SNRC-1449, Informs That Compliance Not Achieved W/All Commitments Made in Re Deletion of Steam Condensing Mode of RHR Sys in Normal Operation.Approval of Present Controls Since Deletion Unnecessary for Plant Operation Requested

Informs That Compliance Not Achieved W/All Commitments Made in Re Deletion of Steam Condensing Mode of RHR Sys in Normal Operation.Approval of Present Controls Since Deletion Unnecessary for Plant Operation Requested

ML20153D214
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/27/1988
From:	Leonard J LONG ISLAND LIGHTING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SNRC-1449, NUDOCS 8805090084
Download: ML20153D214 (4)

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[fgg@ LONG ISLAND LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY ROAD + WADINO R'VER. N.Y.11792 JOHN D. LEON ARD. JR.

VICE PAESt0 TNT NUCLE AR OPE R AttONS SNRC-1449 APR 27 E68 U.S. Nuclear Regulatory Commission ,

ATTN: Document Control Desk Washington, DC 20555 Humphrey Concerns 3.3 and 3.4 Shoreham Nuclear Power Station - Unit 1 Docket No. S0-322 D;Ierences: (1) LILCO letter SNRC-824, dated January 28, 1983, (J. L. Smith, Manager, Special Projects) to Harold R. Denton, Director, Office of Nuclear Reactor Regulation, NRC, cubject: Humphrey Concerns 3.3 and 3.4 (2) NUREG-0420, Safety Evaluation Report related to the operation of Shoreham Nuclear Power Station - Unit No. 1, Supplement No. 4, September 1983 (3) Shoreham Nuclear Power Sta tion, Facility Opern ' i r.g License , NPF-36 Gentlemen:

The purpose of this letter is to inform you that, during the course of a detailed review of Shoreham Nuclear Power Station (SNPS) compliance with commitments made to the NRC, Long Island Lighting Company (LILCO) discovered that complete compliance was not achieved with all commitments, as contained in the reference (1) letter, related to the deletion of the Steam Condensing Mode (SCM) during normal operation. The SNPS Project Manager and Resident Inspector were immediately notified of this condition.

As explained below, LILCO believes that SNPS is in compliance with the staf f conclusions stated in reference (2) and the Condition of License as found in reference (3) and that the closure of manual isolation valves in the Residual Heat Removal (RHR) system, as committed to in reference (1) , is unnecessary to ensure that the Steam condensing Mo6e of the Residual Heat j Removal system will not be used during normal plant operation.

However, we request your review, concurrence and approval of the present controls, {

i 8805090084 E80427 p1 PDI< ADOCK 05000322 'I O l P DCD ,

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/ .* SNRC-1449 Page 2 ,.

Reference (1) stated that LILCo had elected to delete the SCM as i an operating condition of the RHR system for all normal plant ,

operations at SNPS. Accordingly, LILCO committed to issuing a SNPS standing order to operating personnel prohibiting the use of SCM during normal plant operations. In addition, to preclude inadvertent operation in the SCM, LILCO, in reference (1), had proposed the following:

I a) isolate RHR system pressure control valves lE11*PCV007A 4 and 1 Ell *PCV007B (using manual isolation valves);

b) isolate upstream RHR system pressure control valves  !

1E11*PCV003A and 1E11*PCV003B-(using upstream manual ,

isolation valves);

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c) isolate RHR Heat Exchanger level controllers 1 Ell *LIC002A:and 1E11*LIC002B by closing manual isolation valves; and .

i d) isolate RHR Heat Exchanger pressure controllers -

1 Ell *PIC003A and 1 Ell *PIC003B by closing manual  !

isolation valves.

In reference (2), Section 3.8.2, Concrete and Structural _ Steel i Internal Structures, the NRC staff found "that, given the above commitments 1' , the adequacy of Shoreham's Mark II containment has ,

been retained at the level that was found acceptable during the NRC staff's previous review. Therefore, the NRC staff will' ,

condition the operating license for Shoreham to delete the SCM as -

an operating mode for the RHR for all normal plant operations. ,

i However, the SCM may be put'into service when all other means for  ;'

core / containment cooling have been lost, such as during postulated severe accidents."

