ML20012C778

Requests Interim Relief from Certain Requirements Re Emergency Diesel Generators for Plant,Pending Disposition of Util Outstanding Request in 900105 Ltr to Amend License to Create Defueled Facility OL

ML20012C778
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/16/1990
From:	Steiger W LONG ISLAND LIGHTING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
SNRC-1694, NUDOCS 9003230205
Download: ML20012C778 (3)

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h lb g j ' LONG SHOREHAM ISLANDNUCLEAR LIGHTING COM5%NY I x_ 4 ~ , < . _

' POWER STATION P.O. DOM G18. NORTH CDUNTRY ROAD e WADING RIVER. N.Y.11798  ;

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SNRC-1694 MAR 101990 j U.S. Nuclear Regulatory Commission i 1

Attn Document Control Des)-

Washington, D.C. 20555 j LILCO's Request for Interim Relief from the One-Time Five Year Inspection Requirement of Paragraph A, Attachment 2 to NPF-82 and j Technical Specification Surveillance Requirements 4.8.1.1.2.e2, 3, 4, 5, 6, 7, 8 and 10 Pending Disposition of January 5, 1990 License Amendment Application Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Reft LILCO (W.E. Steiger, Jr.) letter to NRC (SNRC-1664) dated January 5, 1990; subject: License Change Application .

P Gentlemen: '

By this letter LILCO requests interim relief from certain  !

requirements pertaining to the emergency diesel generators (EDGs) i for the Shoreham Nuclear Power Station, pending disposition of LILCO's outstanding request in the referenced letter, SNRC-1664, to amend NPF-82 to create a Defueled Facility Operating Licenco,

.h Under'the requirements in NPF-82, Paragraph A, Attachment 2, 1 LILCO must undertake a one-time burdensome and costly inspection ba of the diesel generators, even though, with Shoreham defueled, an8  ;

-oa 'there is simply no health and safety need to maintain the

$8 operability of the generators. See Shoreham Nuclear Power gQ Station Defueled Safety Analysis Report, (Attachment 3 to SNRC-1664) at Section 8.3.1.

ou gg Under the requirements in Technical Specification Section oc 4.8.1.1.2.e2, 3, 4,5,6,7, 8 and 10 LILCO must verify that the l

@ emergency diesel generators 1) energize permanently connected and gg auto-connected shutdown loads, 2) operate for greater than or vaA equal to five minutes while loaded with shutdown loads or 3) respond properly to an ECCS actuation signal. As previously reported to f the NRC, LILCO has already implemented the System l Lay-Up Implementation Program (SLIP) for many of the systems which contain significant portions of the shutdown loads Y

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, 'C-L SNRC-1694 {

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I (e.g. core spray and residual heat removal). Thus to obtain the i technical specification shutdown loads would require LILCO to undertake the burdensome and costly task of placing these systems back into the condition they were in prior to their current ,

, protected state. Additionally, the ECCS actuation logic has been ,

deenergized in accordance with the SLIP. l s

In SNRC-1664, LILCO requested, pursuant to 10 CFR 50.90, that

[ Shoreham's license be amended to remove, among other things, the one-time five year inspection requirement contained in Paragraph A, Attachment 2 to NPF-82 and the surveillance requirements L associated with the EDGs. Due to the nature and extent'of the entire amendment application, LILCO anticipates a longthy review on the part of the NRC Staff. Interim relief will permit LILCO i to defer performance of 1) the one-time 25% sample inspection.

following five years of service and 2) those portions of the eighteen month surveillance tests in which simulation of a loss of offsite power up to and including coincident with a loss of ,

coolant accident occurs.

LILCO believes interim relief should be granted on the following  !

basis:

1. The Shoreham reactor has been defueled and all fuel is in the spent fuel storage pool.

2. LILCO will continue to meet the remaining emergency diesel

. generator. surveillance requirements of the Shoreham Technical Specification.

3. Under the settlement Agreement with the-State.of New York, LILCO is contractually prohibited from ever operating  !

Shoreham. .,

4. Design bases accidents for Shoreham in a defueled condition '

are described in Chapter 15 of the DSAR submitted in LILCO-letter SNRC-1664 dated January 5, 1990. Only two accidents have been found relevant: (1) Fuel Handling Accident and (2)  ;

Liquid Radwaste Tank Rupture. Because of the low-burnup condition of Shoreham's spent fuel, the amount of decay heat -

being generated is negligible and thus, active systems for pool water cooling.are not required.-

For the above reasons, LILCO-respectfully requests that it '

promptly be granted interim relief from having to perform the one-time five year (25% sample) inspection and the Tech Spec surveillances detailed above, pending the Staff's disposition of LILCO's January 5, 1990 license amendment request. LILCO will continue the other periodic:surveillances under the technical specifications.

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• , .i Should youihave any questions or need additional clarification, 1 p, .. please do:not' hesitate to contact my. office. .i o  ;

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. W. E. Steig Jr., .. ..

P- 3 Assistant Vice' President

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