ML20093D771
| ML20093D771 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/13/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8407170213 | |
| Download: ML20093D771 (3) | |
Text
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e 1-7 DUKE POWER GOMPANY P.O. BOX 33180 CHARLOTTE, N.C. 28242 HALH. TUCKER Tztzenown (704) om-4 sat
====**m July 13, 1984 Mr. Harold R. Denton, Director 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 Pattial Exemption from GDC 64
Dear Mr. Denton:
Pursuant to 10 CFR 550.12, Duke Power Company, et al.
(Applicants) hereby request an exemption from the requirement of 10 CFR Part 50, Appendix A.
General Design Criterion (GDC) 64, as such relates to fuel load and pre-critical testing activities.
In a July 2, 1984 letter to Mr. James P. O'Reilly Applicants noted that the process tubing for the following radiation monitors would have to be modified in order to acheive design flow rates:
EMF 38 - Containment Air Particulate Monitor EMF 39 - Containment Gas Monitor EMF 40 - Containment Iodine Monitor -
Subsequent analysis and tested of EMF 39 has confirmed that this monitor will accomplish its design function and is considered operable. The modification previously identified will be implemented prior to Mode 4 entry to enhance opera *. ion of this monitor.
Modifications to EMF 38 and EMF 40 will also be implemented prior to entering Mode 4.
This will ensure that EMF 38 will~ comply with the requirements of the proposed Technical Specifications, i.e., that the monitor be operable for Mode 4 and above.
These particular monitors serve to monitor the levels of airborne activity in the containment to determine the magnitude of reactor coolant leakage, evaluate Containment entry requirements and analyze activity released to the environment by the Containment Purge System.
As discussed in previous exemption requests, there will be no fission product inventory in the cone during this time period..Therefore, there would be no airborne activity in the Containment that would require the monitors to be operable.
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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7; By letters dated June 20 and June 28, 1934 Applicants requested a partial exemption from CDC 17 in order to permit the diesel generators for Unit 1 to be inoperabAe yntil initial _cgiticality. It is considered that the
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information rc.gaiding' exigent cirdumstances supporting that request also t
o encomp' ass the sit!uat'ivn Mwserted in this application. Therefore, Applicants Z
-herchy request that'thD Coilim.i'ssion issue an-exempti.on to GDC 64 that would 4 ;,
allo %w thry above mrdferenced itws to be. completed, prior.to Mode 4 entry.
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t HAL B. Tucker, being duly sworn, states that he is Vice President of
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Duke Power Company; that'he. is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this application; and that 'all statements and matters set forth therein are true and correct to the best of his knowledge.
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Hal B. Tucker, Vice President e
4 Subscribed and sworn to'before me this 13th day of July, 1984.-
d c. ck O Notary Public
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