ML20090F565

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Requests Partial Exemption from Requirement of 10CFR50, App A,Gdc 1,permitting Diesel Generators to Be Inoperable Until Initial Criticality to Support Fuel Load & Precritical Testing
ML20090F565
Person / Time
Site: Catawba Duke Energy icon.png
Issue date: 07/16/1984
From: Tucker H
DUKE POWER CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8407230149
Download: ML20090F565 (3)


Text

DUKE POWER GOMPANY P.O. box 33180 C21AMLOTTE, N.C. 28242 HALH. TUCKER m EPHONE VMS PataEDENT (704) 373-4531 July 16, 1984 mu...o.mmo-Mr. Harold R. Denton, Driector Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Re: Catawba Nuclear Station, Unit 1 Docket No. 50-413

Subject:

Applicants' Application for Partial Exemption from GDC 1

Dear Mr. Denton:

Pursuant to 10 CFR 950.12, Duke Power Company, et al.

(Applicants) hereby request an exemption from the requirement of 10 CFR Part 50, Appendix A General Design Criterion (GDC) 1, as such relates to fuel load and pre-critical testing activities.

By letter dated October 26, 1983 the Applicants proposed to upgrade the pressurizer PORVs and steam generator PORVs to safety-related and to design them to safety grade criteria in order to comply with the criteria of RSB BTP 5-1, that cold shutdown can be achieved from the Control Room using only safety-related equipment, and in order to take credit for them in the steam generator' tube rupture analysis. -In order to allow sufficient time to implement these modifications, Applicants requested that the modifications be installed during the first refueling outage for the unit. The staff agreed in Supplement 2 to the Catawba Safety Evaluation Report that this was an acceptable schedule.

In order to support fuel loading and pre-critical testing activities Applicants request that an exemption to GDC 1 be issued that relates to this time period.

If necessary, Applicants will supplement this request at a later date to cover the period between criticality and the first refueling outage.

As discussed in previous exemption requests, there will be no fission product inventory in the core and, thus, no decay heat during this time period. There-fore, there would be no need to expeditiously proceed to cold shutdown in the event of certain operational occurrences while operating above cold shutdown.

Based on this analysis, it is Applicant's position that the proposed mode of operation would be as safe as that were the Applicant to fully comply with the regulations at the time of license issuance.

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Mr. Harold R. Denton, Director 0ffice of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission July 16, 1984 Page 2 By letters dated June 20 and June 28, 1984 Applicants requested a partial exemp-i tion from GDC 17 in order to permit the diesel generators for Unit 1 to be inoperable until initial' criticality.

It is considered that the information regarding exigent circumstances supporting that request also encompass the situation presented in this application. Therefore, Applicants hereby request

-that the Commission issue an exemption to GDC 1 that would allow the above-referenced condition to exist prior to initial criticality.

Very truly yours, g

Hal B. Tucker NAR: sib cc:

Mr. J. P. O'Reilly, Regional Administrator Robert Guild, Esq.

U. S. Nuclear Regulatory Commission Attorney-At-Law Region II.

P. O. Box 12097

'101 Marietta Street, NW, Suite 2900 Charleston, South Carolina 29412

. Atlanta, Georgia 30323 Mr. Jesse L..Riley Palmetto Alliance

Carolina Evnironmental Study Group 2135 Devine Street 854 Henley Place Columbia, South Carolina 29205 Charlotte, North Carolina 28207

.NRC Resident Inspector Catawba Nuclear Station m

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.i HAL B. TUCKER, being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this Application for Partial Exemption from GDC-1, and that all statements and matters set forth.therein are true and correct to the best of his knowledge.

h Hal B. Tucker, Vice Presiient Subscribed and sworn to before me this 16th day of July,1984 0-Notary Public-My Comission Expires:

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