ML19350C706
| ML19350C706 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/24/1981 |
| From: | SHOREHAM OPPONENTS COALITION, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8104060626 | |
| Download: ML19350C706 (19) | |
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NUCLEAR REGULATORY COMMISSION 4
BEFORE THE ATOMIC, SAFETY & LICENSING BOARD 3ectGT 16 t%
a Louis J. Cartes, Chairman MAR 241981 P ::
Dr. Oscar H. Paris, Member Sp -g Frederick J. Shon, Member L
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In the Matter of Cn LONG ISLAND LIGHTING COMPANY Docket No. 5 9,
Shoreham Nuclear Power Station,
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x kOTION OF INTERVENOR 0 319gg,
[g%4hguy, SHOREHAM OPPONENTS COALITION FOR ACCEPTANCE.0F v
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_ PARTICULARIZED CONTENTION 19 cu m
The Shoreham Opponents Coalition (SOC) hereby moves for the admission of particularized Contention 19 for litigation in the above captioned proceeding.*
A copy of Contention 19 is attached to this Motion as Attachment A.
As noted below, SOC, NRC Staff, and LILCO (the parties) have engaged in a number of informal discovery-sessions in order to adequately particularize SOC's original Contention 19 as directed by the Board in its' Order dated March.5, 1980 (at pages 21-22).
The parties have agreed that the attached Contention 19 constitutes an adequately particularized contention.
However, the parties have been unable to agree upon which specific regulatory guides, if any, contained in the attached Contention 19 fall outside the scope of the
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Board's Order referenced above.
Accordingly, Staff and LILCO will be submitting separate arguments to the Board on this issue.
SOC's position on the admission of Contention 19'is set forth below.
- The Board formally admitted SOC's Regulatory Guide contention to the proceeding in its March 5, 1980 Order, subject to adequate particularization as outlined in that Order (p.22).
Thus, this Motion simply asks for acceptance of Contention 19 as particularized in Attachment A.
The parties have agreed to use the
" Motion" format in order to permit a specified time for replies by Staff and Applicant as provided by 10 CFR
,2.730(c).
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BACKGROUND ON CONTENTION 19 1
'The Board conditionally admitted the Shoreham 6pponents Coalition to the above captioned proceeding by Order dated March 5, 1980.*
In that Order, the Board
. rejected Staff's argument that SOC's assertions rega,rding the applicability of Regulatory Guides could
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not,-be litigated in the Shoreham OL Proceeding.
The Boa.rd stated:
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" Staff believes that this Contention (19) fails to ctate an issue and therefore, should be dismissed.
-(Staf f Answer at 25-26. )
We believe, however, that it would be appropriate for the Board to consider whether the standards or goals of recent Regulatory Guides have been ~ et.
SOC m
must, however, specify which recent Regulatory Guides it believes have not been met, and why it believes they should be met."
SOC, the Applicant, and the NRC Staff subsequently held several meetings on Contention 19 in Bethesda, Maryland, Riverhead, New York, and at the SNPS site.
In addition, SOC's consultant, MHB Technical Associates, met with the NRC Staff to obtain the needed background information on some of the Regulatory Guides in issue.
On October 6, 1980, SOC submitted a " Joint Motion for Acceptance of SOC Contention 6(a)(i) and for Extension to Complete Particularization."
This Joint Motion identified the progress that the parties had made regarding the p'articularization of Contention 19 and requested additional time to complete the process.
The
-requested extension was granted by a' Board Order dated October 27, 1980.
The parties continued to narrow the sepe of the issues to be litigated, and were granted a further extension of time to particularize by a Board Order datbd December 9, 1980.
This Motion signifies the conclusion of the particularization process.
The individual Ragulatory Guides contained in the attached Contention 19 were principally gleaned from the 63 Regulatory Guides identified on page 2 of SOC's
. October 6,-1980-submission to the Board.
