U-600510, Requests Specific Exemptions to GDC of 10CFR50,App a for Limited Time During Initial Fuel Load.Exemptions Relate to Deferral of Preoperational Testing Only

Requests Specific Exemptions to GDC of 10CFR50,App a for Limited Time During Initial Fuel Load.Exemptions Relate to Deferral of Preoperational Testing Only

ML20138C078
Person / Time
Site:	Clinton
Issue date:	03/27/1986
From:	Hall D ILLINOIS POWER CO.
To:	Butler W Office of Nuclear Reactor Regulation
References
U-600510, NUDOCS 8604020149
Download: ML20138C078 (8)

Text

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, , U-600510 L30-86(03-27)-L 1A.120 ILLINO/S POWER COMPANY

. CLINTON POWER STATION. P.O. BOX 678, CLINTON. ILLINOIS 61727 March 27, 1986 Docket No. 50-461 Director of Nuclear Reactor Regulation Attention: Dr. W. R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Clinton Power. Station Request for Exemption from 10CFR50, Appendix A, General Design Criteria

Dear Dr. Butler:

In accordance with 10CFR50.12 of the Commission's regulations,-Illinois Power Company (IP) hereby requests that the NRC grant specific exemptions to the General Design Criteria (GDC) of 10CFR50 Appendix A, for a limited amount-of time during the initial Fuel Load of the Clinton Power Station. The exemptions requested herein are a result of the deferral request contained in the " Initial Test Program Activities Projected For Completion After Fuel Load"~ letter, dated March 12, 1986, and relate to the deferral of particular preoperational testing only. All construction activities required to support Fuel Load will be completed.

In requesting these exemptions, IP is strictly interpreting the regulations contained in 10CFR50 Appendix A to assure that-all criteria are adhered to.

Section 50.12(a)(1) of the rule authorizes the Commission to grant exemptions which are:

"... authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security."

As described in the attachment, the requested exemptions are authorized by law, will not present undue risk to the public health and safety, and will not impact the common defense and security.

Section 50.12(a)(2) of the rule provides that the Commission will not consider granting an exemption unless special circumstances are present. The special circumstances under which the Commission will grant an exemption, provided that the general standards of Section i 50.12(a)(1) are also met, are identified in Sections g g eogo g gifd" t -] 'D A

• U- 600510 L30-86(03-27)-L 1A.120 50.12(a)(2)(1) through (vi). The attachment provides IP's evaluation of these special circumstances. As noted in the attachment, Sections 50.12(a)(2)(ii) and (v) apply to these specific exemptions.

An affidavit in support of these requests is also attached. Please contact F. A. Spangenberg of my Staff if there are any questions regarding these' specific exemptien requests.

Sincerely yours,

. . all Vice President TLR/ksf Attachment cc: Mr. B. L. Siegel, NRC Clinton Licensing Project Manager NRC. Resident Office Region Administrator, Region III, USNRC Illinois Department of Nuclear Safety

F-U- 600510 L3 0-86(03-27 )-L .

lA.120 AFFIDAVIT ILLINOIS POWER  :

ss.

COUNTY OF DEWITT  : l

-D. P. Hall being first duly sworn, deposes and says:

That he is Vice President of Illinois Power Company, the Applicant herein; that he has reviewed the foregoing request, pursuant to Section 50.12 of the United States Nuclear Regulatory Commission's regulations, for certain specific exemptions to the requirements of Appendix A to 10CFR Part 50 together with the Justification For the Requested Exemptions and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

D. P. Hall - Vice President Subscribed and sworn to before me this J ff day of t/)]AMltj 1986.

I ffw)

Notary Public Iny Canission Expiw.[.U/.![b

, , Attachment to U-600510 JUSTIFICATION FOR THE REQUESTED EXEMPTIONS TO 10CFR50 APPENDIX A In accordance with 10CFR50.12(a)(1), the Commission may grant exemptions under the following circumstances: (1) the activities to be conducted are authorized by law. (2) operation with the exemption will not present uncue. risk to the health and safety of the public, and (3) the common defense and security are not endangered. The evaluations to these standards, contained herein, are in accordance with 10CFR50.12 as revised by final rule dated December 12, 1985 (Federal Register, Volume 50, No.'239, page 50764).

