ML20127A463

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Recommends Commission Concurrence Re Process of Issuing Exemptions Deemed Warranted for Issues Described in Integrated Plant Safety Assessment Repts for SEP Plants
ML20127A463
Person / Time
Site: Millstone, Dresden, Palisades, Oyster Creek, Haddam Neck, Ginna, San Onofre, Yankee Rowe, La Crosse, Big Rock Point
Issue date: 04/14/1987
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20127A467 List:
References
FOIA-92-500, TASK-PINV, TASK-SE SECY-87-100, NUDOCS 8706030176
Download: ML20127A463 (14)
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POLICY ISSUE (Notation Vote); j April 14, 1987- SECY-87-100.

For: The tcranissioners From: Victor Stello, Jr.

Executive Director-for Operations Subiect: SYSTEMATIC EVttt'AT:0N FROGRAM (SEF) FLANT EXEMPTIONS' Purcose: To obtain Ccmissien concurrence on the crecess of

  • issuint exemptions c'eemeo warrartec - for issues described 'in the Integrated Plant- Safety Assessirent Reports (IPSARS)lfor -

the SEP Plants. The purpose e' this activity is to procerly reflect in facility 1 1 censes deviaticni _from regulatory, requirements identified in the review'of the SEP oiants.

Cateoorv: This paper presents a oclicy issue on the' process' of-issuino exemptions for the SED Flants.

Backcround: Ly memorance cated January U 6nd Sovember IS, Ic77, from Samuel J. Chilk, Secretary, to 1.ee V Gossick, Exoct.tiver Director for 0perations, entitled, "SECY-7f.-545 -L Ccmission -

Guidance on NU Systematic Evalestion Program;for Operating -

Reacters," and Staff Heeuiratents Policy Session- 77-51",.

regarding "SECY-7'-561 - Syrtenatic Evaluation of Operating 9eactors - Phases 1?,1-", the Comission aperoved the imple-reentation and continuation of the Cystematic' Evaluation 'of Operating Peactors Program Plan. The SEP, in sumarv,11s a-program which was established _for the purpose of-evaluating older operating nuclear reactors to determine the degree te- 4 which they meet current licensing requirements. The .

proaram providei'or the development of an overail balanced technical position concerning any needed backfittirg of the evaluated facilities'and documenting-the results of the evaluations performed in the form of an IPSAR.

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~l The Ccmissicners As described in SECY-76-545 and-SECY-77-561, the NRR staff recognized that there was a need to document thoroughly evaluations of the disparity between current technical positions on safety issues and those that existed when a particular plant was licensed with the end purpose of effectively and justifiably confinning the level of safety provided in older operating plants and to maintain documen--

tation of the acceptability of that level of safety. The SEP objectives were established to include:

1. Assessment of the safety adequacy of the design and operation of currently licensed nuclear power plants.
2. Documentation which establishes how each operating plant reviewed compares with current criteria on significant safety issues and provide a rationale for acceptable departures from those criteria.
3. Capability te rake integrated and balanced decisions with respect to reouired backfitting and including early identi-fication and resolution of any significant deficiencies.
4. Efficiently use available resources and minimize recuirements for additional resources-by NPC or. industry.

In March.1977, NRp established an SEP Deview Group. The primary responsibility of the Review Group during Phase I of the SEP was to develop a cceprehensive list of all significant safety issues / topics to be used as a basis for performing-systematic evaluations of the operating reactors.

The original Phase II of the SEP, as outlined in SECY-76-545 recomended the review of the eight plants for which operating licenses had been issued prior to 1969. Because of the.

uncertainty of the future cperation of Dresden 1 and Humboldt Pay Unit No. 3, at that time, the staff deferred the review of these two facilities. As. proposed in SECY-77-561, and approved by a vote of 4-0, the Comission expanded- the SEP to include five nuclear power plants with Provisional Operating Licenses at the time. Dresden 1 was subsequently dropped frem the evaluation list because of the announcement of plans to decomission the plant. Humboldt Bay also subsequently announced plans to decomission.

