ML20211D224

Requests Exemption for Plant SER Topics Not Meeting Current Regulations,Including Topics II-1.A, Exclusion Area Authority & Control & II-3.B.1, Capability of Operating Plants to Cope W/Design Basis Flooding..

ML20211D224
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	10/10/1986
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	Zwolinski J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0827, RTR-NUREG-827, TASK-***, TASK-RR LAC-11883, NUDOCS 8610220139
Download: ML20211D224 (6)

Text

D DA/RYLAND <

i hh[S/[ COOPERATlVE e O BOX 817 2615 EAST AVE.SO LA CROSSE. WISCONSIN 54602-0817 (608) 788-4000 1

3 JAMES W. TAYLOR

~ GIneral Manager October 10, 1986 In reply, please

, refer to LAC-11883 DOCKET NO. 50-409 Mr. John A. Zwolinski, Director BWR Project Directorate #1 Division of Licensing U.S. Nuclear Regulatory Commission

. Washington, DC 20555

SUBJECT:

DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)

PROVISIONAL OPERATING LICENSE NO. DPR-45 SYSTEMATIC EVALUATION PROGRAM EXEMPTION REQUEST

REFERENCES:

(1) NUREG-0827, " Integrated Plant Safety Assessment -

Systematic Evaluation Program - La Crosse Boiling Water Reactor", dated June 1982.

(2) NUREG-0827, Supplement 1, dated August 1986.

(3) LACBWR License Amendment 44, dated May 28, 1985.

(4) LACBWR License Amendment 45, dated January 6, 1986.

(5) NRC Letter, Denton to Linder, dated August 29, 1980.

(6) NRC Letter, Zwolinski to Linder, dated September 6, 1985.

(7) NRC Letter, Zwolinski to Taylor, dated September 9, 1986.

(8) NRC Letter, Zwolinski to Linder, dated August 13, 1985.

(9) NRC Letter, Crutchfield to Linder, dated August 12, 1982.

(10) DPC Letter, Taylor to Zwolinski, LAC-Il606, dated May 28, 1986.

(11) NRC Letter, Crutchfield to Linder, dated September 20, 1982.

(12) NRC Letter, Crutchfield to Linder, dated July 20, 1982.

(13) NRC Letter, Crutchfield to Linder, dated July 19, 1982.

(14) DPC Letter, Linder to Crutchfield, LAC-9555 dated January 30, 1984.

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4 Mr. John A. Zwolinski, Director October 10, 1986 BWR Project Directorate #1 LAC-11883 J .

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REFERENCES:

(cont'd) i .(15) DPC Letter, Linder to Paulson, LAC-10251, dated October 11, 1984.

(16) DPC Letter, Linder to Zwolinski, LAC-10639, dated March 15, 1985.

.(17) DPC. Letter, Linder to Zwolinski, LAC-10673, dated April 1, 1985.

(18) DPC Letter, Linder to Crutchfield, LAC-9514, dated December 29, 1983.

(19) DPC Letter, Linder to Paulson, LAC-10476 dated December 20, 1984.

Dear Mr. Zwolinski:

You have requested that we~ formally request exemptions for those Systematic Evaluation Program topics for which the La Crosse . Boiling Water Reactor (LACBWR) does not meet the current regulations. We have reviewed References 1 and 2 to determine which topics were considered to be acceptably resolved, but for which the current regulation will not be met as-is or following any actions committed to be implemented. Additionally, issues still under evaluation for~which the current regulations will not be met were identified.

The following list contains the topics identified to the best of our knowledge for which exemptions will be needed based on the above criteria. Items on which exemptions have already been granted are not included in this list.

Therefore, we request that exemptions from the regulations be granted for the following topics.

Topic II-1.A " Exclusion Area Authority and Control" Exemption is needed from 10 CFR 100.3 because there are two small unoccupied, privately owned land parcels in.the exclusion area. Refer to Reference 1, Section 4.1, Reference 2, Section 3.1 and Reference 3 for justification.

