ML20027D726
| ML20027D726 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/13/1982 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Budnitz R FUTURE RESOURCES ASSOCIATES, INC. |
| Shared Package | |
| ML20027C458 | List: |
| References | |
| NUDOCS 8211080305 | |
| Download: ML20027D726 (3) | |
Text
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DISTRIBUTION :
OCT 13 1982
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NRC PDR w/ cqy of ~ incoming
- Lo al PDR
- Bordenick, OELD E. L. Jordan, DEQA:IE NSIC*
LB#2 File J. M. Tay1or, DRP:IE PPAS ASchwencer S. Hanauer Dr. Robert J. Budnitz, President RGil bert/EWeinkam R. Mattson Future Resaurces Associates, Inc.
EHyl ton R. Vollmer 2000 Center Street HDenton/ECase H. Thompson Suite 413 DEisenhut/RPurple Berkely, CA 94704 P. Check MJambor case se d e 1 M TNovak/LBerry
Dear Dr. Budnitz:
Correspondence clerk, NRR(NRR#82-406)
Your Septenaer 24, 1902 letter to '!r. Harold De/ original yellow ticket w
nton indicates that you have reviewed a preliminary draf t PRA report prepared by Science Applications, Inc.
(SAI) on the Shorehan duclear Power Station. You state that in the course of your review you have concluded that "one type of accident involving internal flooding nay lead to important plant danage states with a significantly higher probanility than is calculated in the craft PRA."
You state that the sequences involve routine on-line maintemnce of important safety equipnent at level 8, the botton level of the Shoreham reactor building.
Juring the course of our review of the Shoreham facility, we considered the potential for loss of safety-related equipnent due to flooding at level 8 caused by pipe breaks that could introduce water inventory to level S.
We considered the fact that no safety related equipnent is located less than 22 inches above the level 8 floor, that the ECCS pung notors are about 6 feet above that floor and the fact that With no operator intervention it would take about 30 minutes for flooding to reach an elevation of 22 inches above the level U floer. The applicant also has procedures to alert the operator to such flooding.
Nevertheless, because of the concern expressed in your letter which relates to routine on-line maintenance we have asked the applicant to provide us with an additianal evaluation, concentratinj on the potential flooding consequences of aaintenance activities. A copy of that letter is enclo.ed.
We also notified the Shorehan Board (Board Notification 82-99, copy enclosed) of your coacern, noting that we would address the applicant's further analysis of flooding events in our safety revies.
'le will be pleased to provide you with a copy of the additional analysis that is expected from the applicant as well as the results of our safety review.
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J Thoaas H. Novak, Assistant director h,
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NRC FORM 318 (10-80) NACM O240 OFFICIAL RECORD COPY uswo = _m E
Shoreham l
Mr. M. S. Pollock Vice President - Nuclear N
Long Island Lighting Company 175 East Old Country Road Hicksville, New Yoric 11801 cc:
Howard L. Blau, Esquire MHB Technical Associates Blau and Cohn, PC.
1723 Hamilton Avenue, Suite K 217 Newbridge Road San Jose, California 95125 Hicksville, New York 11801 Stephen Latham, Esquire Mr. Jay Dunkleberger Twomey, Latham & Shea New Yoric State Energy Office Post Office Box 398 Agency Building 2 33 West Second Street Empire State Plaza Riverhead, New Yoric 11901 Albany, New York 12223 Matthew J. Kelly, Esquire Energy Research Group, Inc.
Staff Counsel 400-1 Totten Pond Road New York State Public Service Commission Waltham, Massachusetts 02154 Three Rockefeller Plaza Albany, New York 12223 Mr. Jeff Smith Shoreham Nuclear Power Station Ezra I.' Bialik, Esquire Post Office Box 618 Assistant Attorney General Wading' River, New Yoric 11792 Environmental Protection Bureau New York State Department of Law W. Taylor Reveley, III, Esquire 2 World Trade Center Hunton & Williams New York, New York 10047 Post Office Box 1535 Richmond, Virginia 23212 Resident Inspector Shoreham NPS, U.S. NRC Ralph Shapiro, Esquire Post Office Box B Cammer & Shapiro Rocky Point, New York 11778 9 East 40th Street New York, New York 10016 Herbert H. Brown, Esquire Kirkpatrick, Lockhart, Hill, Christopher & Phillips Mr. Brian McCaf frey a-Long Island Lighting Company 1900 M Street, N.W.
175 E. Old Country Road Washington, D.C.
20036 Hicksville, New Yort 11801 Lawrence Coe Lanpher, Esquire Honorable Peter Cohalan Kirkpatrick, Lockhart, Hill, Suffolk County Executive Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
Veteran's Memorial Highway Washington, D.C.
20036 Hauppauge, New York 11788 Karla J. Letsche, Esquire David Gilmartin, Esquire Kirkpatrick, Lockhart, Hill, Suffolk County Attorney Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
Veteran's Memorial Highway Washington, D.C.
20035 Hauppauge, New York 11788
c 2-Shoreham
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Lawrence Brenner, Esq.
Administrative Judge Atomic Safety & Licensing Board
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U. S. Nuclear Regulatory Commission Washington, D. C.
20553 Dr. James L. Carpenter Administrative Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory Coimmission Washington, D. C.
20555 Dr. Peter A. Morris Administrative Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
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Mr. Harold R. Denton
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Dear Mr. Denton:
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For the past three months my company has been analyzing the Shoreham Nuclear 6'
Power Station under contract to Suffolk County, New York.
