ML20097C515

Requests Enforcement Discretion from Requirements of TS for Performing Required Type C Tests for Listed Containment Penetrations at Facility,As Discussed W/Nrc on 960202

ML20097C515
Person / Time
Site:	Limerick
Issue date:	02/03/1996
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9602090030
Download: ML20097C515 (11)

Text

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PECO ENERGY

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v 965 Chesterbrook Boulevard Wayne. PA 19087-5691 l

February 3,1996 L

Docket Nos. 50-352 License Nos. NPF-39 l

U. S. Nuclear Regulatory Commission Attn: Docurrent Control Desk Washington, DC 20555

SUBJECT:

Limerick Generating Station, Unit 1 Hequest for Enforcement Discretion for Deferring Completion of Certain Technical Specifications Surveulance Requirements

Dear Sir:

As discussed with the NRC on February 2,1996, PECO Energy Company hereby requests

. Enforcement Discretion (ED) from the requirements of the Limerick Generating Station (LGS),

Unit 1, Technical Specifications (TS). LGS, Unit 1, began its Sixth Refueling Outage (1R06) on the morning of February 2,1996. However, shortly after reducing power and removing the turbine / generator from service on February 2,1996, the Pennsylvania-Jersey-Maryland Interconnection (PJM) declared a " Cold Weather Alert

• due to severe winter weather conditions (i.e., extreme coid) predicted for the Pennsylvania and New Jersey area over the next several days, and forecasted a new all-time winter peak demand for PJM on Monday, February 5,1996, and Tuesday, February 6,1996, and requested LGS, Unit 1, remain operational to maintain PJM transmission system reliability and voltage stability on Monday and Tuesday. Several large generating stations, Salem, Hope Creek, and Peach Bottom, Unit 3, all within the PJM network, are currently shutdown and impacting the capacity available to PJM. In addition, the severe cold weather has also affected neighboring power pools which has resulted in inadequate surplus capacity which could have supplemented the PJM network.

This ED is being pursued, in support of PJM's request, to avoid a plant shutdown which would result from forcing compliance with the TS. The requested relief is non-recurring and of short duration. Further, the period for which the relief is being requested is of such short duration that a license amendment cannot be issued This ED is requested for a maximum of approximately two (2) days, from February 6, at 1051 hours0.0122 days <br />0.292 hours <br />0.00174 weeks <br />3.999055e-4 months <br />, to February 8,1996, at 1608 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.11844e-4 months <br />. if the PJM network conditions improve earlier than currently expected, LGS, Unit 1, wal take appropriate action to come into compliance with the TS.

TS Surveillance Requirements (SRs) require that primary containment leakage rates be determined. Specifhally, TS SR 4.6.1.2.d requires that Type B and Type C tests be conducted in accordance with the requirements of 10CFR50, Appendix J. This ED requests relief from l

performing the rentsed Type C tests for the following containment penetrations at LGS, Unit 1.

l 09001i 9602090030 960203 PDR-ADOCK 05000352 PDR p

i February 3,1996

, 'Page 2 j

- X 212, HPCI Pump Test

- X-214, RCIC Pump Suction j

- X-3D, PClG Supply to ADS Valves E & K

- X 1178, D/W Rad Monkor Supply and Retum

- X-228D, HPCI Vacuum

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- X-201 A, Suppression Pool Purge Supply

- X-25, DryweN Furge Supply

- X-21, Service Air System a

in accordance wkh the guidance cor,tained in NRC Administrative Letter 95-05, " Revisions to Staff Guidance for implementing NRC Policy on Notices of Enforcement Discretion," and Part 9000 of the NRC Inspection Manual, the following information is provided:

1)

The TS or other License Conditions that wBl be violated.

TS Section 4.0.3. will not be complied with since the identified Primary Containment j

isolation Valves (PCIVs) wNI not be declared inoperable when the subject PCIVs are not i

tested as required by the applicsbie TS sections. Specifically, TS SR 4.6.1.2.d 4.6.1.2.g, and 4.6.1.2.h require that the specific penetrations and associated PCIVs be tested on a 24-month survetlance interval. Furthermore,10CFR50, Appendix J, Section Ill.D.3(a) wHl j'

not be met since the subject PCIVs wil not be tested wkhin the 24 month testing interval. This ED requests relief from satisfying the requirements of TS SR 4.6.1.2.d, 4.6.1.2.g. and 4.6.1.2.h for performing Local Leak Rate Tests (LLRTs) (i.e., Type C leakage tests) on the specific valves / penetrations listed in Tables 1 and 2 below. These i