As of December 18, 1986 all of the IPSARs have been issued in final form (See Enclosure 1 for the list of plants included in the SEP).

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,4 The Comissioners Discussion: The_SEP was initiated to-re-evaluate the? design and operation

.of older operating plants in order to provide a comprehensive-documentation of their safety in light of current licensing.

requirements.

As a result of the completion of the IPSAR, plant-specific equipment modifications and procedural- changes for all ten .

of the evaluated plants have been identified. :Various completion schedules for-the identified changes' have been established for each of the respective SEP plants.- For; _ -.

example, Big Rock Point has established a fonnal! Integrated.

Schedule as part of the Facility Operating 1.icense which incorporates, as appropriate, all of'the-IPSAD generated issues. These issues, as wellfas other facility and NPC '

initiated issues, have established completion schedules which-are governed by' the Integrated Schedule Plan. In all cases each SEP facility IPSAR identified.'necessary facility changes.

of which many have already been implemented.. Certain technical issue topic evaluations,.however,'are still under. ,

. evaluation. For these topics, supplements to the !PSAR-are being issued.

For all evaluated plants, the conclusions-derived in the? .

respective IPSARs include facility modifications and_' procedure changes. In some instances, deviations from the.recuirements'.

of some Ccmission regulations -(e.g., the' General; Design Criteria (GDCU were identified during:the course of the review. Each was screened to assure;that it did not pose a-short -term safety. concern; thereafter, each was: evaluated to identify the safety need for--and proposed methods of-satis-fying the regulations-or the adequacy of proposed compensatorya measures. In some instances, as discussed:in__ the applicable IPSAR, the licensee demonstrated an- adequate _ margin of safety despite a departure from a particular regulatory-requirement.

In other instances the licensee proposed or demonstrated -l

'adecuatelcorrpensatory measures. However.lin'both! instances,-

these deviations _would necessitate exemptions from Commission regulations. Deviations from Comission : regulations were .

deemed acceptable only if -the _NRR- staff- evaluation showed that the plant will. respond . satisfactorily to all:' design basis

-events or the. consequences of.its, occurrence are'not signifi -

cantly higher than for a plant licensed-in'accordance with current criteria.- In every case, therefore, exemption bases l

-from the existing regulations have_ evolved for varicus plant l q

technical issues. The identification of the~ technical areas i where an exemption may be necessary and the technical;suppor.t for the safety rationale for granting the exemption is > I presented in the plant-specific IPSARs. - Examples of such conclusions have been provided.in Enclosure _2.

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+. i The Commissioners From'the outset of the SEP, it was recognized that a large number of deviations from " current regulatory standards" would likely be identified during implementation _ of the program. The likelihood that these would include a number of instances of non-compliance with the GDC and other Commission regulations was also recognized. It was a fundamental element of the SEP program that, unless such deviations posed a threat to reactor or radiological- safety, NRC actions _tn correct such deviations, if any, would not be taken on ;

piecemeal basis but rather on an " integrated" basis at tne cor.clusion of the integrated assessment o' plant safety as a -

whole with no civil penalty for continued operation. In this-

'ashion, it was envisioned that perhaps a single order covering an optimum corrective action orngram could be used rather then a plethora of individual orders or other actions correcting individual instances of nonconDliance. At the same time, it was recoenized that based on an inteorated assessment o# plant safety, it nicht well be detennined that in particular cases',

literal compliance with specific GDCs would not be necessarv to assure safety and that exemptions would be warranted. .

Agair, except in unusual cases, this judgment was to. await the-conpletion of the integrated assessment. In.short, for SEP deviations which were screened and judged not to pose a' threat to safety, the NDC exercised its enforcemert discretion for the period of the SEP program so as +o determine appropriate action-on the basis of an integrated assessment of plant safety.