Since that
- SOC was formally admitted to the Shoreham Proceeding by Order of the-Board dated May,1, 1980. 4 i
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3 submission, SOC has determined that certain other Regulatory Guides will no longer be pursued and thus the attached Contention 19 references 46 Regulatory Guides.
During the informal discovery meetings, the parties further agreed that a number of Regulatory Guides might be more appropriately considered in SOC's proposed TMI Contention rather than in Contention 19.
The Regulatory Guides which f all in this category are identified in the footnote _on page 1 of the attached Content' ion 19.
It should be noted that of the 145 Regulatory Guides subject to review and informal Discovery by the
. parties, approximately 100 of those Regulatory Guides nave been resolved.to the satisfaction of each party.
SOC fully expects that additional Regulatory Guides from the 46 that remain will be reviewed and resolved prior to hearings in the informal discovery process on this issue... Thus, discussion among the parties has already substantially contributed to answering the Board's question of whether the standards or goals of recent Regulatory Guides have been met.
We urge the Board to admit the remaining 46 Regulatory Guides (and those referenced in the footnote on page 1 of Contention 19) -
so that this process may continue.
II.
EACH OF THE REGULATORY GUIDES REFERENCED IN THE ATTACHED CONTENTION 19 FALLS WITHIN THE SCOPE.0F THE BOARD'S MARCH _5, _1980 ORDER As far as SOC is able to determine, the principal
. disagreement among the parties is centered on what the Board meant by the term "recent Regulatory Guides" e
(March Sth Order at p. 22) and whether the Board, in reviewing the attached particularized Contention 19, should-assign some arbitrary date to the term "recent" and exclude certain Regulatory Guides on that basis.
l SOC strongly. believes that~if the Board were to exclude
-any of the attached Regulatory Guides on that basis,
_that would not only contradict the Board's March 5, 1980 l
ruling 'tiut would. effectively remove any meaningful l-evaluation of whether the " standards and goals" of the (attached Regulatory Guides have been met at the.Shoreham facility.-
L With regard to the t'erm "recent", it is clear that L
.the. Board-wascadopting a* scope identical to that L
suggested by_ SOC inLits Petition to' Intervene (dated
' January. 23,=1980).
SOC's position on the Regulatory
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Guide issue was clearly; set forth in its original formulation!of-Coatention 19:
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2 Current NRC procedure does not require that existing nuclear plants under construction meet the criteria contained in NRC. Regulatory Guides.
As indicated by the accideht'at Three Mile Island Unit 2, the accident was aggravated or caused by factors which were the subject of Regulatory Guides but
-which were not incorporated into the design of Three Mile Island Unit 2.
Similarly, the Shoreham Nuclear Unit 2 design does not incorporate all safety requirements contained in recent regulatory guides.
The failure of the applicant and staff to demonstrate that the Shoreham design conforms with each regulatory guide presently applicable to plants of the GEBWR type unduly endangers the public health and safety.
(SOC Petition to Intervene, January 23, 1980, at p.
52.).
In its March 5, 1980 Order, the' Board correctly recognized that while ' Regulatory Guides were not requirements to be specifically met by an Applicant, the Board snould properly evaluate whether the "standurds and! goals" of.those Regulatory Guides were being met by
.at.the Shoreham plant.
The thrust of SOC's Contention 19 and its relevance p
to the accident-at=TMI-2 is unmistakable.
The TMI i-accident' demonstrated the urgent need to verify that the L
Shoreham design and construction meet the standards and goals of all Regulatory Guides currently applicable to Jthe Shoreham plant.
Some of those Regulatory Guides undoubtedly predate the TMI-2-accident, but it is whether or not the standards'or goals have been met--not
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the -date on which. a particular Regulatory Guide or
. Revision was' enacted--that"is the critical factor in L
evaluating the. safety of the plant....
. To set an. arbitrary cut-off:date for the inclusion of Regulatory Guides in SOC Contention 19 would be
' illogical and would lead to an absurd-resitlt.
The Board
~would.be' arbitrarily deciding, on the basis of the cut-off date,.which Regulatory Guides are important for
= evaluating safety and which.are not.
