ML20066E133

Requests limited-scope Exemption from Seismic Qualification Requirements of Criterion 2,App A,10CFR50 to Permit Deletion of 125-volt Dc Batteries 1R42*BA-A1 & 1R42*BA-C1

ML20066E133
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/15/1991
From:	Leonard J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20066E128	List: ML20066E125 ML20066E133
References
NUDOCS 9101180088
Download: ML20066E133 (10)

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UNITED STATES-OF: AMERICA -

NUCLEAR REGULATORY COMMTSSIONJ q Before the Director,-Office of Nuclear Reactor Regulation, In the Matter of "~~)-

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LONG ISLAND LIGHTING COMPANY- L) Docket No.=50-322:

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(Shoreham Nuclear Power Station, "p

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Long. Island' Lighting Company's_ Requestl for a-

-Limited-Scope, Exemption _ l from the Seismic-Qualification Requirements of '

Critorion 2,-Appendix A,-10 CPR 50- j I. Introduction Pursuant to 10'CFR 50.12, the Long IslandfLighting Company?(LILCO:

or the Company) hereby requests 1a= limited-scope exempt 4on:.fromt the seismic qualification requirements Amposed"by criterien?2-of Appendix A to 10 CFR-50. Specifically,JLILCO request.s that'the 4

scope 1of the Shoreham Nuclear Power Station. (SNPS or :Shoreham):

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Seismic Qualification:- Program- for -125V' DC' power Loystem_ batteries' L _

a 1R42*BA-Al and-1R42*BA-C1,.whose documented) qualified seihmicl 7

, lives. expire June 1991, and which :otherwise; fully comply with-Rthe 8 l

Commission's regulations,Lbe modified torpermititheir' deletion L

subsequent to the> expiration of theiridocumentediqual~ified i.

i' seismic lives. LILCO also : requests :that :the exemption be grant'ed. j

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L and remain in effect until such time as the:Commissionfapproves-LILCO's request-for a~ Possession-Only license.-

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LII.: The Exemption Is Authorized rvy Lawi Nill >Not-~Present*An: -

1 Undue Risk To The Public Ilea'lth Ard Safety And Is? Consistent With?

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The commoniDefanae and security. s t 1

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The legal standard for obtaining._sn exemption fromfthe seismic , i qualification requirements 'of d0 CFR 50', . Appendix A, QCriterion :2f

- is provided by 10 CFR SO 12 (a)-('lt whichiprovides that, lupotr application by an interected: person-, the -Commissien- may: I y ,

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grantfexamptionsLfrom-the: requirements ef-the! ,

regulations'of thisfpartt whichuare authorized.- ,

by law,_will not present an undue -

risk to the'publicchealth'and: safety, and-are consistent with the commen defense:and security.

Further, .10 CFR 50.-12 (a) (2) lprovid'es in part that the Commission will not consider granting an exemption'unless-I special. circumstances are;present. -Special-circumstances-are:present whenevera-(ii)-Application'of?the' regulation in the: j

.particular circumstances-wouldcnot-serve

'the underlying purpose of the rule or is;  !

not necessary to achieve the-underlying  ;

purpose of the rule; or-(vi)JThere is.present any_other: material circumstance not: considered whenetha .

regulation was. adopted-for-which_it would1 be in the'public interest to grant'an; exemption.

f LILCO's' request satisfies-the standards 1 cited'above'.

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First,zthe Commission 10 plainly-authorized by lawtto. grant LILCO' 4

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an. exemption concerning requirements for-theiseismic-fqualification of equipment. :This application-for exemption. .

complies with the' standards and; requirements of thuLAtomic Energy; i Act. of 1954,~ as ' amended (the Act) , and'the-Commission's rules ~and-regulations.