I. The Requested Exemptions and the Activities Which Would Be Allowed Thereunder Are Authorized by Law There are no other prohibitions of law to preclude the activities which would be authorized by the requested exemption. Therefore, the Commission is authorized by law to_ grant this exemption request.

II. The Requested Exemptions Will Not Present Undue Risk to the Health and Safety of the Public The evaluation of "no undue risk" consiBers such

' factors as the type of plant operation contemplated, the length of time the exemption would be in effect, the existence of alternative means of compliance or .

compensatory measures, and other safety factors. The results of the evaluations considering these factors are discussed below.

A. Containment Monitoring (CM) System 10CFR50 Appendix A, General Design Criterion (GDC) 41,

" Containment Atmosphere Cleanup", rec uires , in part, that "Sya* 2ms to control fission proc ucts , hydrogen, oxygen, and other substances which may be released into the reactor containment shall be provided as necessary to reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen.or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained."

The reference letter requested a deferral of those aortions of the Cf4 preoperational test related to the lumidity monitors, containment pressure monitors, and Suppression Pool and Drywell excess flow instrument line check valves until prior to Initial Criticality.

Attachm:nt to U-600510 That letter also provided technical justification-related to the above instruments that s' hows for the

.short time period the deferral would be in effect, no undue risk to the health and safety of.the public would exist.

B. Control Room HVAC (VC) System 10CFR50 Appendix A, GDC 19, " Control Room," requires ,

in part, that " A control room shall be provided from which actions can be taken to' operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures'in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident."

The reference letter requested a deferral of the loading of activated charcoal inte HVAC filters and final in-place filter testing of the VC System until prior to Initial Criticality. That letter also provided technical justification related to this testing that shows for the short time period the deferral would be in effect, no undue risk to the health and safety of the public would exist.

C. Fuel Handling (FH) System 10CFR50 Appendix A, GDC 61, " Fuel Storage and Handling and Radioactivity Control," requires, in part, that the fuel bandling system be designed "(3) with appropriate containment, confinement, and filtering systems, ...

and (5) to prevent significant reduction in fuel storage coolant-inventory under accident conditions".

The reference letter requested a deferral of that portion of the FH System preoperational phase test related to transfer of fuel bundles under wet loading conditions until prior to exceeding 5% of rated reactor power. Since the initial Fuel Load at Clinton Power Station (CPS) will be performed under dry conditions, operation of the FH System under wet conditions is not required and the above regulations do not apply.

Therefore, no undue risk to the health and safety of the public would exist.

D. Fuel Pool Cooling and Cleanup (FC) System 10CFR50 Appendix A, GDC 61, " Fuel Storage and Handling and Radioactivity Control", rec uirec , in part , that the fuel storage system be designec. "(5) to prevent significant reduction in fuel storage coolant inventory under accident conditions."

1

, . Attachm:nt to U100510 The reference letter requested a deferral of that portion of the FC System preoper&tional phase test related to demonstration of design ability to maintain and alter pool water levels until prior to exceeding 5%

of rated reactor power. Since the initial Fuel Load at CPS will be performed under dry conditions and no water is presently in the pools, testing of the FC System water level control function cannot be completed.

Considering the short time period that the deferral would-be in effect and the above discussion, ne undue risk to the health and safety of the public would exist.

E. Leak Detection (LD) System 10CFR50 Appendix A, GDC 30, " Quality of Reactor Coolant Pressure Boundary," requires, in part, "Means shall be provided for detecting and, to the extent practical, identifying the location of the~ source of reactor coolant leakage." GDC 64, " Monitoring Radioactivity Releases," requires that, "Means shall be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of loss-of-coolant accident fluids, effluent discharge paths, and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents."