The TMI accident was. aggravated 1by-Regulatory-Guides that were " current" priorgtoltnattaccident. _ Obviously, it would make no sense to limit: SOC to. Regulatory Guides or Revisions enacted afterjtheidate;of that' accident--or any other Ecut-off.date.-
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In SOC's Petition to Intervene, SOC relied heavily on the accident at TMI-2 as a circumstance justifying EOC's late intervention.
The Board found, in its March 5th Order, p.7, that the issues raised by the accident at TMI-2 did indeed constitute'.a good reason to admit SOC as an intervenor.
The Boar'd made this crystal-clear in its' Memorandum and Order Relating to Response of SOC to Board Order, Dated March 5, 1980 (dated May 1,
1980).
The Board wrote at page 4:
"(W]e clearly indicated in our Order dated March 5th, 1980 [that] SOC is being admitted to this proceeding...because it has come to us with TMI-related issues it wishes to litigate.
We have opened this proceeding to a new intervenor (SOC) and new issues because of the accident at TMI-2, as SOC asked us to do."
As is obvious from the foregoing description of SOC's Initial Contention 19, SOC has contended in Contention 19 from the beginning that' it was the NRC's f ailure to apply then-current Regulatory Guides to TMI-2 that aggravated or caused the accident at TMI.
In short, SOC argued that the Regulatory Guides which were current when TMI came on line ought to have been applied to TMI and ought to be applied to Shoreham.
That was and is the only possible meaning of SOC's use of the phrase:
"Similarly the SNPS-1 design does not incorporate all safety requirements..." (see SOC's Petition to Intervene, p.52).
Of course, it'was also implicit in the contention that the goals and standards of'any Regulatory Guides enunciated since the accident L
at TMI, too, ought to be applied to Shoreham.
But the l
Board cannot have intended to exclude Regulatory Guides enunciated before.the accident at TMI from the scope of Contention 19.
This is because the Board viewed Contention 19 as raising a TMI-related issue.
It is the NRC's failure to order compliance with the goals and standards.of those Regulatory Guides enunciated at the time of the TMI accident which SOC contends raises a TMI-related issue.
Both the Kemeny Report and the NRC's own Rogovin Report stress the importance of backfitting plants to meet the goals and standards of currently-applicable Regulatory Guides.
Their recommendations are especially applicable to Shoreham because Shoreham design dates all the way back to the 1960's.
Such an old design, particularly, needs to be updated in light of current
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knowledge.
It is 'for precis ~ely. the Shoreham-type of situation that the NRC enunciated 10 CFR Section 50.109 suthorizing backfitting when such backfiting is necessary to protect public health and safety.
The Kemeny Commission pointed out that, prior to the accident at TMI, the issue of backfitting represented a serious shortcoming in the NRC's regulatory performance.
The Commission wrote at page 19
~of the Kemeny Report:*
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"[T]he evidence suggests that the NRC has sometimas erred on the side of the industry's convenience rather than carrying out its primary mission of assuring safety."
As an example of such error, the Kemeny Commission pointed out at page 20:
"The old AEC attitude is also evident in reluctance to apply new safety standards to previously licensed plants.
While we would accept a need for.
reasonable timetables for 'backfittin3', we did not
~ find evidence that the need for improvement of older plants was systematically considered prior to Three Mile Island."
The Kemeny Commission followed up this observ7 tion with two specific recommendations.
At page 66 of.cs report,-the Commission recommended:
"There should be an improved program for the systematic safety evaluation of currently operating
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plants, in order to assess compliance with current requirements, to assess the,need to make new requi,rements retroactive to older plants, and to identify new safety issues."
The Commission did not limit its recommendation to backfitting of operating plants.
The Commission recommended,.at page 65 of its report:
" Licensing procedures should foster early and meaningful resolution of safty issues before major financial commitments 'in construction can occur."
