ML20078D809

Rept on Mod of Automatic Depressurization Sys Logic in Response to ASLB Request.Aslb Should Defer Further Consideration Pending Status Rept on Implementation of Option 2,due by 840115.Certificate of Svc Encl

ML20078D809
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	09/30/1983
From:	Twana Ellis HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.18, TASK-TM ISSUANCES-OL, NUDOCS 8310040630
Download: ML20078D809 (7)

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LILCO, September 30, 1983 JI.L 00CNETED

- USNRC UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETAFP Before the At'omic Safety and Licensing Bgj g TB lC

.In the Matter of )

)

-LONG ISLAND LIGHTING COMPANY )-

Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

LILCO REPORT REGARDING MODIFICATION OF ADS LOGIC By Order dated September 1,-1983, the Board requested that LILCO, by September 30, 1983, inform the Board as follows:

whether it still intends to defer the ADS logic modification until the first refueling outage in view of the change in fuel load schedule subsequent-to its August 5, 1983 letter to the Staff. If so, LILCO shall supply the basis for its decision. LILCO shall make clear whether its basis depends on a reading of the application to Shoreham of the schedule set forth in item II.K.3.18 which differs from the Board's preliminary view, or on the opportunity open to an appli-cant to establish that the NUREG-0737 imple .

mentation schedule is not necessary to reasonably assure protection of public health and safety, or both.

Thi a Report responds to the Beard's request for information on LILCO's plans concerning the ADS logic modification.

0310040630 830930 PDR ADOCK 05000322 O PDR )

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Item'II.K.3.19 of NUREG-0737, Clarification of TMI Action. Plan Requirements," states that the Automatic Depressurization System (ADS) logic should be modified to,

- ell'minate the need for manual actuation to assure adequate core cooling. The Boiling Water Reactor Owners' Group 4

(BWROG) , of1which LILCO is a member, submitted .a' letter dated October 28, 1982, delineating several modifications which could .1xa. made to meet - the requirements of item II.K. 3.18. The NRC' Staff approved two of these modifications in an internal memorandum dated April 1,1983.

i On' August 5, 1983, LILCO adviset the Staff in SNRC-947 that LILCO would implement approved Option 2 'cn1 a schedule l'

consistent with the first refueling outage. This option eliminates the high drywell pressure permissive signal and-

! adds lan ADS manual inhibit switch. - LILCO has not received a response to this letter, but based on informal discussions with Staff.~ personnel, LILCO understood that the Staff found this~ schedule acceptable. Based on this premise and based on existing engineering priorities for modifications to be made prior.to'the first refueling outage, work on a conceptual i

design was' deferred until a later time. Thus, when LILCO received the Board's memorandum dated September 1,

-engineering work had not yet commenced on the ADS modifica-tion. In view of the Board's inquiry and the delay in Shoreham's estimated fuel '

oad date to late in the first s

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LILCO now intends to' implement this modific tion prior.# ' '

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to fuel load, but notes that initial schedule projectiohn ,

indicate that this may not be possible. The engineering _

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effort requires design interface among LILCO, Geher,di Electric .

m and Stone & ~ Webster which will increase the time necessdry to, s

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complete the design for this modification. S c.hed 31e, s cj ec- '

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tions based upon the preliminary conceptual desian 3'ust com -- i s 3s '

i pleted suggest that engineering and material proburgdt nt for this modification can be completed sometime in lat'e, February, 1984. A firm determination of the implementation. schedule cannot be made until the detailed design is conpletId. Imple-mentationofthismodificationjustpriortofu'e;L' load)iscon-a siderablymoredifficultthanitwouldhavebeen@uringthe construction phase or during a major outac.e. Nevdrtpeless, LILCO will make every effort'to achieve implementation prior to ,

fuel load. ,

Upon completion of engineering and material.. prc$curbment, e '

LILCO will commence implementation of the modific$tio'n if', ,

t sufficient time is available prior to the then schedu'.ed ':uel -

load. It is estimated that six to eight weeks wilL be required

% s to complete the physical work (including mountingnew- switches on control panels, wiring new annunciators, removing cable tray v

covers, removing fire stops, and performing cable pulls) to perform preoperational testing, to revise station procedures,

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Review of Operations Committee approval.

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Y after approval of the engineering package, insufficient time v s. -

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remains prior to the then scheduled. fuel. load to complete the modification, LILCO's intention is to defer completion of the

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work until!h,he- irst appropriate opportunity after fuel load.