Although identified in the app.licable' IPSARs, the identified deviations # rom the Commission regulations and related ccm-pensatory measures have not been re'lected in formal licensing -

documents (the t.icense and related Technical Specifications, Orders, or Exemptions). In order to bring the SEP process to a close and to return the SEP plants to the traditional licensing framework requiring compliance with Comission regulatiens r.xcept to the extent that exemptions have been granted, it is now appropriate to consider grantino exenptions for the deviations identified in the varicus_ facility IPSARs. <

Based on the analysis sumaries contained in the plant-specific IPSAPs, exemptions identi#ied wculd cuali'y #nr exemption relief under 10 CFR 50.12/aWil, i.e. , will not present an undue risk to public health and safety and are consistent with common defense and security in accordance with 10 CFR 50.12failli.

The SEP process provided an integrated assessment of the-safety of older plants based on the current regulatory criteria and on updated technical insights and methodology.

The SEP process of evaluation censisted of an integrative analysis which u..

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The Commissioners and/or sound engineering judgments, The NRR staff believes this process provides a sound basis for alternatives to strict adherence to .the regulations, as interpreted by regulatory guides and the Standard Review Plan, such that it fulfills the underlying purpose of the Commission's regulations. A number of examples of the type of regulations for which exemptions would be granted for a sample of plants has been included as Enclosure 2. In each of the areas in which deviations from regulations have been approved, the SEP process, as reflected in the IPSARs, has assured that there is an adeouate level of reactor safety.

It is the staff's position that all of the proposed individual the special circumstances criterion in exemptions 10 CFR 50.12(a)(2) (ii), in which application of the regulation satisfy would not serve the underlying purpose o# the rule or is not necessary to achieve the underlying purpose of the rule, because of the nature of SEP process. "he SEP process was prograrmatically approved by the Commission for the specific purpose of conductina a comprehensive integrated evaluation cf the safety of older plants based on current technical insights and methodology. This has resulted in irtegrated tecFnical evaluations with subsecuent findings of an adequate level of safety. In conducting these technical evaluations the staff censidered the safety significance of the deviations, as well as the existence of alternative means of compliance. Therefore, the staff believes it is appropriate for the Commission to apply the special circumstances criterion in 10 CFR 50.12 f a)(2)(ii) to all SEP exemptions.

In consideration of the information presented, the staff proposes that there should be a consistent and coordinated procedure for processing these exemptions, as a result, the following-actions are proposed by the staff:

1. The Integrated Safety Assessment Profect Directorate in NRR will construct listir.gs of the affected GDC and other regulations as appropriate for each SEP plant. Table 4.1 in each IPSAR identifies all of the differences identified during the SEP reviews and their disposition. The corresponding IPSAR text usually identifies the specific GDC or regulation involved. This infortnation will be used to construct a first-cut of the exemptions required for the Operating Reactor Project Managers (0RPMs) to review (See Enclosure- 11,
2. The ORPMs will arrange a meeting with their respective licensees to review the exemption list and. discuss a manageable procedure for the licensee to submit a formal recuest for exemption.

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3. A standard format will be develnped for ~ integrated exemption approval. The integrated exeeption will address all apprepriate GDC and regulations identified in the plant ,

IPSAR, specifically, fi) where no licensee action was required and an exemption was found to be warranted by the staff, (ii) for those. items where licensee action was-required and implementation has been completed, and (iiii for those items where recommended -licensee actions.are not '

yet completed; for this cateoory, the exemption would be contingent upon completion.

4. Af ter the use of this process to approve exemptions . .

identified in the IPSARs and their Supplements, all future proposed exemptions for these plants will be considered under normal exemption processing procedures.

Decommenda tion: That the Commission:

1. Approve the procedure for processire the SEP IPSaR identified exemptions.
2. Note the Office of General Counse' has reviewed this paper ind has no legal objection to the raterial therein.

Schedul ine: If scheduled on the Commission acenda, the staff recomrends that this issue be considered at an oper meetino. So specific circumstances are known by the staf# which would require Commissior action by any particular date in the near term.

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VTctor Stellos'yr'.