- Report of the President's Commission on the Accident At Three Mile-Island, October, 1979.
y This recommendation fol' lows up the Commission's criticism, expressed at page 53aof its report, that:
"When NRC issues new guidelines concerning safety, there is usually no systematic review, on a plant l
j by plant basis, of operating plants and plants under construction for possible 'backfitting'."
The'Rogovin Report, too, found backfitting to be an j'
Achilles' heel of the regulatory process.
In its i
general critique of NRC regulations as lacking criteria, it cited 10,CFR 50.109 as an especially flagrant l
example.
As the Rogovin Report
- put it in Volume 2, page 21:
"In the more than nine. years that followed issuance of the backfitting regulation, these [backfitting]
decisions continue to be made without workable backfitting criteria."
This Board has evidenced an intention to consider TMI-related issues and profit by the lessons of TMI.
The Rogovin and Kemeny Reports are cited hercin as a reminder of the problems which the Board has already stated it intends to consider.
Given that criteria for making backfitting decisions are lacking, it is especially appropriate that the Board allow Contention
.19 to be fully litigated and that the Board receive the
. benefit of.adversarial expert testimony on the subject in the Shoreham proceeding.-
In fact, the Board has manifested an intention to do exactly that.
As it stated in its Order dated March 5th, at page 8:
"We believe'that this Board will he greatly aided
- in' discharging its responsibilities with respect to the matters raised by' SOC if SOC is a full participant."
As specified by.10 CFR'Part 50.57(a)(3)(i), the Board must make an affirmative finding that operation of is the plant will not jeopardize public health and safety.
- N' If the Board refuses even to consider whether failure to
- meet the goals and.standardslof current Regulatory Guides endangers public health-and safety, or if it
. excludes c'ertain Regulatory Guides on the basis of an
' arbitrary cut-of f date, ' it - 1:s difficult to'see how the
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record will~contain.information sufficient to. support the Board's finding on the' subject.*
- Three_ Mile Island:- A Report To The_Commissio_ners And
'To The_ Publicf January, 1980.
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I IV, CONCLUSION On the basis af the foregoing, SOC respectfully
- moves that this board accept the, attached version of Contention 19 for litigation in this proceeding.
4 Respectfully submitted, TWOMSY, LATHAM & SCHMITT Attorneys for The Shoreham Opponents Coalition 9
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REVISED SOC CONTENTION 19 1
19:
APPLICATION OF REGULATORY GUIDES A major contributing factor in the TMI-2 accident has been that the old operating plants have not been required by the NRC Staff /(Staf f) to be in compliance with current regulatory practices (i.e.,
Regulatory Guides, Branch Technical Positions, and Standard Review Plans).
The TMI-2 accident has also demonstrated that the current regulatory practices, practices similar to those being applied by.the Staff in their safety evaluation of the Shoreham Nuclear Station, were in a
' number of cases (i.e., hydrogen generation, radiation shielding, source terms, and single failure criterion for example) not suitably conservative to properly protect the health.and safety of the public.*
zIntervenors contend that the Regulatory Staff has not required that the Applicant incorporate measures to assure that the Shoreham Nuclear Station conforms with the standards or goals of safety criteria contained in
'recent NRC Regulatory _ Guides and as a result, the l
Regulatory Staff has noterequired that Shoreham
. structures, systems, and components be backfitted as frequired by 10 CFR, 50.55 a, 10 CFR, 50.57, and 10 CFR,.
!50.109 with regard to:
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(Reg. Guide-1.2)_
The Applicant's general description-of the pressure vessel' fails to specifically
. describe' howJ the Shoreham pressure vessel will behave in a non-brittle manner under loss of coolant conditions and thereforeLdoes noti. comply with-Appendix-A, GDC 31.
- A number of. Regulatory Guides are.related to TMI issues and,:.-the parties agree, might.be more appropriately
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' considered as part of SOC's TMI contention.
