ML20247N053
| ML20247N053 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/19/1989 |
| From: | Earley A LONG ISLAND LIGHTING CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| CON-#390-10531 NUDOCS 8909260128 | |
| Download: ML20247N053 (7) | |
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[E,g LONG ISL_AND LIGHTING COM PANY hmg_ _-
l EXECUTIVE OFFICES.175 E AST OLD COUt41RY ROAD
- HICKSVILLE, NEW YORK 11801 ANTilONY F. EARIEY,JR.
PitfallHiNT AND(:511f F OPl.RA l'fM(e OFFH Ut September 19, 1989 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 LILCO's Response to the August 30, 1989 Letter From NRC (T. Murley) to LILCO (A. F. Earley, Jr.)
Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Ref: (1)
NRC (T. Murley) letter to LILCO (A. F. Earley, Jr.)
dated August 30, 1989
( 2.?
LILCO (W. E. Steiger, Jr.) letter SNRC-1626 to NRC (W. T. Russell) dated August 31, 1989; subject:
" Staffing Report" (3)
LILCO (A. F. Earley, Jr.) letter to NRC (W. Russell),
dated July 5, 1989
Dear Dr. Murley:
LILCO hereby presents its written response to your letter of August 30, 1989 to me (reference (1)).
1.
LILCO's Intentions Regarding Plant Equipment and Staffing Your August 30 letter requested LILCO's intentions and assurances with respect to three specific aspects of plant equipment and staffing at Shoreham pending NRC authorization of decommissioning or other disposition of the facility.
LILCO responds as follows:
(1)
Systems required for safety in the defueled mode will be maintained in a fully OPERABLE status f9001 8909260128 890919 PDR ADOCK 05000322 I
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LONG ISLAND LIGHT 1NG COMPANY Dr. Thomas '.. Murley, Director September 1989 Page 2 pursuant to existing technical specifications.
The term OPERABLE is discussed more fully in 5 2A below.
(2)
Systems not required for safety in the defueled mode at Shoreham but necessary for full-power operation will be protected on a cost-effective basis consistent with NRC regulations and LILCO's 2icense obligations pending plant disposition.
Depending on their function, such systems will be classified and maintained as OPERABLE, or as FUNCTIONAL or PROTECTED as defined in 1 2A below, in accordance with a three-phase program involving (1) development of a conceptual plant configuration, (2) development of a specific lay-up program, and (3) program implementation.
This overall program is described in greater detail in 5 2 below.
(3)
An adequate number of properly trained staff to ensure the health and safety of the public in the defueled state will be maintained, as stated more fully in 1 3 below.
LILCO reserves its right to modify these and other existing activities by, as appropriate, analyses pursuant to 10 CFR S 50.59, requests to alter license and technical specification orovisions pursuant to 10 CFR S 50.90, or other means permitted by the Commission's regulations.
2.
Further Description of Treatment of Systems Not Required for Safety in the Defueled Mode LILCO has designed a systematic program for the equipment in the Shoreham p1'nt during the reasonably anticipatable duration a
of NRC proceedings concerning disposition of its operating license for the plant.
The three phases of this program are described below.
A.
Conceptualized Plant Configuration Development of the necessary conceptualized plant configuration is now complete.
This phase consisted of a technical specification applicability review, system review and categorization, and an extensive review and approval cycle.
The technical specification applicability review, preliminarily
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conducted by Operations Section personnel along with the Plant
{
Manager, conservatively considered that with the fuel in the i
spent fuel storage pool, most Limiting Conditions for operation
("LCOs") in the technical specification for OPERATIONAL
.s-LONG ISLAND UGHT1NG 'COMf%NY Dr. Thomas E. Murley, Director September 19, 1989 Page 3 i
CONDITIONS 4, 5 AND
- would be applicable.
Additionally, the "at all times"'and."whenever" LCOs. applied.
