ML20093D997

Requests Exemption from Requirement of 10CFR50,App A,Gdc 4 Re Fuel Load & Precritical Testing Activities.Prior to Initial Criticality,No Fission Product Inventory in-core & Moderator Temp Coefficient beginning-of-life Positive

ML20093D997
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 8407170337
Download: ML20093D997 (3)

Text

m Duxu POWER GOMPANY Powen Burturno Box 00180, CHAHLOTrE. N. G. 2a242 W.M.OWEN tutCimvt viCC pett'Otut

<===~ "a== = July 13, 1984 ir o. ,,,-. .

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

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) 4, as such relates to fuel load and pre-critical testing activities.

On March 19, 1984 representatives from Duke Power, Westinghouse, and the NRC met to discuss Confirmatory Item 12, Main Steamline Break (MSLB) Using a Revised Heat Transfer Model, which is discussed in Section 6.2.1.1 of the Catawba FSAR. Duke subsequently provided the staff with additional informa-tion concerning this subject in a letter dated March 28, 1984, and Westing-house submitted for NRC review WCAP 8354, that documents Ice Condenser Containment analysis techniques.

On July 9, 1984, pursuant to 10 CFR 550.55e, Applicants submitted Signifi-cant Deficiency Report No. SD 413-414/84-16, detailing the effects of super-heated steam generated by a steam generator for the Main Steamline Break analysis, which could result in increased doghouse temperatures outside con-tainment. In this report Applicants committed to determine final actions required to resolve this issue by August 31, 1984.

Duke Power has reviewed this situation with respect to the pending request to load fuel and perform pre-critical testing for Catawba Unit 1. It was concluded that there would be no significant consequences as a result of the design basis accident analyzed in FSAR Section 15.1.5 for the following reasons:

8407170337 840713 /

PDR ADOCK 05000413 [

A PDR IfD

o Mr. Harold R. Denton, Director Office of Nuclear Peactor Regulation U. S. Nuclear Regulatory Commission July 13, 1984 j Page Two

1) Prior to initial criticality, there would be no fission product inventory in the core.

1

2) The moderator temperature coefficient at beginning-of-life (BOL) is slightly positive. Therefore, the core would not go critical as a result of a MSLB accident.

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.

By letters dated June 20 and June 28, 1984 Applicants requested a partial exemp- t 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 4 that would allow the above referenced items to be completed prior to initial criticality.

Very truly yours.

W. H. Owen RWO: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 Alliance 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.

RJ -

. Notary Public,'

• r My Commission Expires: (

l September 20, 1984  :

l i

F

. , , ._ - .- - - . - , - . , - - -. . . - _ _ ,_ -. . - - ,