Executive Director for Operations

Enclosures:

-1. First-cut of Recuired Exemptions for SEP Plants

2. Sample of Deviations i

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Commissioners' comments or consent should be provided directly -

to the office of the Secretary by c.o.b. Thursday, April 30, 1987 --

t commission Staff office comments, if any, should be submitted-to the Commissioners NLT Thursday, t.pril 23, 1987,.with an information copy to the office of the Secretary. If the paper  !

is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the  ;

Secretariat should be apprised of when comme..ts may be expected. ,

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ENCLOSURE 1 Page 1 of 4 FIRST-CUT PRELIMINARY LIST OF EXEMPTIONS FR5F"5ERERAL DESIGN CRITGI A AND OTHER REGULATIONS IPSAR SEP General Other Section Topic Design Reg.

Number Number Criteri6 Regts. Subject BIG ROCK POINT - DOCKET NUMBER 50-155 04.04 03-01 01 APP. B QUALITY GROUP 04.05 03-02 02 WIND / TORNADO MISSILES 04.10 03 05.A 04 PIPE BREAK INSIDE CONTAINMENT 04.12 03-06 02 SEISMIC CESIGN/ LOADS 04.20.02 06-04 55 56 57 CONT. ISOL. - INSTRUMENT LINKS 04.20.03 55 56 CONT. ISCL. - LOCAL MANUAL 04.20.04A 55 56 CONT. ISOL. - AIR SYS. LEAK TEST 04.20.05 55 56 CONT. ISOL. - MSIV 04.20.06 57 CONT. ISOL. - CLOSED SYSTEMS-04.20.07.01 APP. J CONT. ISOL. - AIRLOCK TESTING 04.20.07.02 APP. J CONT. ISOL. - MSIV/0 RAIN TEST '

04.20.07.03 APP. J CONT. ISOL. - TEST CLOSED SYSTEM 04.22 07-10.A 24 RPS ISCLATION 04.24 08-04 50 CONT. ELECTRICAL PENETRATIONS DRESDEN UNIT 2 - DOCKET NUMBER 50-237 04.02 03-01 01 APP. B QUALITY GROUP 04.08 03-05.8 04 PIPE BREAK OUTSIDE CONTAINMENT

-04.10 03-07.B 01 02 04 DESIGN CODES, LOAD COMBINATION 04.18.04 06-04 55 56 CONT. ISOL. - CHECK VALVES 04.18.05 55 CONT. ISOL. - LOCATION 04.21.01 06 07.01 17 ABT - BREAKER ADEQUACY 04.21.05 17 ISOLATICN FROM NON-1E LOADS '

04.23.01 06-10.B 05 SHARED DC SYSTEMS 04.24.01 07-91.A 24 RPS ISOLATION - CONTROLS /

COMPUTER GINNA - DOCKET NUMBER 50-244 04.03 02-03.B 02 DEER CREEK FLOODING 04.08 03-02 02 STRUCTURAL UPGRADE 04.13.03 03-05.A 04 PIPE BREAK INSIDE CONTAINMENT -

FRACTURE MECHANICS 04.14D 03-05.B 04 PIPE BREAK OUTSIDE CONT. - MS/MF LINES

3 Page 2 of 4 FIRST-CUT PRELIMINARY _ LIST OF EXEMPTIONS FROM GENERAL DESIGN CRITERIA AND OTRER REGULATION 5 IPSAR SEP General Other Section Topic Design Reg.

Number Number Criteria Regts. Subject 04.17.01 03-07.B 50 CONT. LINER INSULATION 04.22.01 06-04 55 56 57 CONT.-ISOL. - BOTH OUTSIDC-04.22.02A 55 56 CONT. ISOL. - ONE VALVE 04.22.02B 55 56 CONT. ISOL. - SEAL RETURN 04.22.03A 56 CONT. ISOL - SMALL LINES CV 04.22.04 56 57 CONT. ISOL. - CLOSED SYSTEM 03.03.09 06-04 50 CONT. ELECTRICAL PENETRATIONS HADDAM NECK - DOCKET NUMBER 50-213 04.01.02 02-03.B1 02 SITE FLOODING 04.02 03-01 01 APP. B QUALITY GROUP 04.03 03-02 02 WINDS AND TORNADO MISSILES 04.08 03-05.A 04 PIPE BREAKS INSIDE CONT.

