ML20030D760
| ML20030D760 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/31/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Pollock M LONG ISLAND LIGHTING CO. |
| References | |
| NUDOCS 8109160147 | |
| Download: ML20030D760 (4) | |
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..l11 Mr. H. S. Pollock 4
Vice President - Huclear tu Long Islaw) Lighting Cmpany 175 East Old Country Road dicksville, new York liffl Cear IIr. Pollock:
SU3 JECT:
STAFF POSIT 1GNS - SHOREHN1 !:UCLEAR POWER STATICH During our review of LILC0's application for an operating license for the Shoreha, Nuclear Pome Station, we developed staff oositions on several issues.
These issues nust be resolved prior to issuance of an operating license. A discussion of our positions are presented below.
The first issue is iten II.B.3 fran HUilEG-0737, " Clarification of TMI Action Plan Re qui reqents."
We reviewed LILCO's letters of May 15, July 23, and July 31, 1981, which describe your prnposal to meet the require 1ents of 11.B.3.
He found that these submittals did not provide sufficient infornation to de,onstrate tnat the reactor coolant and suppression chamber sanples are representative, to provide d procedure for relating radionuClide Concentratinns to fuel da'tage, and to provide operational capability of the post-accident sampling system with loss of of f-si te po 6e r. Our specific concerns in these areas are as follows:
1.
That the reactor coolant liquid sanp'le whicli is taken from the jet ptnp diffuser will be diluted to an uncertain degree Sy the reactor coolant system makeup water source. This condition occurs when low voluaes of steam are being generated which significatly reduces the amount of uoisture which leaves the core and is subsequently returned to the downcomer via the moisture Leparators.
This condition can result in the samples being analyzed at lower concentratinas of soluble species (chloride, boron, iodine, etc.) than are actually present in the core area, and thus provide an imprecise estimate of the core driage.
2.
That the suppression chanber triples, due to the location of the sa'1ple points relative to reactor coolant system safety valve discharge points, will either be excessively diluted or virtually undiluted resulting in erroneous estimates of core damage. We require the applicant to provide information to demonstrate to our satisfaction that these sartple points are located such that adequate mixing will occur and the smples are representative of the mixture rather than only the discharged fluid, o.ma p
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That an acceptable procedure be provided to relate specific radienJclide concantrations to the estiniated extent of core dalage.
4.
Ihat all electrically powered cmiponents associated with post-accident sampling are capable of being su;) plied with poier and operated within thirty minutes of an accident in which there is core degradation, or supplied with pomr at some time creater than thirty minutes af ter an accident so that a sa:iple can be taken and analyzed within three hours of an accident,
'asu' ting loss of offsite power.
The next issue involves our review of the Per. tote Shutdown System at Shoreham.
In the cient Gf loss of habitability of the control roon for reasons other thin fire, are Concerned that randon single faiieres in the instrunents and controis of wd systms controlled fron the remote panel or in the systens thenselves may prevent attaininq celd or hot shutdown from the renote shutdown panel.
It is our position that you denanstrate a cipability to attain and naintain hot shutdom and subsequently cold shutdown frm1 outside the control room, assuming a single fa119ee in the systels required for affectinq safe shutdown. Offsite pomr should be assunted to be unavailable.
Your response to thi. issue should address the following specific require 1ents.
These requireuents nost be met in order to demonstrate compliance with 10 CFR Part 50, Appendix A (GDC-19). Appendix K, and Appendix R.
- 1) The design should provide redundant safety grade capability to achieve and maintain hot shutdown from a location (s) remote from the coatrol roon, assuming no fire danage to any required systems and equipment and assuning no accident has occurred Credit may be taken for manual actuation (exclusive of continuous control) 0: systems fron locations that are reasonably accessible from the Remote Shutdom Panel. Credit nay not be taken for manual actions involving jtripering, rewiring or disconnecting circuits.
- 2) The design should provide redundant safety grarie capability for attaining subsequent cold shutdom through the use of suitable procedures.
- 3) The design should be such that the inanual transfer of control to the remote location (s) should not disable any autoaatic actuation of ESF functions while the plant is attaining or maintained in hot shutdown, other than where ESF features are manually placed in service to achieve or maintain hot shutdom.
It is pernissible to disable automatic t.PCI acutation in this nanner only when necessary in order to enable control of the RHR system fro 1 the remote r <ation.and while operating this system to effect cold shutdown from hot soutdown.