Subsequently a'further, more detailed evaluation was j
conducted by a task force of System Engineers, Cognizant Site Engineers and On-shift-Operations Advisors expending over 4,000 man-hours to develop a detailed plant. configuration plan conforming with. license. requirements for the defueled condition.
Included in.this process were the-evaluation and incorporation, as applicable, of commitments identified during the USAR/FRAR i
review by the Nuclear Operations Support Department (NOSD).
Plant systems were then categorized as either required to be OPRRABLE'or not.
Those' systems which were designated as not required to be' OPERABLE were categorized as FUNCTIONAL or as PROTECTED.-
This determination was fully reviewed to complete comment resolution by.a Review of Operations Subcommittee and approved by the. full Review of Operations Committee.
The NRC Senior Resident Inspector was cognizant of the process and attended pertinent meetings.
As used in this discussion, the term. OPERABLE is defined in Section 1.26 of the SNPS Technical Specifications.
ACTION requirements in the Technical Specifications will be adhered to in the event a system required for safety becomes inoperable.
The term FUNCTIONAL refers to essential ~ support systems not required to be OPERABLE by technical specifications for the current plant condition but necessary for various plant functions and habitability concerns.
FUNCTIONAL systems differ from OPERABLE ones in that technical specification requirements apply only at higher operational modes and, therefore, need not be maintained current; or there are no technical specification which.
apply to the system in. question.
PROTECTED systems are those not to be operated in the defueled mode.
These systems will be left in a deenergized safe state and layed-up in accordance with System Lay-up Implementation Package (SLIPS), which specify maintenance and custodial services necessary to protect them pending disposition of LILCO's operating license.
These SLIPS, which are being developed for each affected system and will be available for 10perational condition "*" involves fuel movement in secondary containment.
_r_
LONG ISLAND LIGHTING COMFWNY Dr. Thomas E. Murley, Director September 19, 1989 Page 4 I
Staff review at the Shoreham site, are described in the following paragraphs.
l The results to date of this evaluation are as follows:
L a) 40 systems remain OPERABLE; b) 42 systems are to be maintained FUNCTIONAL; c) 43 systems are to be PROTECTED.
B.
Lay-up Program Development LILCO's plant management established a Lay-up Task Force with the charter of developing a program that will be consistently applied to each of the PROTECTED systems.
The intent of the program is to maintain these systems, in accordance with appropriate system-by-system criteria, for the reasonably anticipatable duration of NRC proceedings on the disposition of LILCO's operating license for Shoreham.
The Lay-up Task Force is comprised of members with broad expertise.
The systems engineer, compliance engineer, radiochemistry engineer and nuclear engineer are members of the task force.
The development process consisted of researching industry reference documents such as EPRI NP-51068, conducting utility surveys and holding working meetings to discuss essential program elements.
As a result, the Task Force developed the guidelines and instructions for the preparation of system lay-up implementation packages, the ingredients of system lay-up packages, guidelines for dry lay-up of systems, an administrative approval process for a SLIP, a system lay-up schedule, and the long term monitoring program which is still under development.
To the maximum extent practical the task force utilized existing programs and procedures which govern plant activities.
As a minimum each System Lay-up Implementation Package consists of:
1)
A safety evaluation 2)
A maintenance work request 3)
An approval cover sheet 4)
Marked-up system boundary drawing (s) 5)
Valve lineup checklist 6)
Component power supply checklist 7)
Annunciator listing 8)
Lifted lead and jumper permit (as required) 9)
Specific narrative instructions (as required) 10)
Special lay-up instructions (as required).
i
LoNG seLAND WGHnNG COMf%NY
^
.Dr. Thomas E.'Murley, Director September 19, 1989 Page 5 i
Once a SLIP is prepared, it is reviewed by a subcommittee of the Review of Operations Committee (ROC) and the I
full ROC, and approved by the Plant Manager.
The package is then ready for implementation.
C.
Lay-up Program Implementation I
When a SLIP is ready-to be implemented, it will be reviewed to determine the extent to which special lay-up f
equipment is required.
It will then be forwarded to the Work Planning and Scheduling Group.
