ML20212D927

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Requests Schedular Exemption from 10CFR50.34(b)(2)(i) Due to Inability to Respond to NRC 861128 Request for Addl Info Re Design of Spent Fuel Racks in Time for NRC Review Prior to Fuel Load Date
ML20212D927
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 12/29/1986
From: Bailey J
GEORGIA POWER CO., SOUTHERN COMPANY SERVICES, INC.
To: Youngblood B
Office of Nuclear Reactor Regulation
References
GN-1267, NUDOCS 8701050152
Download: ML20212D927 (2)


Text

Georgo Fbwer Company Post Offica Box 282 Waynesboro, Georga 30830 Telephone 404 554 9%1 404 724 8114 Southern Company Services, Inc.

Fbst Of fice Box 2625 b

Birmingham, Alabama 35202 Telephone 205 870 60H VOgtle Project l

Decembe r 29, 1986 l

Director of Nuc1 car Reactor Regulation Files X7BC35 Attention:

Mr. B. J. Youngblood Legt GN-1267 PWR Project Directorate #4 Division of PWR Licensing A U. S. Nucicar Regulatory Commission Washington, D.C.

20555 REF:

(1) LETTER FROM M. MILLER TO R. CONWAY, 11/28/86 (2) LETTER FROM B. YOUNGBLOOD TO J. O'REILLY, 12/19/86 NRC DOCKET NUMBER 50-424 CONSTRUCTION PERMIT NUMBER CPPR-108 VOCTLE ELECTRIC GENERATING PLANT - UNIT 1 SPENT FUEL RACKS t TEMP 0RARY EXFMPTION REQUEST Dear Mr. Dentont By letter dated November 28, 1986, your staff requested additional information concerning the design of the spent fuel racks to he employed at Plant Vogtle.

Georgia Power Company in preparing this information and will provide it shortly.

It appea rs, howeve r, that there will be insufficient time for Georgin Power Company to submit and for the NRC Staf f to review the information prior to the fuel load date for U.it 1.

Accordingly, pursuant to 10 CFR l 50.12(a), Georgia Power Company requents a achedular exemption from 10 CFR S 50.34(h)(2)(1), an it pertainn to General Design Criteria 61 and 62, and from such other regulations an might require NRC approval of the denign of the Unit I npent fuel racks prior to innuance of a fuel load and low power licenne for Unit 1.

Thin exemption would be temporary, applying only for the period between innuance of the Unit 1 Itcense and the completion of your staf f'n review of the apent fuel racks.

The exemption will not present an undue risk to the public health and nafety and in connistent with the common defense and security. The spent fuel racks are not acheduled to be used to store irradiated fuel until the first refueling outage for Unit 1 (acheduled for 1988).

In addition, the spent fuel racks are not relied upon to prevent or mitigate design basin events for Plant Vogtle. Connequently, thin innuo han no immediate nafety significance.

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e Director of Nuclear Reactor Regulation File: X7BC35 Decembe r 29, 1986 Log:

GN-1267 Page 2 Special circumstances are present which justify the granting of the exemption.

Because the spent fuel racks are not scheduled to be used to store irradiated fuel until the first refueling outage, application of the regulations is not necessary to achieve their underlying purpose. The regulations are intended to ensure that, prior to their use, spent fuel racks have been found to be properly designed to prevent criticality. Since the present exemption request is only schedular and temporary, this purpose will still be fulfilled. The Unit 1 spent fuel racks will not be used to store irradiated fuel until their review has been completed by the NRC.

Further, requiring completed review of the spent fuel racks prior to issuing the Unit 1 license would result in undue hardship.

Delay in issuance of a fuel load and low power license will produce concomitant delay in commercial operation. Each day's delay is estimated to cost Georgia Power Company and its consumers approximately one m'.111on dollars.

Finally, the exemption would provide only temporary relief from the applicable regulations, with which Georgia Power Company has made good faith efforts to comply. As described in Amendment 75 (dated September 1986) to the FSAR, Georgia Power Company has evaluated its spent fuel racks and believes that the racks meet the applicable design criteria. Georgia Power Company is pursuing expeditiously the answers to the questions asked in the November 28 letters to respond fully, however, we have found it necessary to obtain additional information from the vendor.

Since the exemption is only schedular, it involves no significant environmental impact. Based on the exigent circumstances described above, Georgia Power Company reopectfully requests that the exemption be granted as expeditiously as possible.

If your staff requires any additional information, please do not hesitate to contact me.

Sincerely,

.k.

J. A. Bailey Project Licensing Manager JAB /sm xc:

R. E. Conway NRC Regional Administrator R. A. Thomas NRC Resident Inspector J. E. Joiner, Esquire D. Feig B. W. Churchill, Esquire R. W. McManus M. A. Miller (2)

L. T. Cucwa B. Jones, Esquire Vogtle Project File G. Rockhold, Jr.

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