04.10.03 03-06 02 SEISMIC PIPING 04.10.04 02 SEISMIC - ELECTRICAL / MECHANICAL 04.11 03 07.B 01 02 04 DESIGN CODES, LOAD COMBINATIONS-04.22.01 06-04 55 56 CONT. ISOL. - LOCATION . .

04.22.02 55 56 CONT. ISOL. - CHECK VALVES 04.22.05 55 56 CONT. ISOL - REDUNDANCY 04.24.01 06-07.C.01 17 OJSITF AC - ABT 04.26 07-01.A 24 RPS ISOLATION 04.27 07-03 17 ELECTRICAL DISTRIBUTION 04.34 15-01 10 15 FW FLCW INCREASE LACROSSE - DOCKET NUMBER 50-409 04.05 03-01 01 APP. B QUALITY GROUP 04.06 03-02 02 PART 100 INTEGRATED CONSEQUENCE STUDY 04.13 03-06 02 SEISMIC ANALYSIS 04.14 03 07.B 01 02 04 DESIGN CODES, LOAD COMBINATIONS 04.21.01.01 06-04 56 57 CONT. ISOL. - PROCEDURES 04.21.01.02 56 CONT.- ISOL. - VALVE LOCATION 04.21.01.04 57 .CCNT. ISOL. - SCS ATM. VENT.

04.21.02.03 55 CONT. ISOL. MANUAL VALVE MOVED 04.21.02.04 56- CONT. ISOL. - CHECK VALVES 04.21.03.02 55 CONT. ISOL. - SDC OffGAS VENT 04.21.03.04 57 CONT. ISOL. - CHECK VALVE 04.21.04 56 CONT. ISOL. - RM/ PROCEDURES 04.26.01 07.01.A 24 RPS ISOLATION - METERS &

RECORDERS 04.26.02 24 RPS ISOLATION - QUALIFICATION 04.27 08-01.A- 17 _ DEGRADED GRID - LOP

Page 3 of 4-FIRST-CUT PRELIMINARY LIST OF EXEMPTIONS '

FROR~EENERAL DEITCFCRITHIA AND OTRER-'REUUDTIONS IPSAR SEP General Other Section Topic Design Reg.

Number Number Criteria Regts. Subject MILLSTONE UNIT 1 - DOCKET NUMBER 50-245 04.02 02-04.F 02 PILE FOUNDATIONS / PEAT 04.03 03-01 01 APP. 8 QUALITY GROUP 04.04 03-02 02 WIND /TORNAD0/ MISSILES 04.10 03-05.B 04 PIPE BREAK OUTSIDE CONT.

04.12 03-07.B 01 02 04 DESIGN CODES, l.0AD COMBINATIONS 04.20.04 06 04 56 CONT. ISOL. - LOCATION 04.20.05 56 CONT. ISOL. - INSTRUMENT 04.20.06 55 56 CONT. ISOL. - CHECK VALVES 04.20.07 55 CONT. ISOL. - BRANCH LINES 04.23.01 06-07.01 17 AUTOMATIC BUS TRANSFERS 04.25.01 07-01.A 24 RPS ISOLATION - METERS 04.26 07-03 13 17 19 34 CR INSTRUMENTS - FAILURE OYSTER CREEK - DOCKET NUMBER 50-219 04.02 03-01 - 01 APP. B QUALITY GROUP 04.03 03-02 02 WIND AND TORNADOES 04.10 03-05.B 04 EMERGENCY CONDENSER 04.12 03-07.B 01 02 04 DESIGN CODES, LOAD COMBINATIONS 04.22.03 06-04 55 CONT. ISOL. - LOCATION 04.22.04 56 CONT. ISOL. - INSTRUMENTS 04.22.05 55 56 CONT. ISOL. CUECK VALVES 04.24 06-07.A4 35 APP. K CORE SPRAY N0ZZLE 04,23 06-07.01 17 AUTOMATIC BUS TRANSFERS 04.27.01 07-01.A 24 RPS ISOLATION - FMEA 04.30 07-03 13 17 19 34 CR INSTRUMENTS - FAILURE 04.33 08-04 50 CONT. ELECTRICAL PENETRATIONS PALISADES - DOCKET NUMBER 50-255 04.09 03-05.A 04 PIPE BREAK INSIDE CONT.

