ML20195E764
| ML20195E764 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/30/1988 |
| From: | Leonard J LONG ISLAND LIGHTING CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20195E760 | List: |
| References | |
| FRN-53FR32919, RULE-PR-50 VPNO87-29, NUDOCS 8811110050 | |
| Download: ML20195E764 (7) | |
Text
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LONG lSLAND LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION P.O. BOX 618. NORTH COUNTRY RO AD e WADING RIVER. N.Y.11792 JOHN D. LEONARD. JR.
VM:t P At8 0 TNT.NvCLt An cM m ATHl>Nt January 30, 1987 VPNO87-29 Mr. Samuel J. Chilk, Secretary U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTN:
Docketing and Service Branch
Subject:
Request for Public Comment on the NRC's Statement of Policy for Nuclear Power Plant License Renewal -
Federal Register of Thursday, November 6, 1986
Dear Mr. Chilk:
The Long Island Lighting Company (LILCO), owners of the Shoreham Nuclear Power Station, desires to comment on the subject policy statement.
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As you know, LILCO 1,s in the beginning phases of operating the Shoreham plant - presently with a low power (less than 54) license set to expire on April 13, 2013.
Usual industry practice sets initial licensing at 40 years after the date of conversion of the construction permit to an operating license.
In the case of Shoreham, due to the absence of State and local government cooperation in emergency planning, it has now been more than two years that the plant has been held to its status of less than 5%
of rated capacity.
Much of the time the reactor has been at zero power.
Thus, in a very real sense, we at Shoreham know that the real service lifetime of a plant, nuclear or otherwise, is very much a function of its integrated usage factors.
Certainly, as long as the plant is held virtually inactive, this time, however much longer it becomes, should be added to the termination date i
of the present eventual license period for plant operations.
l In the matter of the NRC's request for public comment on the commission's policy statement on nuclear plant license renewal or l
8911110050 001027 ong pp l
50 53FR32919 PDR
P0ga 2 plant life extension, LILCO is in receipt of a copy of the Nuclear Utilities Plant Life Extension (NUPLEX) Steering Committee's letter to the NRC on the subject.
Together with other utilities, LILCO has been invited by the NUPLEX Committee to comment to the Commission on any or all of the positions outlines in Enclosure A to their letter.
At the outset, LILCO desires to state its general endorsement of the NUPLEX positions.
Discussion of our concurrence is outlined in the paragraphs below which follow the NRC Questions published in the subject Policy statement.
NRC Ouestions 1.a, 1.b, 1.c, and 6 (These questions call for discussion of the extent to which the NRC should proceed, in the near term, in defining regulatory policy regarding plant life extension; when such policy must be in places and what is the overall schedule appropriate to achieve resolution relative to plant life extension.)
We. concur with the NUPLEX position in response to Question 1.a that it is now timely for the Commission to proceed in defining the regulatory policy applicable to requests by utilities to extend the operational life of commercial light water plants beyond the current forty-year license period.
In particular, we endorse the twelve (12) year license period stipulated as a reasonable time for planning should it become necessary to provide replacement baseload sources for a nuclear station which may be retired.
The schedule outlined by the NUPLEX Committee in response to NRC's Question 6 to achieve timely submission of the earliest applications for plant life extensions seems reasonable.
Early solidification of a regulatory policy will provide all licensees with guidance toward effective evidenciary plant record keeping in support of eventual application for licensing plant life 1
extension.
NRC Question 1.de (Asks for discussion of the extent of individual license or industry group activity on planning, at this time, to request NRC permission for plant life extension beyond expiration of licenses.)
Situated as LILCO is, at the beginning of meaningful operation cf the Shoreham plant, we view positively the option to seek renewal of licensure for plant life extension when that time arrives.
We, therefore, endorse the actions of the NUPLEX Steering Committee in its response to this Question 1.d as presented in Enclosure A to their letter.
LILCO, along with the nuclear utility industry as a whole desires that "a practicable and predictable process and criteria for license renewal can be reached in a timely manner."
We support the industry groups (NUPLEX, NUMARC, the AIF, and others) in their work (in this as well as other work) with the NRC on behalf of the industry.
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4 WRC Question 2.as (Asks what timely and sufficient criteria should be applied to judge that a request for license extension is both timely and suf ficient).
