ML20011E096

Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Util Intends to Indefinitely Defer Implementation of Generic Ltr Recommendations & Requirements for Plant

ML20011E096
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/30/1990
From:	Steiger W LONG ISLAND LIGHTING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-10, SNRC-1671, NUDOCS 9002070320
Download: ML20011E096 (4)

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3, m .- .--e LONG ISLAND WGHTING COMf%NY SHOREHAM NUCL. EAR POWER STATION y ,

WILLIAM E. STiletR, JR.

ADDetTA%Y vlCE PMitlDtNT=NUCLt AM Ort HAT 40NG SNRC-1671 JAN 3 01990 1

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk j Washington, D.C. 20555 Response to Generic Ietter 89-10 Ghoreham Nuclear Power Str. tion - Unit 1 Docket No. 50-322 Reft (1) Generic Letter 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance - 10CFR50.54 (f)", June 28, 1989.

(2) LILCO letter SNRC-1621 dated September 27, 1989 to U.S.

Nuclear Regulatory Commission from W.E. Steiger, Jr.;

subject: Deferral of Certain Regulatory Activities.

(3)-LILCO letter SNRC-1664 dated January 5, 1990 to U.S.

Nuclear Regulatory Commission from W.E. Steiger, Jr.;

subject: License Change Application Operating License NPF-82.

(4) LILCO (A.F. Earley, Jr.) letter dated September 19, 1989 to'U.S. NRC (T. Murley); subject: LILCO's Response to the August 28, 1989 letter from NRC to LILCO.

Gentlemen:  ;

The Long Island Lighting Company (LILCO) has reviewed Generic Letter 89-10 (reference 1) as it relates to the Shoreham Nuclear Power Station (SNPS). Commensurate with SNPS' current non-operating and defueled condition, and consistent with the information previously submitted to the Commission by SNRC-1621 (reference 2), LILCO has determined that the requirements and recommended actions of Generic Letter 89-10 as they pertain to SNPS'will be indefinitely deferred. The deferred status of this Generic Letter request will be tracked on LILCO's computerized administrative tracking system.

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! SNRC-1671 Page 2 Generic Letter 89-10 imposes specific requirements upon licensees in order to ensure that all safety-related motor-operated va.1ves (MOVs) will operate as required under design basis conditions.

In Shoreham's current non-operating, defueled condition, i.e.,

with the reactor vessel defueled and the low activity fuel stored .

in the Spent Fuel-Storage Pool, the safety significance of timely remote actuation of plant MOVs is substantially reduced. As described in SNPS "Defucled Safety Analysis Report" (Attachment 3 to reference 3), many of the design basis accident scenarios are no longer considered credible events (e.g., loss of coolant decident, lo3s of feedWater, closure of main Steam isolation valves, etc.).

In the current defueled condition, most MOVs at SNPS are located in plant systems currentiJ designated non-operational (i.e.

FUNCTIONAL or PROTECTED; see reference 4). As a result of Technical Specifications or operational requirements, approximately 40% of the safety-related MOVs are maintained OPERABLE in eight systems. These systems are Peactor building Service Water (RBSWS), Reactor Building Standby Ventilatica (RBSVS)/CRAC Chilled Water, Reactor Water Clean-up (RWCUS),

Reactor Building Standby Ventilation (RBSVS), Miscellaneous HVAC, Diesel Generator Ventilation, Control Room Air Conditioning and Radwaste. With SNPS in its current defueled state, the original design basis capability of several of these systems far exceeds present requirements and failures of MOVs in these systems would not present safety significant concerns (see Attachment 3 of Reference 3). For example, the RBSWS, RBSVS/CRAC Chilled Water and RBSVS are designed to remove heat loads associated with full power operation. In the present plant condition, heat loads are substantially reduced. This allows for increased flexibility to accommodate procent heat removal requirements. Moreover, some MOVs will no longer be exposed to the high differential pressures associated with full power operation. MOVs such as containment '

isolation valves and valves in the Reactor Water Cleanup system fall into this category. Indeed, in Shoreham's current defueled condition, most of the original design basis criteria do not apply and would be inappropriately used in this context.

With the plant in a defueled state, LILCO recognizes the

'importance of maintaining water level in the Spent Fuel Storage Pool. However, because of the low decay heat level associated with the spent fuel, a very small makeup flow rate is required.

This allows for an extended period of time (several days) in which compensatory actions can be taken to restore pool level if water level dropped below technical specification limits and the primary makeup capability is unavailabic. This extended time interval in conjunction with negligible radiation levels in the Reactor Building will permit repair or local operation of most MOVs, or performance of other actions necessary to restore pool level. Loss of remote manual or automatic valve operation is therefore not considered safety significant.

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.SNRC-1671 l L Page 3  :

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Finally, in accordance with item 1 (Reporting Requirements) of Generic Letter 89-10, LILCO is hereby informing the Commission of its intent to indefinitely. defer implementation of the Generic i Letter's recommendations and requirements-for SNPS. The

technical justification for deferral is based on the plant's  ;

t current defueled' status,_and the resulting absence of any design ,

basis event requiring timely remote MOV actuation, as noted 1 above.-  !

E 1 LILCO_ assures the. Commission that-the deferred action will be  :

tracked and, should the present SNPS nituat. ion charige, .the ,

requirements and recommended actions of Generic Lattor 89-10 will be addressed.

If additional information or further discursion is required,.

please da not hesitato to contact my effice. ,

Very truly ye' arc,  ;

WM,) ,

W. E. Stef e , Jr.

• Assistant Vice President Nuclear Operations i MP/ap cca S. Brown >

.W. T. Russell F. Crescenzo

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STATE OF NEW YORK ) ,

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COUNTY OF SUFFOLK )

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I, WILLIAM E. STEIGER, JP.,.being duly sworn, depose..and say that l I am the Assistant Vice Presi5 lent - Nuclear Operations for the Long Isinnd Lighting Company. I am authorized on the part of ,

said Company to sign and file with the U.S. Nuclear Regulatory i Commf.ssion the enclosed letter (SNRC-1671) for the Shoreham  :

Nuclear Power Station. This response'was prepared under my ,

supervision and directions :and the stat.er.ents contained therein are-true and correct to the best of my knowledge, information and  :

belief.

1./2.th'q hb < ,

William ERSteiger, ,Trf .

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Sworn to before me this M day of vo v i

1990 i AMES A. UTTLE NOTtIV PuiRIC, State of New York No. 488G267, Sutlo!k Com Term liapres May 18. I L

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