View source for B13265, Requests That NRC Process 890331 Amend to License DPR-61 Re Containment Integrity During Containment Air Recirculation Fan Motor HX Cleaning Activities as Exigent Change

{{Adams
| number = ML20247Q349
| issue date = 05/25/1989
| title = Requests That NRC Process 890331 Amend to License DPR-61 Re Containment Integrity During Containment Air Recirculation Fan Motor HX Cleaning Activities as Exigent Change
| author name = Mroczka E
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B13265, TAC-72871, NUDOCS 8906060403
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
| project = TAC:72871
| stage = Other
}}

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                                             "                                           HARTFORD, CONNECTICUT 06141-0270 k    L    J I,U,["",,,no'."w"d*                                     (203) 665-5000 May 25, 1989 Docket No. 50-213 B13265 Re:     10CFR50.90 and 50.91 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Haddam Neck Plant Proposed Revision to Technical Specifications Containment Integrity During Containment Air Recirculation Fan Motor Heat Exchanaer Cleanino Activities (TAC 72871)
In a {{letter dated|date=March 31, 1989|text=letter dated March 31,1989}}(I) Connecticut Yankee Atomic Power Company (CYAPCO) proposed to amend Operating License DPR-61 by changing the Haddam Neck Plant Technical Specifications to allow cleaning or replacement of the Containment Air Recirculation (CAR) fan motor heat exchangers while at power.
The purpose of this letter is to request, pursuant to 10 CFR 50.91(a)(6), that
_ the NRC Staff process the above: referenced license amendment request as an
                       " exigent change." The following represents CYAPC0's justification for this request.
Backcround In a {{letter dated|date=February 10, 1989|text=letter dated February 10, 1989}},(2) CYAPC0 proposed changes to the Tech-nical Specifications for the Haddam Neck Plant that would allow the service water side of the four CAR fan heat exchangers tge cleaned while the plant was at power. In a {{letter dated|date=March 7, 1989|text=letter dated March 7,1989}},                   the NRC Staff issued the license amendment approving CYAPC0's request.
(1)    E. J. Mroczka letter to the U.S. Nuclear Regulatory Commissicn,
                              " Containment Integrity During Containment Air Recirculation Fan Motor Heat Exchanger Activities," dated March 31, 1989.
(2)    E. J. Mroczka letter to the           U.S. Nuclear Regulatory Commission,
                              " Containment      Integrity    During  CAR    Fan     Heat       Exchanger           Cleaning Activities," dated February 10, 1989.
(3)    A. B. Wang letter to E. J. Mroczka, " Issuance of Amendment (TAC No.
72024)," dated March 7, 1989.
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U.S. Nuclear Regulatory Commission B13265/Page 2 May 25, 1989 i
Following receipt of the license amendment, CYAPC0 initiated the process of cleaning the CAR fan heat exchangers. During the cleaning process (from 10-14 days in length), CYAPC0 concluded that it would be necessary to clean (or replace) the CAR fan motor heat exchangers as well. CYAPC0 reevaluated the service water system and concluded that with the CAR fan heat exchangers cleaned, Haddam Neck Plant operation would be acceptable up to a service water temperature of 75'F. However, to operate above 75'F, CYAPC0 determined that the CAR fan motor heat exchangers would have to be cleaned or replaced as well. CYAPC0 began to discuss with the NRC Staff what we believed were different options as _ to the most appropriate regulatory vehicle to authorize cleaning or replacement of these CAR fan motor heat exchangers while the plant continued operation, given existing technical specifications as amended by the license amendment issued on March 7,1989. Following consultation with the NRC Staff, CYAPC0 expeditiously processed a proposed change to the Haddam Neck Plant Technical Specifications to support the CAR fan motor heat exchanger            ,
cleaning or replacement and submitted a license amendment request to the NRC Staff by {{letter dated|date=March 31, 1989|text=letter dated March 31, 1989}}. CYAPC0 made every effort to have this license amendment request processed under normal circumstances recognizing the uncertainty of the rate of increase in service water temperature (Connecticut River water) during this time of the year.
Exiaent Circumstances CYAPC0 now believes that the processing of the March 31, 1989 license amend-ment request under exigent circumstances, pursuant to 10CFR50.91(a)(6) is necessary to preclude unnecessary shutdown of th{4yaddam Neck Plant. Accord-ing to the NRC Staff's {{letter dated|date=May 8, 1989|text=letter dated May 8, 1989}},      the 30-day time limit for the federal register notice on this license amendment request expires on June 12, 1989. Therefore, the license amendment could not be issued until at least that date. In addition, CYAPC0 projects that at least one week will be required to perform the CAR fan motor heat exchanger cleaning / replacement evolution. Accordingly, if the normal license amendment request process continues, the Haddam Neck Plant will be required to shutdown if the service water temperature exceeds 75'F on or before June 19, 1989. A review of recent historical trends in service water temperature reveals that temperatures of 70*F can be achieved during the second half of May with 75'F following shortly thereafter. Also, tidal effects can result in very rapid, short term increas-es in service water temperature. As of Monday, May 22, 1989, service water temperature at the Haddam Neck Plant was at 64*F. More significantly, the temperature had increased over 10*F in the course of one week, demonstrating           ,
that substantial increases in temperature over short time periods are quite           l possible this time of year. In addition, the long term forecast for Southern           I i
l (4)   A. B. Wang letter to E. J. Mroczka, "Haddam Neck Plant - Containment Integrity Technical Specification Change (TAC No. 72871)," dated May 8, 1989.