SOC reserves'the right to particularize.a contention addressing:the-following-Regulatory Guides as part of 1
'that TMI contention:
1.7; 1.26;-1.29;~1.52; 1.53; 1.98; 1'.109-1'.113.-
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B.
The Applicant's design fails to provide adequate independence between redundant power as re' quired by GDC 17 in that automa' tic transfer of power
. sources is provided for critical a-c valves in the RHR system (LPCI) and the reactor recirculation loops.
C.
The Applicant's propo5ed posc-accident hydregen control management is inadequate in tnat the applicant complies with the measures descried in Rev. O, rather than Rev. 2, of the Guide and therefore does not comply with 10 CFR 50.44.
D.
Inadequacies in personnel qualification and training were noted by various reviewers of the TMI-2 accident.
ANSI Std. 3.1-1978, the successor to ANSI-18.1-1971, is undergoing extensive-revision in an_ effort to provide upgraded requirements for personnel. qualification and training.
The Applicant complies with the 1971 version of the Guide (Rev. 0) and the ANSI Standard, rather than.the measures described in
. the; Feoruary, 1979 and Septe.nber, 1980 proposed Rev. 2 to. the Guide.
E.
The Applicant fails to describe the degree of_ compliance to Rev.'2 of the Guide addressing ihe-selection, design,:and qualification of diesel-generator _ units.uced as standby (onsite) electric power _' systems with regard to~ those ' requirements of IEEE
- Std.-387-1977, "IEEE Standard Criteria for
-Diesel-Generator Units Applied as Standby Power Supplies"; IEEE Std. 308-1974, "IEEE Standard Criteria forEClass IE Power Systems"; IEEE Std._ 323-1974, "IEEE
/ Standard _ forL Qualifying Class IE. Equipment"; and IEEE Std. 344-1975,_" Recommended Practices for Seismic Qualification-of Class IE Equipment" included in the
-regulatory position'of'the. guide.. Rather, the Applicant
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commits to the diesel generator _ requirements described
.=inRev. Ofof'the Guide: dated March,~1971..
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'F.
The instrument lines penetrating the primary reactor containment comply with Rev. O of the Guide.
Tne Applicant has failed to address supplemental guidance for backfitting considerations presented in Rev. 1 of this Guide dated February, 1972.
G.
(Reg._ Guide 1.13)
The spent fuel stora@e design basis has not been updated oy tne Applicant to comply with the ' regulatory position of Rev. 1 o'.
the Guide dated December, 1975 and therefore does not comply w'Ith Appendix A, GDC 61 with regard to dropping of heavy loads, tornado missiles, and single failure-proof Cranes.
H.
The Applicant has failed to upgrade the meteorological measurement program to comply.
with the regulatory ~ position of Draf t Guide 1.23 dated September, 1980, and enerefore does not comply with 10 CFR, 100.10(c)(2), 10 CFR, 50.36a(a)(2), Appendix I, and Appendix E in order to adequately measure and document basic meteorological data and to estimate potential radiation doses to the public.
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I.
(Reg. Guide 1.26 and 1.29)
The Applicant's general list of. quality group classifications for safety-related components Tin.FSAR Table 3.2.1-1 does not fully comply witn the classifications contained in Rev. 3 of duide 1.26 dated February 1976 for safety-related components containing water, steam, or radioactive materials and thereforeLdoes not comply with Appendix A, GDC 1, and 10 CFR, 50.55a.
The seismic design classifications, also Egenerallyilisted byL the Applicant in FSAR Table 3.2.1-1, do.not comply with Rev~. 3 of the Guide dated September
-.1978 and therefore do not comply with Appendix-A, GDC 2
'and 10'CFR, 100, Appendix A,..with regard to control room Lhabitability and radioactive-waste systems.
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Tne control of ferrite content in stainless steel weld metal by the Applicant complies w.ith Rev. 1 of the Guide rather than Rev. 3 of.the Guide dated April, 1978 with regard to verification of delta ferrite content of filler materials and to examination for ferrite content by a magnetic measuring instrument and therefore does not comply with Appendix A, GDC 1 and 14.
