ML20023A805
| ML20023A805 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/17/1982 |
| From: | Bordenick B, Bordernick B, Irwin D, Lanpher L, Shaw J LONG ISLAND LIGHTING CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD), SHOREHAM OPPONENTS COALITION, SUFFOLK COUNTY, NY |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8210200036 | |
| Download: ML20023A805 (11) | |
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- SECRCAC 7,.hSk;D AN "NG UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (OL)
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(Shoreham Nuclear Power Station,
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Unit 1)
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RESOLUTION OF SUFFOLK COUNTY CONTENTION 25/SHOREHAM OPPONENTS COALITION CONTENTION 19(a) -- PRE-SERVICE INSPECTION AND IN-SERVICE INSPECTION AND REACTOR PRESSURE VESSEL INTEGRITY I
This Agreement among Long Island Ligh ing Company
("LILCO"), the Nuclear Regulatory Commission Staff (" Staff"),
Suffolk County ("SC") and Shoreham Opponents Coalition (" SOC")
(hereinafter collectively, the " Parties") resolves SC Contention 25/ SOC Contention 19(a) in accordance with the terms stated below, subject to the approval of the Atomic Safety and Licensing Board.
SC Contention 25/ SOC Contention 19(a) involve several issues related to the pre-service inspection and in-service inspection (" PSI /ISI") programs as well as reactor pressure vessel ("RPV") integrity.
In essence, in these contentions SC and SOC alleged that LILCO failed to demonstrate the following:
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1.
The adequacy and completeness of the PSI program; 2.
The timely definition of the ISI program and assurance that the approved program will be complete; 3.
Assurance that there is correlation between the PSI and ISI programs; 4.
Compliance of the PSI /ISI programs with Regulatory Guide 1.150; and 5.
The integrity of the RPV in accordance with Regulatory Guide 1.2.
On June 14, 1982, LILCO, the Staff and SC pre-filed direct testimony on SC Contention 25 and LILCO and the Staff pre-filed direct testimony on SOC Contention 19(a).
In its prefiled testimony, SC set forth its concerns relating to the PSI and ISI programs at Shoreham.
By this Resolution Agreement, LILCO documents that it either has or will take the steps described below, which respond to the SC and SOC concerns expressed in SC Contention 25/ SOC Contention 19(a) and in SC's direct testimony.
SC and SOC have determined that LILCO's actions respond to their con-cerns and thus satisfy those concerns.
Accordingly, based upon LILCO's actions and commitments, SC and SOC find that SC Contention 25/ SOC Contention 19(a) are resolved.
As a result, the Parties jointly urge the Board to accept this Resolution to terminate litigation on SC Contention 25/ SOC Contention 19(a). L
i The details of discussions among SC and SOC consultants
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and LILCO representatives, review of materials by SC and SOC consultants, and actions and undertakings by LILCO regarding each of the issues raised in SC Contention 25/ SOC Contention 19(a) are described below.
1.
PSI Program SC's concern regarding the adequacy of Shoreham's PSI program stems from the fact that the reactor vessel and por-tions of the Shoreham system design predate the establishment of the ASME Code PSI definition.
SC is therefore concerned 4
that the PSI program at Shoreham would result in LILCO's sub-mitting to the NRC an unacceptable number of exemotions and relief requests.
The PSI program at Shoreham is now basically complete, and subsequent to the filing of testimony on SC Contention 25/ SOC Contention 19(a), LILCO documented the extent of the PSI program relief requests.
(See SNRC-759, August 16, 1982, Attachment I hereto.)
This letter lists the relief requests for the Class 1 and Class 2 piping systems, and for the RPV.
SC consultants have reviewed the relief requests sub-mitted by LILCO and are satisfied that the Shoreham PSI program is nearly in complete compliance with the Code requirements and is as complete as is reas'onably achievable.
A number of relief i.
