ML20039G621

Forwards Demonstration of Compliance to NRC Regulations - Title 10 Code of Federal Regulations (10CFR), Per NRC 800929 Request.Covers 10CFR20,50,51 & 100

ML20039G621
Person / Time
Site:	Clinton
Issue date:	01/13/1982
From:	Wuller G ILLINOIS POWER CO.
To:	John Miller Office of Nuclear Reactor Regulation
References
NUDOCS 8201180513
Download: ML20039G621 (41)

Text

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. ILLINOIS POWER COMPANY U-0349 gp 30LB

, s0 k&cauuums s252s January 13, 1982 ,- q,

@ S Mr. James R. Miller, Chief Standardization & Special Projects Branch NgG9 Il} p,*iG -

Division of Licensing -- $$Sp .A -

Office of Nuclear Reactor Regulation gg 3%t\ II U. S. Nuclear Regulatory Commission '

S Washington, D. C. 20555 '-

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Dear'Mr. Miller:

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Reference:

NRC Letter, August 29, 1980, D. G. Eisenhut to L. J. Koch, IP, Subj ect: Acceptance Review for Clinton Power Station Units 1 and 2.

Clinton Power Station Unit 1 Docket No. 50-461 Compliance to NRC Regulations This is in response to the request in the referenced letter regarding regulatory compliance. Enclosed are five (3) copies of a " Demonstration of Compliance to NRC Regulations Title 10 Code of Federal Regulations (10 CFR)", for the Clinton Power Station Unit 1. Per the request, the compliance demonstrations cover Parts 20, 50, 51 and 100 of 10 CFR.

Sincerely, G. E. Ruller Supervisor - Licensing

Nuclear Station Engineering GEW/em Enclosure cc

Mr. J. H. Williams, NRC Clinton Project Manager Mr. H. H. Livermore, NRC Resident Inspector Bo$ol II

'g-Og11e0513820113 A ADOCK 05000461 PDR

o Clinton Power Station Unit 1 Docket No. 50-461 Construction Permit No. CPPR-137 DEMONSTPa\ TION OF COMPLIANCE TO !iRC REGULATIONS TITLE 10 CODE OF FEDERAL REGULATIONS (10CFR)

Part 20 - Standards for Protection Against Radiation Part 50 - Licensing of Production and Utilization Facilities Part 51 - Licensing and Regulatory Policy and Procedures for Environmental Protection Part 100 - Reactor Site Criteria Appl icten t s :

Illinois Power Company (IP)

Soyland Power Cooperative, Inc. (Soyland)

Western Illinois Power Cooperative, Inc. (WIPCO)

Date: January 13, 1982

i l

i Compliance of Clinton Power Station Unit 1 NRC Regulations of 10 CFR Parts l 20, 50, 51, and 100 l 2

l l 10 CFR '

Regulation Compliance i

i 20.1(a) This regulation states the general purpose for '

which the Part 20 regulations are established and does not impose any specific obligations on licensees.

l 20.1(b) This regulation describes the overall purpose of l

. the Part 20 regulations to control the possession,  ;

1 use and transfer of licensed material by any  ;

licensee, such that the total dose to an individual will not exceed the standards prescribed therein. It does not impose any specific obligation on licensees.

20.1(c) Confornance to the ALARA principle stated in this regulation is ensured by the implementation of IP policies and radiation protection procedures.

.; Chapters 11 and 12 of the FSAR describe the 4

specific equipment and design features utilized in i this effort. Appropriate Technical Specifications are being written.

20.2 This regulation establishes the applicability of [

the Part 20 regulations and imposes no specific (

j obligations on those licensees to which they apply.

20.3 The definitions contained in this regulation are

adhered to in all appropriate Technical j Specifications and procedures, and in applicable j sections of the FSAR.

! 20.4 The Units of Radiation Dose specified in this regulation are accepted and conformed to in all j applicable IP procedures.

20.5 The Units of Radioactivity specified in this regulation are accepted and conformed to in all-l applicabic station procedures.

i 20.6 This regulation governs the interpretation of

regulations by the NRC and does not impose

obligations on the licensee.

20.7 This regulation gives the address of the NRC and does not impose obligations on licensees.

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10 CFR Regulation Compliance 20.101 The radiation dose limits specified in this regulation are complied with through the implementation of and adherence to administrative policies and controls and appropriate radiation protection procedures developed for this purpose.

Conformance is documented by the use of appropriate personnel monitoring devices and the maintenance of all required records.

20.102 When required by this regulation, the accumulated dose for any individual permitted to exceed the exposure limits specified in 20.101(a) is determined by the use of Form NRC-4. Appropriate radiation protection procedures and administrative policies control this process.

20.103(a) Compliance with this regulation is ensured through the implementation of appropriate radiation protection procedures relating to air sampling and monitoring for radioactive materials, and bioassay of individuals for internal contamination.

Administrative policies and controls provide adequate margins of safety for the protection of individuals against intake of radioactive materials. The systems and equipment described in Chapters 11 and 12 of the FSAR provide the capability to minimize these hazards.

20.103(b) Appropriate process and engineering controls and equipment, as described in Chapters 9, 11 and 12 of the FSAR, are installed and operated to maintain levels of airborne radioactivity as low as practicable. When necessary, as determined by IP administrative guidelines, additional precautionary procedures are utilized to limit the potential for intake of radioactive materials.

20.103(c) The station Respiratory Protection Manual implements the requirements of this regulation by ensuring the proper use of approved respiratory protection equipment. The IP Respiratory Protection Manual incorporates fully the stipulations of Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection".

20.103(d) This regulation describes further restrictions which the Commission may impose on licensees. It does not impose any obligations on licensees.

10 CFR Regulation Compliance 20.103(e) The notification specified by this regulation will be i

made as required.

1 20.103(f) The Respiratory Protection Program is in full conformance with the requirements of 20.103(c).

20.104 Conformance with this regulation is assured by Chapters 11 and 12 of the FSAR (see also subsection 14.2.12.2.2.4 and Tables 15A.2-1 and 15A.2-2) and the Radiation Protection Manual which allows individuals under 18 years of age into station radiological areas only with permission of the Power Plant Manager and in strict adherence to the applicable sections of this regulation.

20.105(a) Chapters 11 & 12 of the FSAR provides the information i and related radiation dose assessments specified by this regulation.

20.105(b) The radiation dose rate limits specified in this regulation will be complied with through the implementation of station procedures, Technical Specifications, and administrative policies which control the use and transfer of radioactive materials. Appropriate surveys and monitoring devices assure this compliance. (See Chapter 12 of the FSAR.).

20.106(a) Conformance with the limits specified in this regulation is assured through the implementation of i

station procedures and applicable Technical Specifications which provide adequate sampling and analyses, and monitoring of radioactive materials in effluents prior to and during their release. The level of radioactivity in station effluents is minimized to the extent practicable by the use of appropriate equipment designed for this purpose as described in Chapter 11 of the FSAR.

20.106(b) IP has not and does not currently intend to include (c) in any license or amendment applications proposed limits higher than those specified in 20.106(a), as provided for in these regulations.

j. 20.106(d) Appropriate allowances for dilution and dispersion of radioactive effluents are made in conformance with this regulation, and are described in detail in Chapter 11 of the FSAR, and will appear in appropriate reports required by the Technical Specifications.

0 10 CFR Regulation Compliance

! 20.106(e) This regulation provides criteria by which the-Commission may impose further limitations on releases of rcdioactive materials made by a licensee. It imposes no obligations on licensees.

20.106(f) This regulation states that the provisions of 20.106 do not apply to disposal of radioactive material into sanitary sewerage systems. It imposes no obligations on licensees.

20.107 This regulation clarifies that the Part 20 regulations are not intended to apply to the

! intentional exposure of patients to radiation for the I

purpose of medical diagnosis or therapy. It does not impose any obligations on licensees.

