ML20065C651

Submits Third Suppl to Section 2.206 Request by Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy W/Respect to Issues & on Bases Set Forth in Original 890714 Request

ML20065C651
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/31/1989
From:	Mcgranery J DOW, LOHNES & ALBERTSON, SCIENTISTS & ENGINEERS FOR SECURE ENERGY, SHOREHAM-WADING RIVER CENTRAL SCHOOL DISTRICT, NY
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20065C649	List: ML20065C645 ML20065C651 ML20067A833 ML20067A836 ML20067A840 ML20067A848
References
2.206, NUDOCS 8908250193
Download: ML20065C651 (8)

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VTA TELECOPY Dr. Thomas E. Murley Director Office of Nuclear Reactor Regulation Mail Stop 12-G18 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re Third Supplement to The 's'ection 2.206 Request by the Shoreham-Wading kiver central School District and Scientists and Engineers for I

Secure Enerav in U.S.N.R.C. Docket No. 50-322

Dear Dr. Murley:

i This is to further supplement +.he requests for immediately effective orders in the subject docket with respect to the issues and on the bases set forth in the original request dated July 14, 1989 as supplemented by our letters of July 19 and July 21, 1989.

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[U JUL' 3199 16s19 FROM D.L.A. WASHINGTON-DC PAGE.003 l July-31, 1989 Page 2 Two events occasion this third supplement. First, the briefing presented by the Long Island 'ighting Company

("LILCO"), licensee in the above-captioned docket, to you and other members of. senior management'at the NRC on Friday, July 28, 1989 revealed certain new information and reinforced other information relevant to the bases on which the Section 2.206 requests were originally mado. Second, and most important, I attach (as Exhibit 1 hereto) a letter of July 27, 1989 from Admiral Watkins to Admiral Carr which states among other things:

. .. . the Department would support the issuance by the NRC of an immediately effective order prohibiting LIICO from taking actions which, in effect, initiate the decommissioning process for Shoreham t before NRC permission is sought and granted for that action following a full adjudicatory hearing."

In short, President-Bush's Administration supports the request for immediately effective orders made by the School

-District and SE2 Both of these matters are addressed below in detail.

A. INFORMATION FROM TITE JULY 28 BRIEFING The-July 28 briefing addressed various matters concerning the defueling, destaffing and maintenance

" activities" (or lack of maintenance activities) at the

_Shoreham Nuclear Power Station-("Shoreham") as well as LILCO's plans'for licensing amendments in the~ future; neither

-the licensee or the NRC Staff addressed their respective obligations under the National Environmental Policy Act of 1969 ("NEPA") at that meeting.

1. Defuelina: LILCO reported that as of the morning of July 28 approximately 287 of the 560 fuel bundles

-had been removed from the core and that if that activity is allowed-to continue, LILCO expects to complete the defueling between August 5 and August 8. LILCO also describedLvarious Section 50.59 analyses of the defueling and the risk of the l

subsequent residence of the fuel in the spent fuel pool which are being conducted, but which are not comolete at this time.

That revelation in and of itself is a sufficient basis for L

the~NRC to find that LILCO does net have the appropriate basis at this time to make the required determination, under l Section-50.59, that the defueling activity does not involve 1

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', JUL 31 -'99 15:20 1 ROM D~L.A.

. WASHINGTON DC PAGE.004 y

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~[ July 31, 1989 Page 3 an "unreviewed safety question". Further, none of those analyses described at the briefing consider the issue raised in our request of July 14, namely, the acceptability of the risk in light of the fact that the defueling is unnecessary.

We do not argue that there is a great risk in the defueling activity and subsequent residence of the fuel in the spent fuel pools rather, we argue that previous reviews of defueling activities have addressed the acceptability of that risk in light of the benefit to be achieved (1.s., either reloading ct new fuel for continued operation er, in rare cases, mitigation of an accident) which is totally lacking here. Thus, the current defueling presents an unreviewed safety question deserving careful scrutiny by the NRC in the conduct of its regulatory activities.