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requests, identified on key welds in the recirculation and RHR systems, are of concern to SC; however, because these defi-ciencies are being addressed in connection with SC Contention 24, they are not viewed by SC as an impediment to resolution of the PSI portion of SC Contention 25.
2.
ISI Program SC's concern relating to the Shoreham ISI program is that the program had not yet been developed at the time SC sub-mitted prefiled direct testimony on SC Contention 25.
- Indeed, in SC's view at that time, LILCO had not even made a commitment relating to such a program.
However, in response to the con-cerns raised by SC, LILCO provided SC consultants, subsequent to the filing of testimony on SC Contention 25, with the following materials:
(a) Instruction manuals and drawings of the RPV inspec-tion system for ISI, including:
(i)
NES Document 80A2980 (ii)
NES Document 80A2981 (iii)
NES Document 80A3047 (iv) 102 NES Permanent and Magnetic Track Drawings as follows:
80(B,C,D or E) 2983 through 2997 80D299 80(D or E) 3001 through 3041
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80C3043, 3046, 3049, 3050, 3051, 3056, 3064 and 3065 80(C or D) 3077 through 3113 (v)
NES Lower Head Track System Drawing (80E4441)
(b)
Layout drawing of the RPV welds showing the extent of weld inspection coverage and relief requests.
As a result of a review of the information described above, SC consultants agree that the Shoreham ISI program planned for the RPV is nearly in complete compliance with 1980 ASME Section XI.
Although they cannot be predicted with cer-tainty, no significant changes are anticipated in the edition of the ASME code to which Shoreham's ISI program will adhere.
In addition, LILCO agrees to the following with respect to the Shoreham ISI program:
(a) LILCO will complete development and documentation of the ISI program in a timely manner (no later than one year after issuance of an operating license).
(b)
The scope of the piping inspections of the ISI program to the fullest extent possible should be at least as extensive as implied by the PSI program unless Code or regula- >
tory requirements change.
(See SNRC-759, Attachment 1 hereto.)
(c)
The RPV ISI program will be conducted in accord-ance with, and to the fullest extent possible as provided by, the NES documents and drawings identified above. U
i SC agrees that the above commitments by LILCO satisfy the concerns of SC regarding the development of the ISI pro-gram.
3.
PSI /ISI Correlation SC's concern regarding the correlation between Shoreham's PSI and ISI programs arises because the PSI program is required to be based on the 1971 edition of the ASME Code, whereas the ISI program must meet a 1980 or later edition of the Code.
In SC's view, the earlier provisions of the Code do not require complete inspection of all welds. In SC's view, this results in the potential for problems in correlating the PSI results with those from the ISI program.
Subsequent to the filing of testimony on SC Contention 25, however, LILCO reported that the PSI program is now nearly complete.
LILCO has also now identified all PSI relief requests.
The PSI program has included a complete inspection of all possible RPV welds and approximately three times the number of Class 2 welds as is likely to be necessary to satisfy the anticipated ISI program requirements for the first 10 year inspection period.
Therefore, SC is now satisfied that its concerns relating to the correlation of PSI and ISI programs at Shoreham have been addressed.
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4.
Regulatory Guide 1.150 SOC Contention 19(a) expressed the concern that the Shoreham PSI /ISI programs were not being performed in compli-ance with newly issued Regulatory Guide 1.150, and thus would not meet state-of-the-art requirements.
Subparts of this con-tention addressed calibration requirements, photographic records, travel time, and ALARA concerns.
LILCO has taken the position that the PSI program did not need to follow Regulatory Guide 1.150 because the PSI inspection of the RPV was completed prior to the implementation date of the Regulatory Guide.
LILCO has demonstrated, however, that the calibration require-ments used in the Shoreham PSI program were actually more restrictive than those specified in Regulatory Guide 1.150.
With regard to travel time and ALARA issues, LILCO has demon-strated that these concerns are not directly addressed in Regulatory Guide 1.150.