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n -~ ~ ~ n ~_ - n Second, the exempt $on #111 not present an undue risk to the public health and safety for the following reasorn:

( l. Under the Settlement Agrect?ent with the State of New York, LILCS is contractually prohibited from ever operating Shoreham. a

2. Shoreham has bien defueled and all fuel has buen pieced ,

o in the Spent F tel Storage Pool. (

l 1 3. In accordance with the Commission's Confirmatory order Modifying Liccase \APF-8?) is, sued March 29, 1990, LILCO I

is prohibited from placing a;iy nuclear fuel into the Shoreham reactor vessel without prior approval from the NRC

4. Design basin accidents for Shoreham in a defueled condition are dencribed in Chapter 15 of the Defueled i

Safety I.nalysis Report (DS11) submitted via SNRC-1664 l

[ (January Se 1990). The ')SAR, supported by LILCO's technical report, "Radi31ocjical Safety Analysis for Spent h Fue) Storcge and Handling," submitted to the NRC via SNBC-1651 (December l',, 1989), establishes that l Shoreham's spent fue3 in in a low burnup condition l (equivalent to two full power days) And that the amount

g of decay heat being generated Ly the fuel in the Spent l

Fuel Storage Pool as of June 1989 is negligible --

I l approxi nately 550 we,tts. The decay heat currently being p'[ ' f R .

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generated is approximately -300 watts. -With the' fuel in f

I such a low burnup condition,-the safety-analyrds. _!

l indicates that active systems for storage pool water  !

I makeup are not required and that' passive cooling in the Spent Fuel Storage Pool is sufficient to maintain fuel  !

cladding integrity.

Pased on its safety analysis, LILCO has determined that  !

the consequences of previously evaluated accidents are greatly decreaced given Shoreham's non-operating, -l defueled status. The safety analysis reviewed the spectrum of accidents evaluated in 'ho Shoreham Updated Safety Analysis Report (USAR) and identified those events that apply to-the storage and handling of spent fuel.

Two events have been found to be relevants (1) Fuel-Handling Accident (USAR bection 15.1.36), and _(2) Liquid Radwaste Tank Rupture (USAR Section 15.1.32). For the Fuel-Handling Accident, the safety-analycio calculated that the integrated whole body'doso (1.74E-06 rem) is well below the Environmental-Protection. Agency's Protective Action Guides (EPA PAGs) for protecting the public from exposure (1-5 rem whole body dose). For'the Liquid Radwaste Tank Rupture _ Accident, the whole body dose (1.00E-08 rem) is also much less than the EPA PAG limits. The safety analysis also postulated a " worst case" radiological event in which the1 total gaseous inventory of the core is released. For this event the whole body dose (1.08E-03_ rem) is still well below the EPA PAG limits.

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Based on the analysis of possible events at Shoreham, LILCO concludes that there is no credible accident for Shoreham in the defueled condition which could result in the release of radioactive materials to the environment in quantities which would require protective actions for the public, j i

The NRC Staff has reviewed this analysis and concurs with the LILCO conclusion stated above (See Section 2.0 of the Safety Evaluation by the Office of Nuclear Reactor Regulation supporting Proposed Exemption and Amendment No. 6 to Facility Operating License NPF-82. dated July 31, 1990).

5. The exemption will not place Shoreham in a degraded plan

• condition. Shoreham is in a non-operating and defueled condition and the 125V DC batteries no longer serve a i safety-related purpose.

Third, granting the exemption would have no impact on the " common defense and security" of the United States. See Florida Power and Light Co. (Turkey Point Nuclear Generating Station, Units 3 and 4), 4 AEC 9, 12 (1967).

III Special Circumstances Are Present ,  ;

Regarding the existence of special circumstances which justify I the exemption, 10 CFR 50.12 (a) (2) (ii) applies to Shoreham's i situations s ,

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Application of the regulation in the particular circumstancas would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

For operating nucicar plants, scismic qualification of equipment

! is essential to safety and regulations exist so that safety-related electric equipment, which is relied upon to remain functional during and following design basis events, ensures (1) a the integrity of the reactor coolant pressure boundary, (2) the

. capability to shut down the reactor and maintain it in a safe shutdown condition, and (3) the capnLil'ty to prevent or mitigate the consequences o.f accidents that cou4d racult in potential-offsite exposures comparable to the 10 CFR'100 guidelines.

LILCO's safety analy01s (see item 4 above) determined'that no 1

credible accident can occur at Shoreham in its defueled I

configuration that would adversely affect the public-health and safety in terms of offsite rcdiological consequences.