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LILCO' believes that the current ADS design, with imple-mentation of the BWR Emergency Procedure Guidelines (as was

[doneforShorehamEmergencyProcedures), is adequate for all s

design basis events which require reactor pressure vessel h( depressurization to,, maintain adequate core cooling. Implementa-

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tiog of thh hDS mobification enhances ADS operation but is not requir,ed prio'r t'6;, fuel load reasonably to assure protection of y .

p, the public health'and safety. LILCO believes its view is sup-1,portedShy Yhi' fact that the schedule originally proposed for ys ,

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[# this abdification would have allowed LILCO to operate through r . ,

i the fir,st refueling outage without modification.

w 4 J In summary,.in response to the Board's inquiry, LILCO f now intends to use its best efforts to install the modification toEthe ADS' system (Option 2) prior to fuel load. Engineering a' s

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has commenced on a priority basis and procurement is underway.

LILCO notes, however, that uncertainties in the fuel load date and the time required to complete the engineering and installa-tion work associated with the modification make it impossible to predict with certainty at this time whether this modification A

can be' accomplished-p'rior.to fuel load. If the modification cannot be completed prior to fuel load, it is LILCO's intention to defer the modification until the first appropriate oppor-tunity-after fuel. load. -But given LILCO's intention to attempt to implement the modification prior to fuel load, LILCO believes

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it is unnecessary at this time to address the questions whether the'NUREG-0737 implementation schedule, as applied to Shoreham, requires implementation of the modification prior to fuel-load and, if so, whether such an implementation schedule is necessary to provide reasonable. assurance of the public health and safety.

Accordingly, LILCO respectfully suggests that the Board defer further consideration of tbis matter pending receipt from LILCO of a status report on the. progress of the implementation of Option 2, which report LILCO proposes to submit on January 15, 1984. LILCO believes it will then be better able to predict.

with accuracy whether the modification will be completed prior to fuel load.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

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T./5. Ellis, III Anthony F. Earley, Jr.

Hunton & Williams P. O.. Box 1535 Richmond, Virginia 23212 DATED: September 30, 1983

s LILCO, September 30, 1983 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit-1)

Docket No. 50-322 (OL)

I certify that copies of LILCO's Report Regarding Modification of ADS Logic were served this date upon the following by first-class mail, postage prepaid, or by hand, as. indicated by an asterisk:

Lawrence Brenner, Esq.* Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory

. Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear. Regulatory Commission- Atomic Safety and Licensing 4350 East-West Highway Appeal Board Panel North Tower, Fourth Floor U.S. Nuclear Regulatory Bethesda, Maryland 20814 Commission Washington, D.C. 20555 Dr. Peter A. Morris

• Administrative Judge Atomic Safety and Licensing Atomic Safety.and Licensing Board. Panel Board. Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 4350 East-West Highway North Tower, Fourth Floor Bernard M. Bordenick, Esq.*

Bethesda, Maryland 20814 U.S. Nuclear Regulatory Commission

, Dr. George A. Ferguson* Maryland National Bank Building

-School of Engineering 7735 Old Georgetown Road Howard University . Bethesda, Maryland 20814 2300 6th Street, N.W.

Washington, D.C. 20059

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M EHerbert H.. Brown, Esq.*. . David J. Gilmartin, Esq..

Lawrence'Coe Lanpher,lEsq. Attn: Patricia.A.-Dempsey, Esq.

Alan Roy Dynner,_Esq.-. County Attorney

.Kirkpatrick, Lockhart,' Hill,- Suffolk County Department of Law Christopher-&~Phillips . Veterans Memorial Highway .

1900 M Street Hauppauge, New York.' 11787 8th Floor Washington, D.C.. 20036 ' Stephen B. Latham, Esq.

'Twomey, Latham~&'Shea Mr. Marc W.~ Goldsmith 33 West Second Street Energy'Research Group P. O. Box'398

.4001 Totten-LPond Road Riverhead, New York. 11901 Waltham, Massachusetts' 02154 Ralph-Shapiro, Esq.

MHB Technical Associates Cammer and Shapiro, P.C.

1723 Hamilton Avenue 9 East 40th Street Suite K - New Yo rk , N . Y . 10016 L San' Jose,. California 95125 Howard L. Blau ':

Mr. Jay-Dunkleberger 217 Newbridge Road

New'. York State' Energy Office .Hicksville, New York 11801 Agency Building 2-Empire State Plaza. .

Matthew'J. Kelly, Esq.

Albany,.New-York 12223 State of.New York j .

Department of Public Service James Dougherty, Esq. Three Empire State Plaza 3045 Porter Street- Albany, New York 12223 Washington, D.C. 20008

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/f lll k$p@i'P T. Krti-lis, III Hunton & Williams l 707' East Main Street P. O. Box'1535 -

Richmond, Virginia .23212

[ DATED: September 30,-1983 t

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