04.18 06-02.D 16 38 50 50.49 MSLB-CONTAINMENT 04.20.01 06-04 55 56 57 CONTAINMENT ISOLATION - LOCATION l

i 04.26 08-04 50 CONT. ELECTRICAL PENETRATIONS 04.30 15-02 34 MSLB-MSIV FAILURE SAN ON0FRE UNIT 1 - DOCKET NUMBER 50-206

[ 04.01.03 02-01.C 04 19 CONTROL ROOM VENTILATION i 04.04 03-01 01 APP. B QUALITY GROUP 04.05 03 02 WINDS / TORNADO MISSILES l

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Page 4 of 4 FIRST-CUT PRELIMINARY LIST OF EXEMPTIONS FROM GENERAL DE5TGF MITERIA AND

~0TRER REGULATIONS IPSAR SEP General Other Section Topic Design Reg.

Number Number Criteria Regts. Subject 04.06 03-03.A 02 GROUN0 WATER 04.09 03-05.A 04 PIPE BREAK INSIDE CONT.

04.10 03-05.B 04 PIPE BREAK OUTSIDE CONT.

04.12 03-07.B 01 02 04 DESIGN CODES, LOADS 04.13 03-07.0 16 50 CONTAINMENT INTEGRITY 04.23.02 06-04 55 56 CONT. - !$0L - RM VALVES 04.23.03 56 57 CONT. ISOL. - CHECK VALVES 04.23.04 56 CONT. ISOL. - LOCATION 04.23.05 57 CONT. ISOL. - CLOSED SYSTEM 04.25.04 06-07.02 35 ECCS - FMEA STUDIES 04.27 07-01.A 24 RPS ISOLATION 04.31 08-04 50 CONT. ELECTRICAL PENETRATIONS 04.35 15-01 10 15 FW FLOW INCREASE 04.36 15-02 34 HSLB YANKEE - DOCKET NUMBER 50-029 04.01.02 02-03.B1 02 PROBABLE MAXIMUM PRECIPITATION 04.01.03 02 PROBABLE MAXIMUM FLOOD 04.01.04 02 LOCAL SITE FLOODING 04.01.06 02 DAM FAILURE 04.01.08 02-03.C 02 EMERGENCY PROCEDURES 04.04 03-01 01 APP. B QllALITY GROUP 04.05 03-02 02 WIND AND TORNADOES 04.09 03-05.A 04 PIPE BREAK INSIDE CONT.

04.11.01 03-06 02 SEISMIC - STRUCTURES 04.11.02 02 SEISHIC - PIPING 04.11.03 02 SEISMIC - MECHANICAL 04.11.04 02 SEISMIC - ELECTRICAL 04.12A 03-07.B 01 02 04 DESIGN CHANGES 04.12B 03-07.8 02 SNOW LOADS 04.22.01 06-04 55 56 CONT. ISOL. - REDUNDANCY 04.22.02 55 56 57 CONT. ISOL. - CHECK VALVE 04.22.05 55 CONT. ISOL. - LOCATION 04.22.11 55 56 CONT. ISOL, - VENT LINES 04.26 07-03 13 17 19 34 CR INSTRUMENTS - FAILURE 04.29 08-04 50 CONT. ELECTRICAL PENETRATIONS 04.33 15-04 10 15 26 LOSS OF AC POWER 04.34 15-07 10 15 26 PART 100 RCP SEIZURE

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i. ENCLOSURE 2 Page 1 of 3 .