Specifically,wehave.k reactor accident sequence probabilities and release magnitu been contracted to provide an independent opinion as to the validity of the
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in a preliminary draft report carried out by Science Applications, Inc. and y /e '
supported by Shoreham's owner, Long Island Lighting Company, entitled "Probabi-This draft PRA analysis, M listic Risk Assessment, Shoreham Nuclear Pcwer Station".
e which we have reviewed, contains calculations of internal accident sequence p 'j,,,(
F probabilities, discussion of accident phenomena, and calculations of magnitudes of potential releases. The County's interest in these issues stems from their
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need to have an acceptable technical basis for their emergency planning activities./
4 In the course of our review, we have concluded that one type of accident involving internal flooding may lead to important plant damage states with a significantly higher probability than is calculated in the draft PRA.
Indeed, this group of sequences might, in our opinion, be among the dominant sequences contributing to 7/d residual public risk at Shoreham.
The sequences under discussion were analyzed by SAI in the draft PRA, but we believe that because of an error the accident probabilities have been underestimated. The sequences involve routine on-line maintenance of important safety equipment at level 8, the bottom level of the Shoreham reactor building where much important safety equipment is located.
If during on-line maintenance there were to be an accidental opening of the isolation valve that separates the specific component being maintained from the rest of the system, then under some circumstances a local flood would result, which could become a serious and disabling flood if the isolation valve cannot be reclosed in adequate time.
This flood, while it would disable emergency equipment, still would not cause an accident unless there were to be an additional loss of heat removal capability through loss of the power conversion system. The issue is how probable these types of sequences are.
We have done a rough calculation of our own of the likelihood of the sequences.
The results are found in our draft report (attached) prepared for Suffolk County.
Section 3.3 and Appendix D of our report contain our technical discussion.
(However, a copy of SAI's draft PRA report on Shoreham is probably needed to put our discussion in the proper context.) While we believe that this set of M 3001@
H.R. Denton page 2 24 September 1982 sequences could be an important contributor to overall residual risk at Shoreham, we have been unable to quantify the risks ourselves, because we haveri't done a complete analysis (either probabilistic or deterministic),
nor were we able to test the sensitivity of our conclusions to various engineering assumptions.
Furthermore, while we suspect that this issue might be important also at other reactors, especially at other BWR-Mark 2 reactors with similar designs but possibly at other reactors too, we have not addressed that issue ourselves.
I do not believe that the internal flooding sequences under discussion have been adequately analyzed either deterministically or probabilistically.
It is possible, in fact, that Shoreham contains features not yet uncovered that would compound the severity of a minor internal flooding incident, turning a relatively benign event into one with severe consequences to the reactor of even to the public:
for example, there may be operator procedures, hardware, or control system features that might erroneously isolate the power conversion system upon inception of some int _ernal flooding scenarios, thereby compromising an important heat sink exactly when it is needed most.
If careful analysis reveals that these sequences pose problems not yet considered, we can think of several easy fixes that could provide added protection to the utility's investment and to the public at relatively low cost.
In any event, I believe that the issue requires additional analysis which has been beyond the scope of my own company's work for Suffolk County.
If I can be on any assistance to llRC, please do not hesitate to contact me.
Sincerely yours, 3
Robert J. Budn tz President
Enclosure:
as stated cc:
F. Jones, Suffolk County R. DeYoung, NRC/IE O
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UNITED STATES s-,
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Docket No.:
50-322 SEP 2 9 i982' '.
Mr. M. S. Pollock Vice-President - Nulear Long Island Lighting Company-175 East Old Country Road Hicksville, New York 11801
Dear Mr. Pollock:
Enclosed is a report prepared by Future Resources Associates, Inc., (FRA).
This report, which was contracted by Suffolk County as part of Suffolk County's emergency planning efforts, provides a tentative independent opinion as to the validity of the reactor accident sequence probabilities and releas'e magnitudes that are' contained in the LILCO funded SAI Shoreham prelim 4 nary draft PRA.
A concern is expressed by FRA that "one type of accident. involving internal _
flooding may lead to important plant damage states with a significantly higher probability than is calculated in the draft PRA".
FRA carefully acknowledges that its calculations are rough, that it has not quantified the risks, and has not done a complete analysis related to internal flooding.
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In view of the concerns expressed by FRA, we are requesting that LILCO prvide us with the following evaluations and position within 45 days of receipt of this letter.
1.
An evaluation of the findings concerning the alleged changes in the dominant sequences.
2.
An evaluation of the potential, bo.th probablistically and determi-nistically, for nificant safety-related local flooding at level 8 due to accide,n 1 opening and then lack of rapid closure of an l
isolation, valve ring maintenance.
Information already on th'e Shoreham docket including source water inventories, level 8 floodable volume (in gallons per vertical foot), flooding rates, levels of safety-related equipment, and response times assumed for corrective actions may be l
I included by explicit reference.
3 ~. Develop a position regarding any possible design or equipment changes proposed because of these evaluations.
l Your submitted material will be reviewed by the staff us'ing the Standard Review Plan Criteria as part of its continuing safety review of the Shoreham facility.
The probablistic aspects will also be eval,uated by the staff during its review l
of the Shoreham PRA.
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, Utrector 1s nn l
Division of Licensing Office of Nuclear Reactor Regulation
Enclosure:
As stated yeenextpage M
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