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Ihe design should provide, as a mintmn, non-redundant safety grade systens necessary to achieve and maintain hot shutdown from either the control room or from a reacte location (s) assuming a postulated fire in any fire area,,
including the control room or the Remote Shutdown Panel. Credit may be taken for manual actuation (exclusive of continuous control) of systems from locations that are reasonably accessible from the control room or the Remote Shutdown Panel, as a9plicable. Credit inay not be taken for manual actions involving juviring, rewiring or disconnecting circuits.
- 5) The dasign should provide, as e ainimtr.i, non-redundant safety grade systeas necessary to achieve and maintain cold shutdoun fron either the control room or from a remote location (s).
The design should be such that in the event of fire damage in any fire area, systems could he repaired or made opera 5le within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if required for cold shutdown.
The last issue involves the mininum separation criteria for electrical cables and raceways at Shorehani. LILCo was originally notified of this problem in Inspection Report 50-322/79-07 dated August 21,1979.
You commited to separation criteria for electrical equipment in Section 3.12 of the Shoreham Final Safety Analysis Re port. These criteria wre found acceptable by the NRC Staff during our current review of Shoreham. The Office of Inspection and Enforcement identified several instances where the electrical cables and raceways did not meet the separation cri teria. This failure to meet your mininum separation criteria at Shoreham has been a continuing violation as stated in 79-07 and subsequent reports from the Office of Inspection and Enforcement.
In LILCO's letter to Report T. Carlson of the Region I Office of Inspection and Enforcenent dated April 16,1980 (SNRC-471), you stated that a separation analysis was being developed to justify your policy of nct correcting the separation deficiencies at Shoreham.
In a meeting held on February 10, 1981, your represen-tatives presented the Shorehan separation analysis to menbers of the hRC staff.
Shortly after this meeting, our Shoreham project manager notified your represen-tatives that the separation analysis war aa unacceptable justification for not meeting your own minimum separation criteria at Shorehri.
It is our position that each deficiency in separation for electrical cables and raceways meet one of the following options:
1.
Correct the deficiency to meet the electrical equipment separation criteria setforth in Section J.12 of the Shorehari Final Safety Analysis Report.
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Correct the deficiency to meet Regulatory Guide 1.75, " Physical Independence of Electric Systems," Revision 2 dated September,1973.
3.
Correct the deficiency by installing an acceptable barrier.
4.
Justify the deficiency by per#cr. ling a specific analysis for each cable or raceway whera the r11nimun separation is not net to deconstrate that a failure will not propagate because of the insufficient separation.
I encourage ycu to give your personal attcntion to each of these natters so that they may be resolved expeditously.
Sincerely.
OriginalWgned D Robert L. Tedesco, Assistant Director for Licensing Division of Licensing cc:
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a Mr.
H. S. Pollock Vice President - Nuclear Lono Island 'inhtina comoany David Gilmartin, Esq.
175 East 010 Country Road Suffolk County Attorney Hicksville, New York 11801 County Executive / Legislative Bldg.
Veteran's Menorial Highway Haupoauge, New York 11788 cc:
Howard L. Blau, Esa.
MGB Technical Associates Blau and Cohn, P. C.
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1723 Hamilton Avenue - Suite K 217 Newbridae Road San Jose, California 95125 Hicksville, New York 11801 Stephen Latham, Esq.
Jeffrey Cohen, Esa.
Twomey, Latham & Schmitt Genuty Commissioner and Counsel P. O. Box 398 New York State Energ~y Office 33 West Second Street Agency Buildina 2 Riverhead, New York 11901 EmDire State Plaza Albany, New York 12223 Joel Blau, Esauire New York Public Service Commission Energy Research Group,.Inc.
The Governor Nelson A. Rockefeller Bldg.
4n0-1 Totten Pond Road Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 R. R. McCaffrey Ezra I. Bialik Shoreham Nuclear Power Station Assistant Attorney General P. O. Box 618 Environmental Protection Bureau Madinn River, New York 11792 New York State Department of Law 2 World Trade Center
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New York, New York 10047 Hunton 1 Milliams P. O. Box 1515 Richmond, Viroinia 23212 Ralph Shaniro, Esc.
Cammer & Shaoiro O East 4 nth Street New York, New York 10016 Jeffrev Futter Long Island Lichting Company 250 Old Country Road "ineola, New York 11501 Desident Inspector /Shoreham NPS c/o II.S. Nuclear Regulatory Conmission D. O. Box B Rocky Doint, New York 11778 Honorable Deter Cohalan Suffolk Countv Executive County Executive /Leaislative Buildina Veteran's Memorial Hiohway Haunnaune, New York 117R9