ML20038D068

Forwards Responses to NRC Concerns Re NUREG-0737 Items II-B.3 (post-accident Sampling) & II.F.1 (Suppression Pool Water Level) & to Question 8 (Fire Detection Devices) & Evaluation of License Condition 10 (Util Organization)

ML20038D068
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/11/1981
From:	James Smith LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20038D069	List: ML20038D068 ML20038D083
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM SNRC-643, NUDOCS 8112160036
Download: ML20038D068 (6)

Text

'

t LONG ISLAND LIGHTING COM PANY gufzgw SHOREHAM NUCLEAR POWER STATION P.O. DOX 618, NORTH COUNTRY ROAD e WADING RIVER. N.Y.11792 December 11, 1981 SNEC-643

1. A Mr. Harold R. Denton, Director (( ((' N' Office of Nuclear Reactor Regulation y eL -

U.S. Nuclear Regulatory Commission Ej OEC] 4 gOI* 7 Washington, DC 20555 - u. a. ,%,,

Q. %ss ,L*W Shoreham DocketNuclear No. 50-322 Power Station -2 Unit $r# 's s s

Dear Mr. Denton:

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Enclosed please find sixty (60) copies of items in response to NRC concerns. These items are listed in Attachment 1, which, in order to facilitate your review, includes the cite where these concerns are referenced.

Also included is a revised response to Question No. 8 to the FHAR which was previously submitted by letter SNRC-344 dated 12/11/78. This response has been revised to indicate that ad-ditional fire detectors have been added in accordance with prior discussions with your Staff and that the system has been approved by ANI.

On a separate note, LILCO has evaluated License Condition No. 10,

" Organizational Structure of Applicant"; specifically, section 12.1.3.1 of SSER No. 1. The Training Coordinator position in NOSD Nuclear Training sectionl/ will serve the function of LILCO's training supervisor. That responsibility will include the over-all training coordination of all contract and management person-nel associated with Shoreham. The position will be filled prior to fuel load, thus placing LILCO in compliance with this part of the SSER license condition.

The second aspect of this license condition calls for replace-ment of the contract training instructors within six months fol-lowing issuance of the License. LILCO does not commit to re-placing these individuals, but does agree to increase the current QO$ Y b! Refer to SSER No. 1 ( NU REG-04 2 0 ) , page 13-5.

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8112160036 811211' PDR ADOCK 05000322 F PDR F C-8 93 5

4 Mr. Harold R. Denton December 11, 1981 Page 2 number of training instructors with qualified LILCO training personnel. LILCO believes this approach is prudent and con-servative in that the training staff will be directly increased by the addition of the LILCO training instructors to the existing complement. This program will be implemented by the required date.

If you require clarification or further information, please contact this office.

Very truly yours, s- jl - -

/ ~ G<fio u J. L. Smith Manager Special Projects Shoreham Nuclear Power Station RWG:pg Enclosure

Question 8 (Section 1, Position E12) :

Provide the technical basis, supported where necessary by test data, which substantiates that the sensitivity of fire detection devices, the number and placement of detectors are sufficient to provide detector response in time to prevent loss of safety related systems or components. The analysis should include both fire detection used to notify personnel and those used to activate fire protection systems.

Response

The fire detection and actuation detectors are UL listed.

Prototypes of detectors are tested in accordance with the standard for detectors: UL 167 (ionization detectors) and OL 168 (photoelectric). Each detector is tested at the factory for UL sensitivity tests before shipment. The in-place acceptance test of the individual detectors (smoke and temperature) will be performed under the direction of and with results approved by the authority having juris-diction (ANI). All procedures to be used for acceptance test are approved by ANI.

The type, number and placement along with the technical re-quirements for detectors is described in the Fire Hazards Analysis Report (FHAR) Tables 1 through 6 and Section lE.

Additional detectors have been added as described in re-sponse to FHAR Questions 17 and 23. The FHAR is being re-vised to include these additional detectors.

The placement of detectors has been approved by ANI as the authoricy having jurisdiction under NFPA~72E.

December 1981

NUREG-0737 Item II.B.3 - Post Accident Sampling - Boron Analysis Capability J

In the event of a transient' coupled with a CRD system failure requiring the injection-of boron into the reactor vessel, Shoreham will be able to measure boron concentration as per the requirements of both NUREG-0737 and_ Regulatory Guide 1.97.

This measurement will be done by equipment positioned in-line and located within the protective confines of the Post Acci-dent Sampling Facility.

If the in-line boron anaiyzer should fail at the same_ time as this series of events occurs requiring boronJinjection, and should these events cause excessive fuel damage resulting in samples having T.I.D. 14844 derived radiation sources, Shoreham is capable of analyzing a diluted (600:1)' grab sample for boron concentration on-site within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the-event. Such a sample will be 100 R/hr on contact and-will require. working at a distance of'approximately 1/2 meter (.04 R/hr - with no shielding).

J-l _It is LILCO's position that such a scenario is extremely un-likely. It is expected that boron injection will result _in.a subcritical condition without fuel damage thereby enabling a standard backup analysis for. boron concentration on a low ac-tivity level coolant _ sample within the normal plant laboratory facility.

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t December 10, 1981

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Additional Information TMI Item II.F.1 - Attachment 5 Suppression Pool Water Level 1/

LILCO has committed "to installing redundant Suppression Pool Water level measurement capability utilizing a bubbler system.

The NRC has requested design details of the level measurement system. The following provides such details of the proposed system.

Bubbler System for Suppression Pool Level Measurement The principal component of the bubbler system (shown in Fig.

II.F.1-2) is the flow regulator. This regulator will maintain a constant minimal flow ( Rf l0 cc/ min)- of inert gas through the instrument line exiting at el 12-0 (this exit point of the gas is subject to change pending further evaluation to assure minimum turbulence at the point of. exit). The theory of operation of the bubbler system is backpressure control; i.e., as the water level in the Suppression Pool rises, the back pressure on the flow regulator increases and the regulator must compensate by increasing the downstream pressure'necessary to overcome the increase in head.

This increase in pressure is sensed at the o P transmitter and is directly proportional to the rise in suppression pool level. The action of the flow regulator is reversed on decreasing pool level.

The inert gas supply for this instrument is from the existing Category I nitrogen distribution and accumulator system for ~

gas-operated valves inside containment. A pressure regulator is provided for the nitrogen supply. The pressure regulator setpoint is adjusted to overcome the head of liquid in the pool, the maximum suppression pool chamber pressure, and the line friction.

Following calibration adjustments, the accuracy of the transmitted signal will be equal to the sum of the transmitter .

accuracy and the accuracy of the level instrumentation used to make the final zero adjustment. Based on the above the accuracy _

of the transmitted signal.will be between one and two percent.

The response time will be somewhat longer than a conventional level measu'rement and will ne dependent on the gain of the flow regulator. Two separate and redudant Category I-water level measurement systems will be installed, supplementing the existing suppression pool level instrumentation.

Implementation of these instrumentation systems will be made by fuel' load contingent upon commercial availability and a suitable construction window.

1/ See SNRC-624 dated 8/13/81 December 10, 1981

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