SRs pertain to performing air and hydrostatic LLRTs on containment penetrations. The first valve that reaches the end of its 24-month testing interval is PCIV HV-55-1F071, and its 24-month interval ends on Tuesday, February 6,1996, at 1051 hours0.0122 days <br />0.292 hours <br />0.00174 weeks <br />3.999055e-4 months <br />. At that time LGS, Unit 1, would have to be in COLD SHUTDOWN (OPCON 4) in order not to rely on the containment integrity of this valve.

l Egig See Tables 1 and 2 in response to Question 3 below for detals on the specific i

containment penetrations / valve designations.

2)

Ibe circumstances surroundino the situation includino root causes. the need for oromot action. and identification of any relevant historical events.

4 On February 2,1996, at 1122 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.26921e-4 months <br />, PJM issued a Cold Weather Alert for Monday and Tuesday, February 5 and 6,1996. Simultaneously, PJM issued a Maximum Emergency l

Generation Alert and called for Maximum Emergency Generation to be called into the j

PJM capacity for the same period. (These actions are in accordance with PJM Operation Instructions.) The events leading to these actions were: 1) the weather forecast for the period which predicts low temperatures of 0 -10 F and high temperatures of 14 19 F; 2) the forecasted unavailablity of approximately 4000 MW; 3) a load forecast of approximately 42,000 MW for the PJM; and 4) the potential for import l

restrictions from neighboring control areas due to the fact that the extreme temperatures f

will extend over a wide area.

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February 3,1996

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Cold weather impacts the operation of the transmission system in two (2) ways. First, it causes the load (demand) to rise. (At the forecasted temperature range, each 1*F of temperature drop causes load to increase by 500-800 MW.) The forecasted peak load of 42,000 MW would eclipse the PJM all-time winter peak load of 41,351 MW (set on January 18,1994, at 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />). Secondly, it has the ablity to cause disruptions in the fuel supply to fossu generation stations. During the Cold Emergency of January 19, 1994, PJM experienced a forced outage rate of 28% (vs.14% average forced ou: age rate).

Declaration of a Maximum Emergency Generation Alert is to provide an alert that system condklons may require the use of emergency procedures. Maximum Emergency.

Generation is the use of aN avalable generation that is avalable to run, regardless of size, econc,74cs, or fuel type. If Maximum Emergency Generation is called for, but is unable to cope with system conditions, further measurm would be undertaken, including, interruption of Interruptable Load (expected to be approximately 2000 MW),

Voltage Reduction, and Load Shedding. (This series of Emergency Actions was invoked by PJM on January 19,1994, when a series of rotating curtauments was implemented within PJM during simuar weather condklons). Customers with Interruptable Loads have been notified that they may be interrupted on Monday and Tuesday, February 5 and 6, 1996.

Based on these potential situations, PJM requested that PECO Energy allow LGS, Unit 1, which began a planned shutdown for refueling, to operate through the Cold Weather Alert period in addition to its obvious capacity benefit in bolstering the PJM abuky to meet forecasted load (demand), LGS, Unit 1, significantly strengthens the transmission system because of its electrical position in the network. PJM is a constrained transmission system for west-to-east transfers. PJM system operators use three (3) interfaces to monitor west-to-east flows across PJM. LGS is on the eastem side of the eastem most interface. LGS strengthens eastem PJM voltage profHes when operating.

In addition, having this generation on in eastem PJM increases the import capabHity from the west. Seasonal studies are conducted with PJM's neighboring control areas (ECAR, VACAR, and NPCC) to confirm interface flow limits, and PJM monitors the flow limits in real time to assure the security of the network and to maximize import capability.

Further actions taken by PJM have been to arrange for import from neighboring control areas as follows:

- 4000 MW Systems to the west of PJM

- 600 MW NY Power Pool (NYPP) (Supplemental Energy)

- 800 MW Other NYPP transfers Whether these imports can be implemented on the system wRI depend on the system configuration at the time of the transfers. Certainly, the avalabHity of LGS, Unit 1, would greatly increase the probabuity of implementing those transfers, due to the reasons given in the preceding discussion. The magnitude of the transfers from the west will push the west-toeast limit. If the limit is expected to be exceeded in real time operations, interregional operating procedures would be invoked.