20.108 Necessary bioassay equipment and procedures, including whole body counting, are utilized at the station to determine exposure of individuals to concentrations of radioactive materials. Appropriate radiation protection procedures and administrative policies implement this requirement.

l 20.201 The surveys required by this regulation are performed l at adequate frequencies and contain such detail as to be consistent with the radiation hazard being i evaluated. When necessary, the Radiation Work Permit system established at the station provides for l detailed physical surveys of equipment, structures and work sites to determine appropriate levels of radiation protection. The station Radiation Protection Manual and applicabic radiation protection procedures require these surveys and provide for their documentation in such manner as to ensure compliance with the regulations of 10 CFR Part 20.

20.202(a) The station Radiation Protection Manual and applicable radiation protection procedures set forth policies and practices which ensure that all individuals are supplied with, and required to use, appropriate personnel monitoring equipment. The Radiation Work Permit system is established to provide additional control of personnel working in radiation areas and to ensure that the level of protection afforded to these individuals is consistent with the radiological hazards in the work place.

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10 CFR Regulation Compliance 20.202(b) The terninology set forth in this regulation is accepted and will be conformed to in all applicable

station procedures, Technical Specifications, and those portions of the station Radiation Protection Manual in which its use is made.

20.203(a) All materials used for labeling, posting, or o therwise designating radiation hazards or radioactive materials, and using the radiation symbol, conform to the conventional design prescribed in this regulation.

20.203(b) This regulation is conformed to through the implementation of appropriate radiation protection

{ procedures and portions of the Radiation Protection

, Manual relating to posting of radiation areas, as j defined in 10 CFR Part 20.202(b)(2).

20.203(c) The requirements of this regulation for "High Radiation Areas" will be conformed to by the implementation of appropriate Technical Specifications and radiation protection procedures, as well as the station Radiation Protection Manual.

The controls and other protective measures set forth in the regulation are maintained under the surveillance of the station Radiation Protection group. FSAR Subsections 12.3.1.1 and 12.5.3.3 outline access control methods to be applied for i prevention of unauthorized entry into a high

radiation area.

20.203(d) Each Airborne Radioactivity Area, as defined in this regulation, is required to be posted by provisions of the Radiation Protection Manual and appropriate radiation protection procedures. These procedures also provide for the surveillance requirements

. necessary to determine airborne radioactivity levels, 20.203(e) The area and room posting requirements set forth in this regulation pertaining to radioactive materials are complied with through the implementation of appropriate radiatica protection procedures, and portions of the station Radiation Protection Manual.

20.203(f) The container labeling requirements set forth in this regulation are complied with through the implementation of appropriate radiation protection procedures, and portions of the station Radiation Protection Manual.

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10 CFR Regulation Compliance 20.204 The posting requirements exceptions Jescribed in this regulation are used where appropriate and necessary at the station. Adequate controls are provided within the station radiation protection procedures to ensure safe and proper application of these exceptions.

20.205 All of the requirements of this regulation pertaining to procedures for picking up, receiving, and opening l packages of radioactive materials are implemented by the station Radiation Protection Manual and appropriate radiation protection procedures. These procedures also provide for the necessary documentation to ensure an auditable record of compliance.

20.206 The requirements of 10 CFR 19.12 referred to by this regulation are satisfied by the General Employee Training Program conducted at the station.

Appropriate radiation protection procedures set forth requirements for all radiation workers to receive this instruction on a periodic basis.

20.207 The storage and control requirements for licensed materials in unrestricted areas are conformed to and documented through the implementation of station radiation protection procedures and applicable portions of the station Radiation Protection Manual.

20.301 The general requirements for waste disposal set forth in this regulation will be complied with through the station special nucleer materials program, the Technical Specifications, and the provisions of the Radiation Protection Manual. Chapter 11 of the FSAR describes the Solid Waste Disposal System installed at the station.

20.302 No such application for proposed disposal procedures, as described in this regulation, has been made or is currently contemplated by IP.

20.303 No plans for waste disposal by release into sanitary sewerage systems, as provided for in this regulation, are currently utilized or contemplated by the station.

20.305 Specific authorization, as described in this regulation, is not currently being sought by IP for treatment or disposal of wastes by incineration.

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10 CFR Regulation Compliance 20.306 IP does not plan to dispose of licensed material without regard to its radioactivity.

20.401 All of the requirements of this regulation are complied with through the implementation of appropriate Technical Specifications and radiation protection procedures pertaining to records of surveys, radiation monitoring and waste disposal.

The retention periods specified for such records are l also provided for in these specifications and procedures.

i 20.402 The station has established an appropriate inventory and control program in the Radiation Protection t

Manual to ensure strict accountability for all i licensed radioactive materials. Reports of theft or loss of licensed material will be made as required by the regulations.

20.403 Notifications of incidents, as described in this

regulation, are assured by the station Radiation Protcetion Manual and appropriate radiation protection procedures (which also provide for the necessary assessments to determine the occurrence of such incidents), and will also be required in the Technical Specifications.

20.405 Reports of overexposures to radi ation and the occurrence of excessive levels and concentrations, as required by this regulation, will be provided for by reference in the Technical Specifications and in appropriate radiation protection procedures.

20.407 The personnel monitoring report required by this regulation will be expressly provided for by the Technical Specifications. Appropriate health ohysics procedures will establish the data base from which this report is generated.

i 20.408 The report of radiation exposure required by this regulation, upon termination of an individual's emplovment or work assignment, will be generated thrnugh IP procedures.

20.409 The notification and reporting requirencnts of this regulation, and those referred to by it, are s

satisfied by the provisions of a station radiation 4

protection procedure.

10 CFR Regulation Compliance 20.501 This regulation provides for the granting of exemptions from 10 CFR Part 20 regulations, provided such exemptions are authorized by law and will not result in undue hazard t o life or property. It does not impose specific obligations on licensees.

20.502 This regulation describes the means by which the Commission may impose upon any licensee requirements which are in addition to the regulations of Part 20.

It does not impose specific obligations on licensees.

20.601 This regulation describes the remedies which the Commission may obtain in order to enforce its regulations, and sets forth those penalties or punishments which may be imposed for violations of its rules. It does not impose any obligatioas en licensees.

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10 CFR Regulation Complianc_e 50.1 This regulation merely states the purpose of the Part 50 regulations and does not impose any obligations on licensees.

50.2. This regulation defines various terns and does not impose obligations on licensees.

50.3 This regulation governs the interpretation of the regulations by the NRC and does not impose obligations on licensees.

50.4 This regulation gives the address of the NRC and does not impose obligations on licensees.

50.10 These regulations specify the types of activities 50.11 that may not be undertaken without a license from the NRC. IP does not propose to conduct any such activities at Clinton 1 without an NRC license.

50.12 This regulation provides for the granting of exemptions from 10 CFR Part 50 regulations, provided such exemptions are authorized by law and will not endanger life or prnperty or the common defense and security and are otherwise in the public interest.

It does not impose obligations on licensees.

50.13 This regulation says that a license applicant need not design against acts of war. It imposes no obligations on licenses.

i 50.20 These regulations describe the types of licenses that 50.21 the NRC issues. They do not address the substantive 50.22 requirenents that an applicant must satisfy to

50.23 qualify for such licenses.

a' 50.30 This regulation sets down procedural requirements for the filing of license applications, such as the number of copies of the application that must be provided the NRC. IP has substantially complied with the procedural requirements in effect at the time when filing its license application and the amendments to it. In particular, 10 CFR 50.30(f) requires that a license application must be accompanied by an Environmental Report required pursuant to 10 CFR Part 51, and IP has submitted an Environmental Report for the Clinton Power Station.

50.31 These regulations permit more efficient organization 50.32 of the license application and impose no obligations on licensees.

10 CFR Regulation Compliance 50.33 This regulation requires the license application to contain certain general information, such as an identification of the applicant, information about the applicant's financial qualifications, and a list of regulatory agencies with jurisdiction over the applicant's rates and services. This information is provided in IP operating license application for the Clintou Power Station.

