SNRC-1746, Requests Interim Relief from Limiting Condition for Operation 3.7.1.2.b.3 Re Tech Spec for Plant Svc Water Sys - Shutdown

Requests Interim Relief from Limiting Condition for Operation 3.7.1.2.b.3 Re Tech Spec for Plant Svc Water Sys - Shutdown

ML20058N554
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/10/1990
From:	Leonard J LONG ISLAND LIGHTING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
SNRC-1746, NUDOCS 9008140192
Download: ML20058N554 (3)

Text

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-- SHOREHAM NUCLE AM POWE R ST ATION

• P.O. BOX 628

• WADING Rive R. NEW YORK 11792 TE L (5161929 8300 Jdn D. taned, Jr.

Vice Pneidnt Office of Oxprate Services and Office of tirlear g

r- I SNRC-1746 AUG 101990 U. S. Nuclear Regulatory Commission  :

ATTN: Document Control Desk i Washington, D.C. 20555 Long Island Lighting Company's Request for Interim Relief i From Technical Specification Limiting Condition For Operation 3.7.1.2.b.3 Shoreham Nuclear Power Station - Unit 1 J Docket No. 50-322  ;

Reft (1) LILCO letter SNRC-1664 dated January 5, 1990 to the U.S. "

Nuclear Regulatory Commission; subject: License Change Application ,

i Gentlemen:-

5 By this letter the Long Island Lighting Company (LILCO) requests interim relief from Limiting Condition For Operation 3.7.1.2.b.3

associated with the technical specification for Plant Service

Water System - Shutdown. LILCO requests interim relief pending H disposition of LILCO's outstanding request in SNRC-1664 '

(reference 1) to amend operating license NPF-82 to create a Defueled Facility Operating License for Shoreham Nuclear Power h

Station (SNPS).

Under the Limiting Condition For Operation (LCO) requirements of technical specification 3.7.1.2.b.3, LILCO must have at least one plant service water system loop capable of taking suction from the ultimate heat sink and comprised of, among other items, an L

OPERABLE residual heat removal service water (RHRSW) flow path capable of transferring water through the associated RHR heat exchanger in order to maintain an OPERABLE Plant Service Water System during Operational Conditions 4, 5, and *.

As previously reported to the Commission, LILCO has already implemented the System Lay-Up Implementation Program (SLIP) for many of the systems, including the Residual Heat Removal (RHR) ,

system, which would otherwise be required to remain operable to ens.usentha rpafe operation and shutdown of an operating plant.

9008140192 900s10 ,

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O SNRG-1746

• Page 2 LILCO is planning:to A ve fuel to perform a radiation survey and

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physical inspection. This movement will take place in the spent fuel pcol on or.before August 20, 1990. Under the requirements

, of LCO 3.7.1.2.b.3,.in order to handle irradiated fuel in the secondary containment, including the movement of fuel in the-Spent Fuel Storage Pool, LILCO must undertake a burdensome and costly re-establishment of an operable RHRSW flow path.. With Shoreham in a non-operating, defueled condition, there is simply no health or safety benefit associated with this activity. See c

Shoreham Nuclear Power Station Defueled Safety Analysis Report.

. ~ In SNRC-1664, LILCO requested, pursuant to-10 CFR 50.90, that.

'Shoreham's license be amended to create a Defueled Facility Operating License. Due to the nature and extent of the entire amendment application, LILCO anticipatee a 3engthy review on the part of the Commission's Staff. The expeditious grantf.ng of this current interim. relief request will permit LILCO to handle the slightly irradiated fuel in the secondary containment (Spent Fuel

- Storage Pool) without having to undertake the burdensome and costly task of placing a portion of the RHR system back.into the condition it was in prior to its current protected state.

LILCO believes interim relief should be granted on the following

, basis:

1. Under the Settlement Agreement with the State of New York, LILCO is contractually prohibited from over operating Shoreham.

'2.- The Shoreham reactor has been defueled and all fuel has been placed in the Spent Fuel Storage Pool. j

3. In accordance with the Commission's Confirmatory Order Modifying License (NPF-82) ' issued March 29, 1990, LILCO is prohibited from placing any nuclear fuel into the Shoreham reactor vessel without prior approval from the I Commission.

4. Design bases accidents for Shoreham in a defueled condition are described in Chapter 15 of the DSAR

- submitted in LILCO letter SNRC-1664 dated January 5, 1990. Only two accidents have been found relevant (1).

Fuel Handling Accident and (2) Liquid Radwaste Tank Rupture. Because of the low-burnup condition of  ;

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Shoreham's spent fuel, the amount of decay heat being generated is negligible and thus, active systems for ],

pool water cooling are not required. NRC concurrence of this conclusion is found in the safety evaluation i i

provided in NRC letter dated July 31, 1990 transmitting approval of LILCO's request to cease offsite emergency planning' activities and implement the defueled emergency plan submitted in SNRC- 1651,12/15/ 89.

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5. As reviewed by the Commission, the RHR system has been -

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. layed-up in accordance with SLIP, and the heat.  !

l exchangers have been opened-up, i J.

The RHR system,:and its flow path, serves no purpose

6. l il (function) in Shoreham's non-operating, defueled' Moreover,. technical specification 3.4.9 and' q h, condition.

7 3.9.11, governing the RHR system, do not require'RHR  ;

b, , operability in the current SNPS defueled condition.- .;

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7. LILCO will continue to meet the remaining LCOs of l technichi specification ~3.7;1.2.-  !

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1 For the above reasons, LILCO respectfully requests that'it )

-promptly.be' granted.the interim relief requested, pending the .

Staff's disposition of LILCO's January 5, 1990 license amendment  ;

request.

Should you have any questions or need additional clarification,  !

please do not' hesitate to contact my office.

b Very;truly yours, f s' ,

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L D. Leonard,EJr. } 3 Vic President Office f Corporate Services

.and Office.of Nuclear

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cci. S. Brcwn "T'. T.-Martin .

B. Norris

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