ML20011E183

Requests Approval of Schedular Exemption from 10CFR50,App J, Type C Local Leak Rate Testing Requirements by 900301,based on Interval Between Completion of Unit 1 First Refueling Outage & Second Refueling Outage Start of Only 6 Months

ML20011E183
Person / Time
Site:	South Texas
Issue date:	01/30/1990
From:	Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ST-HL-AE-3336, NUDOCS 9002090004
Download: ML20011E183 (4)

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January 30, 1990 ST llL A2-3336 File No.: G20.1~

10CFR50.12 U. S. Nuclear Regulatory Commission Attention: Document Control Desk

. Washington, DC 20555 South Texas Project Electric Cenerating. Station Unit 1 Docket No. 50 498 Request for Schedular Exemption from 10CFR Part 50, Anoendix J Tvoc C Local Leak Rate Testinc Reauirements Pursuant to 10CFR50.12, Houston Lighting & Power Company requests a one-time exemption from certain requirements of 10CFR50, Appendix J, Section III.D.3._ The exemption would specifically permit Type C tests presently- required to be performed during the Unit 1 second refueling outage

.to be_ deferred until the third refueling outage.

The basis for the request is that the interval between completion of STPEGS Unit 1:first refueling outage and the second refueling outage start is-only 6 months-(October 1989 to April 1990). Imposing the Type C tests after this short interval is unnecessarily burdensome and not technically justified for assurance of containment integrity when compared with the 24 month limit allowed by the' rule. IIL&P does-not believe such short intervals were expected when the rule was developed.

Type C tests were satisfactorily performed during the first refueling of Unit 1. Deferring the testing until the third refueling outage (April 1991) would establish an 18 month interval, still well within the span allowed by.-

the rule and the STPEGS Technical Specifications.

-The short time between the first and second refueling outages

-constitutes a special circumstance within the meaning of 10CFR50.12(a)(2) for the following reasons:

(1) Application of Appendix J,Section III.D.3 where the time since the last Type C testing is so short is not necessary to achieve the

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underlying purpose.of the regulation. The purpose of Section III,D.3 is to assure that Type C tests-are repeated at reasonable intervals, not to exceed 2 years, to verify that containment integrity is being maintained. Due to_ the unusual scheduling of the second and third Unit I refueling outages, _

< performance of the Type.C testing during the Unit 1 third refueling outage will be adequate to assure that such tests are performed at intervals no greater than 2 years. Compliance with the Technical Specifications also assures that the Type'C tests will be performed-at intervals no greater than 2 years, and that the design bases are maintained.

(2) _ Compliance with Appendix J,Section III.D.3 would result in unnecessary work scope and associated costs in excess of that contemplated when the regulation was adopted. When Section III.D.3 was adopted it was contemplated that refueling outages would be -:

scheduled at intervals of one year or more. _ However, application of the rule in the case of the short interval between the first and second Unit I refueling outages would result in requiring unnecessary repetition'of the Type C tests at substantial expense 1

_ to South Texas Project Generating Stution owners. i (3) Elimination of the requirement to repeat the Type C tests during '

the second refueling outage would: result in some reduction in radiological exposures to plant personnel associated with the ,i performance of Type C tests.

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The requested exemption would not involve a significant increase in the-probability or consequences of an accident previously evaluated; nor create the possibility of a new or different kind of accident from any accident

_previously evaluated; nor involve a significant reduction in margin of safety.

Accordingly, the. exemption involves no significant hazards consideration.

Issuance of the requested exemption is authorized by law, will not present an i l- unduo'. risk to public health and safety, and is consistent with the _ common defense and security. '

The proposed exemption would not result in a significant change in the _;

types or significant increase in che amounts of any effluent that may be  !

released off site, and there would be no significant increase in individual or ,

l cumulative occupational radiation exposure. Accordingly, the exemption u. auld j not result in a significant environmental impact. In fact, in substantially i similar circumstances, NRC regulations provide for a categorical exclusion for  !

l issuance of a license amendment which changes an inspection or surveillance  !

requirement. _F2e 10CFR51.22(c)(9).

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.Page 3 The proposed. exemption has been reviewed by the Plant Operations Review Come.ittee and the Nuclear Safety Review Board and found acceptable.

NRC approval of this request is needed by March 1, 1990 to avoid the necessity of performing the tests during the next refueling outage.

If 'you should have any questions on this matter, please contact Mr. A. W. Harrison at (512) 972-7298 or myself at (512) 972-7921.

9 G. E. Vaughn Vice President Nuclear Operations GEV/SDP/n1 .

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- SouthTexas Project Electric Generating Station

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F Regional Administrator, Region IV Rufus S. Scott

' Nuclear Regulatory Commission Associate General Counsel-

,. 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company.

O Arlington, TX 76011- P. O. Box 61867 Houston, TX 77208-George Dick, Project Manager U.S.-Nuclear Regulatory Commission INPO Washington, DC 20555. Records Center '

1100 circle-75 Parkway

-J. I. Tapia Atlanta, CA _30339 3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory' Dr. Joseph M. Hendrie Commission 50 Bellport Lano l P. O. Box 910 Be11 port, NY 11713 y

-Bay City, TX 77414 D. K., Lacker J. R. Newman, Esquire. Bureau of Radiation Control l .Newman & Holtzinger..P.C. Texas Department of Health  ;

1615 L Street N.W. 1100 West 49th Street l

~ Washington,_DC 20036 Austin, TX 78704 L D.'E. Ward /R. P. Verret ,

L Central Power 6 Light Company

l. .P. O. Box 2121 i L Corpus Christi, TX 78403 j' J. C. Lanier Director of Generation City of Austin Electric Utility 721 Barton Springs Road Austin, TX .78704

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R J . Costello/M T. Hardt-

~ City Public Service Board P.-0. Box'1771 San = Antonio, TX 78296 i

t Revised 12/15/89 L4/NRC/