The difficulty in predicting the need for this variance is that the transmission network is a highly dynamic system. The availability (or unavailabuity) of single elements (transmission lines, generating plants, capacitors, etc.) can have significant impacts on the transmission system. Therefore, the most appropriate time to make the decision is

February 3,1996 I

"Page 4 in-close to real time. However, the startup time for a large nuclear unit such as LGS, Unit 1, prevents that possibliity. What can be said with certainty is that LGS, Unit 1, is a very important element in the PJM transmission system and would be necessary to have In operation, in any emergency situation, due to its size and strategic location in the transmission system.

The Petinsylvania Emer0er,cy Management A0ency (PEMA) was notified of this situation on Saturday, February 3,1996.

3)

,Ihe safety basis for the reauest. Includina an evaluation of the safety slanificance and j

ootential con.lHt2uences of the orooosed course of action.

Extending the surveHiance intervals for Type C tests for the penetrations listed in Tables 1 and 2 below will not alter any safety limits which ensure the integrity of fuel barriers, and wHI not increase the primary containment leakage limits. The total containment leakage wHl continue to be maintained below 0.6 Lg only certain test intervals will extended on a one-time basis. Furthermore, the effect of increasing containment leakage rate testing intervals has been evaluated by the Nuclear Energy Institute (NEI) using the methodology described !n NUREG-1493, " Performance Based Containment Leak Test Program," and historical representative industry rate testing data period. The results of this evaluation, as published in NEl 94-01, Revision 0, " Industry Guideline for implementing Performance-Based Option of 10CFR50, Appendix J,' are that the j

increased risk corresponding to extended test intervals is small (i.e., less than 0.1% of j

total risk) and compares well to the guidance of the NRC's safety goal. It is Important to note that the NRC has endorsed NEl 94-01, Revision 0, and that the extended test intervals analyzed for increased risk are up to five (5) year intervals for Type C tests.

Based on the performance indicated below in Tables 1 and 2 increasing the surveillance by only 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> wHl not result in any increase to onsite or offsite dose. Additionally, the penetrationa discussed in this ED are single faHure proof which ensure that sufficient redundancy exists in the eusnt that one (1) barrier (i.e., PCIV) faus.

Review of the past two cycles of test data for these penetrations does not indicate any adverse trends. The penetrations / valves of concem are identified in Tables 1 and 2 (attached). Included in the tables are the Appendix J leakage test results. Six of the penetrations have met their PECO administrative leakage limits and would be candidates for extended frequency and 25% grace under Appendix J Option B. Additionally, Penetrt.tlons X-212 and X-214 are under a closed system water seal post accident and would not contribute to Primary Containment leakage. These penetrations are currently being reviewed by the NRC for deletion from the TS under License Change Request 95-134.

Two of the penetrations / valves have not met their administrative leakage limits for two consecutive tests and would not be undidates for extended frequency under 10CFR50, Appendix J, Option D. In each casa one valve of the 2 valve test contiguration did not meet its administrative leakage limit whlie the second valve did. This occurred on one test for each penetration. These two penetrations would not be candidates for extended frequency under Appendix J, Option B but would be subject to 25% grace under Appendix J Option B.

February 3,1996

'Page 5 s

TABLE 1 1R06 Surveillance Tests - Expiration on 02-06-96 TEST #

PENE.

PENETRATON EXPtRATON TIME VALVE LEAKAGE LAST DESCRIPTON DATE DATE ST 4-LLR-761 1 X-212 HPCI Pump Test 02 M 96 1061 HV-55-1F071 0.01 gpm 02-05-94 0.00 9pm 03-23-92 ST 4-LLR 7711 X-214 RCC Pump Suctum 0246-96 2015 HV-49-1F031 0.0 9pm 02 4 94 0.1 gpm 03-27-92 ST-4-LLR421 1 X-3D PCIG Supply to ADS Valves 02 06-96 2338 50-1112 20accm 02 4 94 E&K 29sccm 03-23-92 HV-50151B 20scem 0245-94 20 scom 03 23-92 ST 4-LLR-561 1 X-117B D/W Red Monitor Supply and 02-06-96 1156 SV-26190A 20seem 0245-94 Retum 20 seem 0441-92 SV-26190B 20 sccm 02-05-94 20 sccm 0441-92 SV-26-190C 20 scom 0245-94 36sccm 0441-92 SV-261900 20 scem 0245-94 35 seem 04-01-92 ST-4-LLR491 1 X-228D HPCIVacuum Relief 024696 1158 HV-551F003 105 seem 02-05-94 HV-551F095 06 05-92 HV-551F093 3315 scom*

02-05-94 HV-55-1F095 0645-92

• Did not meet Administrative Leakage Requirement.

