ML20111C696

Forwards Affidavit of RP Barkhurst Re Power Ascension Testing Program to Be Performed at Levels Above 5% of Rated Power

ML20111C696
Person / Time
Site:	Waterford
Issue date:	03/14/1985
From:	Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Asselstine J, Palladino N, Roberts T NRC COMMISSION (OCM)
Shared Package
ML20111C698	List: ML20111C696 ML20111C702
References
CON-#185-065, CON-#185-65 OL, NUDOCS 8503150508
Download: ML20111C696 (2)

Text

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SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNEPSMID OF PROFESS 60NAL COppORAfeONS 4800 M STRECT N. W.

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Nunzio J. Palladino, Chairman -

U. S. Nuclear Regulatory Commission Washington, D. C. 28555 Thomas M. Roberts, Commissioner

U. S. Nuclear Regulatory Commission l Washington, D. C. 20555 j

James K. Asselstine, Commissioner ,

O. S. Nuclear Regulatory Commission Washington, D. C. 28555 Frederick Bernthal, Commissioner U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Lando W. Iech, Jr., Commissioner U. S. Nuclear Regulatory Commission Washington, D. C. 28555 I

In the Matter of Louisiana Power & Light Company '

(Waterford Steam Electric Station, Unit 3)

Docket- No.58-382 P/-

Dear Commissioners:

This refers to my letter to you of March 12, 1985 on behalf l of Louisiana Power & Light company concerning the schedule for I considering and implementing full-power operating authority for Waterford 3. That letter was prompted by Joint Intervenors' letters to you dated March 8 and 11, 1985, in which they re-l quested that the Com.nission defer its decision on full-power operation and defer the immediate effectiveness of any such i decision in order to allow them time to seek court review.

l

, Attached for your consideration is the affidavit of Ross P.

Barkhurst, Waterford 3 Plant Manager. The affidavit describes

! the power ascension testing program to be performed at levels l

above 5% of rated power and demonstrates that any delay in the l

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4 issuance of full-power operating authority will result in a com-mensurate, day-for-day delay in the commercial operation of l Waterford 3. Each day of unnecessary delay results in signifi- ,

i cant detriment to Applicant and the public it serves. The cost I

! is estimated to be over $1,088,888 for each day of delay.

With respect to Joint Intervenors' request for a " grace period" within which to seek review in the courts, the description of the power ascension program illustrates that there would be no significant public health and safety consideration resulting from allowing Applicant to begin its power ascension program during the short period of time within which Joint Intervenors '

! might' seek court review. The plant successfully completed its low l power testing program on March 11, and is ready for power ascen-sion. As shown in Mr. Barkhurst's affidavit, power ascension is gradual and intermittent, and the program is projected to i require 184 days to complete. During the first 12 days, power is

gradually increased, and does not exceed 28% of full power. Full  !

l power is not even reached until 84 days af ter the start of the j program. Considering the care and rigor with which each step is i evaluated and problems corrected before proceeding to the next j step, these periods could be even longer.

i~

The Waterford 3 safety analysis shows that the plant meets the Commission's requirements under full-power operation and with

, full-term fission product. inventories. As with the previously

! authorized 54 power operation, the fission product inventory

! developed during the first 12 days, when power does not exceed 28%

! of full power, is a very small fraction of the full-term, full-power inventory for which the plant has been successfully

evaluated.

l l Immediate effectiveness of operating authority would not preclude Joint Intervenors from seeking court review. Given a l Commission determination that Waterford 3 is ready for safe l operation at full-power, there would be no public health and safety reason for delaying such operating authority for even a brief period for Joint Intervenors to seek court review. As noted, any further delay will be severely costly to Applicant and the ratepaying public.

l Sincerely yours, i 1

l i

c liWt! il Counsel for Applicant cca Service List (attached) ,

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