ML20247H908

Forwards Request for Addl Info Re Severe Accident Mitigation Design Alternatives,Per Nepa.Response Requested within 30 Days of Ltr Receipt

ML20247H908
Person / Time
Site:	Limerick
Issue date:	05/23/1989
From:	Clark R Office of Nuclear Reactor Regulation
To:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-73082, NUDOCS 8905310364
Download: ML20247H908 (5)

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May 23, 1989 -

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Docket Nos. 50-352/353- DISTRIBUTION w/ enclosure 40cketJi le,, ~

RClark o Mr. George A. Hunger, Jr. NRC PDR RMartin F Director-Licensing Local PDR ETrottier Philadelphia Electric Company PDI-2 Reading GSuh L

Correspondence Control Desk SVarga 0GC P. 01 Box-7520 BBoger EJordan Philadelphia, Pennsylvania '19101 WButler BGrimes M0'Brien ACRS(10)

Dear Mr. Hunger:

3UBJECT: CONSIDERATION OF. SEVERE ACCIDENT MITIGATION DESIGN ALTERNATIVES (TACNOS.73082)

RE: LIMERICK GENERATING STATION, UNITS 1 AND 2 In an opinion issued February 28, 1989, the United States Court of Appeals for the Third Circuit granted, in part, a petition for review filed by intervenor Limerick. Ecology Action. In granting that petition, the Court ordered the NRC to give additional consideration to an intervenor contention asserting that, j in order to comply with its obligations under the National Environmental Policy L Act, the agency must consider certain design alternatives for the mitigation of severe accidents at the Limerick Generating Station. In response, the Chairman of-the Atomic Safety and Licensing Board Panel convened a Licensing Board to conduct additional proceedings relating to this contention.

l To allow preparation of an NRC staff position on this issue, we request that Philadelphia Electric Company provide the additional information described in the enclosure. Please provide this information within 30 days of receipt of this letter. This request for information is specific to one applicant and l

thus Office of Management and Budget clearance is not required under P. L.96-511.

Sincerely, Original signed by Richard J. Clark Richard J. Clark, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page

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May 23, 1989 l

Docket Nos. 50-352/353 Mr. George A. Hunger, Jr.

Director-Licensing Philadelphia Electric Company 1 Correspondence Control Desk P. O. Box 7520 Philadelphia, Pennsylvania 19101

SUBJECT:

CONSIDERATION OF SEVERE ACCIDENT MITIGATION DESIGN ALTERNATIVES (TACN05.73082)

RE: LIMERICK GENERATING STATION, UNITS 1 AND 2

, In an opinion issued February 28, 1989, the United States Court of Appeals for the Third Circuit granted, in part, a petition for review filed by intervenor Limerick Ecology Action. In granting that petition, the Court ordered the NRC to give additional consideration to an intervenor contention asserting that, ,

in order to comply with its obligations under the National Environmental Policy Act, the agency must consider certain design alternatives for the mitigation of severe accidents at the Limerick Generating Station. In response, the Chainnan of the Atomic Safety and Licensing Board Panel convened a Licensing Board to conduct additional proceedings relating to this contention.

To allow preparation of an NRC staff position on this issue, we request that Philadelphia Electric Company provide the additional information described in the enclosure. Please provide this information within 30 days of receipt of this letter. This request for information is specific to one applicant and thus Office of Management and Budget clearance is not required under P. L.96-511.

Sincerely, 2

R .. C1 rk, Project Manager P oject Dire torate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page

A Mr. George A. Hunger, Jr. Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc: .

Troy B. Conner, Jr., Esquire Mr. Ted Ullrich Conner and Wetterhahn Manager - Unit 2 Startup 1747 Pennsylvania Ave., N.W. Limerick Generating Station Washington, D. C. 20006 P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Rod Krich 57-1 Philadelphia Electric Company Mr. John Doering 2301 Market Street Superintendent-Operations Philadelphia, Pennsylvania 19101 Limerick Generating Station P. O. Box A Mr. David Honan N2-1 Sanatoga, Pennsylvania 19464 Philadelphia Electric Company 2301 Market Street Thomas Gerusky, Director Philadelphia, Pennsylvania 19101 Bureau of Radiation Protection PA Dept. of Environmental Resources Mr. Graham M. Leitch, Vice President P. O. Box 2063 Limerick Generating Station Harrisburg, Pennsylvania 17120 Post Office Box A Sanatoga, Pennsylvania 19464 Single Point of Contact P. O. Box 11880 Harrisburg, Pennsylvania 17108-1880 Mr. James Linville U.S. Nuclear Regulatory Comission Mr. Philip J. Duca Region I Superintendent-Technical 475 Allendale Road Limerick Generating Station King of Prussia, PA 19406 P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Thomas Kenny Senior Resident Inspector US Nuclear Regulatory Comission P. O. Box 596 Pottstown, Pennsylvania 19464 Mr. Joseph W. Gallagher Vice President, Nuclear Services Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Mr. John S. Kemper Senior Vice President-Nuclear Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

1 ENCLOSURE

,. REQUEST FOR ADDITIONAL INFORMATION LIMERICK GENERATING STATION. UNITS 1 AND 2 I

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1. On the ba W of PRA results to date, identify those accident sequences i that are expected to dominate the overall mean freauency projected for severe core damage and for the significant off-site risks (i.e., projected.

risks of early fatalities and person-rem). It is suggested that those-sequences that collectively contribute 905 to the overall mean frequency for severe core damage be identified as dominant and each described. For these dominant sequences, present the projected mean value for each, consideringthatthreecategories(i.e.,internalinitiations, fire initiations and earthquake initiations) will likely contribute to the overall results.

2. For the internal and fire initiated sequences, assess the potential severe accident design mitigation alternative (s), that (if put in place or installed) have a reasonable chance of reducing the projected severe core damage frequency and off-site risks.and (1) which may result in a substantial increase in the overall projection of the public health and safety, and (2) which are justified by the attendant direct and indirect costs associated with putting the alt,ernative into place. As noted, this assessment should be limited only to those internal and fire initiated sequences (exclude those sequences initiated by earthquakes over any portion of the earthquake hazard spectrum). Regarding this exclusion, it~

is the staff's opinion that the incremental severe accident risks due to the nuclear plant relative to all other risks that could potentially be presented by severe earthquakes (up to those large enough to cause the severe core damage accident) would be negligibly small, (i.e., so small l

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that the' pro.jec.ted risk reduction benefits attendant to seismic related plant improvements would represent a very remote and speculative projection given the uncertain, competing risks presented to the public off-site from the' severe earthquake itself).

3. Provide the results from (1) and (2) above. In view of the positive choice by PECO to maintain its PRA in a "living" status since the PRA became available, you may elect to use the PRA insights to enumerate and briefly discuss those various alternatives considered in the interim and/or improvements actually made to the plant design and operational procedures, that would in your judgement, serve the objectives of (2) above and have served to increase the level of public protection through either prevention and mitigation of severe accidents.

_ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _. _ _ _ _ _ . . _ _ . _ _ _ - _ _ _ _ . . . _ _ _ . . _ _ _ _ _ . . . . _ _ _ _ _ _ _ _ _ .