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February 3,1996

• Page 6 TABLE 2 1R06 Surveillance Tests - Expiration on 02-07-96 4

l TEST #

PENE.

PENETRATION EXPtRATION TIME VALVE LEAKAGE TEST DESCRIPTION DATE DATE ST-4-LLR-571 1 X-201A Suppression Pool Pur9e 0247-96 1326 HV-57147 850 soom 0246-94 Supply 630 socm 05-27-92 HV-57124 850 soom 0246-94 630 seem 05-27-92 l

57 1022 20 scom 0246-94 i

20 soom 05-27-92 57 1093 20socm 0246-94 20 scom 05-27-92 1

ST-4-LLR-2221 X-25 Drywell Purge Supply 02-07-96 0810 HV-57-123 94 sccm 02 06-94 64socm 04-10-92 HV-57135 94socm 0246-94 64 sotm 04-10 92 ST-4-LLR-191 1 X-21 Service Air System 02 07-96 0150 15 1139 3190 socm*

02 06-94 363 scom 05-30-92 15-1140 99socm 02-06-94 20sccm 05 30-92

• - Did not meet Administrative lhaka9e Requirement.

In addition, the proposed actions discussed in this ED have no impact on the LGS Probabilistic Safety Assessment (PSA) assessed Core Damage Frequency (CDF). The PSA assessment of large early release frequency is insensitive to containment leakage changes given that containment pressure boundary integrity is maintained. It is therefore concluded that the proposed action has no impact on plant risk as assessed by the LGS PSA. Maintaining PJM transmission system is also important in preventing any risk increr.se to nuclear plants within PJM.

February 3,1996

'Page 7 4)

The basis for the licensee's conclusion that the noncomoliance wHI not be of notential detriment to the public health and safety and that neither an Unreviewed Safety Question nor a Sionificant Hazards Consideration is involved.

The proposed ED does not involve en Unreviewed Safety Question, as concluded 10CFR50.59 Evaluation performed in support of this ED, nor does it involve a Significant Hazards Consideration because operation LGS, Unit 1, with this change does not:

1) involve a significant increase in the probability or consequences of an accident previously analyzed.

This ED requests a one-time extension to the survelHance intervals for performing Type C tests for certain containment penetrations. There is no permanent Technical Specification change required. No structures, systems, or r'omponents (SSC) are being changed as a result of this change.

Implementation of the activity wHl affect the manner in which these SSC are tested; however, the one-time surveulance interval extension is not an initiator of any analyzed event.

Extending the surveulance interval for primary containment penetrations described in Tables 1 and 2 does not increase the probabHity of occurrence of an accident previously evaluated in the SAR. The containment structure itself is passive Passive faBures resulting in significant containment structural leakage are extremely unlikely to develop between Type A tests. No such faBures have ever occurred at LGS. All other penetrations wRl continue to be maintained in survegiance, and in their current design configuration. There is no correlation between the testing frequencies and accident probabuity.

The consequences of the postulated accident (LOCA inside prk.ury containment) do not change as a result of this activity. The current postulated accident analysis remains valid even if certain Type C tests are extended several days on a one-time basis.

The total containment leakage wHI continue to be maintsMed below 0.6 L,. Only certain test intervals wRI be extended on a one-time basis. Furthermore, the effect of increasing containment leakage rate testing intervals has been evaluated by the NEl using the methodology described in NUREG-1493. The increased risk corresponding to extended test intervals is smaH (i.e., less than C.1% of total risk) and compares well to the guidance of the NRC's safety goal.

It is important to note here that NEl 94-01 is endorsed by the NRC and that the extended test intervals analyzed for increased risk are up to five year intervals for Type C tests. This change discussed in this ED only requests an extension of the surveillance intervals for 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

Extending the surveNiance intervals for the Type C tests does not increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the SAR. As discussed in NEl %01, the estimated increase in risk as a result of extending Type C test li.tervals (based on performance) up to five years is very small.

February 3,1996

'Page 8 Extending the survelNance intervals for Type C tests for the penetrations listed in Tables 1 and 2 above wHl not alter any safety limits which ensure the integrky of fuel barriers, and will not increase the primary containment leakage limks.

