View source for B11994, Requests Exemption from Requirements of App J to 10CFR50. Util Has Initiated Detailed Evaluation of Scope & Schedule for Mods Required to Achieve Compliance W/App J as Part of Facility Isap

{{Adams
| number = ML20138B126
| issue date = 03/12/1986
| title = Requests Exemption from Requirements of App J to 10CFR50. Util Has Initiated Detailed Evaluation of Scope & Schedule for Mods Required to Achieve Compliance W/App J as Part of Facility Isap
| author name = Fee W, Opeka J
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = Grimes C
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B11994, NUDOCS 8603200286
| package number = ML20138B132
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
| project = 
| stage = Other
}}

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f                                                      D CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. CO N N E C TIC UT P o Box 270   HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-ses-sooo                                      March 12,1986 Docket No. 50-213 Bil994 Office of Nuclear Reactor Regulation Attn: Mr. C. I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:
Haddam Neck Plant 10CFR50, Appendix 3 Request for Exemption in response to an NRC request dated January 2,1975(l), Connecticut Yankee Atomic Power Company (CYAPCO), submitted proposed changes to the Haddam Neck Plant Technical Specifications which were intended to implement Jhe requirements of 10CFR50, Appendix 3. Subsequently, on May 28, 1975t2),
CYAPCO requested exemptions from certain of the requirements of Appendix 3.
epemption requests were later supplemented and modified (3-9). On May 7, Thesp,07, 1982u            the NRC Staff issued Amendment 49 to Facility Operating License No DPR-61 for the Haddam Neck Plant, which issued revised Technical Specifications reflecting the requirements of Appendix 3.
CYAPCO subsequently documented (ll,12) the need to re-evaluate containment penetration designs and proposed modifications required to achieve Appendix 3 compliance in light of the results of SEP Topic VI-4, containment isolation, i.e.,
modifications required to achieve compliance with 10CFR50, Appendix A. Based upon the favorable experience of the Systematic Evaluation Program (SEP),
CYAPCO expressed the belief (13,14) that a similar integrated evaluation of all pending regulatory requirements would result in the greatest increase in plant safety.
In a {{letter dated|date=December 28, 1983|text=letter dated December 28, 1983}}(15), CYAPCO specified " Containment Penetration Evaluations" as an issue to be evaluated under the auspices of the Haddam Neck Plant Integrated Safety Assessment Program (ISAP). At that time, CYAPCO informed the NRC Staff that modifications required to achieve compliance with 10CFR50, Appendix 3 would be addressed as part of the scope of ISAP. CYAPCO further stated that periodic leak rate testing at the Haddam Neck Plant, coupled with the low probability of a design basis accident, provided adequate justification for deferral of Appendix 3 modifications.
In an April 5, 1984(16) letter, the NRC Staff noted that not all containment penetrations are tested in accordance with Appendix 3. The Staf f concluded that 8603200286 860312
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6 3 it was acceptable to defer implementation of specific Appendix 3 .and Appendix A modifications until an integrated assessment, i.e., ISAP, could be performed. The basis for the Staf f's conclusion was that, although the integrated containment (Type A) leak test is not performed as frequently as local leak rate tests would be, the integrated leak rate test does provide an indication of overall containment leak-tightness, including penetrations.
In a {{letter dated|date=July 31, 1985|text=July 31,1985 letter}} (17), the NRC Staff formally established the scope of the Haddam Neck Plant ISAP and designated Appendix 3 issues as ISAP Topic 1.03,
    " Containment Penetration Evaluations." In this letter, the Staff recognized that some issues would require exemptions to defer action until such time as the Haddam Neck Plant ISAP is completed.
CYAPCO .has recently completed a comprehensive review of the status of Haddam Neck Plant compliance with the requirements of Appendix 3. The results of this review, as documented in Attachments 3 and 4, indicate the need for CYAPCO to request certain exemptions from Appendix 3 requirements as well as evaluate the need for further exemptions. Attachments I and 2 to this letter provide requests for several exemptions from the requirements of 10CFR50, Appendix 3. Those provisions from which CYAPCO is requesting permanent exemptions are addressed in Attachment 1. Attachment 2 identifies those provisions from which CYAPCO is requesting schedular exemptions, pending final resolution of Appendix 3 issues via the Haddam Neck Plant ISAP.
CYAPCO believes the exemption requests satisfy the general standards of 10CFR50.12(a). The exemptions will not endanger life or property or the common defense and security and are otherwise in the public interest. The equities of the situation are clearly balanced in favor of granting the exemptions.
CYAPCO believes the costs associated with unnecessary testing or a premature address of Appendix 3 noncompliances would clearly represent a financial burden on the company and the rate payers. The failure of the NRC Staff to provide a favorable determination on these exemption requests, e.g., to permit the integrated resolution of Appendix 3 and Appendix A issues, would substantially increase the eventual cost to comply with Appendix 3. CYAPCO has initiatcd the detailed evaluation of the scope and schedule for modifications required to achieve compliance with Appendix 3 as part of the Haddam Neck Plant ISAP in a good faith effort to comply with Appendix 3.
Unless otherwise advised by the Staff, CYAPCO plans to conduct Appendix 3 related activities during the current outage in accordance with the attached material.
_)