Topic II-3.B.1, " Capability of Operating Plants to Cope uith Design Basis Flooding Conditions" Exemption is needed from 10 CFR 50, Appendix A, GDC 2 because not all structures, systems, and components important to safety can withstand the maximum predicted flood. Refer to Reference 1, Section 4.3, Reference 2, Section 3.2 and Reference 4 for justification.

Topic II-3.C, "Safettf-Related Water Supply (Ultimate Heat Sink)"

Exemption is needed from 10 CFR 50, Appendix A, GDC 2 because the cribhouse pumps are not protected from low river water level events, nor other environmental events. Refer to Reference 1, Section 4.4 and Reference 2, Section 3.3 for justification.

Topic II-4, " Geology and Seismology" Exemption is needed f rom 10 CFR 100, Appendix A because the plant soil may be susceptible to liquefaction. ' Refer to Reference 5 for justification.

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4 Mr. John A. Zwolinski, Director October 10, 1986

.BWR Project Directorate #1 LAC-11883

, Topic III-1, " Classification of Structures, Components and Systems

~ (Seismic and Quality)"

Exemption is needed from 10 CFR 50, Appendix A, GDC 1 because the plant was built to recognized codes and standards at that time which differ from current codes and standards. Also,.there was no Quality Assurance program at the time of construction. Refer to Reference 2, Section 2.1 for justification.

Topic III-3.A, " Effects of High Water Level on Structures" Exemption is needed from 10 CFR 50, Appendix A, CDC 2 since the cribhouse, which contains the Alternate Core Spray Pumps, is not protected. Refer to 1 Reference 1, Section 4.7', Reference 2, Section 2.3 and Reference 6 for j us tification.

Topic III-4.A, ' Tornado Missiles" Exemption is needed from 10 CFR 50, Appendix A, GDC 2 because plant structures-are not designed to withstand missiles generated by current design basis tornado. Refer to Reference 7 for justification.

Topic III-4.C, " Internally Generated Missiles" Exemption is needed from 10 CFR 50, Appendix A, GDC 4 because portions of the Emergency Core Cooling Systems (ECCS) are vulnerable to missiles, though no.

one missile could cause failure of more than one of the two redundant ECCS systems. Refer to Reference 13 for justification.

Topic III-5.A, "Effect of Pipe Break on Structures, Systems and Components 1 Inside Containment" i Exemption is needed from 10 CFR 50, Appendix A, CDC 4 because the decay heat line has a manual isolation valve outside containment which is normally open and will be closed if necessary following a Loss of Coolant Accident, rather

than a normally closed valve. Refer to Reference 2, Section 2.5 and Reference 8 for justification.

Topic III-S.B, " Pipe Break Outside Containment" Exemption is needed f rom 10 CFR 50, Appendix A, GDC 4 due to the design of the main steam line between the Main Steam Isolation Valves and because the 1A Essential Bus Switchgear is not protected from the Alternate Core Spray line.

Refer to Reference 1, Section 4.12 and Reference 9 for justification.

Topic III-8. A, " Loose Parts Monitoring and Core Barrel Vibration Monitoring" Exemption is needed from 10 CFR 50, Appendix A, CDC 13 because LACBWR does not have a loose parts monitoring system. Refer to Reference 1, Section 4.15 for j ustificat ion.

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Mr. John A. Zwolinski, Director October 10, 1986 BWR Project Directorate #1 LAC-11883 Topic V-10. A, " Residual Heat Removal System Heat Exchanger Tube Failures" d

Exemption is needed from 10 CFR 50, Appendix A, GDC 46 because auxiliary cooling water heat exchangers are not tested for leakage. Refer to Reference 1, Section 4.18 for j ustification.

Topic V1-4, " Containment Isolation System" Exemption is needed from 10 CFR 50, Appendix A because the Resin Sluice, Alternate Core Spray, Decay Heat, Seal Injection, and Shutdown Condenser Vent to Offgas lines do not meet GDC 55; the High Pressure Service Water, Demineralized Water, Containment Building Ventilation, Containment Building Drain Snction, Control Air, Reactor. Cavity Air Purge, Offgas Vent Header, Station Air, Shutdown Condenser Sample, and Waste Water lines do not meet GDC 56; the Shutdown Condenser Atmospheric Vent, Component Cooling Water Suction and Discharge, and Heating Steam lines do not meet CDC 57; and instrument lines for Containment Building pressure and level do not have excess flow check valves. Refer to Reference 1, .Section 4.21, Reference 2, Section 2.8 and Reference 10 for justification.