In regards to timeliness, LILCO agrees that (as noted in the i
NUPLEX response to Questions 1 and 6 above) twelve (12) or more years in advance of license expiration, in view of necessary lead i
time to prepare plans for replacement base load power, is a i
reasonable time to seek license renewal for a commercial light
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i water reactor power plant.
The planning "lead time" is necessary to allow for exploration of alternate baseload power sourc es i
should it become apparent that these sources may become necessary in lieu of the plant life extension under consideration.
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we also concur, however, with NUPLEX's view that extenuating i
circumstances could result in a much shorter time for an individual plant request.
We suggest in such cases that the 30 l
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day provision for any and all license renewals given present2v in i
10 CFR 2.109 is entirely unrealistic for NRC's review to act upon a license renewal of the size and scope of permission to
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operate a power reactor beyond its original license term.
We agree with NUPLEX that, as a minimum, a two year lead for filing would be appropriate under conditions where a well formulated NRC policy I
and industry experience are in place for plant life extension.
t In the matter of sufficiency, LILCO concurs with NUPLEX's i
response that these standards should be provided by the US code, i
(5 USC 558 (c)) - the Administrative Procedures Act, and art thus 4
best left to each individual agency "in accordance with (its) i rules,....".
NUPLEX goes on to state in view of the absence of present provisions of the Atomic Energy Act of 1954 and present j
i NRC regulations in the matter, new NRC license renewal policy and implementation by the Convission are required.
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Paramount in this policy making should be implementation of 10 i
CFR 50.32 which permits incorporation by reference in license renewal considerations to documents previously filed with t.he Commission.
Much of the previous documentation will be applicable.
Where this data relates to aging of components, t
etc., it is central to the application.
If this kind of data
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requires augmentation, it must be developed and furnished to j
support the application.
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j WRC Question 2.b: (Asks whether a plant should be limited in its operations beyond its 40 year license expiration date pending NRC i
j completion of its plant life extension application, j
As is stated in Enclosure A to the NUPLEX Steering Committee t
letter, a "timely and sufficient " application for plant life l
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extension should, according to 5 UsC 558(c) (the Administrative i
Procedures Act), eveke permission to operate a plant in a ssfe
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and proper manner until the NRC has given its decision on the j
application regardless of whether such decision comes later than 4
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Pago 4 r
the expiration date.
As is noted by NUPLEX, the Commission does have ample power and authority to limit or curtail plant operation under its rules now in place if there is legitimate i
concern for the health and safety of the public - regardless of where the plant is in terms of timing vis-a-vis expiration of fts l
license.
l NRC Questions 3a and 3bt (These address the use of performance Eased information coupled with PRA insights for decision making in license extension and ask whether plants applying for life extension should be required to change their licensing basis to conform with regulations or "current require-ments" in effect at the date of the extension application).
i LILCO concurs with the NUPLEX Steering Committee's contention
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that the plant's original "approved licensing basis" for the j
plants original license should be followed as the basis for j
relicensing, provided that this basis will be augmented where i
evidences of new safety requirements have evolved.
(The enclosure to the NUPLEX letter cites as an example, the TMI i
Action Plan.)
In such cases, the basis for license extension t
should be modified to be in compliance with "current requirements" on a case-by-case determination.
In these cases, use should be made of the NRC's revised backfit rule (10 CFR 50.109), as required, just as would be required for a plant whose
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original license term still had not run its course.
Further, as j
noted in the M*JPLEX response, the use of relevant operating I
1 experience regarding data related to the performance of equipment subject to age degradation, would seem to be more appropriate i
than changing the "approved licensing basis" for decision making l
by NRC regarding life extension licensing.
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NRC Ouestions 4.b and 4.ca (Asks which, if any, of the NRC's i
licensing criteria are not appropriate for the purpose of reviewing plant life extension and how and to what extent should l
prior operating history of the plant be factored into 1
considerations for license extensions.)
l These questions again lead to the conclusion, as stated above, that those original licensing basis criteria which examined age related degradation should again require examination for estab-l j
lishing the new licensing basis for plant life extension, i
License basis criteria, ot,her than age related are, by defini-l 4
tion, less time dependent and, therefore, less strongly coupled to plant life and the extension thereof.
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LILCO regards records of the integrated plant history as vitally
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relevant to determining the service age of plant components whose present condition are known to be subject to age degradation.