Considering the defueled condition and low-burnup fuel at i

Shoreham, requiring LILCO to continue to meet the full seismic

.,aalification requirements of Criterion-2 in this instance is not necessary in order to achieve the underlying purpose of the Critorion. LILCO will be fully capable of respcnding adequately to the spectrum of credible accidents that could_ occur at

.Shoreham in its defueled condition even in the unlikely situation of the unavailability of all 125V DC batteries.

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10 CPR 50.12 (a) (2) (vi) also applies to Shoreham's situations i

There is.present any other material circumstance not ,

considered when the regulation was adopted for which it would be in the public interest to grant an exemption.

W The material circumstance present today which was not considered when the regulation was adopted is the Settlement Agreement in ,

effect between LILCO and New York State. In accordance with this Settlement. Agreement, LILCO will not operate Shoreham, is cooperating with officials of New York Ctate'to transfer Shoreham to the Long Island Power Authority (LI1A), and is maintaining Shoreham on a safe cost-effective basis.

Shoreham's 125V DC batteries had an originally documented qualified seismic life of ten years. The B1 battery was replaced in 1988 providing a seismic qualified life'to the year 2003. The seismic life for the Al and C1 batteries was extended to fifteen years-nine months based on the testing-performed-at the time for -

GNB Incorporated (GND). Based on the_ currently updated documentation, which extended the battery. life, the Al and C1 battery seismic life will' expire in June 1991. To-generate seismic qualification of a 19+-year old battery which was used previously in the qualificatic'.. of Shoreham batteries, GNB has informed LILCO that the seismicLtest would cost.approximately

- $40,000 to $50,000. If successful, this test would only extend the seismic life of the Shoreham-Al and C1 batteries from 15.75 to 19 years (new qualified' seismic life expiration of September i

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1994). At present, LILCO cannot predict the success or failure of the GNB seismic tests. If the battery test is not successful, .

then new batteries would have to be purchased. Battery replacement is estimated to. cost approximately $120,000 to

$150,000 per battery and would routinely require approximately 34 weeks. If new batteries were required onsite and operational by 4

the end of June 1991, LILCO estimates that appropriate actions under an expedited schedule would have to be initiated no later than January 1, 1991. Since battery purchase and installation is a long Icad item, this would become a critical path task if fuel has to be moved in accordance with the existing SNPS technical specificationa. Based on Shoreham's non-operating and defueled, low-burnup condition, this expenditure is unnecessary and presents an undue hardship on LILCO.

IV Shoreham Is As Safe With The Limited-Scope Exemption As It Is Without It.

USAR Table 8.3.2-1 lists the safety-related loads on the three safety-related 125V DC batteries. The safety-related equipment constituting loads on each battery was designed to perform onefor more of the following safety-related functions:

1 (1) Assure the integrity of the reactor coolant pressure boundary, (2) Assure the capability to shutdown the reactor and maintain it in a safe shutdown condition, or (3) Assure the capability to prevent or mitigate the consequences of accidents which could result in

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l l potential offsite exposures comparable to the 10 CFR 100 limits.

Given Shoreham's non-operational, defueled mode and the March 29, 1990 Confirmatory order modifying the Shoreham operating license

'I to ensure that the Shoreham reactor remains defueled, these battery loads no longer perform any of the safety-related

.; - functions indicated above. Additionally, 13 of 27 loads no longer exist as the equipment is in a deenergized preserved state in accordance with'the Shoreham System Layup Implementation Program. Most of the loads which areistill connected are associated with emergency diesel generator operation.

LILCO's analyses have also concluded tcat the emergency diesel generators do not perform safety-related functions in the l defueled condition (see Sections 3 and 8 of Attachment 3 to SNRC-1664 dated January 5, 1990). Therefore, in the defueled condition, Shoreham is as safe with the limited scopo exemption as it is without it.

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III. Conclusion For the reasons given above, LILCO respectfully requests a limited-scope exemption from the requirements of 10 CFR 50, Appendix A, Criterion 2 as its relatos to the seismic qualification of station batteries 1R42*BA-Al and 1R42*BA-C1 until such time as the NRC approves LILCO's request for a Possession only license.

Respectfully submitted, n  ?>

J- C GlDQL .l

,~do n D. Leonard, Jr.fi e Vi e President, Office of Corporate

( SO vices and Vico P S aident, Office

's of' Nuclear -

MAP /ap cc S. Brown T. T. Martin B. Norris ,

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