50.33(a) This regulation requires applicants for construction permits to submit information required for antitrust review. The antitrust review required under Section 105c of the Atomic Energy Act of 1954, as amended, was performed at the construction permit stage.

Additionally, IP provided information for antitrust review of operating license application per Regulatory Guide 9.3 on May 23, 1980.

50.34(a) This regalation governs the contents of the Prelinf. nary Safety Analysis Report and is relevant to the construction permit stage rather than the operating Ilconse stage.

50.34(b) A Final Safety Analysis Report (FSAR) was submitted, and addresses in the chapters indicated the information required:

1. Site evaluation factors - Chapter 2.

2. Structures, systems and components - Chapters 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, and 15.

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3. Radioactive effluents and radiation protection Chapters 11 and 12.

4. Design and performance evaluation - ECCS performance is discussed and shown to meet the requirements of 10 CFR 50.46 in Chapters 6 and 15.

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5. Results of research programs - Chapter 1.

6. i. Organizational structure - Chapter 13.

t ii. Managerial and administrative controls -

j Chapters 13 and 17. Chapter 17 discusses compliance with the quality assurance requirements of Appendix B.

1

10 CFR Regulatioit Compliance 50.34(b) iii. Plans for preoperational testing and cont'd. initial operations - Chapter 14.

iv. Plans for conduct of normal operations -

Chapter 13 and 17. Surveillance and periodic testing will be specified in the Technical Specifications.

v. Plans for coping with emergencies -

Emergency Plan (Chapter 13 - Appendix 13.B).

vi. Technical Specifications - (Chapter 16).

vii. This requirement for potential hazards evaluation for a multi-unit site is not presently applicable as the OL review is for Clinton Power Station Unit 1 only.

7. Technical qualifications - Chapter 13.

8. Operator requalification program - the program is described in Subsection 13.2.2.1 of the FSAR and complies with the requirements of 10 CFR 55, Appendix A and NUREG-0737.

50.34(c) A Physical Security Plan was submitted to NRR by IP letter of December 1, 1979. This plan and subsequent i

supplements describe compliance to this regulation

, and 10 CFR Part 73.

50.34(d) A Safeguards Contingency Plan is included as Appendix A to the Physical Security Plan.

50.34a(a) Design bases and system descriptions for liquid and gaseous radioactive management systems are contained in FSAR Sections 11.2 and 11.3. The design objectives and program for keeping radioactive levels "as low as reasonable achievable" are described in FSAR Section 12.1.

50.34a(b)(1) Design considerations for equipment in the liquid and gaseous radioactive effluent management systems are described in FSAR Sections 11.2 and 11.3.

50.34a(b)(2) Procedures and quantities for liquid and gaseous radioactive effluent releases are contained in Subsections 11.2.3 and 11.3.3 of the FSAR. Tables 11.2-1 and 11.3-9 show calculated annual releases of nuclides in liquid and gaseous effluents.

10 CFR Regulation Compliance 50.34a(b)(3) The management system for packaging, storage and shipment offsite of solid waste containing radioactive material is contained in Section 11.4 of the FSAR.

50.34(c) A general description of equipment to be used for control of gaseous and liquid effluents and the quantities of radioactive to be released are contained in Sections 11.2 and 11.3 of the FSAR.

50.35 This regulation is relevant to the construction permit stage rather than the operating stage.

50.36 Technical Specifications are in preparation and will include items in each of the specified categories, safety linits and limiting safety settings, limiting conditions for operation, surveillance requirements, design features, and administrative controls.

50.36a Environmental Technical Specifications will include specifications which require compliance with 10 CFR 50.34a (releases as low as is reasonably achievable),

and that ensure that concentrations of radioactive effluents released to unrestricted areas are within the limits specified in 10 CFR 20.106. The reporting requirements of 10 CFR 50.36a(a)(2) will also be included in these specifications.

50.37 This regulation requires the applicant to agree to limit access to Restricted Data. IP's agreement to do so is in the operating license application for the Clinton Power Station.

50.38 This regulation prohibits the NRC from issuing a license to foreign-controlled entities. IP's statement that it is not owned, controlled, or dominated by an alien, foreign corporation, or foreign government is in the operating license application for the Clinton Power Station.

50.39 This regulation provides that applications and related documents may be made available for public inspection. This imposes no direct obligations on applicants and licensees.

50.40 This regulation provides considerations to " guide" the Commission, in granting licenses and imposes no obligation on the licensee.

10 CFR Regulation Compliance 50.41 This regulation applies to class 104 licensees, such as those for devices used in medical therapy. IP has not applied for a class 104 license, and so 50.41 is not applicable.

50.42 Section 50.42 provides additional " considerations" to

" guide" the Commission in issuing Class 103 licenses.

The two considerations are (a) that the proposed activities will serve a useful purpose proportionate to the quantities of special nuclear material or source material to be utilized and (b) that due account will be taken of the anti-trust advice provided by the Attorney General under Subsection 105c of the Atomic Energy Act.

The "useful purpose" to be served is the production of electric power. The need for the power was determined by the licensing board at the construction permit stage.

The anti-trust review was done at the construction permit stage.

50.43 The regulation imposes certain duties on the NRC and addresses the applicability of the Federal Power Act and the right of government agencies to obtain NRC licenses. It imposes no direct obligations on licensees.

50.44 The Clinton Power Station hydrogen monitoring and combustible gas control systems are described in FSAR Subsections 7.3.1.1.7 and 6.2.5. These systems are designed to maintain hydrogen concentration in containment at safe levels following a LOCA with release levels specified in this regulation.

The combustible gas control system is completely redundant, consisting of two hydrogen analyzers, two mixing systems and two hydrogen recombiners.

IP has also committed to install a hydrogen ignitor system in the Clinton 1 containment.

As a backup means of control, containment atmosphere can be purged through the standby gas treatment system or the drywell purge system.

10 CFR Regulation Compliance 50.44 Subsection 6.2.5.2.1 of the FSAR indicates that the cont'd. recombiners can be placed into caeration in sufficient time to maintain the aydrogen concentration following a LOCA at a level below the 4 percent lower hydrogen flammability limit.

In accordance with 50.44(d)(2), the hydrogen contribution of the core metal-water reaction is assumed to be that resulting from reaction of 5 percent of the fuel cladding. Core metal-water reaction calculated in accordance with 50.46 does not exceed 1% of the total amount of zircaloy in the reactor. Consequently, the requirements of 50.44 are satisfied.

Subsection 6.3.3.7.8.2 of the FSAR establishes compliance with the limits of 10 CFR 50.46 and the maximum hydrogen generation is less than 0.17%, well below the 1% limit.

Subsection 6.3.3.8 of the FSAR establishes compliance with applicable acceptance criteria and 10 CFR 50.46 and concludes that the ECCS will perform its function in an acceptable nanner, given operation at or below the maximum average planar linear heat generation rates in FSAR Table 6.3-6.

50.45 This regulation provides standards for construction permits rather than operating licenses and is therefore not material to this operating' license review.

50.46 FSAR Section 6.3 describes the ECCS and Section 15.6.5 provides an evaluation of LOCA's resulting from the spectrum of postulated piping breaks within the coolant pressure boundary, including steam lines inside the containment.

Compliance with 10 CFR 50 Appendix K is shown in a Supplement to Safe Code Description, transmitted to U. S. NRC by letter, G. L. Gyorey to Victor Stello, Jr., dated December 20, 1974, entitled " General Electric Refill Reflood Calculation," and NEDO-20566 submitted August, 1974, " General Electric Company Analytical Model for Loss-of-Coolant Analysis in Accordance with 10 CFR 50, Appendix K," now amended through Amendment 7, June 1978.

10 CFR Regulation Compliance 50.46 The above sections provide the res'ults of LOCA-ECCS cont'd. analysis for Clinton Power Station using NRC approved evaluation model which is in compliance with Appendix K to 10 CFR 50.

Technical Specifications will account for any standards (relevant to BWR's) that are proposed in NUREG-0630.