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an example, an important factor in the service age of the reactor j
1 pressure vessel is the effect of neutron fluence or integrated neutron flux exposure as this relates to the embrittlement and i
the related nil ductility temperature properties of the vessel.
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Page 5 NRC Question 5.at (Asks which criteria for selection of com-ponents and structures will require residual lifetime evaluations in consideration for life extension).
LILCO concurs with the NUPLEX response which states that components and structures which are safety significant;' subject to age degrad: lien during extended life operation; and are not part of norr.a1 mairtenance or replacement should be part of the life extension program.
LILCO submits that these considerations should be approached on a p! ant specific basis and should be analyzed in the light of that plant's integrated operating history; its maintenance and repair history; and its component replacement records.
NRC Questions 5.b and 5.c (Asks for major technical parameters and criteria which should be considered in NRC reviews to permit reactor operation past expiration of its first full term license
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and which are major lead time items for review and data
- ollection of such parameters.)
LILCO endorses the NUPLEX position that plant components should be considered by the following two categories:
Category 1 - Components of very long lifetimes where age related degradation is not a significant factor for them during their projected life extension period; and Category 2 - Components which have known degradation mechanisms which could impact component, system, or structure performance and must be reviewed to justify life extension.
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LILCO concurs with NUPLEX that it is Category 2 itemJ which must be reviewed to establish a basis for continued operation of the plant during extended life.
Technical factors for "lead time" data collection of plant life extension determination are accurate evidence of low cyclic fatigue of safety significant components; records on ambient exposure conditions to which electrical cables are exposed; and data on reactor vessel embrittlement resulting from integrated neutron flux exposure.
l Nuclear power plants, including Shoreham, maintain in place careful and extended programs to ensure accumulation of these i
data.
These record keepf.ng activities are the bases for l
prediction of properties of the reactor vassol and other safety related equipment during extended plant life.
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i Page 6 NRC Questions 5.e and 5.fi (Asks about adequacy of codes and standards to cover life extension and what studies or research
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have been and are ongoing to address nuclear plant life I
extension.)
l LILCO endorses the NUPLEX views on the adequacy of present codes I
and standards.
Ongoing review and control (as well.as allocation.
I of jurisdiction of revising and formulation of new standards is under the continuing review of the Nuclear Standards Review Board.
This board, consisting as it does, of representatives from all parts of the industry has functioned well over the years in guiding such code and standard groups as ANSI, ANS, IEEE,
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ASCRE, ASME and others to formulate workable nuclear power plant documents which have withstood the test of time and i
applicability.
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LILCO has supported and will continue to support as well as I
contribute technically to industry groups which are engaged in research addressing generic issues for the industry as well as
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reactor plant specific studies.
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NRC Question 7.a and 7.br (Discusses procedural considerations -
should there be procedural changes regarding future operating i
i license extensions and current treatment of initial license l
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applications?
If so, what?)
r LILCO concurs with NUPLEX in response to these considerations.
We believe that any changes to the existing rules and regulations i
to allow and facilitate plant life extension, can be achieved i
i under the framework of existing law.
i Determination of the appropriateness of plant life extension for
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a particular plant falla properly under the aegis of amending an j
existing license.
10 CFR 50.90 through 50.92 (amended as necessary to cover reculation of plant life extension) should be the pattern for such an amendment request and for the l
j commission's procedures in conducting its determinations.
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The determination governing significant hasards consideration is i
the appropriate arena for the amendment of a license to operate a
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pwer reactor beyond its originally stipulated term.
The I
hearings which would inevitably result from application for such 1
plant life extension should probably follow the Coemissions I
existing rules.
In cases where a "no significant hazards j
determination" can be made, such hearings need not take place l
prior to granting the license amendment to extend the life of the l
plant.
T In the above discussion and other aspects of the procedural l
considerations leading to plant life extension and the rules for j
the granting thereof, LILCO generally concurs with the NUPLEX j
submission.
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POg3 7 LILCo welcomes the opportunity to supply its comments to this important matter of the NRC's development of its policy statement on nuclear power plant license renewal.
Very truly yours, orn D. Leonar,
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Vi e President - Nuc1 a Operations G ck cc Mr. Jack H. Ferguson Chairman, NUMARC Executive Group l
Mr. Gerald Deils, Chairman
'NUPIEX Steering Committee l
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