Topic VI-10.A, " Testing of Reactor Trip System and Engineered Safety Features, Including Time Response Testing" Exemption is needed from 10 CFR 50.55a(h) and Appendix A, GDC 21 because complete time response testing is not performed, not all Reactor Protective System parameters can be tested / checked / calibrated during plant operation, and not all system accuracies were fully established during plant design. Refer to Reference 1, .Section 4.25 and Reference 11 for justification.

Topic VII-1.A, " Isolation of Reactor Protection System from Non-Safety Systems, Including Qualification of Isolation Devices" Exemption is needed from 10 CFR 50.55a(h) since all power range nuclear instrumentation channels are supplied by the same non-interruptible bus and some non-safety related items are also fed by that bus. Refer to Reference 1, Section 4.26 and Reference 2, Section 2.10 for justification.

Topic VIII-1.A, " Potential Equipment Failures Associated with Degraded Grid Voltage" Exemption is needed from 10 CFR 50, Appendix A, GDC 17 because LACBWR has a single offsite power supply. Refer to Reference 1, Section 4.27 for justification.

Topic VIII-3.B, "DC Power System Bus Voltage Monitoring and Annunciation" Exemption is needed from 10 CFR 50, Appendix A strictly from the aspect that j the DC Power System does not meet GDC 2 and GDC 4 regarding protection from j natural phenomena and environmental and missile design bases. This aspect was reviewed under the topics dealing with natural phenomena and environmental and missile design bases rather than under this topic. Therefore, refer to references for these topics for justification.

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Mr. John A. Zwolinski, Director October 10, 1986 BWR Project Directorate #1 LAC-11883 Topic IX-3, " Station Service and Cooling Water Systems" Exemption is needed from 10 CFR 50, Appendix A, GDC 44 because Alternate Core Spray is not single passive failure-proof. - Refer to Reference 12 for j ustification.

Topic IX-5, " Ventilation Systems" Exemption is needed from 10 CFR 50, Appendix A, GDC 4 because the Electrical Equipment Room ventilation system is not supplied by vital power and the 1A Emergency Diesel Generator Room ventilation is not single failure-proof.

Refer to Reference 1, Section 4.29 and Reference 2, Section 2.12.2 for j ustification.

Exemptions are needed also for the following topics for which the NRC review is not yet completed.

l Topic III-2, " Wind and Tornado Loading" Exemption is needed from 10 CFR 50, Appendix A, GDC 2 because the plant was not designed for and cannot withstand the currently considered maximum design basis wind and tornado events. Refer to References 14,.15, 16, 17 and 7 for j ustification.

Topic III-6, " Seismic Design Criteria" 1

Exemption is needed f rom 10 CFR 50, Appendix A, GDC 2 because the plant was not designed for and cannot withstand the currently considered design basis earthquake. Refer to References 7,14,15 and 16 for justification.

. Topic III-7, " Design Codes, Design Criteria, Load Combinations, and Reactor Cavity Design Criteria" j Exemption is needed from 10 CFR 50, Appendix A, GDC 1, 2, and 4 because the design codes the plant was designed to are not equal to current design codes.

Refer to Reference 2, Section 2.7 and References 18 and 19 for justification.

Enclosed is a check for $150 to cover the application fee for this exemption i request.

If there are any questions, please contact us.

Yours truly,

/ /$

JWT:LSG:sks l

Enclosure

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Mr. John A. Zwolinski, Director October 10, 1986 BWR Project Directorate #1 LAC-Il883 cc: Mr. John Stang, LACBWR Project Manager Mr. James Keppler, Region III NRC Resident Inspector STATE OF WISCONSIN )

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COUNTY OF LA CROSSE)

Personnally came before me this /[ I day of M , 1986, the above named, James W. Taylor, to me known to be the person who executed the foregoing instrument and acknowledged the same.

I. j7 J Notary Public,/ /La Crosse County Wisconsin My commission expires February 21, 1988 l

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