ML20093D885
| ML20093D885 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/13/1984 |
| From: | Owen W DUKE POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8407170278 | |
| Download: ML20093D885 (3) | |
Text
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DUKE Pownn GO)H%NY I"owEn 13nrLnrxo, Ilox ontoo, CliAHLOTTE, N. C. usu4u W.H.OWEN July 13, 1984 inev=e m m.
Emesngenease & C0htfudChose t704 373 4820 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 Partial Exemption from GDC 4 and GDC 54
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 Criteria (GDC) 4 and 54, as such relates to fuel load and pre-critical testing activities.
In Section 6.2.4 of the Catawba SER it was noted that "The staff has reviewed the containment Air Release and Addition System and concludes that it satisfies the provisions of BTP-CSB 6-4, contingent on the isolation valves being found operable by the staff...."
On March 13-16, 1984 the NRC staff conducted a site review in the area of seismic and dynamic qualification of electrical and mechanical equipment at Catawba. Based on this review and subsequent submittals made by Duke, the staff concluded in Section 3.10.2 of Supplement 2 to the Catawba SER that
"... the Catawba pump and valve operability assurance program is acceptable.
The Applicant should confirm, before initial criticality, that all outstanding qualification programs for safety-related components and accessories have been completed...."
At this time, the staff has not yet determined that the containment Air Release and Addition System (VQ) valves meet the necessary dynamic requirements as specified in SER Section 3.10.
Duke has verified that VQ System valves will close properly against the buildup of containment pressure in the event of a LOCA.
Pressure drop across any of the valves during a LOCA will not exceed 15 psig.
All four valves have electric motor operators that were sized to provide sufficient output torque to close the valves against 150 psig pressure drop.
Therefore, considerable margin exists.
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Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Reg 21 story Commission July 13, 1984 Page Two Combined seismic, LOCA and piping loads have alto been considered and were con-firmed to be less than allowed by the valve qualification documents.
These valves serve to isolate the containment from outside atmosphere. As discussed in previous exemption requests, there will be no fission product inventory in the core ducing this time period. Therefore, there would be no airborne activity in the containment that would require the isolation valves to be operable.
Based on this analysis, it is Applicants' position that the proposed mode of operation would be as safe as that if the Applicant were to be in full compliance with the regulations at the time of license issuance.
By letters dated June 20 and June 18, 1984 Applicants requested a partial exemption from GDC 17 in order to permit the diesel ge nerators 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 if the staff needs information in addition to that provided above in order to close this item, then th a Commission issue an exemption to CDC 4 and GDC 54 thnt would allow the above referenced itema to be completed prior to initial criticality.
Very truly yours, W. H. Owen NAR:scs 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 Allianca Carolina Environmental Study Group 2135 1/2 Devine Street 854 Henley Place Columbia, South Carolina 29205 Charlotte, North Carolina 28207 NRC Resident Inspector Catawba Nuclear Station
W. H. OWEN, being duly sworn, states that he is Executive 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; and that all statements and matters set forth therein are true and correct to the best of his knowledge.
W. H. Owen, Executive Vice President Subscribed and sworn to before me this 13th day of July, 1984.
Yo 0 mbl Notary Public
.My Comission Expires:
September 20, 1984 b
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