K.
The Applicant's criteria for safety-related electric power systems is based on IEEE Std. 308-1971 (Rev. O of Guide) rather than IEEE Std. 308-1974 (Rev. 2 of Guide dated February 1977) and therefore does not comply with Appendix A, GDC 17 and 18, with regard to the off-site network, availability of
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off-site power, and battery charger supply requirements.
L.
The Applicant's control of the use of1 sensitized stainless steel does not fully comply with tne regulatory position of the Reg. Guide and therefore does not comply with Appendix A, GDC 1 and 4.*
M.
The-cesign limits and load combinations utilized by the Applicant for seismic category I fluid system components has not been analyzed l
and documented in accordance with Rev. O of the Guide idated May, 1973 and therefore_does not comply with Appendix A, GDC 2.
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- SOC. reserves the right to reparticularize this contention based on~the new'NRC position described in NUREG-0313f(Rev. 1).
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(Rea. Guide 1._52)
Tne Applicant's proposed post-accident atmosphere clean-up complies only partially with Rev. O of the Guide (Reactor Building Standby Ventilation System and, Control Room Air Conditioning filter trains are 'not removable as single units) rather than Rev. 2 of the Guide which was issued in 1978 prior to the TMI-2 accident and therefore the Applicant has failed to satisfy the habitability requirements of Appendix A, GDC 41, 42, 43, and 61.
O.-
The criteria for maintenance cf water purity in the reactor coolant by the Applicant is in accordance with Rev. O rather than Rev. 1 of the Guide and therefore does not comply with Appendix A, GDC 13, 14, 15 and 31 in that the. Applicant has failed to document the following measures:
1.
Describe how resin transfers will be monitored in the reactor water cleanup system.
2.
Table 5.2.3-2 of the FSAR specifies the con-iductivity and' chloride concentration limits for the. reactor water to be 2 umho/cm and 0.1 ppm, respectively, during reactor operation up to 10 percent of rated power.
Table 1 of Reg.
Guide 1.56, Rev.
1, specifies the same limits, but for power operation at steaming rate less than one percent of rated steam flow.
The Applicant should verify that steaming rates will be less than one percent of the rated steam flow at power levels up;to.10 percent of the rated power.
l 3.
Describe and summarize the procedures for l
l determining.the pH, chloride concentrations, and conductivity in the reactor vessel water (regula-tory position C.6 of Reg. Guide 1.56, Rev. 1).
4.
The.FSAR does not indicate that chemical
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analysis for suspended impurities will be performed in accordance with regulatory position c.1 of Reg.
Guide-1.56, Rev.
1.
The Applicant should verify that such~ analyses are to be performed and state the sampling and analysis frequency and established limits and the basis for such limits.
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Describe the water chemistry control program to assure maintaining the condensate conductivity within the limits of Table 2'of Reg. Guide 1.56, Rev.
1.
Include conductivity meter alarm set points and the corrective actions to be taken when the limits of Table 2 are exceeded.
P. (Reg'. Guide 1.60 and 1.61)
The design response spectra for the seismic design of Shoreham i's not based on the standards in the Reg. Guide and, thus, the spectra has not been demonstrated to be appropriately conservative and th'erefore does not comply with Appendix A, GDC 2, and 10 CFR, Part 100, Appendix A.
In addition, the Applicant did not ut'ilize the Reg. Guide 1.61 value of damping (4%) for the OBE analysis of Category I reinforced concrete structures, but rather utilized a higher value of damping (5%).
Q.
_(Reg. Guide _1.63)
Shoreham has installed General Electric containment electrical penetrations which utilize epoxy as a pressure sealant and as an insulator.
The GE-furnisned epoxy has cracked and peeled due to aging and has reverted due to moisture absorption and therefore'does not comply witn Rev. O of the Guide.
In addition, the electrical-penetrations at Shoreham have been qualified to Rev. O of the Guide dated November, 1973 rather than the current revision (Rev. 2 dated July, 1978) of tne Guide.