The reference letter requested a deferral of the LD System preoperational testing until prior to Initial Criticality and 'provided technical justification for the same. Considering the short time period that the deferral would be in effect, no undue risk to the health and safety of the public would exist.

III. The Requested Exemptions Will Not Endanger the Common Defense and Security The requested exemptions will have no impact on the common defense and security.

In conclusion, the standards of 10CFR50.12(a)(1) are met for these specific exemptions.

In accordance with 10CFR50.12(a)(2), the Commission will not consider granting an exemption unless special circumstances are present. Special circumstances in which the Commission believes i'. would be reasonable to grant an exenption are identified in Sections 50.12(a)(2)(1) through (vi) of the rule. The following evaluations pertain to criteria (ii) and~(v).

Attachment to U-600510 50.12(a)(2)(ii) - " Application of the_ regulation in the particular circumstances would not serve the. underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule".

Application of these special circumstances shows that application of the regulation is not necessary to serve the specific purpose of the regulation.

A. Containment Monitoring (CM) System Prior to Initial Criticality, there does not exist an appreciable quantity of fission products in the fuel.

Therefore, no significant release of radioactivity is possible, nor is it possible to generate appreciable quantities of hydrogen or oxygen. The purpose of GDC 41, " Containment Atmosphere Cleanup", is to assure control of " Fission products, hydrogen, oxygen, and other substances which may be released into the reactor containment..." Thus, it is not necessary to apply the regulation in this particular circumstance to achieve

.the underlying purpose of the rule.

B. Control Room HVAC (VC) System As discussed above, prior to Initial Criticality, no significant release of radioactivity is possible. A purpose.of GDC 19, " Control Room", is to assure that adequate radiation protection is provided to permit access and occupancy of the control room under accident conditions. Thus, it is not necessary to apply this portion of the regulation to achieve the underlying purpose of the rule.

C. Fuel Handling (FH) and Fuel Pool Cooling and Cleanup (FC) Systems Initial Fuel Loading will occur under dry conditions at CPS: thus, there is no fuel storage coolant inventory to filter or to maintain, as required by GDC 61, " Fuel Storage and Handling and Radioactivity Control."

Therefore, it is not necessary to apply the regulation in these particular circumstances to achieve the underlying purpose of the rule.

D. Leak Detection (LD) System The purpose of GDC 30, " Quality of Reactor Coolant Pressure Boundary", is to ensure that the integrity-of the reactor coolant pressure boundary (RCPB) is maintained through the use of quality components and to detect and locate any RCPB leakage. The underlying Attachmsnt. to U-600510 m

purposeyis to minimize the effects of coolant leakage that could threaten the ability of the. plant to adequately cool the reactor core. Prior to Initial Criticality, fuel cooling is not required. Thus, it is not necessary to apply the regulation in this particular circumstance to achieve the underlying purpose of the rule.

50.12(a)(2)(v) -

"The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good-faith efforts to comply with the' regulation".

This special circumstance applies in all deferral requests as follows:

Temporary Regulation Relief Requested Until Prior to Initial Criticality Containment Monitoring System - GDC 41 Control Room HVAC System - GDC 19 Leak Detection System - GDC's 30 and 64 Temporary Regulation Relief Requested Until Prior to-Exceeding 5% of Rated Power Fuel Handling System - GDC 61 Fuel Pool Cooling and Cleanup System - GDC 61 The temporary relief requests detailed herein indicate that Illinois Power Company has made good faith efforts'to comply with the regulations, but in some cases it is not feasible, and in others it is not necessary to complete the preoperational testing required to be in compliance with the applicable regulations.

As a result of the evaluations contained herein, IP considers the applicable provisions of 10CFR50.12 have been met and that, on this basis, the NRC should grant these specific exemptiens to 10CFR50, Appendix A, GDC's 19, 30, 41,.61, and 64.

Reference U-600469, D.P. Hall, Vice President, Illinois Power Company, to Mr. Harold R. Denton, Director, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission, "Clinton Power Station Initial Test Program Activities Projected For Completion Af ter Fuel Load", March.12, 1986