In short, the briefing clearly demonstrated that this defueling activity is not being conducted in accordance with Section 50.59 and demonstrated the need for immediately effective orders requiring the cessation of defueling and the return of the fuel bundles, which have been removed, to the reactor vessel where the health and safety of the public will be protected not only by the secondary containment, but also by the primary containment and the reactor vessel itself until reviews of the activity pursuant to the Atomic Energy Act of 1954 as amended ("AEA") and NEPA have been completed.

2. Destaffina: Contrary to one of the premises of your interim reply to the School District request, the July 28 briefing also revealed that LILCO has already significantly reduced staff at Shoreham as of July 28 and has plans for even more significant reductions in the very near future. The most significant staffing change which was revealed at that meeting was LILCo's intent to transfer John D. Leonard, Jr.,. Vice President - Nuclear Operations, from that post effective August 1, 1989 and to replace him with the current plant manager. Mr. Leonard is not only extraordinarily well respected in the industry, but also he is unarguably the key man on whom the NRC relies for assuring conpliance with the full power operating license terms.

In our initial request, we reported that in the June 30, 1989 LILCO-NRC Region I meeting, Mr. Leonard had said among other things "I think you all know me very well enough that I try to run the,show the way you want it run, and there will be no violation in that license, as lona as I have it in my cover to control it." SWRCSD Request pursuant 3

to 10 C.F.R. 52.206 (July 14, 1989), at D.(3). We '

considered that qualification ominous at the time and l

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, [ JOL' 35 '?9 iBi25 ~ FROM D.L.A. UkSHINGTON DC PAGE.009 i July 31, 1989 Page 4 therefore stressed *he qualification in our report of the meeting to the NRC. Our worst fears will now be fulfilled, unless the NRC acts promptly to prevent his transfer.

If the transfer occurs, the NRC will no longer have Mr. Leonard to rely on, and it will not have had the opportunity to review the qualifications of his proposed successor prior to that person taking control. Moreover, there may be a cascading effect throughout the LILCO organization with people being promoted to positions which they have not previously handled and for which the NRC has no assurance they are qualified.

Under these circumstances, there is a crying need for immediately effective orders requiring LILCO not to transfer Mr. Leonard, not to further deplete the Shoreham staff and to return IILCO and contractor personnel to the required personnel positions to allow for prior review of LILCO's proposed actions under both the AEA and NEPA.

3. Maintenance: At the July 28 briefing, LILCO said that it was going to continue maintenance in accord with its obligations under the full power operating license, kul (a) it was not going to make further modifications required of other full power operating licensees, and (b) it explicitly described:what it was going to do with maintenance of existing plant systems: Defining the plant as 124 operating systems, LILCO said it was going to maintain 40 systems as " operable," (itn2, meet Technical Specification l requirements"), 42 systems-in a " functional condition", 36 systems in a " secured" condition, and 7 systems in a

" preserved" condition. Exhibit 2 hereto displays our understanding of how LILCO intends to address maintenance for each of the 124 plant systems.

There are two key concepts involved in understanding LILCO's proclaimed pattern of maintenance:

(a) the concept of Operating condition 6 ("0C 6") and' (b) the definitions of " operable", " functional", " secured", and

" preserved". There is un Operational Condition 6 in LILCO's Technical Specifications. Egi NUREG - 1357 (April 1989), at Table 1.2. And while the Shoreham Technical Specifications do contain a definition of " operable", those Technical Specifications contain an definitions of " functional",

" secured", or " preserved". E.gg NUREG - 1357 at Section 1.0 pAIJim and-specification 1.26. In short, LILCO has directly informed the NRC staff that it is creating a new operating Condition (1.g., OC 6% and that it will nat maintain 84 of

JUL ^J 1 '00 lbidd EROM D.L.A. - WASHINGTON DC PAGE.006'

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July 31, 1989 Page 5 the Shoreham plant's 124 systems in accord with the Technical Specifications.