LILCO has also committed that the ISI program will implement the provisions applicable to BWRs of the June 1981 issue of Regulatory Guide 1.150, or of the next subsequent revision of the Guide.
However, as is noted in the Regulatory Guide, " methods and solutions different from those set out in the [ Guide] will be acceptable, if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.",
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LILCO's ISI contractor (NES) has been active on an EPRI committee working on recommendations for revisions to Regulatory Guide 1.150.
This will help to assure compliance of the ISI program at Shoreham with the latest recommendations.
LILCO has provided' SOC consultants with a copy of the EPRI report which was recently submitted to the NRC.
Based on the foregoing information and commitments of LILCO', SOC agrees that LILCO is now adequately responding to Regulatory Guide 1.150 and, therefore, SOC's concerns are sat-isfied.
SC concurs.
5.
Regulatory Guide 1.2 SOC Contention 19(a) also addressed the issue of com-pliance with Regulatory Guide 1.2 in the design of the pressure vessel. LILCO has committed in the FSAR to compliance with Regulatory Guide 1.2 and has also included consideration of the Heavy Section Steel Technology Committee recommendations.
The recent generic concern for potential pressure vessel failure due to pressurized thermal shock has been asserted by LILCO to be primarily a PWR issue.
SOC agrees with this assertion and therefore agrees that this issue is resolved.
Based on the foregoing actions and undertakings by LILCO, SC considers SC Contention 25 to be resolved.
In addi-tion, based on LILCO's commitments and actions taken, SOC believes that SOC Contention 19(a) is resolved, and SC concurs.
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Counsel for Counsel for
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LONG ISLAND LIGHTING COMPANY SUFFOLK COUNTY Wu!/ae N W\\
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W1 C @isel for Counsel for SHOREHAM OPPONENTS COALITION NUCLEAR REGULATORY COMMISSION STAFF DATED:
September 17, 1982 t
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I CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I certify that copies of Resolution of Suffolk County Contention 25/Shoreham Opponents coalition Contention 19(a) --
Pre-Service Inspection and In-Service Inspection and Reactor Pressure Vessel Integrity were served upon the following by first-class mail, postage prepaid, by Federal Express (as indi-cated by an asterisk), or by hand (as indicated by two asterisks):
Lawrence Brenner, Esq.**
Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel Dr. Peter A. Morris **
U.S.
Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Dr. James H.
Carpenter **
Commission Administrative Judge Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Daniel F.
Brown, Esq.
U.S. Nuclear Regulatory Commission Attorney Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Y
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.- Bernard M.
Bordenick, Esq.**
David J.
Gilmartin, Esq.
Richard L. Black, Esq.
Attn:
Patricia A.
Dempsey, Esq.
David A.
Repka, Esq.
County Attorney U.S. Nuclear Regulatory Suffolk County Depar' ment of Law c
Commission Veterans Memorial Highway Washington, D.C.
20555 Hauppauge, New York 11787 Herbert H. Brown, Esq.
Stephen B.
Latham, Esq.
Lawrence Coe Lanpher, Esq.**
Twomey, Latham & Shea Karla J.
Letsche, Esq.
33 West Second Street Kirkpatrick, Lockhart, Hill, P. O.
Box 398 Christopher & Phillips Riverhead, New York 11901 1900 M Street, N.W.
8th Floor Ralph Shapiro, Esq.
Washington, D.C.
20036 Cammer and Shapiro, P.C.
9 East 40th Street Mr. Mark W.
Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road Howard L.
Blau, Laq.
Waltham, Massachusetts 02154 217 Newbridge Road Hicksville, New York 11801 MHB Technical Associates 1723 Hamilton Avenue Matthew J.
Kelly, Esq.
Suite K State of New York San Jose, California 95125 Department of Public Service Three Empire State Plaza Mr. Jay Dunkleberger Albany, New York 12223 New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223
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Hunton & Williams 707 East Main Street P. O.
Box 1535 Richmond, Virginia 23212 DATED:
October 13, 1982
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