety-related or whose continuous functioning is no longer required to maintain safe plant conditions."
Additionally, this SER demonstrates that "... all loads potentially served by the emergency diesel generators either can be interrupted safely for a length of time conservatively assumed necessary to restore off-site power or can be supplied with back-up power from the existing station batteries."
Therefore, full compliance with the requirements of GDC 17 is not necessary to achieve the underlying purpose of this rule since the required " functioning of structures, systems and components important to safety" at TMI-2 can be assured, during normal and accident conditions, through the use of the off-site power supply and the station batteries.
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ATTACHMENT 2 4410-86-L-0207 JUSTIFICATION FOR EXEWTION FROM GENERAL DESIGN CRITERION 19 General Design Criterion (GDC) 19, " Control Room," to 10 CFR 50, Appendix A requires that, "A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe shutdown condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 mrem whole body or its equivalent to any part of the body, for the duration of the accident."
The analysis presented in GPU Nuclear letter 4410-86-L-0081 dated May 20, 1986, specifically addressed this issue. This letter concluded that:
"Within its limits, the Control Room Emergency Air Cleanup System would provide protection from a TMI-2 event.
In the unlikely event that concurrent TMI-1 LOCA and TMI LOOP compromise the habitability of the Control Room, temporary evacuation could be effected since no actions would be required to be taken in the Unit 2 Control Room to maintain TMI-2 in a safe shutdown condition or to protect the health and safety of the public."
Therefore, due to the unique condition associated with TMI-2, compliance with the requirements of GDC 19 is not necessary to achieve the underlying purpose of the rule, i.e., "...to operate the nuclear power unit safely under normal conditions and to maintain it in a safe shutdown condition under accident conditions, including loss-of-coolant accidents."
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