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DEVIAll0N TYPES

)' (FOR WHICil EXEMPTIONS MAY BE GRANTED) ,

.i i- Applicable Abbreviated IPSAR Deviation scility Regulation Subject Basis for Exemption

! ig Rock Point GDC-55, 56 RCS Pressure Boundary Main steam line is equipped The NRR staff agrees with the

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Penetrating Contain- with only a single isolation licensee's PRA evaluation which

, ment; Primary Contain- valve; rather than redundant shows little person rem / reactor ment'Isciation itolation valves. year savings from the addition

'of a second isolation valve; I' the conclusion is also based in a

part upon the conservative as-sumptions in the offsite dose evaluations performed in conjunc-tion with SEP Topic XV-19.

iq Rock Point GOC-50 Containment Design with a LOCA environment ir - Six different PRAs, including

?. Basis - Electrical side containnent, tte '.aw- the ]jCensees and the NRR staff's, 4

Penetrations voltage penetratiors do not concluded that no dominant acci-comply with.the current dent sequence involved electrical a criteria. penetration failure as a release mechanism. Failure of electrical penetrations is less significant because the potential leak paths are much smaller than those for  !

piping and containment ventilation.

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! resden 2 GDC-4 Environmental and No stress data are available A limited PRA of the importance of '

Missile Design Basis - to demonstrate that the the various postulated pipe breaks '

Pipe Break Outside piping between the contain- as unisolable LOCAs showed that the 4 Containment. ment penetration area and LOCA frequencies associated with 3

the isolation valves outside these pipe breaks are all less containment for the Main than 2 X 10 7 per year, since Steam Isolation Condenser both a pipe break outside contain-

, and Reactor Water Cleanup ment and a failure of an isolation

System complies with current- valve inside containment are criteria. necessary; Importance to risk is low.

ENCLOSURE 2 Pcge 2 cf 3

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DEVIATION TYPES (FOR WillCil EXEMPIIONS MAY BE GRANTED) i Applicable Abbreviated IPSAR acility Regulation Subject Deviation Basis for Exemption

.INNA GDC-4 Environmental and The effect of pipe breaks Based on a conservative fracture Missile Design Basis - inside containment was not mechanics analysis, leak detection Pipe' Break Inside part of the original design systems available, and the Inservice .

Containment basis; specifically the Inspection Program, adequate protec-accumulator and pressurizer tion against the effects of pipe surge line. break for these two lines has been provided.

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INNA GDC-50 Containment Design The containment liner . Based on the licensees

  • evaluation Basis - Containment insulation is provided and the NRR staff evaluation, the Liner Construction for. limiting temperature staff concluded that, although stud.

rise curing a LOCA of the failure may occur .there is reason-inside surface of the con- able assurance that any such f ail-crete in the cylindrical ure will occur in the stud and that

' portion of the structure. the liner will retain its leaktight l The liner in the dome integrity.

is not insulated.. This discontinuity will cause high thermal stresses in the liner and could result in the liner buckling and failing.

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ENCLOSURE 2 -

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,b DEVIATION TYPES (FOR WHICH EXEMPi10NS MAY BE GRANTED) .

Applicable Abbreviated IPSAR acility Regulation Subject Deviation Basis for Exemption acrosse GDC-17 Electric Power Systems; There is only one source of Plant design is such that the  ;

Offsite Power Systems offsite power. facility can be safety shut down for Structures, Systems without any offsite power and also and Components important without the two onsite diesel-to Safety generators. Shutdown can be accom-plished through the use of two diesel driven pumps or an emergency service

. water supply system consisting of three gasoline-driven pumps and one.

back up; the gasoline-driven pumps can be used to achieve cold shutdown.

aCrosse GDC-1 Quality Standard and Insufficient information Licensee completed additional evalu-Records existed in certain areas; ations, the results of which were radiography, fracture included in the updated FSAR.

toughness, piping, valves, Section 3.9 of the updated FSAR pumps, storage tanks. describes.the radiography that was performed and the inservice inspec-tion and testing programs. No in-adequate components have been identified.

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