The Contairwnent Combined Leakage Rate TS requirement is 0.6 L,. The LGS, 7

Unk 1, current running total is 0.34 L,. The hydrostaticaNy tested valve TS requirement is 51 gpm. The LGS current combined hydrostatic leakage rate is approximately 5 gpm. These represent sizeable margins to the TS limks.

Review of the past two cycles of test data for these penetrations does not indicate any adverse trends. The penetrations / valves of concem are identified in Tables 1 and 2 above included !n the tables are the Appendix J leakage test results. Six of the penetrations have met their PECO administrative leakage limits and would be candidates for extended frequency and 25% grace under Appendix J Option B. Additionally, Penetrations X-212 and X-214 are under a closed system water seal post accident and would not contribute to Primary Containment leakage. These penetrations are currently being reviewed by the NRC for deletion from the TS under License Change Request 95-134.

Two of the penetrations / valves have not met their administratke leakage limits for two consecutive tests and would not be candidates for exter.ded frequency under 10CFR50, Appendix J, Option B. In each case one valve of the 2 vane test configuration did not meet its administrative leakage limit whue the second valve did. This occurred on one test for each penetration. These two penetrations would not be candidates for extended frequency under AptwvW J, Option B but would be subject to 25% grace under Appendix J Option B.

Since Appendix J, Option B, industry experience, and LGS experience have shown that these penetrations are reliable, leak rate testing can be justified to be extenoed beyond the 24-month frequency. Since these penetrations are reliable, extending the test interval by a few days results in no discemable increase in the probabuity of the occurrence of a malfunction of the valves associated with the penetrations.

Based on the above, the potential for time-based and activity-based failure mechanisms which could lead to excessive containment leakage are co small that R is concluded that there is no discemable increase in the probabuity of occurrence of a malfunction to the valves associated with the eight penetrations.

This change will not result in any increase to onsite or offsite dose. Additionally, penetrations are single failure proof which ensure that sufficient redundancy exists in the event that one barrier faus.

The proposed actions discussed in this ED have no impact on the LGS Probabuistic Safety Assessment (PSA) assessed Core Damage Frequency (CDF). The PSA assessment of large early release frequency is insensitive to containment leakage changes given that containment pressure boundary integrity is maintained. It is therefore concluded that the proposed action has no impact on plant risk as assessed by the LGS PSA.

Therefore, a one-time surveNiance interval extension for the penetrations discussed in this ED does not involve any increase in the probability or the consequences of an accident previously evaluated in the SAR.

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February 3,1996

• Page 9 2)

Create the poesitdlity of a new or different type of accident from any accident previously evaluated.

Extending the surveillance intervals for certain Type C tests wiH not create the pnaaNity of a different type d malfunction of equipment important to safety than previously evaluated in the SAR. No now fature modes of plant equipment previously evaluated win be introduced. Additionally, the increase in test intervals does not introduce any hardware changes, and wlH not alter the intended operation of plant structures, systems, or components utRized in the mitigation of accidents or transients.

No new or different type of accident than previously evaluated in the SAR wil be created. This change wiH not alter the operation of equipment assumed to be avagable for the mitigation of accidents or transients. The safety objective of the primary containment is stated in 10CFR50, Appendix A, " General Design Criteria for Nuclear Power Plants." The safety function of the primary containment wBl be met since the containment wlN continue to provide 'an essentiaHy leak tight barrier against the uncontrolled release of radioactivity to the environment.

for postulated accidents.

Therefore, the change wRl not create the possibuity d a new or different kind of accident from any accident previously evaluated.

1 3)

Involve a significant reduction in a margin of safety.

No margins of safety are reduced as a result of a one-time increase in test Intervals for certain Type C leak tests. As stated above, the effect of increasing containment leakage rate testing intervals was published in NEl 94-01 The results of this evaluation are that the increased safety risk corresponding to extended test intervals is small (less than 0.1% of total risk).

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The Technical Specifications wRI continue to maintain the allowable leak rate of 0.6 L, as the combined Type C tests performance criterion.

Therefore, extending the surveillance intervals for certain Type C tests does not involve a reduction in the margin of safety and will continue to ensure the Appandix J regulatory goal of an essentiaHy leak tight containment boundary.

5)

The basis for the licensee's conclusion that the noncomoliance will not involve adverse conseauences to the environment.