50.47 Appendix 13B to the FSAR shows compliance with this regulation and NUREG-0654. Operating procedures, which will be submitted as required prior to fuel loading, will reflect the commitments-contained in Appendix 13B.

50.48 A Fire Protection Evaluation Report for Clinton Power Station was submitted to NRC on April 12, 1978. It forms the basis of initial compliance to fire protection requirements. IP complies with the guidelines of Appendix R, with exceptions as given in the response to FSAR Question 410.7.

50.50 This regulation provides that the NRC will issue a license upon determining that the application meets the standards and requirements of the Atomic Energy Act and the regulations and that the necessary notifications to other agencies or bodies have been duly made. It imposes no direct obligations on licensees.

50.51 This regulation specifies the maximum duration of licenses. Compliance will be by adherence to the license conditions.

50.52 This regulation provides for the combining in a i

single license of a number of activities. It imposes no obligation on the licensee.

50.53 This regulation provides that licenses are not to be issued for activities that are not under or within the jurisdiction of the United States. The operation i

of Clinton Power Station will be within the United States and subject to the jurisdiction of the United States, as is evident from the description of the tacility in the operating license application.

50.54 This regulation specifies certain conditions that are incorporated in every license issued. Compliance is achieved by adherence to the license conditions.

l 10 CFR Regulation Compliance 50.54 Much of 50.54 provides that other provisions of the cont'd. law apply. FSAR Subsection 13.5.1.3 references procedural compliances to this regulation.

50.55 This regulation addresses conditions of construction permits, not operating licenses, and so it is not relevant for OL review.

50.55a(a)(1) Various Chapters of the FSAR discuss desigr.,

fabrication, erection, construction, testing, and inspection of safety related equipment. For example, Chapter 14 provides information on testing of safety related systems. Chapter 17 provides information concerning the Quality Assurance Program. As a further examp"le of a specific system, Chapter 5, Section 5.2, Integrity of the Reactor Coolant System Boundary", discusses the design of the reactor coolant system. FSAR Subsection 5.2.1.1 establishes compliance with 10 CFR 50.55a.

50.551(a)(2) This paragraph is a general paragraph leading into paragraphs (c) through (i) of the regulation.

50.55a(b)(1) These paragraphs provide guidance concerning the 50.551(b)(2) approved Edition and Addenda of Sections III and XI i of the ASME B&PV Code.

50.55a(c) Design and fabrication of the reactor vessel was

carried out in accordance with ASME Sections III and l IX, 1971 edition, summer 1973 addenda of the ASME Boiler and Pressure vessel Code, Class 1.

l Information can be found in Subsection 5.3 l

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50.55a(d) Reactor coolant system piping meets the requirements l

of ASME Sec. III 1974 Edition, Summer 1975 Addenda.

l Information can be found in Chapter 5, Subsection 5.4.3 and Subsections 3.9.3.1.2 and 3.9.3.1.4 of the FSAR.

50.55a(e) Reactor Coolant pumps meet the requirements of ASME III 1971 Edition, Winter 1973 Addenda, Class 1.

Information can be found in Chapter 5, of the FSAR.

1 50.55a(f) Based upon the construction permit date of Feb. 24, 1976, the valves within the Reactor Coolant System pressure boundary were ordered and supplied in accordance with the requirements of ASME Sec. III 1

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10 CPR Regulation Compliance 50.55a(f) 1971 Edition, Winter 1973 Addenda for gate valves, cont'd. and 1974 Edition, Summer 1974 Addenda ior flow control valves.

f 59.55a(g) Inservice Inspection (ISI) requirements are delineated in this part and will be outlined in the Technical Specifications. FSAR Subsection 3.9.6 states: Inservice testing of ASME Code Classes 1, 2, and 3 pumps and valves will be performed to ensure operational and functional readiness throughout their service life. The applicable edition and addenda of the Code will be as required by 10 CFR 50.55a paragraph (g), pursuant to relief granted by 10 CFR 50.35a paragraph (g) (6) (1).

The inservice inspection program will be submitted prior to license issuance, delineating the pumps and valves to be tested in accordance with the requirements of 10 CFR 50.55a paragraph (g), and specifying the Edition Addenda of the Code to be followed.

50.55a(h) As discussed in FSAR Chapter 7, the protection systems neet IEEE 279-1971 requirements.

50.55a(i) Fracture toughness requirements are set forth in Appendices G and H of 10 CFR 50. Technical Specifications will be written accordingly.

Information relative to the irradiation surveillance program is given in FSAR Subsection 5.3.1.5.

50.55a(j ) Since our construction permit was not issued prior to December 31, 1970 this regulation does not apply to Clinton Power Station.

50.56 This regulation provides that the commission will. in the absence of good cause shown to the contrary, issue an operating license upon completion of the construction of a facility in compliance with the terns and conditions of the construction permit. It imposes no obligations on the applicant.

50.57(a) This regulation requires the Commission to make certain findings prior to the issuance of an operating license.

50.57(b) The operating license, when issued, will contain appropriate conditions to assure that items of construction or modification are completed on a schedule acceptable to the Commission.

10 CFR Regulation Compliance 50.57(c) This regulation allows for requesting of a low-power testing license. At an appropriate time, IP may make a motion under the provisions of this regulation.

50.58 This regulation provides for the review and report of the Advisory Committee on Reactor Safeguards. It imposes no obligations on the applicant.

50.59 This regulation provides for changes to the facility and safety related procedures, and the conduct of certain tests or experiments. All such tests or changes are controlled by plant operating and design control procedures, and reviewed by an independent off-site review group. The functions of this group are described in FSAR Subsection 13.4.2. Records of all changes to facility and tests / experiments conducted will be retained, and appropriate safety evaluations will be submitted, as required by this regulation. Any proposed changes, tests or experiments involving unreviewed safety questions, or changes to technical specifications shall be submitted as an application for license amendment prior to implementation.

50.70 The Commission has assigned a resident inspector to the CPS. IP has provided office soace in a~ccordance with the requirements of this section. IP permits access to the station by NRC inspectors in accordance with 10 CFR 50.70(b)(3).

50.71 Records are and will be maintained in accordance with the requirements of sections (a) through (e) of this regulation and the license; including an FSAR update 24 months after licensing, and periodic revisions thereafter.

50.72 Notification of significant events to the NRC will be nade in accordance with the reauirements in this regulation and the Technical Specifications.

50.78 If CPS is identified under the US/IAEA Safeguards agreement, we shall comply with this regulation-50.80 This regulation provides that licenses may not be transferred witbout NRC Consent. IP has no intention to request license transfer.

50.81 This regulation permits the creation of mortgages, pledges, and liens on licensed facilities, subject to certain provisions. The regulation prohibits secured

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10 CFR Regulation Compliance 50.81 creditors from violating the Atomic Energy Act and cont'd. the Commission's regulations. To the best of our knowledge, none of IP's creditors has attempted to violate the applicable provisions of law.

50.82 This regulation does not apply to CPS because we have not requested the termination of a license.

50.90 This regulation governs applications for amendments to licenses. Future requests for license amendments will be made in accordance with these requirements.

50.91 This regulation provides guidance to the NRC in issuing license amendments.

50.100 These regulations govern the revocation, suspension, 50.101 and modification of licenses by the Commission under 50.102 unusual circumstances.

50.103 50.109 This regulation specifies the conditions under which the NRC may require the back-fitting of a facility.

This regulation imposes no obligations on a licensee unless the NRC proposes a back-fitting requirement.

50.110 This regulation governs enforcement of the Atomic Energy Act, the Energy Reorganization Act of 1974, and the NRC's regulations and orders. No enforcement action is at issue in the Clinton Power Station review.

Part 50 Appendix A General Design Criteria (GDC)

GDC 1 Ouality 5tandards and Records Section 1.2 of the FSAR describes the principal design criteria. FSAR Subsection 3.1.2.1.1 describes the provisions made to ensure that these requirements are met. Structures, systems, and components important to safety are listed in Table 3.2-1, and the quality assurance program and provision for record maintenance is applied to these items as described in Chapter 17. Also see FSAR Subsections 7.1.2.7.1 and 7.2.2.1.2.2.1. Safety-related equipment qualification is described in FSAR Section 3.11. FSAR Section 1.8 provides conformance to NRC Regulatory Guides and IEEE Standards.

