ML20196D918
| ML20196D918 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/05/1988 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8812090232 | |
| Download: ML20196D918 (4) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET S'f REET P.O. BOX 8699 4
PHILADELPHI A. PA 19101 (2 Isi e414 500 semenv D Isfe'eU"Suc6a" December 5, 1988 Dr. Thcrnas E. Murley, Olrector Docket No.90-353 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Ccmnission Attn: Document Control Desk Mall Station P1-137 Washington, DC 20555
Subject:
Limerick Generating Station, Unit 2 Request for Exenution from 10CFR50.44
Dear Dr. thriey:
In accordance with 10CFR50.12(a) Philadelphia Electric Ccevany requests an exerption frcri 10CFR50.44CcX3XI) to extend the pemitted time of operation with a non-Inerted contalment to acecrrodate conple-tion of the Power Ascension Test Program. The, Limerick Unit 2 Pcwer Ascension Test ".w.wn is based on reintaining the contalrrnent in a non-Inerted condition mtl1 the successful ecmpletion of the 100-hour warranty run, a ecvxiltion which nomally wculd be expected to occur within approximately 120 effective full pcwer days of core burn-up.
The attactraent to this letter provides the specific justifications In acccrdance with the requirements of 10CFR50.12(a).
If you have any questions, please do not hesitate to contact us.
Sincerely, l
Ih y
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J. S. K anpe r Senior Vice-President tbclear s'EP/sw/10248t01 Copy to: Addressee R. J. Clark, USNRC Project Managor W. T. Russell Ariministrator, Reglen I, USPRC T. J. Kemy, USNRC Senior Resident inspector, LGS-1 R. A. GranTn, UStRC Senior Resident inspector, LCS-2
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SS12090232 G81205 FDR ADOCK 05000353 A
LGS thit 2 Dccket No. 50-353 ATTACWENT REQUEST FOR EXEMPTION FRCN THE REQUIREMENTS OF 10CFR50.44(aX3XI)
Exent,t lon Requested Inerting the contalnrnent for the Lirmrick Generating Station Unit 2 is required by 10CFR50.44 Section 50.44(cX3XI) states in part that, "Effective May 4,1982 or 6 tmnths after Initial criticality, whichever is later, an inerted attrosphere shall be provided for each bolling f
light-water nuclear ocwer reactor with a Mark I or Mark !! type conta i rrent".
Philadelphia Electric Ccepany requests an exermtlen frcm 10CFR50.44(cX3XI) to extend the permitted tIrne of operation with a I
non-Inerted contalrnent to acccTodato ccrrpletion of tl'e Pcter Ascension Test Prcgrem. The Lirnerick Unit 2 Pcwer Ascension Test Progrem is based on rmintaining the containment in a non-Inerted condit ico unt !) the successful ccroletion of the 100-hour warranty run, a r:ondition which ncrrully would be expected to occur within approxtrmtely 120 effective full permr days (EFPD) of core burn-up.
Just ificat ion for Recuested Extretion, The requested exermtion rmy be granted by the NRC under 10CFR50.12(a) provided that the exmotlon is:
- 1) authorized by law, !!) will not present an undue risk to the pubile health and safety, !!!) is consis-terit with the cceron defense and security, and IV) Justified by the presence of special ciretratances of the type Identified in Section 50.12(aX2).
1.
The Reouested Ezwotle.ns and the Activities Which Wcold Be A11rwd Thereunder Are Auther t red bv tm If the criterla established in 10CFR$017(a) are satisfied and if no other prehlbitice of Im exists to preclude the activltles which would be authorized by the requested exertp-j tico, then the Ccmt ssion is authorized by Im to grarit the i
l exmption request.
Slrce, as derronstrated herein, the recuested exemption rTets the appilcable criteria anc there i
l is no legal prohibition to its grant, the Ccrnission is l
authorized by law to grant the exrotten.
The Requested Exmotion Will tbt Present an thduo Risk to i
the hihile Heaith and Safety
- ce the reasons stated belcw and in Sectico IV, Special
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Ciretrutances, the requested exmpticn to extend the permit-ted time of operation with a ncn-Inerted centainrnent to l
r l
f
.m-s LGS Unit 2
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Dockat'No. 50-353 Attactinent Page 2 to:ccrrmodate cormletion of the Power Ascension Test Program dces not present undo risk to the pubile health and safety.