For example, LILCO appears to state that it Eili Dat maintain the feed water control syeten, the neutron instrumentation system, the reactor rc:r a shutdown system, the core spray system, the. residual haut removal system, the radwaste of f gas system, the primary containment inerting system, the primary containyont cooling system, the post-accident monitoring systems, rc many other systems which are essential to the health and safety of the public. Egg Exhibit 2-3.

The Requestors suggest that the licensee 8 s proclamation of its anD-modification plans and-its ngn-maintenancs plan also cry out for immediately effective orders to bar the licensee from discontinuing any' required modifications or maintenance to protect the health and safety of the public, to protect the environment and to preserve alternatives for the Shoreham plant prior to full review pursuant to the AEA and NEPA.

4. Licensina Plans: At the July 28 briefing, LILCO's said that it " hoped" to come in for a license-amendment "before the end of the year" and, in response to Staff questions, represented that it was having a hard time deciding whether to transfer the full power operating license to LIPA or to apply for P. reduction of the full power operating license to a " possession only" license prior to applying for a transfer of the license to LIPA. The requestors believe that this is strictly a stalling tactic by LILCO so that the plant will " decommission itself" prior to applying for either license amendment.

The agreements among LILCO, LIPA and the others involved in the so-called " Settlement Agreement" make unarguably clear the precise order in which LILCO is required to proceed in seeking license amendments. For example:

"Promptly after the Effective Settlement Date, LILCO will (1) unless previously accomplished, remove the fuel from Shoreham's reactor and deposit the fuel in the Shoreham spent fuel pool, . . . and then) apply to the NRC for a

" possession only" licens[e and/or other license amendments as are necessary to fecilitate the License Transfer. . . ..

Egg i

i Exhibit 1 to the Requestors' July 14, 1989 letter at its Exhibit'3, Section 5.1(b).

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JOL 3i A 89'16:22 F hh!1 2,w,A. WASHINGTON DC PAGE,007 i July 31, 1989 page 6 The entirn context of the July 28 briefing and all other documentation available to the NRC Staf f make it indisputable that LILCO has embarked upon a single continuum of actions from defueling through decommissioning which may have adverse environmental ef fects and that, if allowed to segment this unitary course of conduct, LILCO will significantly reduce the scope of alternatives available for Commission review under both the AEA and NEPA, contrary to the purposes of both of those acts.

None of the steps being taken by LILCO at this time is justified independently of the continuum of actions; none of them so far has been accompanied by an adequate environmental impact statement; and each one of them will prejudice the ultimate decision under the program. Under these circumstances, the policy behind Section 51.101 of the Commission's Regulations clearly requires an immediately effective order directing LILCO to cease and desist from defueling, destaffing, and reduction of maintenance activities and a return to the status crue ante. Esa 10 C.F.R. 5 51.101 (1988). Given the facts that have been presented to the NRC Staff, inaction would also constitute a

" form of permission"- without environmental review in violation of 10 C.F.R.- 5 51.100(a) (1) (1988), since there is no question but that the final step of the continuum (h, an application for decommissioning) is subject to the requirement for an environmental impact statement or a l supplement to an environmental impact statement. E.en 10 C.F.R. 5 51.20(b) (5) (1988).  ;

5. Public comment: At the conclusion of the July 28 briefing, you thanked .LILCO for its " reassurances" and invited comments from members of the public present for that briefing. At that time, that I of fered comments on behalf of the School District and SE2 on matters discussed, and not discussed, during the briefing which relate to the pending requests for immediately effective orders.

l In addition to the points identified and expanded '

on abovr., my comments included the following: (1) Contrary to yot.c summation to the ef fect that the briefing had "of fered reassurances" to the Staf f, I suggested that the briefing gave clear notice to the Staff that LILCO was ng.t abiding by, and did nga intend to abide by, its license conditions and commitments; (2) The LILCO response to an expressed staff concern that LILCO might let the plant become a " rust bucket" was totally inadequate when the assurance was that LILCO was maintaining a " full staff of 30 janitors"; as

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!- July 3 1, 1989 Page ?

