ML20012C227

Requests Interim Relief from Primary Containment Leak Rate Testing Requirements of 10CFR50.54(o) & App J,III.D.1-3 Pending NRC Disposition of Lilco 891208 Request for Exemption from Same Requirements

ML20012C227
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/13/1990
From:	Steiger W LONG ISLAND LIGHTING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
SNRC-1692, NUDOCS 9003200345
Download: ML20012C227 (2)

Text

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j g "gigy i LONG ISLAND WGHnrtNG COMPANY SHOREHAM NUCLEAM POWER STATION

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AmeOT Alet y:Cf PRE 9lbtNT-NUCLE AR OPERATIONS SNRC-1692 MAR 131990 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C. 20555 LILCO's Request for Interim Relief Pending Disposition of its Request for an Exemption from the Leak Rate Testing Requirements of 10 CFR 50.54(o) and Appendix J, III.D.1 through III.D.3 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 _ _

Reft (1) Hunton & Williams letter dated December 8, 1989 to U.S.

Nuclear Regulatory Commission from David S. Harlow, One of Counsel for Long Island Lighting Company; subject:

Request for an Exemption from the Primary Containment Leak Rate Testing Requirements of 10CFR50.54 (o) and

' Appendix J, III.D.1 through III.D.3 Gentlemen:

By this letter Long Island Lighting Company (LILCO or the Company) requests interim relief from the requirements under 10 CFR 50.54 (o) and Appendix J, III.D.1 through III.D.3 that it perform primary containment leak rate testing, pending the Staff's disposition of LILCO's December 8, 1989 request for an exemption from those requirements (Ref. 1). As LILCO pointed out in its exemption request, under the regulations LILCO must perform burdensome and costly testing of the primary containment, even though, with Shoreham's fuel having been removed from the reactor vessel and placed in the spent fuel pool, there is no health and safety need to maintain primary containment integrity.

Interim relief pending Staf f approval of LILCO's exertrtion request will allow the Company to suspend performing rurther leak rate testing as such tests become due, with corresponding cost savings. As was noted in LILCO's December 8 exemption request, it. costs approximately $ 138,000 to perform a Type A integrated leak rate test and approximately $ 445,000 to conduct the Type B and C local leak rate tests each 18-24 month cycle.

900320034G 900313 PDR. ADOCK 05000322 0 h P PDC j

SNRC-1692 Page 2 ,

.. s-Interim relief should be granted on the following basis:

1. SNPS is in a non-operational, defueled condition with all fuel stored in the Spent Fuel Storage Pool.

2. Primary containment integrity is not required in a defueled condition. Thus, Appendix J testing which provides assurance of this safety function is not required.

3. In accordance with the settlement Agreement between LILCO and the State of New York, LILCO is contractually prohibited from ever operating Shoreham.

4. As evaluated and submitted in LILCO letter SNRC-1664 dated January 5, 1990, design basis accidents for SNPS in a non-operational, defueled condition have been significantly reduced and are only associated with fuel handling and e liquid radwaste tank rupture.

5. As postulated and analyzed, a worst case radiological event, in which the entire gaseous activity of the whole core is released to the reactor building, indicates that integrated doses would be very small fractions of the 10CFR100 limits.

As has been noted in the exemption request, LILCO will perform the necessary leak rate testing, and will reestablish primary' containment integrity as required under Shoreham's technical specifications, prior to returning to any applicable operational condition. Meanwhile, even without periodic testing, under LILCO's systems lay-up program the primary containment will be protected from irreparable degradation. In fact, Appendix J testing has the potential actually to conflict with implementation of LILCO's lay-up program, since the lay-up program includes the drying out of certain systems, while Appendix J testing must be conducted when water is present in many of these same systems.

Should you have any questions or need additional clarification, please do not hesitate to contact this office.

Very truly yours, 7

W. GrCdAch/\r7 E. Steiger,/ J Assistant Vice President i

Nuclear Operations MAP /ap cc: S. Brown T. T. Martin L. Doerflein