ML20059G692
| ML20059G692 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/02/1993 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP2L-1450, NUDOCS 9311090007 | |
| Download: ML20059G692 (3) | |
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M Y NIAGARA
~,R UMOHAWK s
N1AGARA MOHAWK POWER coRPoRATON 'NINE MILE POINT, PO BOX 63. LYCOMING. NY 13093/ TELEPHONE (315) 349-2882 B. Ralph Sylvia Executive Vice President Nuclear November 2,1993 NMP2L 1450 j
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 l
RE: Nine Mile Point Unit 2 Docket No. 50-410 NPF-69 Gentlemen:
On September 28,1993, Niagara Mohawk submitted an Application for Amendment (NMP2L 1447) to the Nine Mile Point Unit 2 Operating License NPF-69. Included were proposed changes to the Technical Specifications which would allow for the performance of
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inservice leakage or hydrostatic testing with reactor coolant temperature up to 212*F while remaining in OPERATIONAL CONDITION 4 provided that certain OPERATIONAL CONDITION 3 Limiting Conditions for Operation (LCO's) are met.
The current Technical Specifications require that reactor coolant system (RCS) temperature j
be maintained between 160 F and 200 F during inservice leakage or hydrostatic testing.
Specification 3/4.4.6, " Pressure / Temperature Limits Reactor Coolant System," requires a minimum RCS temperature of 160"F during inservice or hydrostatic testing and Table 1.2,
" OPERATIONAL CONDITIONS," limits the maximum RCS temperature for OPERATIONAL CONDITION 4 to 200*F. However, because of decay heat associated with the fuel and mechanical heat associated with recirculation pump operation, historically it has been difficult to keep the temperature below 200*F. Additionally, higher levels of decay heat are anticipated for testing during the current outage, since the duration of this refueling outage will be significantly shorter than any previous refueling outage. Therefore, it will be even more difficult to limit reactor coolant temperature.
This letter is a request to process the September 28,1993, Application for Amendment on an exigent basis pursuant to 10CFR50.91 (a) (6) based on the following considerations:
Statement of Erigent Circumstances Approval of the above mentioned amendment was requested on a priority basis in order to support the refueling outage schedule, which included a hydrostatic test on November 13, 1993. The hydrostatic test based on current outage projections, may be 08n025 t)f 9311090007 931102 W
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Fage 2 performed as early as November 12,1993, which is one day earlier than originally scheduled. The schedule has advanced because contingencies built into the schedule based on past experience have not been required for this outage. Examples are: 1) i fuel moves which have progressed faster than anticipated; 2) faster vessel assembly / disassembly with new tools; 3) diesel generator inspections completed ahead j
of schedule; and 4) ability to recover from problems sooner than in past outages.
Also, OPERATIONAL CONDITION 3 requires primary containment as well as various other HOT SHUTDOWN systems to be operable. This would hinder piping inspection within primary containment, thereby lengthening the duration of the hydrostatic test.
Reason %7tv the Situation Could Not Have Been Avoided On May 7,1993, Niagara Mohawk submitted an Application for Amendment consistent with NUREG-1433, " Improved Technical Specifications," issued Septe:nber 28,1992. However, based on an agreement reached with the Staff we withdrew the application and stated that we would re-evaluate incorporation of the NUREG provisions at a later date. Since the hydrostatic test is critical path for this refueling outage, the May 7,1993, submittal was superseded by a plant specific application expeditiously submitted on September 28,1993. This application was i
noticed in the Federal Register on October 13, 1993. The Sholly notice period expires on November 12,1993, which is the projected date for the hydrostatic test.
Based on the justification provided above and current outage projections which indicate that the hydrostatic test may be performed as early as November 12,1993, it is requested that this amendment be approved by November 10, 1993.
t Very truly yours,
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B. Ralph Sylvia Exec. Vice President - Nuclear MGM/Imc xc:
Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. R. A. Capra, Director, Project Directorate I-1, NRR Mr. J. E. Menning, Project Manager, NRR 4
Ms. Donna Ross i
Division of Policy Analysis and Planning New York State Energy Office Agency Building 2 Empire State Plaza Albany, NY 12223 Records Management
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Niagara Mohawk Power Corporation
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Docket No. 50-410
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(Nine Mile Point Unit 2)
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AJFIDAVIT
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B. Ralph Sylvia, being duly sworn, states that he is Exec. Vice President - Nuclear of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and
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belief.
i Wris Ab B. Ralphdylvia/
Exec. Vice President-Nuclear i
Subscribed nd sworn to before me, a Notary Public in apd for the State of New York and County o b o t dog 6,this 3ed day of Al A/h har,1993.
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/' bddG County, New York JGNT PARKNSON Natary Pdde State of NY OasBRnd Onon Ce No 11 My Cmwm Exp May 31.
I My Commission expires:
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