ML20127J275

Application for Amend to License NPF-19,changing Tech Spec 3.10.5 to Allow Suspension of Tech Spec 3.6.6.2 During Performance of Startup Test Program Until Reactor Has Operated 120 EFPD

ML20127J275
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/19/1985
From:	Leonard J LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20127J278	List: ML20127J275 SNRC-1181, Proposed Tech Spec 3.10.5 Suspending Provisions of Tech Spec 3.6.6.2 During Performance of Startup Test Program Until Reactor Has Operated for 120 EFPD
References
SNRC-1181, NUDOCS 8506260538
Download: ML20127J275 (3)

Text

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k mm wene;.ug LONG ISLAND LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION P.O. BOX 610, NORTH COUNTRY ROAD e WADING RIVER, N.Y.11792 JOHN D. LEONARD, JR.

VICE PRESIDENT NUCLEAR OPERATIONS June 19, 1985 SNRC-1181 Mr. liarold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Inerting of Containment Shoreham Nuclear Power Station-Unit 1 Docket No. 50-322

Dear Mr. Denton:

Technical Specification 3.6.6.2, Drywell and Suppression Chamber Oxygen Concentration, requires inerting within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of reaching 15% of rated power. Effective six months after initial criticality,10 CFR 50.44 (c) (3) (i) requires MARK II containments to have an inerted atmosphere.

Technical Specification 3.10.5, oxygen Concentration - Limiting Conditions for Operations, provides an exception to this inerting requirement for "6 months after initial criticality", to permit performance of the startup test program. The Shoreham Nuclear Power Station (SNPS) attained initial criticality February 15, 1985. Siace that time, suspension of the low power license (above 0.001% power) has delayed additional testing or power ascension procedures.

The low power testing and the power ascension testing programs require frequent (approximately 15-20) observations necessitating access to the primary containment. Typical activities are:

1. Reading displacement instrumentation for the thermal expansion and vibration testing program.

2. Visual observation of piping displacements to check for piping interferences.

It is a certainty that this testing will continue beyond August 15, 1985. An inerted primary containment would make this work impossible.

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SNRC-1181 P ga 2' LILCO, therefore, proposes that Technical Specifications 3.10.5 be changed to allow suspension of Technical Specification 3.6.6.2 until the reactor has operated 120 effective full power days. A revised Technical Specification page 3/4 10-5 is attached for your use.

Technically, this change requires an exemption from 10CFR50.44, LILCO believes the proposed wording meets the intent of the regulation and that the ' exigent circumstances' favor the granting of an exemption under 10CFR50.12 (a) . Similar relief has been granted to other recent vintage BWR plants to facilitate completion of their power ascension testing.

With respect to the ' exigent circumstances,' LILCO represents the following a) The Stage of the Facility's Life SNPS is a completed plant. The Technical Specification change and regulation exemption are required to facilitate power ascension testing presently scheduled to occur approximately two weeks after issuance of a full power license.

b) Financial or Economic Hardships If the sought exemption is not granted, power ascension testing can only be accomplished with extensive delays caused by repeated deinerting and reinerting. These delays will have substantial financial and economic impact.

c) Internal Inconsistencies in the Regulations LILCO does not contend that the regulation 10CFR50.44 (c) (3) (1) contains an internal inconsistency. However, LILCO believes that the regulation, as written, does not properly allow for any delays in the licensing process.

d) Applicant's Good Faith Effort to Comply with the Regulation The proposed wording change meets the intent of the regulation and provides a reasonable basis to perform the power ascension test phase of the operation of SNPS.

c) The Public Interest in Adherence to the Commission's Regulations Where an exemption will have no effect on the public health and safety and will promote efficiency and expedition in the licensing process, the public interest requires granting the exemption.

SNRC-ll81 Pcg3 3 f) Safety Significance of the Issues Involved LILCO believes there is no safety significance to the requested Technical Specification change or exemption from the regulation.

There would be no added risk to the public under the proposed rewording over that which would exist if the regulation could be followed. This statement is justified by the following:

1. This change does not affect the probability of any accident previously evaluated in the FSAR nor will the-possibility of a new or different accident be created.

2. This change does not affect the consequences of any accident previously evaluated in the FSAR.

3. Since this change does not Tnvolve any equipments a) The probability of a malfunction of safety related equipment previously evaluated in the FSAR will not be increased.

b) The consequences of a malfunction of safety related equipment previously evaluated in the FSAR will not be increased.

c) The possibility of malfunction of safety related equipment different than any already evaluated in the FSAR will not be created.

4. The margin of safety as defined in the bases to any Technical specifications will not be reduced.

LILCO concludes that no significant hazards are involved.

LILCO requests that the exemption be effective upon issuance of a full power license and that appropriately worded technical specifications be included therein.

We trust the attached /information is satisfactory for considering our request. If your staff requires additional information, do not hesitate to contact this office.

Very truly ours, r

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ohn Vihe President - Nt(c1 ar Operations PGb/cf (_j Attachment cca P. Eselgroth Mr. Jay Dunkleberger New York State Energy Office