The requested ED would not significantly increase the probabuity of exceeding the maximum allowable value of expec:ed primary containment leakage (i.e., L., established by 10CFR50, Appendix J), during a hypothetical Design Basis Accident (DBA); therefore, the primary containment integrity would be maintained. The requirements in 10CFR50, Appendix J, require that Type C tests be performed durits each reactor shutdown for refueling, but in no case at intervais greater than two-years. We have concluded that performing the Type C tests for the specified penetrations no more than 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> beyond the 24-month surveillance interval would continue to meet the undertying purpose of the regulation, that is, any primary containment leakage during a hypothetical i

DBA will remain less than the maximum allowable leakage rate value (i.e., L, established j

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February 3,1996

• Page 10 by 10CFR50, Appendix J). The proposed ED wIl not affect plant radiciogical effluents.

Accordingly, the consequences of an accident would not be increased, that is, the poet accident radiological releases would not be greater that previously determined Therefore, there are no significant radiological 4nvironmental impacts associated wkh this ED. With regard to potential non-radiological impacts, the requested ED involves a one-time schedular change to surveillance and testing requirement intervals (i.e., an extension of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> The ED does not affect non-radiological plant affluents and has no other environmental impact 6)

Any orooosed compensatory measures.

The period of non<ompliance whl be for 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> or less in support of the " Maximum Emergency Generation Condklon." Minimizing the duration of the non-compliance limks the amount of possible containment degradation.

AX other required TS systems wNl be in surveNiance. Having these systems operable would mitigate the consequences d containment breach should one occur. If any other containment operabuity issue arises, the applicable TS Actions wRI be taken.

7)

A I"atkattan for the duration of the noncomdiance.

This ED is requested in. support of the PJM Cold Weather Alert Condition, which is i

expected to be of short duration (i.e., approximately 2 days) and the PJM transmission system condition will be cortinually monitored by PJM and PECO Energy. The critical l

portion of the these two (2) days is Monday and Tuesday moming and evening peak j

periods. These are the times when load will be highest and the probabRity of invoking i

emergency procedures greatest.

8)

A **a' ament that the ran"aat has been annroved by the facRity oraan17ation that normally reviews safety issues (Plant Onsite Review Committee. or its eaulvalentt The LGS Plant Operations Review Committee (PORC) and the Plant Manager have reviewed and approved the contents of this ED.

9)

The reauest must soecifically address how one of ti,e NOED criteria for anoroorlate olant conditions soecified in Section B is satisfied.

The plant conditions associated with this request satisfy Part 9900, Section B, " Criteria,"

of NRC Inspection Manual which stipulate that for other unusual situations, natural events may resu3 in a govemment entity or regional power distribution system declaring an emergency on the basis of need for power for overaH public safety. 83 such circumstances, Part 9900 states that the NRC may balance the overall public health and safety implications of not operating with the potential radiological or other hazards assodated with continued operation of the faculty whWe in nonconformance with a partiettar requirement.

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February 3,1996

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10)

If a follow-uo license amendment is reauired. the NOED reauest must include marked-uo TS nages showing the orocosed TS chanoes, The actuallicense amendment request must follow within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

A follow-up license amendment is not required. The period for which this ED is requested is of such short duration that a license amendment can not be processed and issued 11)

A statement that prior adoption of aporoved line-item imorovements to the TS or the ITS would not have obviated the need for the NOED reouest.

LGS has not converted to ITS. ITS still requires containment leakage testing to be performed in accordance with 10CFR50, Appendix J, requirements. Therefore, conversion to ITS would not have obviated the need for this ED.

12)

Any other Iriformation the NRC staff deems necessary before makina a decision to exercise enforcement disciution.

From 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on Friday, February 2,1996, when LGS, Unit 1, was requested by PJM to return to service, to 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> on Monday, February 5,1996, when the load demand on the PJM transmission system will increase, is 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br />. The estimated time for LGS, Unit 1, to shutdown, perform the necessary testing and retum to power, assuming no additional problems were encountered, is approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />. Therefore, the unit would not be available to supply power Monday moming, February 5,1996.

If you have any questions or require additional information, please do not hesitate to contact us.

Veiy truly yours, f

G. A. Hunger, Jr.

Director - Licensing cc:

T. T. Martin, Administrator, Region I, USNRC N. S. Perry, USNRC Senior Resident inspector, LGS l

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