R.
The'preoperational and initial
, start-up-test program described by the Applicant in Section 14 of the FSAR fails to document and describe how the Shoreham plant's initial test program will meet the measures described in Rev. 2 of the Guide dated August, -1978, particularly with regard to assuring compliance with the principal design criteria contained in' Appendix A to 10 CFR, Part_50.
Rather, the Shoreham program'is based on the recommendations in Rev. O of the t
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. Guide published in Nove.nber, 1973, the Applicant also fails to document in the FSAR the specific measures being implemented at Shoreham to. meet the requirements of Reg. Guide 1.68.1 dated Janaary 1977 for testing of feedwater and condensate systems and to meet the requirements of Reg. Guide 1.68.2 dated July 1978 for testing of remote. shutdown capability.
/
S.
[ Reg. Guide 1.75)_
The design of the Shoreham electrical systems-fail to comply with the regulatory position of Reg. Guide 1.75 for physical independence of electrical systems and therefore'does not comply with 10 CFR, 50.55a, and Appendix A, GDC 3, 17, and 21.
To minimize the potential for physical systems interactions, the electrical systems at Shoreham should be designed in complete compliance with the measures in Rev. 2 of the. Guide dated September, 1978.
T.
(Reg. Guide 1.78 and 1.95,1 Main control room
'nabitability measures during a hazardous chemical release have-not been demonstrated by the Applicant in accordance with these Guides and therefore does not comply with Appendix A, GDC 4 and 19, in that tne Applicant has not adequately documented the basis for the conclusion that'tnere are no significant quantities
-of chemicals within five miles of the site.
U.
The preoperational testing of instrument air systems as required by Appendix A, GDC 2, and Appendix B, Criterion XI has not been demonstrated
.as prescribed in this Guide.
. V.~.
The Applicant has failed to adequately demonstrate qualification of Class.IE electrical. equipment as described in this Guide, as
-specified in-IEEE Std. 323-1974, and therefore does not
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' ' comply with Appendix A, GDC 1, 2
and 4, and Appendix B, Critorion III, with regard to deteriorating effects of
' component aging, accuracy of instrument setpoints, test documentation requirements, and tolerance margins.*
W.
(Reg. Guides 1.92 and 1.122)
The Applicant has failed to adequately demonstrate that the methods utilized by the Applicant for combining modes and spatial components in seismic response analysis presented in Section 3.7 of the FSAR are suitably conservative in all cases when compared with the methods described in Rev. 1 of Reg. Guide 1.92 issued in
. February 1976, and therefore does not comply w.ith Appendix A to Part 50, GDC 2, and Paragraph (a)(1) of Section VI of Appendix A to Part 100.
Further, :he floor design response spectra developed by the Applicant has-not been documented for compliance with paragraph B.3 of Reg. Guide 1.122, Rev. I dated February 1978.
X.-
The design of the main steam isolation-valve leakage control system has not been adequately demonstrated by the Applicant to be in
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. accordance with the measures described in Rev. 1 of this Guide dated June, 1976, and therefore does not comply with Appendix A, GDC 54 with regard to the acceptability of-the alternative control or limitation methods proposed byrthe Applicant and to the adequacy of the leakage control system interlocks..
- SOC. reserves.tne right to reparticularize this
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contention based on the appli."it's response to the new NRC position described in-NUREG-0588.
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The Applicant has failed to commit to conducting a seismic qualification program for Class IE electrical equipment as prescribed by Rev. O and Rev. 1 of this Guide and therefore does not comply with Appendix A, GDC 2 and Ap'pendix B, Criterion III, with particular regard to the testing program, including multi-axis multi-frequency testing and the effects of aging prior to testing.
- Z.
(Reg. Guides 1.109 through 1.113)
The Applicant has not demonstrated that the dose and release measures prescribed in these five Guides (Reg. Guide 109, Rev. 1; Reg. Guide 110, Rev. 0; Reg. Guide 111, Rev. 1; Reg.