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i 10 CFR Regulation Compliance GDC 2 Design Bases for Protection against Natural Phenomena l

All systems required for safety have been designed to withstand the effects of natural phenomena without loss of capacity to perform their safety function.

FSAR Subsection 3.1.2.1.2 addresses the design considerations for natural pheomena, which are described in detail in Chapters 2 and 3. Appropriate considerations have been made in the design basis for historical data, combined effects of normal and accident conditions with the effects of natural phenomena, and the importance of the safety functions to be performed.

GDC 3 Fire Protection FSAR Subsection 3.1.2.1.3 describes in general the measures which have been taken to minimize the probability and effects of fires and explosions.

Section 9.5.1 describes the fire detection and protection systems. CPS complies with NRC requirements based on Appendix A to BTP APCSB 9.5-1 as described in the Fire Protection Evaluation Report submitted to the NRC on April 12, 1978. CPS complies with the guidelines of Appendix R, with exceptions given in the response to FSAR Question 410.7.

GDC 4 Environmental and Missile Design Bases FSAR Section 3.1.2.1.4 describes the design features used to accommodate the effects of and be compatible with the environmental conditions associated with all modes of operation and postulated accidents. Chapter 3 provides information concerning the specific design features for protection against missiles , j et impingenent and pipe rupture.

FSAR Section 3.11 describes the environmental qualification of safety-related electrical equipment.

IP has committed to meet the environmental equipment qualification requirements of NUREG-0588.

GDC 5 Sharing of Structures, Systems, and Components FSAR Subsections 1.2.2 and 3.1.2.1.5 describe those structures, systems and components which are shared between the two units. Safety functions are not significantly impaired by such sharing.

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v 10 CFR Regulation Compliance GDC 10 Reactor Design FSAR Subsection 3.1.2.2.1 shows that the reactor core and associated systems are designed to function throughout the design lifetime without exceeding fuel damage limits, using protection criteria as specified in Subsections 3.1.2.2.1, 1.2, 4.2, 4.3, 4.4 and 5.4.

CDC 11 Reactor Inherent Protection FSAR Subsection 3.1.2.2. indicates that p'rompt compensatory reactivity feedback effects are assured by unit design and operational limit considerations.

The core inherent reactivity feedback characteristics and reactivity control methods are described in FSAR Chapter 4.

GDC 12 Suppression of Reactor Power Oscillations FSAR Subsection 3.1.2.2.3 describes the inherent and design features which eliminate or limit the various types of oscillations. Core stability is further described in Subsection 4.3.4 of the FSAR.

GDC 13 Instrumentation and Control As indicated in FSAR Subsection 3.1.2.2.4 and described in more detail in Chapter 7, instrumentation and control systems have been provided to monitor and maintain plant variables including those variables which affect the fission process, integrity of the reactor core, the reactor coolant pressure boundary, and the containment, over their prescribed ranges for normal operation, anticipated occurrences, and under accident conditions.

GDC 14 Reactor Coolant Pressure Boundary FSAR Subsection 3.1.2.2.5 indicates that the reactor coolant pressure boundary has been designed to acconmodate the system temperatures and pressures attained under all expected operational modes and anticipated transients, and to maintain stresses within applicable limits. Reactor coolant pressure boundary integrity is discussed in detail in FSAR Section 5.2.

10 CFR Regulation Compliance GDC 15 Reactor Coolant System Design As indicated in FSAR Subsection 3.1.2.2.6, the reactor coolant system and associated auxiliary, control and protection systems are designed to ensurc the integrity of the reactor coolant pressure boundary with adequate margins during normal operations and anticipated transients. The design codes used for the Reactor Coolant System are described in Chapter 5. Details concerning the protection systems are provided in Subsection 7.2.2.

GDC 16 Containment Design As described in FSAR Subsection 3.1.2.2.7 and Sections 3.8 and 6.2, a reinforced concrete, steel-lined containment Mark III structure is provided. It is designed to sustain, without loss of required integrity, all effects of gross equipment failures, up to and including the rupture of the largest pipe in the reactor coolant system. The containment and its associated engineered safety features thus meet the required functional capability of these criteria.

GDC 17 Electric Power Systems As described in FSAR Subsection 3.1.2.2.8, onsite and offsite power systems are provided which can independently supply the electric power required for the operation of safety-related systems. This capability is maintained even with the failure of any single active component in either system. Chapter 8 provides the design details of the power systems and their compliance with this criterion.

GDC 18 Inspection and Testing of Electric Power Systems As described in FSAR Subsection 3.1.2.2.9 and Chapters 7 and 8, the redundant electric power systems important to safety are continuously monitored and energized during normal plant operation from redundant offsite power sources. Redundant onsite diesel generators provide automatic backup power sources. Periodic tests of the diesel generators, the transfer system, and the station batteries will be made as required by Technical Specifications.

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10 CFR Regulation Compliance GDC 19 Control Room FSAR Subsection 3.1.2.2.10 describes the Main Control Room, which concains the controls and instrumentation necessary for safe operation of the unit during normal and accident conditions. Safety Related Display Instrumentation is described in detail in FSAR Section 7.5 Sufficient shielding, distance, structural integrity, and ventilation systems are provided to ensure that control roon personnel will not receive radiation exposures in excess of the criterion for the duration of the accident as described Sections 6.4, 9.4 and 12.3. The remote shutdown system as described in Section 7.4.14 provides a means to carry out the reactor shutdown functions from outside the main control room and bring the reactor to cold shutdown conditions in a safe and orderly fashion, via a remote shutdown panel within the protected envelope.

GDC 20 Protection System Functions FSAR Subsections 1.2 and 3.1.2.3 discuss the design criteria for the protection system and engineered safety features actuation, to ensure that the requirements of this criterion are met. Further details are supplied in Sections 4.6, 5.2, 5.4, 6.3, 7.2, 7.3, 7.6, and 15.

GDC 21 Protection System Reliability and Testability As indicated in FSAR Subsections 1.2 anc 3.1.2.3.2, the protection system is designed for the high functional reliability and inservice testability connensurate with the safety functions to be perforned. FSAR Subsections 4.6, 5.4.5, 5.4.7, 6.2, 6.3, 7.2, 7.3, and 15, describe in detail the design features provided to ensure redundancy and testability.

GDC 22 Protection System Independence As stated in FSAR Subsection 3.1.2.3.3, the design of the protection system assures that the effects of natural phenomena, normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in loss of the protection function. The RPS functions incorporate redundant instrument channels with 2 out of 4 logic systens. Bypass of these channels for maintenance, i

10 CFR Regulation Compliance GDC 22 testing, or troubleshooting results in 2 out of 3 cont'd. logic conditions. Diversity is incorporated in the RPS design by utilizing multiple parameter inputs.

Other station protection systems incorporate redundancy and diversity appropriate to the functions performed by that system and with deference to separation and other applicable criteria. Chapter 7 provides further design details.

GDC 23 Protection System Failure Modes As indicated in FSAR Subsection 3.1.2.3.4, if conditions such as disconnection of the system, extreme heat or cold, fire, pressure, steam, water, radiation, etc., are experienced, the protection system is designed to fail into a safe state.

Details are supplied in Chapter 7.

GDC 24 Separation of Protection and Control Systems As FSAR Subsection 3.1.2.3.5 indicates, there is separation between the reactor protection system and the process control systems. Failure or removal from service of any single control system component or channel conmon to the two systems leaves intact a system satisfying all reliability, redundancy, and independence requirements of the protection system.

Chapter 7 gives details concerning interconnection.

