ML20127P464
| ML20127P464 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/20/1985 |
| From: | Boyer V, Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| References | |
| CON-#285-121 NUDOCS 8505240003 | |
| Download: ML20127P464 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.Oi. BOX 8699 PHILADELPHIA. PA.19101 (215)841 4500 V. S. BOY E R SR. VICE PRESIDENT NUC LE A R POWE R May 20, 1985 Docket Fo. 50-352 Mr. Hugh L. Thompson, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Limerick Generating Station Unit 1 - Request for Exemption From 10CFR Section 50.44
Dear Mr. Thompson:
Inerting the containment for the Limerick-Generating Station Unit 1 is required by 10 CFR50.44.
Section 50.44 (c).(3).(i) which states in part that,
" Effective May 4, 1982 or 6 months after initial criticality, whichever is later, an inerted atmosphere shall be provided for each boiling light-water nuclear power reactor with a Mark I or Mark II type containment".
Because Limerick Unit 1 initial criticality occurred December 22, 1984, the date of the required inerting would be June 22, 1985.
Philadelphia Electric Company requests an exemption from section 50.44 of the Commission's Regulations to extend the permitted time of operation with a non-inerted containment and to accommodate the completion of the start up testing program.
The Limerick Unit 1 testing program is based on maintaining the containment in a non-inerted condition until the 100% rated thermal trip test is completed, a condition which normally would be expected to 8505240003 850520
$0 PDR ADOCK 05000352 L,O p
m Mr Hugh L. Thompson Page 2 occur within.approximately 120 effective full power days 4
(EPPD) of_ core burn-up..
As discussed.below, it is advantageous to operate the reactorLwithout inerting_the containment'during the start up testing program to permit inspections for-identification of possible problems important to safety.
' The high frequency of containment entries-during the start up testing period and the required deinerting and re-inerting time (about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) might discourage early and frequent containment-entries for identifying and correcting any potential' safety. problems before they become serious safety problems.
Further, Philadelphia Electric Company believes that it is not the intent of the regulation to require inerting before the start up testing program has
~
been completed but rather is intended to provide _and encourage _ assurance of safety, by providing opportunities to-
. conveniently ~ examine and evaluate components and systems
. inside containment while the tests are underway and systems are dynamic.
Completing the tests with an uninerted containment would reduce the likelihood of the development.
of an event. requiring protective safety actions during the period _of exemption.
The low level of fission product inventory _which will be created during the start up testing program, minimizes the need'for the inerting system during
- the exemption period.
The regulation established a Eix month exemption period after initial criticality when inerting is not-required with the' understanding and expectation that a power ascension testing program would be a continuous program' r
unimpeded by physical or regulatory limits to power increases.-
In the case of Limerick Unit 1, initial criticality occurred on December 22, 1984 under a-license limited to 5%. 'This license power level restriction prevents resumption of the test program and necessitates additional relief to allow completion.of the start up testing program without inerting beyond June 22, 1985.
It has been a long established practice, as reflected in 10CFR 50.44,'to operate boiling water plants
- during start-up testing with non-inerted containments.
The high1 frequency.of containment entries during this period of
- plant operations make it impractical to operate with an inerted containment and impacts the effectiveness of the
- start up testing program.
This matter has been reviewed and found acceptable by.the NRC in a number of prior cases.
The NRC has found that exemption from 10 CFR 50.44 can be granted and does not endanger life or property or the common defense and security and is otherwise in the public interest.
(See LaSalle Unit 1 Operating License NPF-ll, Amendment No. 12 and supporting I
)k.. Hugh L. Thompson Page 3 SER, _ dated, December 20, 1982 and Washington Public Power Supply System Project #2, Amendment #3 to Operating License NPF-21 with supporting SER, dated July 27, 1984).. The justification for granting _these exemptions is also equally applicable to Limerick Unit 1 and should be considered in the granting-of the requested exemption for~ Limerick Unit 1.
Additionally, the NRC has previously determined that similarfexemptions;to 10CFR 50.44 did not authorize changes in effluent types nor increase cower levels and would not result in any.significant environmental impact.
Based on the justifications above, Philadelphia Electric Company requests an exemption under 10 CFR
- 50.12(a), to 10 CFR 50.44.(c).'(3) until either 120 effective full power days (EFPD) have elapsed or until completion of
- the 100% of rated thermal power trip tests.
Please do not hesitate to contact us if you have any question'or need additional information.
Very truly yours,
- cc:
T. Murley, Regional Administrator J. T. Wiggins, Resident Site Inspector See Attached Service List i
cc:
Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B.-Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
n
?-
Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitzer Charles W. Elliott, Esq.
Zori G.-Ferkin, Esq.
1 Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence W. Perry, Esq.
-Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board i
Atomic Safety & Licensing Board Panel Docket & Service Section (3 Copics)
James Wiggins Timothy R.
S. Campbell t
i 1/16/85 L_