ML20093D993

Requests Partial Exemption from GDC 16,38,3 & 50 Concerning Fuel Load & Precritical Testing Activities,Based on 840620 & 28 Requests for Exemption from GDC 17 to Permit Diesel Generators to Be Inoperable Until Initial Criticality

ML20093D993
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 8407170334
Download: ML20093D993 (3)

Text

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DUKE POWER GOMPANY P.O. HOX 33180 CHARLOTn3, N.C. 28242 HALH. TUCKER Tanzen.oxn vuon rarennaint - (704) 373-4531 a'a==e - = 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 Partial Exemption from GDC 16, GDC 38, and GDC 50

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) 16, 38, 3, and 50, 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 certain items related to the completion and testing of the Ice Condenser would not be complete at the time of fuel loading. It was further noted that these items would be complete prior to Reactor Coolant System temperatures exceeding 2000F (Mode 4) as required by the proposed Technical Specifications for this unit. As the Technical Specifications have historically recognized this type of pressure suppression system is not required to be operable when there is insufficient scored energy in the Reactor Cooling System to challenge containment integrity. Furthermore, the time period in question relates to a period in which Catawba will have no fission product inventory, and thus the radiological consequences of any containment failure due to design basis accidents would be non-existent.

As previously stated, Applicants will comply with the proposed Technical Specifications. Therefore, this situation is identical to modes of operation that would have been permitted were the license to be issued with the Ice Condenser fully operable and subsequently removed from service. Thus, Applicants meet the test expoused in Shoreham that the proposed operation would be as safe as that had the licensee fully complied with the regulations.

This position should apply generally to all situations that may arise where the Applicaat will place systems into service as required by the Technical Specifications. Furthermore, although Applicants are submitting the present exemption request, it is Applicant's position that this particular set of circumstances should not warrant an exemption request in the future.

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0407170334 840713 PDR ADOCK 05000413 A PDR

r Mr. Harold R. Denton, Director July 13, 1984 Page 2 By' letters dated June 20, and June 28, 1984 Applicants requested a partial exemption 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 16, GDC 38, and CDC 50 that would allow the above referenced item to be completed prior to Mode 4 entry.

Very truly yours, M .-

Hal B. Tucker NAR/ sib cc: Mr. James P. O'Reilly, Aegional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Catawba Nuclear Station Robert Guild, Esq.

Attorney-at-Law P. O. Box 12097 Charleston, South Carolina 29412 Palmetto Alliance 2135 Devine Street Columbia, South Carolina 29205 Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place -

Charlotte, North Carolina 28207

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8 . y 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; and that all statements and matters set forth therein are true and correct to the best of his knowledge.

G~ & -

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Hal B. Tucker, Vice President Subscribed and sworn to before me this 13th day of July,1984.

da C. cD A Notary Public

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My Commissicn Expires:

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