GDC 25 Protection System Requirements for Reactivity Control Malfunctions The design of the protection system assures that

, specified acceptable fuel limits are not exceeded for any single nalfunction of the reactivity control systems as specified in FSAR Subsection 3.1.2.3.6.

See also Chapter 7.

GDC 26 Reactivity Control System Redundancy and Capability As indicated in FSAR Section 3.1.2.3.7, two independent reactivity control systems of different design principles are provided. One of the systems uses control rod assemblies containing boron carbide powder; the second is provided by the reactor coolant recirculation system and reactor flow control.

Reactivity control cystem redundancy and capability are described further in FSAR Section 4.3 and Chapter 7.

10 CFR Regulation Compliance CDC 27 Combined Reactivity Control Systems Capability There is no credible event applicable to the BWR which requires combined capability of the control rod system and poison additions by the emergency core cooling network. In the very unlikelv event that more than one control rod fails to in' sert, and the core cannot be maintained suberitical by control rods alone, the standby liquid control system would be used to insert soluble boron into the core. See FSAR Subsections 3.1.2.3.8 and 9.3.5.3.1, or general design criteria in FSAR Section 1.2.

GDC 28 Reactivity Limite FSAR Subsection 3.1.2.3.9 explains that the control rod mechanical design incorporates a hydraulic velocity limiter in the control rod which prevents rapid rod ejection. The accident analysis in FSAR Chapter 15 shows that none of the postulated reactivity transients or accidents result in damage to the reactor coolant pressure boundary, and that the integrity of the core and its support structures or other reactor pressure vessel internals are maintained. See also Chapter 5 and Section 4.3 of the FSAR.

GDC 29 Protection against Anticipated Operational Occurrences As indicated in FSAR Subsection 3.1.2.3.10, the protection and reactivity control systens are designed to assure extremely high probability of performing their required safety functions in the event of anticipated operational occurrences. The protection system is further discussed in FSAR Section 7.2. The reactivity control systems are discussed in FSAR Section 4.3.

GDC 30 Quality of Reactor Coolant Pressure Boundary As described in FSAR Section 3.1.2.4.1, reactor coolant pressure boundary components are designed, fabricated, inspected and tested in conformance with recogniaed industry codes and standards listed in FSAR Chapter 5 and Table 3.2-1. Major components are classified as seismic category 1 and are accorded the quality measures appropriate to this classification.

The evaluations of reactor coolant pressure boundary components are discussed in FSAR Section 5.2.

10 CFR 4

Regulation Compliance ,

GDC 31 Fracture Prevention of Reactor Coolant Pressure Boundarv As indicated in FSAR Subsections 3.1.2.4.2, and Sections 5.2 and 5.3 close control is maintained over material selection and fabrication for the Reactor Coolant System to assure that the boundary behaves in a nonbrittle manner. The materials testing is i

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consistent with 10 CFR 50, Appendices G and H and 10 CFR 50.55a. These tests ensure the selection of materials with proper toughness properties and margins as well as verify the integrity of the reactor coolant pressure boundary. Since primary systen pressure is developed by heating of the primary system, operation within the pressure temperature linitation relative to this criteria is assured, i GDC 32 Inspection of Reactor Coolant Pressure Boundary FSAR Subsection 3.1.2.4.3 describes how the design of the reactor vessel and its arrangement in the system provides the capability for accessibility during service life to the entire internal surfaces of the vessel and certain external zones of the vessel. The reactor arrangement within the containment provides sufficient space for inspection of the external surfaces of the reactor coolant piping, except for the area of pipe passing through the primary shielding concrete which can be inspected internally.

Additional details can be found in Subsection 5.2.4.

GDC 33 Reactor Coolant Makeun As indicated in FSAR Subsections 3.1.2.4.4 and 5.2.5 means are provided for detecting reactor coolant leakage. The Reactor Core Isolation Cooling System provides a means of reactor coolant makeup in the absence of normal a-c power concomitant with a loss of feedwater supply as discussed in CSAR Subsection 5.4.6. A high degree of functional reliability and safe response to probable modes of fcilure is assured by the availability of the High Pressure Core Spray System (Emergency Core Cooling System) as described

in FSAR Section 6.3. The electrical system of the HPCS is outlined in Subsection 8.3.1.1.2.1.

10 CFR Regulation Compliance CDC 34 Residual Heat Removal FSAR Subsection 3.1.2.4.5 indicates that the Residual Heat Removal System is designed to remove decay heat and sensible heat from the nucicar boiler system at an acceptable rate while the reactor is shut down for refueling and servicing and to condense reactor steam so that decay and residual heat may be removed if the main condenser is unavailable (hot standby). Two of the three independent loops are located in separate protected areas. Either or both of these redundant RHR heat exchangers can be manually activated. The RHR System is able to operate on either onsite or offsite electrical power. Details of the design are in FSAR Subsection 5.4.7.

GDC 35 Emergency Core Cooling FSAR Subsection 3.1.2.4.6 indicates that the emergency core cooling systems are adequate to prevent fuel and cladding damage which could interfere with effective core cooling and to limit cladding metal-water reaction to an acceptably small amount. Should a break in the reactor coolant pressure boundary occur, the core will remain substantially intact and in place with its essential heat transfer geometry preserved. The system has capable redundant onsite electrical power. Further details are provided in FSAR Section 6.3.

GDC 36 Inspection of Emergency Core Cooling System Subsection 3.1.2.4.7 of the FSAR outlines the compliance with this criteria. Subsection 5.2.4 discusses the inservice inspection plan, access provisions, and areas of restricted access. The spray spargers within the vessel are accessible for inspection during each refueling outage. Inspection of other components , including noccles, is provided for in accordance with the intent of Section XI of ASME B&PV Code.

GDC 37 Testing of Emergency Core Cooling System FSAR Subsection 3.1.2.4.8 indicates that the components of the Emergency Core Cooling System located outside the containment are accessible for leak tightness inspection during appropriate periodic tests. Each active component of the HPCS, LPCS, LPCI, and ADS Systems is individually tested 10 CFR Regulation Compliance 4

GDC 37 periodically to demonstrate operability; flow rates cont'd. are conducted also. Actuation circuits are tested and remote operated valves and pumps exercised periodically. Performance of the full operational sequence that brings each system into operation are verified. The testfb; is described in detail in FSAR Subsection 6.3.4.

GDC 38 Containment Heat Removal FSAR Subsection 3.1.2.4.9 indicates the containment heat removal function is accomplished by the residual

heat removal (RHR) system. The RHR containment cooling mode can recirculate to cool the pressure-suppression pool or cool the containment by spraying cooled suppression pool water directly into the containment atmosphere. Further details are provided in FSAR Sections 5.4.7, 6.2, 9.2 and chapters 8 and 15.

GDC 39 Inspection of Containment Heat Removal System Evaluation against this criterion is shown in FSAR Subsection 3.1.2.4.10. Pumps, valves, piping, and other components outside the drywell can be inspected at any time. The suppression pool is designed to permit periodic inspection.

GDC 40 Testing of Containment Heat Removal System The containment heat removal function is accomplished by a cooling mode of the residual heat removal system (RHR), which is provided with sufficient test connections and isolation valves to permit periodic pressure and flow rate testing. (FSAR Subsection 3.1.2.4.11) i GDC 41 Containment Atmosphere Cleanun FSAR Subsection 3.1.2.4.12 describes the systems provided to control hydrogen and fission products generated by a design basis accident. The systems are sufficiently redundant 'to meet the single failure criterion and are operable with either onsite of offsite power. The standby gas treatment system HEPA (High Efficiency Particulate Air /Absclute) filters, plus charcoal filters, handle the exhaust from the secondary containment minimizing the release of radioactivity to the environment during abnormal occurrences as described in FSAR Subsection 6.5 The

& a 10 CFR Regulation Compliance GDC 41 combustible gas control system regulates the cont'd. concentration of combustible gases in the containment and, with the drywell purge system, functions as a backup to the hydrogen recombiner, filtering air purged from the primary containment post-LOCA as described in detail in FSAR Subsection 6.2.5.