O s.
Pursuant to the requirements of 10CFR170.12(c), enclosed with these exemption requests is the application fee of $150.00.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY
                                                  /
(.f. Opeka       /
Senior Vice President By: W. F. Fee Executive Vice President cc:  T. E. Murley - NRC Region I

Reierences:
(1)     E. 3. Brunner letter to D. C. Switzer, dated January 2,1975, " Inspection Report No. 50-213/74-15."
(2)     D. C. Switzer letter to R. A. Purple, dated May 28,1975, " Exemption from Provisions of 10CFR50 Appendix 3."
      -(3)      D. C.' Switzer letter to R. A. Purple, dated August 20, 1976. (Special Report re Containment Operation and Testing).
(4)     D. C. Switzer letter to 'A.       Schwencer, dated December .27, 1976, j " Containment Leak Rate Testing."
(5) 'l D. C. Switzer letter to A. Schwencer, dated August 8,1977, " Proposed Exemptions to 10CFR50, Appendix 3."
(6)      D. C. Switzer letter to A. Schwencer, dated September 19,1977, " Proposed Exemptions to 10CFR50, Appendix 3."
(7)      W. G. Counsil letter to D. L. Ziemann, dated June 12,1978, " Proposed Exemptions to 10CFR50, Appendix 3."
(8)      W. G. Counsil letter to D. L. Ziemann, dated November 13,1978, " Proposed Exemptions to 10CFR50, Appendix 3."
(9)     W. G. Counsil letter to D. L. Ziemann, dated July 24,1979, " Proposed Exemptions to 10CFR50, Appendix 3."
(10)    D. M. Crutchfield letter to W. G. Counsil, dated May 7,1982, " Appendix 3 Requirements (Containment Leakage Testing)."
(11)    W. G. Counsil letter to D. M. Crutchfield, dated January 5,1983,
               " Appendix 3 Requirements."
(12)    W. G. Counsil letter to D. M. Crutchfield, dated August 16, 1983, "10CFR50 Appendix 3 Requirements, SEP Topic VI-4, Containment isolation System."
(13)    W. G. Counsil letter to W. Dircks, dated June 13,1983, " Integrated Safety Assessment Program."
(14)    W. G. Counsil letter to D. G. Eisenhut, dated September 14, 1983,
               " Integrated Safety Assessment Program."
(15)    W. G. Counsil letter to D. G. Eisenhut, dated December 28, 1983,
               " Integrated Assessment of Regulatory Requirements."
(16)     D. G. Eisenhut letter to W. G. Counsil, dated April 5,1984, " Expanded
                    ~
Integrated Assessments for Haddam Neck and Millstone Unit No.1."
(17)     H. L. Thompson letter to 3. F.'Opeka, dated July 31,1985, " Integrated Safety Assessment Program."
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