Guide 112, Rev. 0; Reg. Guide 113, Rev. 1) have been utilized in the Staff's radiation effects-analysis and tnerefore does not comply with Appendix I to 10 CFR, Part 50.
AA.
The turbine orientation with respect to safety-related structures is unfavorable in the Shoreham design and thus results in additional probability of a turbine missile accident endangering public health and safety.
The Applicant's design for protection against low-trajectory. turbine missiles, as described in Section 10.2.3 of the FSAR, is not in conformance witn the latest procedures outlined in Rev.
1 of this Guide dated July, 1977~and'therefore does not comply _witn Appendix:A, GDC 4.
' 38.
The Applicant has not documented the extent to which the conste:etion Q.A.
= program complies with-the_ measures described in this
-Guide-(ANSI Std. N45.2.8-1975 and 1978)'concerning installation, inspection', and testing of mechanical equipment and systems,.and therefore does not comply
- with-10 CFR,:Part--50, Appendix'B.-
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(Reg. Guide 1._118)
The Applicant and Staff have not adequately documented the extent to which the
- periodi, acting of electric power and protection systems complies with Rev. 2 of this Guide dated June, 1978 and therefore does not comply with Appendix A, GDC 18 and 21.
i DD.
(Reg. Guides 1.124 and 1.130)
The Applicant has f ailed to document. in Sections 3.7, 3.8, and 3.9 of the
-PSAR that the design limits and loading combinations for Class I linear-type component supports comoly adequately with the regulatory position of Rev. 1 of Reg. Guide 1.324 dated January, 1978 and therefore does not comply with Appendix A, GDC 2.
Similarly, the Applicant has also failed to document how the service limits and loading combinations for Class 1 plate-and-shell type
' component supports comply with the Subsection NF requirements as prescribed in Reg. Guide 1.130.
EE.
Tne Staff nas failed to document the extent to which physical models for design of hydraulic structures and systems, such as the intake structure and dif fusers, described in Rev. 1 of this Guide dated October, 1978 were assessed for Shoreham.
FF.
The Applicant and Staff have f ailed to document the extent to which'the General Electric model and related statistical methods for analysis of fuel densification complies with the measures presented'in Rev. 1 of this Guide and therefore
'does not. comply with Appendix K'to 10 CFR, Part 50.
. GG. _ (Reg. Guides 1.128 and 1.129)
The Applicant and
-Staff-have failed toLdocument'the' extent to which the
- lead storage batteries comply with the current requirements presented in Rev. 1 to'the two. Guides.
7.. -
Furtner, in Table 8.1.7-1 and Section 8.3.2.1.2 of the FSAR, the Applicant commits to meet the requirements of IEEE Std. 450-1572 rather than tne requirements of the 1975 version of the standard prescribed by the two guides and therefore does not comply witn Appendix A, GDC 1 and 2.
_ Reg._ Guide 1.139)_
The Applicant and Staff have
(
HH.
f ailed to document the degree of compliance with the guidance for residual heat removal systems contained in the Maf,1978 version of the draf t Guide and therefore does not comply with Appendix A, GDC 19 and 34, with
. particular regard to the equipment to be utilized and qualified to bring the plant to a cold shutdown condition and to the testing of safety relief valves.
II.
_{ Reg. Guides _1.140, 1.141, 1.143, and 1.145)
The
-Staff has failed to adequately document and confirm the degree to which the NRC review utilized the criteria contained in these four Guides (Reg. Guide 1.140, October, 1979; Reg. Guide 1.141, April, 1978; Reg. Guide 1.143, October, 1979; and Reg. Guide 1.145, August, 1979).
JJ.
1, Reg. Guid e 1._14,4 )
The Applicant has failed to document the extent to which the auditing of the QA program during construction conforms to the measures stated in Rev. 1 of the Guide dated September,- 1980, and therefore-does not comply with Criterion XVIII of Appendix 8 to 10 CFR, Part 50.
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