This group will ensure that the necessary permits are obtained (e.g., radiation work permit or station equipment clearance permit) and a quality control review is performed.
Actual implementation of the SLIP will be performed by qualified operations and maintenance personnel.
A copy of the SLIP will be filed in the Shoreham records retrieval system.
3.
LILCO's Plans to Assure an Adequate Number of Properly Trained Staff Because LILCO cannot compel qualified nuclear personnel to remain with.the Company, we have taken steps to offer them careers elsewhere in the organization to retain their expertise.
LILCO's. Chairman, Dr. William Catacosinos, has assured each and every person at Shoreham that they are LILCO employees, not just Shoreham employees.
As a result, they were guaranteed that they would have positions with.the Company no matter what the outcome of the Shorcham controversy.
This guarantee was most helpful in assuring the maintenance of a qualified staff during the past 18 months.
Recently, we have reassigned personnel who are not needed at Shoreham at this time to other positions in the Company.
At present, LILCO believes that it has an adequate number of properly trained staff a? Shoreham.
If further losses beyond LILCO's control make it accessary to transfer former Shoreham personnel back to the plant, LILCO fully intends to do so.
We are also prepared to hire qualified consultants and contractors if necessary.
4.
Emergency Preparedness and LERO Your August 30 letter requested LILCO to discuss its plans for maintaining the approved Shoreham Emergency Plan and the LERO organization.
As has been discussed at the July 28 meeting, there is not any offsite radiological risk associated with the defueled mode at Shoreham justifying maintenance of the Shoreham Offsite Radiological Emergency Response Plan or of the LERO
LONG ISLAND LIGHT 1NG COMPANY Dr. Thomas E. Murley, Director September 19, 1989 Page 6 organization.
LILCO may accordingly file with the Staff a properly documented, specific request for relief appropriate to the changed level of risk at the plant.
Pending such filing and Staff action, however, LILCO will observe its license commitments for offsite radiological preparedness.
LILCO will also maintain its onsite emergency plan and organization despite the minimal level of risk in the defueled e
mode, until permission has been granted to amend them, pursuant to a request which LILCO will file with the Staff.
5.
Selection of Plant Operating Systems / Staff Levels The reference (1) letter also requested that written information be provided to describe the process followed by LILCO in selecting the operating status to be maintained for various plant systems in the defueled conditions and the process followed in determining the intended staffing change.
As promised, reference (2), SNRC-1626, provided that information.
6.
Other Matters On July 5, LILCO formally confirmed to the NRC, via Reference (3), that its agreement with New York State regarding Shoreham had become fully effective and that LILCO was prohibited by it from over operating the Shoreham plant.
That letter also confirmed to the Commission that LILCO intended, pursuant to that agreement, to transfer the plant to a qualified entity of New York State as quickly as practicable, and that LILCO would be j
taking, in the meantime, certain steps to place and maintain he plant in a safe defueled condition.
New York State authorities have indicated that they intend to obtain the NRC's permission to decommission the plant rather than operate it.
LILCO also reiterated its intent to abide by all of its obligations to the NRC pending that transfer.
Those remain LILCO's goals.
The first, central aspect of Reference (3) was LILCO's intention never to operate the Shoreham plant pending transfer to a qualified entity of New York State.
Numerous of the remaining steps to such transfer could be expedited, in LILCO's view, by a formal recognition of that fact.
LILCO urges the Commission, in its discretion, to issue a directive prohibiting LILCO from operating or refueling the plant, or from placing it in any situation which could cause a hazard to the health and safety of the public, pending such disposition, if the Commission concurs
l i
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LONG ISLAND LIGHTING COMPANY Dr. Thomas E. Murley, Director i
l September 19, 1989 l
Page 7 that such a directive would facilitate LILCO's obtaining relief from remaining obligations which are appropriate only in the anticipation of future operation.
(
Very truly yours, OAJdub
' ']
1 Anthony F. Earley, Jr.
President and Chief Operating Officer kmg i
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