GDC-42 Inspection of Containment Atmosphere Cleanup Systems FSAR Subsection 3.1.2.4.13 indicates that most of the components of the containment cleanup systems are located in areas which are accessible and can be inspected during normal plant operation. The piping and isolation valves in the drywell can be inspected during shutdown and refueling.

GDC 43 Testing of Containment Atmosphere Cleanup Systems FSAR Subsection 3.1.2.4.14 assures that the design of the containment atmosphere cleanup systems permits appropriate periodic pressure and functional testing.

Refer to Subsection 6.2.3.4 for standby gas treatment system testing; 6.5 for containment fission product removal and control system testing; Chapter 8 for power source testability; 9.4.7.2.4 for drywell purge system tests; and 9.4.6 for containment gas control system testing.

GDC 44 Cooling Water A shutdown service water system comprising 3 independent, redundant subsystems, each with power available from either the onsite diesel generators or the offsite buses, is provided as per FSAR Subsection

! 3.1.2.4.15. Two of the subsystems are

! interconnected, with normally closed isolation valves between them. Each subsystem is provided with adecuate instrumentation to determine leakage and has the capability of isolating specific pieces of equipment.

! GDC 45 Inspection of Cooling Water System As per FSAR Subsection 3.1.2.4.16, the shutdown service water system is designed to permit periodic inspection and testing of the pumpa, strainers, valves, instruments and heat exchangers in the system. All components of the system are readily accessible for visual inspection during normal l station operation.

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10 CFR Regulation Compliance GDC 46 Testing of Cooling Water System FSAR Subsection 3.1.2.4.17 establishes compliance with this criterion. The design of the shutdown service water system permits periodic functional testing (FSAR Subsection 9.2.1.4), hydrostatic testing prior to startup and periodic testing to verify structural and leaktight integrity and to ensure operation of all components.

GDC 50 Containment Design Basis FSAR Section 3.1.2.5.1 indicates that the containment structure, including access openings penetrations, and heat removal system, is designed with sufficient conservatism to accommodate, without exceeding the design leakage rate, the transient peak pressure and temperature associated with a postulated instantaneous circumferential rupture of a main steamline upstream of the main steamline flow restrictor. Containment design basis is discussed further in Sections 3.8 and 6.2 GDC 51 Fracture Prevention of Containment Pressure Boundary i As outlined in FSAR Subsection 3.1.2.5.2.1, the containment vessel material has a nil ductility transition temperature of at least 30 F below 'the minimum service temperature. Containment ventilation systems maintain the containment temperature at a suitable level during a shutdown of the unit in cold weather. Quality assurance and preoperational-l testing will ensure that the integrity of the i containment meets all requirements.

GDC 52 Capability for Containment Leakage Rate Testing The containment system is designed and constructed and the necessary equipment is provided to permit periodic integrated leak rate tests during the plant

lifetime. The testing program will be conducted in accordance with Appendix J to 10 CFR 50. See FSAR Subsections 6.2.6 and 3.1.2.5.3.

GDC 53 Provisions for Containment Inspection and Testing Conductance of individual leakage rate tests on applicable penetrations, visual inspection, and pressure testing for leaktightness will be done as per FSAR Subsection 6.2.6 and Chapter 14.

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10 CFR L Regulation Compliance GDC 54 Piping Systems Penetrating Containment Piping systems penetrating containment are designed to provide the required isolation and containment capabilities with redundancy and reliability of i operation as required. These piping systems are provided with test connections to allow periodic valve leakage tests to be performed. The engineered safety features actuation system test circuitry provides the means for testing isolation valve operability. See FSAR Subsections 3.1.2.5.5 and 6.2.4.

GDC 55 Reactor Coolant Pressure Boundary Penetrating Containment FSAR Subsection 3.1.2.5.6.1 states that the reactor coolant pressure boundary consists of the reactor pressure vessel, pressure-retaining appurtenances attached to the vessel, and valves and pipes which extend from the reactor pressure vessel up to and including the outermost isolation valve. The lines of the reactor coolant pressure boundary which penetrate the containment have suitable isolation valves capable of isolating the containment thereby precluding any significant release of radioactivity.

See FSAR Sections 5.2; 6.2.4; 7, and 16.

GDC 56 Primary Containment Isolation FSAR Subsection 3.1.2.5.7.1 indicates that lines which penetrate the containment and communicate with the containment interior are provided with two isolation valves, one inside the containment and the other outside containment. These valves are either locked closed, automatic isolation valves, or a combination thereof. For details on the isolation j system mechanism refer to FSAR Sections 6.2.4 and 16.

GDC 57 Closed System Isolation Valves FSAR Section 3.1.2.5.8.1 evaluates against this criterion. Each line that penetrates containment and is not connected to the containment atmosphere and-is not part of the reactor coolant pressure boundary has at least one isolation valve, either automatic, locked closed, or capable of remote manual operation, located outside the containment near the penetration.

Details demonstrating conformance are provided in FSAR Subsection 6.2.4.

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, - s 10 CFR Regulation Compliance GDC 60 Control of Releases of Radioactive Materials to the Environment As described in FSAR Subsection 3.1.2.6.1.1, liquid,

's gaseous, and solid radioactive waste processing equipment is provided . The principles of filtration,

. demineralization, evaporation, solidification and storage for decay are utilized as described in FSAR Subsections 1.2 and Chapter 11. Process monitoring is provided to control this equipment and regulate releases to the environment.

GDC 61 Fuel Storage & Handling & Radioactivity Control The new fuel storage, spent fuel handling and storage, and radioactive waste systems are' designed to meet the requirements of this criterion as discussed in FSAR Subsection 3.1.2.6.2. More detailed information can be found in FSAR Section 9.1 and Chapter 11.

GDC 62 Prevention of Criticality in Fuel Storage & Handling Appropriate plant fuel handling and storage facilities are provided to preclude accidental criticality for new and spent fuel as described in 3.1.2.6.3. More details are provided in FSAR Subsections 9.1 and 7.6.1.1.

GDC 63 Monitoring Fuel & Waste Storage As described in FSAR Subsection 3.1.2.6.4 appropriate systems have been provided to (1) detect conditions that may result in loss of residual heat removal capability and excessive radiation levels, and (2) to initiate appropriate safety actions.

GDC 64 Monitoring Radioactivity Releases As described in FSAR Subsection 3.1.2.6.5 means are provided for monitoring radioactivity releases. See FSAR Subsections 7.6.1.4 (leak detection system),

7.5.1.4 (drywell & containment monitoring), 11.5 (effluent discharge paths) and Chapter 12 for more detail.

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I 10 CFR Regulation Compliance Part 50 Appendix B - Quality Assurance Criteria Chapter 17 of the FSAR describes in detail the provisions of the quality assurance program which has.

been implemented to meet all applicable requirements of Appendix B of 10 CFR 50.

Part 50 Appendix C - Guide for Financial Data This Appendix provides a guide for establishing the l applicant's financial qualification. The financial information requested by NRC for the CPS applicants was provided by IP letter on November 24, 1981.

Part 50 Appendix D This Appendix has been superseded by 10 CFR Part 51.

Part 50 Appendix E - Emergency Planning and Preparedness In compliance with this Appendix, an emergency plan for Clinton Power Station is provided as FSAR

Appendix 13.B. It provides reasonable assurance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety and prevent damage to property. The emergency plan meets the criteria in NUREG-0654.

j Part 50 Appendix F This Appendix applies to fuel reprocessing plants'and

related waste management facilities, not to power i reactors, and is therefore not applicable to this review.

Part 50 Appendix G - Fracture Toughness Requirements l FSAR Subsection 5.3.1.5 lists the interpretations and methods used to comply with Appendix G of 10 CFR 50.

i Subsection 5.3.1.6.3 covers predicted irradiation effects on vessel beltline materials. The limit i curves cre found in Fig. 5.3-4 and discussed in l 5.3.2.1. Temperature Limits for Pre-operational System Hydrostatic Tests and ISI Hydrostatic on. Leak Pressure tests are found in Subsection 5.3.2.1.2; reactor vessel annealing in Subsections 5.3.2.1.4 and 5.3.3. Material surveillance and inservice inspection programs are discussed in Subsection 5.3.3.7.