It is r.ia:+sgeous to operate the reactor without Inerting the r
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' during the Power Ascension Test Program to ons for Identification of possible safety perm preb -
high frequency of contalrvnent entries during
- he required deinerting and rett'erting tIrne this 8
Cabi
- 3) might discourage early and frequent com-
)
tal~
les for identifying and correcting potentlal safet',,.solems during testing. Further, Philadelphia diectric Company believes that it is not the Intent of the regulation to require Inerting before the Power Ascension Test Program has been ccumloted but rather is Intended to provide and encourage assurance of safety, by oroviding opportunities to conveniently examine and evaluate ccmponents and systems inside contalrvnent while the testa are underway and systems are dyr.amic. Ccropleting the tests with an uninarted contaltwent would reduce the Ilkell' hood of the Qvelognent of ai. cuent requiring protective safety actions during the period of-exemption. Additionally, the 1cw level of fission product Inventory which will be created during the Pcwer Asceaslon Test. Program minimizes the need for the l
Inerting system during the extenption period, i
III. The Requested Exemption is Consistent with the Ccmnon Defonse and Securitv 1
The ccrmon defense end security are not endangered by this exc< notion request. Only the potential Impact on public health and safety is at issue and has been determined tu bo Inconsequential.
IV.
Special Cir,curstanem The regulation estabilshed a six nonth exctnption period after Initial criticality when inerting is not required with the understanding and expectation that a Power Ascension Test Program would be a continuous orogrern unirnpeded by physical or regelatory limits to powcr increases.
In the case of L!rnerick Un!t 1, and rrost other recent BWR f nItlal sta tups, unanticipated equipmont, problems and regulatory delays have caused the power ascensica test period to be extended beyond f
the six rrenth duration. The avesvge actual duration is approximately ten trunths.
It has been a long esteb11shed practice, as reflected In 10CFR50.% to operate bolling water plants during power l
ascension testing with non-Inerted contalrments. The high frequency of contairrnent entries during this period of plant operations make it Irmractical to operate with en Inerted containment and Irmacts the ef4ctiveness of the Power I
Ascension Test Program.
It is advantageous to operate the
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reactor without Inerting the contalrvrent during the Pcwor l
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LGS Unit 2 Dockst No. 50-353 Attachment Page 3 Ascension Test Program to permit inspections for identif t-cation of possible safety problans.
Strict comliance with the regulation would result in undue hardships and schedule pressures in excess of those controplated when the regulation was adopted and also in excess of recent Industry power ascension testing experience.
Conclusion Based on the Justifications abovo, Philadelphia Electric Conpany requests an exemption under 10CFR50.12(a) to 10CFR50.44(cX3)fl) untII olthcr 120 EFPO have elapsed or until camletion of the Power Ascension Test Progran. The comletion of the Pcwor Ascension Test Program is signified by the successful conpletion of the 100-hour warranty run.
The Justifications provided represent several of the special circunstance requirements of 10CFR50.12(aX2) necessary In order to grant the requestod exemption. Granting the exemption would re: ult In an overall benefit to the pubile health and safety by pramting effl-cient and expeditious testir.g of facility systems and comonents.
To require inerting before the conclusion of the Power Ar.consion Test Progrem coulo result in less assurance of safety because of the added time and/or decreased ability to di ectly examine and evaluate components and systems inside contarrynent during testing.
The exemption request and JustifIcattons for granting this exanotlon for Limerick Unit 2 are similar to those found acceptable by the NRC on ether dockets Including Limerick Unit 1 (Operating License NPF 39 with supporting Safety Evaluation Report, NUREG-0991, Supplement 45 :ated July 1985) and should be considered in the granting of the requested exerrot Ion.
Finally, Phlalcelphia Electric requests this eremption be granted concurrent with ar prior to tha issuance of the Operating License for Limerick Unit 2.
The draft 1.lmerick Unit 2 Technical Specifications have been proposed to reflect this exemptinn request.
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