e U.S.- Nuclear Regulatory Commission B13265/Page 3 May 25, 1989 New England is for warmer weather over the next week.                                                         -Further contributing to the existence of exigent circumstances is the fact' that at least a one week buffer is prudent between license amendment issuance and service water temper-ature reaching 75'F to allow the cleaning / replacement of the CAR fan motor l                             coolers. Of course, this seven day estimate to conduct the cleaning / replace-ment evolution is only'an estimate, and this period could be longer if unex-pected problems are encountered.
The NRC Staff's {{letter dated|date=May 8, 1989|text=letter dated May 8, 1989}} stated that the license amendment could be issued prior to the 30-day review period expiring if circumstances have changed such that failure to act in a timely manner could result in derating or shutdown of the plant. Accordingly, due to recent rapid increases in the service water temperature, CYAPC0 is requesting that this license amendment be processed pursuant to 10CFR50.91(a)(6).
Significant Hazards Consideration As documented in the {{letter dated|date=March 31, 1989|text=March 31, 1989 letter}}, CYAPC0 has concluded that this license amendment request does not constitute a significant hazards consider-ation. The cleaning / replacement of the CAR fan motor heat exchangers would be performed within the remainder of the 64-hour time limit for having the service water system open inside containment approved by the NRC Staff in the license amendment issued on March 7, 1989. In the {{letter dated|date=May 8, 1989|text=letter dated May 8,1989}},
                              " Notice of Consideration of Issuance of Amendment," the NRC Staff documented their proposed determination that CYAPCO's March 31, 1989 license amendment request did not involve a significant hazards consideration.
Conclusion CYAPC0 has concluded that it is appropriate and necessary that the March 31, 1989 license amendment request be processed under exigent circumstances, for the following reasons:
o                 due to recent increases in the service water temperature, the amendment is needed to avoid a likely shutdown of the Haddam Neck Plant; o                 the license amendment request does not constitute a significant hazards consideration; o                 CYAPC0 made every effort to process this request in a timely manner to avoid this situation; o                 this license amendment request has already been noticed in the federal register for approximately 2 weeks; We also wish to emphasize our conclusion that this proposed amendment involves no undue safety risk.                 We are therefore requesting this action to avoid what

L U.S. Nuclear Regulatory Ccaimission B13265/Page 4 l              May 25, 1989 i
would be an unnecessary plant shutdown, an action which is not in the best interests of the health and safety of the public, our customers, or shareholders.
To support what we believe is an appropriate and prudent schedule, CYAPC0 is requesting amendment issuance by May 31, 1989.
Please contact us if you have any questions, and thank you for your prompt attention to this request.
Very truly yours, CONNECTICUT YANKEE ATOMI POWER COMPANY fdM<s 8ct/
E. J.             //
Senio/trocz'ki r Vice Presfaent Attachment cc:          W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT)
                                            ) ss. Berlin COUNTY OF HARTFORD )
Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Connecticut Yankee Atomic Power Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.
I w 'm. 3kulfJny 0
Notary Public
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