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10 CFR Regulation Compliance Part 50 Appendix H - Reactor Vessel Material Surveillance Reactor vessel material specimens which include the base metal, weld metal, and heat affected zone metal are encapsulated within the reactor pressure vessel to permit periodic evaluation. FSAR Subsection 5.3.1.6.1 discusses compliance with reactor vessel material surveillance program requirements.

Part 50 Appendix I "As Low As Is Reasonably Achievable" (ALARA)

This Appendix provides numerical guides for design objectives and limiting conditions for operation to meet the criteria "as low as is reasonably achievable" for radioactive material in light-water-cooled nuclear power reactor effluents.

FSAR Subsection 3.1.2.6.1.1 assures that systems have been incorporated in the plant design to comply with this regulation. ALARA compliance is provided in FSAR Section 12.1.

IP chose compliance with the annex to appendix I rather than perform a detailed cost benefit analysis as per Section II.D of Appendix I.

Part 50 Appendix J - Reactor Containment Leakage Testing FSAR Subsection 6.2.6 discusses the containment leakage testing program which was designed to comply with this appendix. See FSAR Table 6.2-47. The fact

that the allowable drywell leakage rate (120% in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at 3 psid) is not exceeded will be verified by periodic tests on the same schedule as the primary containment leak tests. (6.2.1.1.5.4). See also evaluation against criterion 52 (3.1.2.5.3.1) and 14.2.12.1.53 preoperational testing.

Part 50 Appendix K - ECCS Evaluation Models Since this appendix specifies features of acceptable ECCS Evaluation models, the above compliance with 10 CFR 50.46 should meet the requirements.

Part 50 Appendix L - Antitrust Review This Anpendix covers information requested by the Attornev General for antitrust review of license applica'tions. See above compliance to 10 CFR 50.33a.

10 CFR Regulation Compliance Part 50 Appendix M - Standardization of Design: Manufacture of Nuclear Power Reactors This Appendix covers standardization of design and is not applicable to the Clinton Power Station review.

Part 50 Appendix N - Standardization of Nuclear Power Plant Designs This Appendix covers standardization of nuclear power plant design at multiple sites and is not applicable to Clinton Power Station.

Part 50 Appendix 0 - Standard Designs This Appendix covers standardination of design and is not applicable to Clinton Power Station.

Part 50 Appendix Q - Early Site Review This Appendix governs preapplication early review of site suitability issues and is not applicable to Clinton Power Station.

Part 50 Appendix R - Fire Protection This Appendix does not apply to Clinton Power Station since it was not in operation prior to January 1, 1979. However, see compliance to Paragraph 10 CFR 50.48.

y 10 CFR Regulation Compliance 51.1 This regulation states the general purpose for which the Part 51 regulations are established and does not impose any specific obligations on licensees.

51.2 The definitions contained in this regulation are followed in all appropriate documents.

51.3 This regulation governs the interpretation of regulations by the NRC and does not impose obligations on the licensee.

51.4 This section provides for exemptions from Part 51 authorized by law and in the public interest and does not impose an obligation on the licensee.

51.5 This section lists the types of actions requiring an environmental impact statement (EIS), those that may require an EIS ar negative declaration / environmental impact appraisal, and those requiring neither. It imposes on a license applicant the duty to provide the Commission with information to aid in preparation of an environmental impact appraisal. No information to support environmental impact appraisals has been requested by the NRC.

51.6 This regulation governs an action by the Commission regarding a notice of intent and is not an obligation of the licensee.

51.7 This regulation relates to the Commission's procedures and does not impose an obligation on the licensee beyond Section 51.5.

A draft environmental statement by the Directorate of Licensing USAEC, related to CPS, was issued June, 1974, and finalized October, 1974, prior to issuance of our construction permit.

NRC issued NUREG-0854, December 1981, " Draft Environmental Statement Related to the Operation of Clinton Power Station Unit No. 1".

51.20 An Environmental Report- Construction Permit Stage was submitted to the NRC on October 26, 1973, for the Clinton Power Station, and a construction permit was subsequently issued.

51.21 An Environmental Report-Operating License Stage (Preliminary Review) was issued Dec. 1, 1979, and found sufficiently complete per NRC's letter dated 8/29/80, after which the actual report was forwarded

10 CFR Regulation Comoliance 51.21 to NRC for review in conjunction with our OL cont'd. application.

51.22 This regulation covers the Comnission's procedures and does not impose obligations on the licensee.

51.23 This regulation covers the Commission's preparation of the draf t environmental impact statement and does not impose obligations on the licensee.

51.24 This regulation covers distribution and public notice of the draft environmental impact statement by the Commission. It imposes no obligations on the licensee.

51.25 This regulation covers requests for comments on draft environmental impact statements and inposes no requirements on the licensee.

51.26 This regulation applies to preparation of an EIS by the Director of Nuclear Reactor Regulation or the i

Director of Nuclear Material Safety and Safeguards

and does not require action by the Clinton Power Station.

51.40 As per NRC letter of 8/29/80 accepting Illinois Power Co. application for an operating license, direct distribut ion of our Environmental Report has been made in accordance with NRC listing enclosed therein and verified in oar letter of 9/15/80 to the Office of Nuclear Reactor Regulation.

51.41 This regulation pertains to materials licensing which is covered by the CPS facility license and Environmental Report as described above.

51.50 This regulation is a general NRC administrative rule governing public notices, distribution of reports and receipt of public comments.

51.51 This section specifies the length of time before licenses, permits, and orders are released from the NRC. No action is required by IP.

51.52 This section deals with public hearings in licensing proceedings and the possibility of changes to the final environmental impact statement during such proceedings, and describes the action which IP and other parties can take during proceedings.

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10 CFR Roqulation Comoliance 51.53 This regulation permits upon approval of the hearing officer limited operation and fuel loading authorization upon compliance with procedures of 10 CFR 50.57.

51.54 This section imposes requirements on the NRC to make available for public inspection lists of environmental impact statements, negative declarations, and impact appraisals in preparation, also names of interested groups and notification to them of availability of document drafts.

51.55 Materials distributed to the public will be without cost or at actual reproduction cost.

51.56 This part establishes that part 51 is applicable to the Clinton Power Station.

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10 CFR Regulation Compliance 100.1 This regulation is explanatory and does not impose obligations on licensees.

100.2 This regulation is explanatory. CPS is not novel in design and is not unproven as a prototype or pilot plant.

100.3 This regulation is explanatory and does not impoce obligations on licensees.

100.10 The factors listed related to both the unit design and the site have been provided in the application.

Site specifics, including seismology, meteorology, geology, and hydrology, are presented in Chapter 2 of the FSAR. The exclusion area, low population zone, and population center distance are provided and described. The FSAR also describes the characteristics of reactor design and operation.

100,11 An exclusion area has been established, as described in FSAR Section 2.1.2. The low population zone required by 100.11 (a)(2) has been established, as described in FSAR Section 2.1.3.4, as the area within a radial distance of 2.5 miles radius (4018 meters) centered on the standby gas treatment system vent.

As indicated in Section 2.1.3.5, the nearest population center, as defined by 10 CFR 100.3(c),

based on the 1970 census, is Decatur, Illinois, located approximately 22 miles south-southwest of the-site.

The FSAR accident analyses, particularly those in Chapters 6 and 15, demonstrate that offsite doses resulting from postulated accidents would not exceed the criteria in this section of the regulation.

Part 100 Appendix A Appendix A to 10 CFR Part 100 provides seismic and geologic siting criteria for nuclear power plants.

The compliance of the CPS site with this Appendix is discussed in the Safety Evaluation Report, NUREG-75/013 and Supplement No. 1 Dec. - 1975. Also see Section 2.5 of the FSAR.