I said then, without denigrating the value of janitors, we do not believe that the janitorial staf f is the most important element in assurb g the proper maintenance of a nuclear power plant ; D) The roquestors repeat their impression that LILCCi's mode of dealing with staffing and maintenance (namely, saying in eeneral terms that they intend to abide by their license conditions and commitments, but then explicitly detailing the nyriad of ways in which they were not going to comply with those conditions and commitments) is a way of asking the commission to "put its head in the sand and pretend it doesn't know what is going on"; and (4)

The requestors repeat their concern that neither the Commission $ta f f nor the Licensee addressed their respective responsibilities pursuant to NEPA during the briefing.

'rME DEPARTMENT OF ENERGY LETTER OF JULY 27, 1989 B.

The Requestors have kept the Department of Energy aware of the request for immediately effective orders pending bef ore _ the NRC.

On July 27, 1989, Admiral James B. Watkins, U.S.

Secretarf of Energy, directed a letter to Admiral Kenneth M.

Carr, Chairman of your Conmission, with copies to the other Commissioners , in which he stated the Department of Energy's positions on both (a) the need for Shoreham and (b) the procedures which can be followed in assuring a full review of the alternatives by your Commission. As part of the relevant procedures, Admiral Watkins said ". . . the Department would support the issuance by the NRC of.an immediately effective order prohibiting LILCO from taking actions which, in effect, 1 initiate the decommissioning process for Shoreham before NRC permi.ssion is sought and granted for that action following a full adjudicatory hearing." Egg Exhibit I hereto, at 2.  ;

This " support" by the Cabinet Secretary responsible for energy matters constituten unmistakable evidence of where the "public interest" lies. S.g.g 10 C . F. R. 5 2. 2 02 ( f ) (1988).

The Requestors suggest that the commission is entitled to give this support for immediate effective orders by a cabinet Secretary at least as much weight as, and )

perhaps more weight than, the Commission gave to the letter of October 4, 1977 from Stuart E. Eizenstat, an Assistant to the : President, in deciding to discontinue the generic environmental statement on mixeo oxide fuel ("GESMO")

proceedings. .Tn the GESMo proceedings , the Commission gave Mr. Eizenstat 's letter decisive weight. See, LL. , 42 Fod.

~JUL~31 'WW 16:24 9 ROM D.L.A. WASHINGTON DC PAGE.009

[ July 31,-1989 Page 8 Reg. 65334 (December 30, 1977); In the Matter of Mixed oxide Fuel, 7 NRC 711, 722 (CL1-78-10) (1978).

C. QQPIES FOR THR.SSMMISSIONERS Under these circumstances and, especially, in light of Admiral Watkins ' " support" for the issuance of immediately effective orders, I am furnishing copies of this letter (and its exhibits) directly to the Commissioners so that they may exercise their supervicory power over delegated staff functions to protect the health and safety of the public, preserve the human environment, and preserve the Shoreham facil-ity in support of U.S. energy policy. 10 C.F.R. 6 2. 2 06 (c) (1) (1988 ) .

Sincerely,

! ^

, /

Cames P. McGranery, Jr.

Counsel for Shoreham-Wading River central School District and Scientists and Engineers for secure Energy t.

