ML20065H034
| ML20065H034 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/19/1982 |
| From: | Pollock M LONG ISLAND LIGHTING CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20065G854 | List: |
| References | |
| SNRC-730, NUDOCS 8210040361 | |
| Download: ML20065H034 (4) | |
Text
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LONG ISLAND LIGHTING COM PANY ag.rsmaw curungmumm 175 EAST OLD COUNTRY ROAD H IC KSV1 LLE. NEW YORK 11801 a
MILLARD S. POLLOCM vsCL PRESIDE NT-NUCLE AR July 19, 1982 Mr. Thomas T.
Martin Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 NRC Inspection No. 82-11 Shoreham Nuclear Power Station, Unit No. 1 Docket No. 50-322
Dear Mr. Martin:
This letter responds to your letter of June 18, 1982, which forwarded the report of the routine inspection of activities authorized by NRC License No. CPPR-95, conducted by Mr.
H.
Nicholas of your office on May 11-14, 17-20, 1982.
Your letter stated that it appeared that one of our activities was not conducted in full compliance with the NRC requirements.
The apparent noncompliance and our response follow.
Apparent Noncompliance with 10CFR50 Appendix B Criterion XI, 10CFR50 Appendix A Criterion 18, and SNPS FSAR Section 8. 3.2.1 10CFR50, Appendix B, Criterion XI, requires a test program with written test procedures to demonstrate that systems and conponents will perform satisfactorily in service, incorporat-ing the requirements and acceptance limits contained in applicable documents.
10CFR50, Appendix A, Criterion 18, requires that electrical power systems important to safety shall be designed to be tested periodically for operability and functional per-formance.
SNPS FSAR Section 8.3.2.1 states that a battery performance test will be performed every five years and that a battery service test will be performed every eighteen months.
8210040361 820927 PDR ADOCK 05000322 G
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Mr. Thomas T. Martin July 19, 1982 Page Two Contrary to the above, as of May 20, 1982, service testing had not been performed on three batteries due to be tested by August 1981, August 1981 and March 1982, respectively.
LILCO Position LILCO does not agree that the finding cited above violates the requirements of:
- 1) 10CFR50, Appendix B, Criterion XI; 2) 10CFR50, Appendix A, Criterion 18; and 3) SNPS FSAR Section 8.3.2.1.
The reasons for this position are as follows:
1)
LILCO conducted the initial performance and service tests in 1980, as stated in the report, using anproved written test procedures.
During the subsequent preoperational testing phase, LILCO has provided for periodic maintenance and testing (such as greasing of terndnals, checking for corrosion, testing specific gravity, etc. ) specifically to prevent deterioration of the batteries or to detect deterioration should it occur.
Written and approved Interim Operating Instructions are used for this function.
Therefore, LILCO has satisfied the conditions of 10CFR50, Appendix B, Criterion XI.
2)
The cited batteries have been designed to permit appropriate periodic testing as required by 10CFR50, Appendix A, Criterion 18.
3)
SNPS FSAR Section 8.3.2.1 states that a battery service test will be performed during each refueling outage or at some other outage with intervals between tests not to exceed 18 mon ths.
This periodicity was intended to apply during the operations phase not the preoperations phase.
Actions to be Taken to Avoid Future Violations The batteries will be subject to service testing in accordance with the Plant Staff surveillance program which commences prior to entering into the initial fuel load plant condition per Technical Specifications.
When the surveillance program is initiated, scope and frequency of battery service will satisfy the Technical Specification capacity test requirements.
Mr. Thomas T.
Martin July J9, 1982 Page Three When Action Will Be Completed A-on will be completed at the time the surveillance program is i..itiated which is prior to entering into an initial fuel load plant condition.
Very truly yours, N.
bY M.
S. Pollock Vice President-Nuclear cc:
Mr.
J.
Higgins All Parties i
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o STATE OF NEW YORK
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- ss.:
COUNTY OF NASSAU
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MILLARD S. POLLOCK, being duly sworn, deposes and says that I am a Vice President of Long Island Lighting Company, the owner of the facility described in the caption above.
I have read the Notice of Violation dated June 18, 1982, and also the response thereto prepared under my direction dated July 19, 1982.
The facts set forth in said response are based upon reports and information provided to me by the employees, agents, and representatives of Long Island Lighting Company responsible for the activities described in said Notice of Violation and in said response.
I believe the facts set forth in said response are true.
A4W b
7'MILLARD S.
POLLOCK i
i Sworn to before me this
- ' day of f *4'y, 1982.
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ROSA LEE OLNEROS fttary Pubiic, Stato of New York No. 30-4708263 Qualif,ed in flassau County ejf Commission capises htar. 30,194.4 l
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