Steam Condensing Mode of Additionally, Residual Heatin Sectionof5.4.2.1, Removal, referenc h (2) ,' thn NRC staf f found that

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"the steam condensing mode of RHR is not an essential mode. ,

j Moreover, Shoreham does not use SCM for mitigation during j transients and accidents. The applicant is committed to the i i 4

1 1/ The "above commitments" refer to rererence (1) and

specifically cite "(the) SCM will be deleted as an operating 1 1 mode of RHR for plant operating modes 1, 2 and 3. However, I to accommodate certain non-design-basis events involving i 1 multiple failures (e.g., station blackout), the applicant l stated that the SCM will be retained as an option that w'll  !

be available for use by the operator when all other sources j of core / containment cooling have been exhausted." i I

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. S,N RC-14 4 9 l Page 3 precautionary measures described above I. For these reasons, the NRC staff has concluded that the applicant's proposal to delete the steam condensing mode of HHR during normal plant operation is acceptable."

In accordance with reference (1) , LILCO issued Standing Order #13 on February 13, 1983. This Standing Order is explicit in its prohibition of the use of the SCM. In addition, Section 8.1.7 of plant procedure SP 23.121.01, Residual Heat Removal (RHR) System, has been revised and specifically prohibits the use of SCM during l normal operation. The SCM use is limited to the Loss of AC Power emergency procedure, and an explanation is given as to why the limitation exists. Also, operator training further reinforces  !

the prohibition of SCM use.  !

We wish to advise you that the additional physical commitments proposed by reference (1), items a through d above, have not been implemented and have been determined to be inadvisable. LILCO l has determined that isolation of the aforementioned components '

would have a negative impact on normal HHR system operation and that, in the event of loss of AC power, SCM operation would be very difficult. Pressure control valves lEll*PCV007A and B, and i lEll*PCV003A and B, which are electro-pneumatically operated and  !

which fail closed with a loss of AC power, are normally closed. 1 However, the valves are equipped with a handwheel so that they can be operated locally. Local manual operation of these valves must be performed with communications set-up between valve operators and those personnel that will be monitoring Heat Exchanger pressure and level. Additionally, manual isolation of 4 the pressure cot.ttol valves 1 Ell *PCV007A and B, and lEll*PC7003A l and B (i ems a and b) would render SCM system use inoperable during a Loss of AC Power event unless operators were dispatched into the plant to manually open these valves. This would be l unnecessarily time consuming. Furthermore, isolation of Heat Exchanger level and pressure controllers (items c and d) by closure of manual valves 1 Ell *0lV7053A and B, lEll*C1V7054 A and  ;

B, and lEll*01V70SSA and B, will also isolate RHR heat exchanger level and pressure transmitter instrumentation - lEll*LT002A and B and lEll*PT003A and B, respectively - and therefore, 2/ The "precautionary measures described above" refer to reference (1) and specifically cite that "the applicant will issue a standing order to operating personnel prohibiting the use of steam condensing during normal plant operations. In addition, valves used in SCM wi.11 be maintained normally closed and administratively controlled to preclude inadvertent operation during normal plant operations.

However, the appl 3 cant anticipates the use of SCM during station blackout when all other means of core / containment cooling have been exhausted."

f. . SNRC-1449 Page 4 specifically for PT003A and B, deny Control Room and field personnel information that is routinely used by thc. to monitor heat exchanger performance. These controllers are also reouired during routine maintenance - for example, during Heat Exchanger draining and refilling cs required by procedure SP 23.121.01.

Additionally, if these controllers are isolated, the SCM would not be available in a loss of AC power event. For these reasons, the manual shut off valves associated with these controllers and valves are normally left open. ,

LILCO believes that, with the actions taken to date, there are sufficient administrative controls in place that any additional restrictions on SCM operation are unnecessary. The present controls prevent any inadvertent or accidental use of the SCM, .

yet keep the SCM available when all means of core / containment cooling have been exhausted.

With the above in mind, LILCO believes that the Shoreham Nuclear Power Station remains in full compliance with the staff con-clusions stated in reference (2) and the Condition of License as found in reference (3). However, we request your review and concurrence that our position is acceptable to the staff.

In accordance with the requirements of 10 CFR 170.21, LILCO encloses a $150.00 check covering the prescribed application fee for this approval request.

Please do not hesitate to call my office or members of my staff should you require additional information regarding this matter.

Very truly yours,

'O n /, f!

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hn D. Leonard, J f. l V e President - Np' clear Operations

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MA":ck I cc: S. Brown F. Crescenzo W. T. Russell 4