JPM/clk Enclosures cc Chairman Kenneth M. Carr

-Commissioner Thomas M. Roberts commissioner Kenneth C. Rogers Commissioner James R. Curtiss

JUL ,31 '?9 15:21 FRoM D.L.A. IJASHINGToH DC PAGE.010 v

The Storetary cf Enetgy Wa6hington 00 20585 I'

July t'/,1989 Admiral Kenneth M. Carr Chairman, Nuclear Regulatory Comission Washington, D.C. 20555 Dear Admiral Carr I understand that, pursuant to the Atomic Energy Act of 19H, as amended, an application or applications will be flied shortly with the huclear Regulatory Comission (NRC) by the Long Island Lighting Company (LILco) and the Long Island Power Authority (LIPA) seeking the required consent of the NRC for (1) LILCO's surrender of its full power operating license in favor of a possession-only license for its Shoreham facilityl (2) transfer of the possession-only itcense to LIPAs and (3) the decomissioning of $1orcham by LIPA utilizing the technical services of the New York Power Authority (NYPA) to perform the decomissioning activities. These NRC authorizations will be sought. solely to effectuate an agreement among LILco, LIPA and New York State pursuant to which the Shoreham facility is to be sold for a token consideration in order to dismantle it before it ever generates electricity comercially.

The dismantling of this invaluable energy resource, the safety of which has been affirmed by the NRC through years of technical review and extensive litigation, would be a colossal mistake. Shoreham's destruction would be contrary to every prjnciple associated with the establishment and maintenance of a sensible national energy policy and would be inconsistent with the provision of an adequate and reliable supply of energy in the Northeast. Further, dismantling of this facility will necessitate the increased use of fossil fuels and the ,

concomitant Adverse enyttonmental_ impacts associated with their use-the e h -very impacts which the Busti~ Administration is striving to mitigate and, where possible, avoid.

The Atomic Energy Act provides that any person whose interests may be affected by the issuance of a proposed operating license eacnd.-ent may request a public ad,1udicatory hearing to contest the proposed amendment.

Important questions exist rege.rding the_imhni34bmnagerial and 7 f.i'nancial qualificationt of LIPA to hold an NRC license for the purpose -

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sou)t., and Dic~siinitters Ylise c6nsiderati6ns of the type which, under /p the Comission's regulations (10 CFR 50.g2), require that a requested l ,

adjudicatory hearing be conducted befo*e_ the Comission approves the proposed amendments.

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' The comission also has discretion pursuant to the Atomic Energy Act and its regulations to hold a prior hearing if it detennines that such a hearing should be held in the public interest. There could hardly be a

. stronger case than this one for the exercise of such discretion.

Significant issues of first impression are obviously raised by the proposal to transfer a new, baseload electric generating facility, n

p9ssessing a full power operating license, to an entity with no u pertise in and no experience with nuclear _ facilities Jor..s.ne express purposiibf~tiaFig It down. In ' addition, once lhe Ticense transfer and

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dismantling are authorized and comenced, the consequences would be irreversible and the availability of any remedy following a hearing on the significant public issues involved would be entirely foreclosed.

In this regard, I an extremely concerned that the plans recently announced by LILCO feraiefuel4pg-the reactor and for drastic reductions in plant staffing will have the effect of finbling_tht_ facility beforeO Q LILCO and LIPA'ever ap) roach the NRC with the aforementioned license emendment requests. Tiere have been disturbing reports in the public media that, following dispersal of the Shoreham operations staff as currently planned, it may take as long as two to three years to .?

reassemble the operating staf_f_ required to safely operate.Shoreham. V LILCO should not be allowed to disable the' facility indirectly prior to formal approval by the NRC of the decomissioning of the plant through the license amendment process. I would urge the Comission to monitor closely any actions, such as defueling, destaffing or reduced

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( regaWthe Department would support the issuance by the NRC of an imediately effective order prohibiting LILCO from taking actions which, in effect, initiate the decomissioning process for Shoreham before NRC J permission is sought and granted for that action following a full adjudicatory hetring.

I als'o strongly urge the Cocunission and the NRC staff not to consider the various steps leading to the dismantlement of Shoreham (license surrender, license transfer, and decomissioning) as independent requests for discrete actions which can be segmented for purposes of the NRC's required safety and environmental review. These actions must be viewed as integral parts of the basic and overriding plan to dismantle Shoreham that was actually memorialized in a written agreement. The possession only license and LIPA's qualifications to hold an NRC license can be essessed properly only in the context of the activities to be authorized under the license. These license amendment requests should only be considered in light of both a full analysis of the decomissioning plan required by the NRC's regulations eqd a full evaluation of the consequences of destroying Shoreham required under the National Environmental Policy Act (MEPA).

In this case, the written agreements among the parties clearly establish that the impending request by LILCO for a possession only license is intended to forn1 ally initiate the process of dismantling Shoreha:n.

Certainly the Comission should treat this license amendment no dif ferently than oo the parties to this ill-considered plan. Under PAP EBB 2268 PAGE.003

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'.iUi. Il 799 16:26

' FROM D.L. ATWASHI GTObDC PAGE.012 c*

3 these circumstances, approval by the NRC of action leading to the dismantlin of a newly completed, licensed nuclear faci 11ty in the face of increas ng energy relia)ility problems on Long Island is clearly a

'ma or federal action si nificantly affecting thedetailed eny ronment.' According y, MPa M* quires _th qualitycomprehensive of the human,{'I environmental impact statement must be prepare a6dWculated for

public coment prior to the approval of any of the ' impending license amendment requests. Aside from the significant environmental impacts associated with alternative energy sources, with the exacerbation of the energy rollability problems on Long Island and with the decomissioning itself, there are alternatives to the impending proposal which are obviously superior to dissantling the facility.

The Shoreham plant is a significant domestic energy source that is capable of meeting the electricity requireLents of Long Island and the surrounding region in a safe, reliable and econosteal manner for years to come. The dismantling of Shoreham would be a grave mistake even if the energy situation on Long Island were more favorable. Taking this action under present circumstances would be simply irresponsible. Thus, it is obvious that the proposal for the NRC to authorize the destruction of the plant raises, and requires the NRC to address, issues involving '

power needs, alternatives and other important environmental considerations in an EIS. Fo11cwing completion of that document, these matters should be fully evaluated in the public hearing afforded those whose interests may be affected before the NRC determines whether to pennit Shoreham to be destroyed. The interests of this Department, the Northeast and the Nation will be affected in a far reaching manner by the Comission's ultimate decision in this matter.

Sincerely,

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James D. Watkins Admiral, U.S. Navy (Retired) cc: Comissioner Thomas H. Roberts Comissioner Kenneth C. Rogers Comissioner James R. Curtis:

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Exhibit 2-1 QPERABLE

_.B21 Nuclear Boiler '

• • / C51: Neutron Instrumentation C71 Reactor. Protection ,

D11 Process: Radiation _ Monitoring

-D21 Area Radiation Monitoring F12 Servicing Aids (Puel)

F15 Refueling a Gil Radwaste G33- Reactor Water Cleanup M43 -Fire Protection.

M50 RBSV & Control' Room Chilled Water P41 ' Service Water

'P64 Meteorological Monitoring R11

.R21 Station Transformer (NSS & RSS)

Non-Segregated Buses R22 ' Metal Clad Switchgear R23 Load Centers and Unit Substations R35 AC Instrument Power R36 AC Uninterruptible-(Vital) Power i R42' Battery Power (125V DC) i R43 Diesel Emergency Power R62 Station Protection:and Metering

-R71 Fire Detection & Station Security R81 Heat' Tracing

$23 138/69KV' Switchyard. Pot. Transformer S24. 138KV. Switchyard: Relay Panels T21 Reactor Building

.T22- Reactor Building Superstructure T23 Reactor Primary Containment T31 (RB) Cranes, Hoists and Elevators T41- Reactor _BuildingEVentilation' T46 Reactor Building. Standby Vent- l U41 Turbine Building Ventilation V41 Radwaste Building _ Ventilation *

'W12 Screenwell Canal

' X41 Miscellaneous HVAC X60 Diesel' Generator-Ventilation 1

X61 Control Room' Air-Conditioning

'Y25 Barge Dock.and_ Waterfront Z94 Seismic Monitoring _ _

296' Post Accident Sampling '

---

...--------------~~~~-----------------------------------

~ **/- " Secured" for'0C6.

Operable: : System (s) maintained to meet Technical-

-Specification requirements.

Total of 41 operable-systems (40 for-0C6).

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, .UL :.81 09'Its:2h hROM D. L 3 'lJ ASH kh4GTONDC PAGE.014 Exhibit 2-2 FUNCTIONAL B11 Reactor Assy G41 Fuel Pool Cool & Cleanup M41 Heating & Auxilary Boiler M42 Domestic Water M44 Sanitary Sewage M61 Building Service Miscellaneous N34 Lubricating oil N39 Turning Gear N42 Hydrogen Seal N43 Generator Stator Cooling N45 General Hydrogen & CO2 Purge N71 Circulating Water-061 Plant-Security Pil Condensate Transfer & Storage P21 Domineralizer & Makeup Water P33 Sample System P43 TBCLCW' P50 Compressed Air P71 Low Conduct & SW Drains R24 Motor Control Centers R34 Auxiliary Grounding -

R41 DC Instrument Power (4BVDC)

R51 Communication (Intra Plant)

R52 Comm-Telephone (Leased Line)

R53 Comm-Sound (Powered Telephone)

R54 Comm-Radio R55 Closed Circuit TV R61 Unit Protection & Metering S21' Plant Substation S25 69KV Switchyard / Gas Turbine T51 Reactor Building Lighting U31 (Turbine Building) Cranes, Hoists, Elevators U51 Turbine Building-Lighting V31 RW Cranes, Hoists and Elevators V51 Radwaste Building Lighting W23 Chlorination

, X37 Security Building X46 Office Building HVAC X50 -Office Building Annex, X70 Secondary Access Facility Y46 Cathodic Protection YS1 Yard Lighting Punctional Essential support system (s) not required per Technical Specifications but necessary for miminal plant functions, habitability, and preservation concerns.

Total of 42 Functional systems.

[ suL Si 'ww lead / PkUM 9.L.A['WHSHINGTON DC PAGE.019

-/ Exhibit 2-3 SECURED C11 CRD Hydraulic Control C32 Feedwater Control C41 Standby Liquid Control

• / C51 Neutron Instrumentation C61 Reactor Remote Shutdown C91 Process Computer E11 Residual Heat Removal '

E21 Core Spray E32 MISV Leakage Control M60 Main Chilled Water N11 Main Steam N21 Condensate and Feedwater N22 Heater Relief and Vent Lines N23 Miscellaneous Draises Secondary Plant N24 Sealing Water N25 reedpump TSI N31 Turbine N33 Seal and Radwaste Steam.

N35 Moisture Separator Reheater & Drains-N36 Extraction Steam N37 Main Turbine Supv Instrumentation N44 Vacuum Priming & Air Removal N52 Condensate Domineralizar N62 Radwaste Offgas P42 RBCLCW P63 Radwaste Solids Handling P65 Vibration Monitoring R13 Isolated Phase Bus S22 13BKV Transformer Breaker T24 Primary Containment Inerting T47 Primary Containment Cooling-T4a Primary Containment Atmospheric Control T49 Primary Containment Inter Leak Test X62 Control Room Self Contained Air Supply 292 Excess Flow Check Valves Z93 Post Accident Monitoring

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• Z " Operable" for OC4, 5 and 6.

Secured: System not to be operated or maintained that will be left in a de-energized / safe state.

Total of 35 Secured Systems (36 for OCS).

, -m --

' o Exhibit 2-4 lil PRESERVED B31 Reactor Water Recirculation  !

E41- High Pressure Coolant Injection E51 Reactor Core Isolation Cooling N32 Turbine control N41 Generator N51 Excitation S11' Main Power Transformer t

Preserved: System equipment of considerable value prese_ved for sale / salvage. Items preserved are at LIICO discretion and may be secured as seen fit.

Total of 7 Preserved Systems.

++ TOTAL PAGE.016-**

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