ML20041C338

Interrogatories Directed to Shoreham Opponents Coalition & Suffolk County.Certificate of Svc Encl

ML20041C338
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/23/1982
From:	Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SHOREHAM OPPONENTS COALITION, SUFFOLK COUNTY, NY
References
NUDOCS 8203010184
Download: ML20041C338 (17)

Text

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c A February-23, 1982

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" krf$$"s 5 ire 4D 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 ) Docket Pa. 50-322

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(Shoreham Nuclear Power Station, )

Unit 1) )

INTERROGATORIES TO SHOREHAM OPPONENTS COALITION AND SUFFOLK COUNTY The parties are directed to pursue all remaining discovery of information presently available (for. all contentions not. objected to) prior to the conference of parties (to be held on March 9-10, 1982].

Board Memorandum and Order of February 8, 1992, at 6.

"All contentions not objected to" include those set out in Part I of the joi3t LILCO/ Staff Consolidated Statement of i

Contentions, dated February 18, 1982, plus those portions of the following suffolk County contentions to which no objections were taken: SC 13, 16, 18 and 22.

Discovery in this proceeding began on October 11, 1977.

Since then, it has involved much resort to formal interroga-tories, motions for protective orders, motions to compel, i

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responsive Board rulings and so forth. It has also involved, far more productively, a great deal of informal discussion and exchange of information among the parties.

The following questions are directed to the Shoreham Opponents Coalition (SOC), beginning on page 2, and Suffolk County '(SC or County), beginning on page 9. They are filed pursuant to 10 CFR S 2.740(b). Although these questions are formally submitted, they are not meant to be the burdensome sort of interrogatories that have characterized most formal discovery conducted previously in this proceeding. Rather, they have been limited to matters quite important to our under-standing of the SOC and County concerns.

QUEST 10HS TO SOC SOC 7.A(1)

1. Don't SER, NUREG-0420, Supp. No. 1, at 22-84 and NEDO-24951 (June 1981) resolve SOC's concern?

2. If not, precisely (a) what issue remains, and (b) why does it remain?

3. If not, define what SOC means by " conditions" in line 10 of the contention and "all plant conditions" la line 13?

SOC 7.A(2)(a)

4. Shouldn't the second sentence of this subpart be rewritten to state:

The SRV pressure and temperature indica-tors and the annunciator are not located in a manner consistent with reliable and safe operation?

5. Is the contention based solely on Findings 7.3, 7.6 and 7.7 of the NRC Control Room Design Audit?

5. If the answer to question 5 is other than an un-qualified yes, specify (a) how the pressure and temperature indicators and the annunciator's locations are not consistent with reliable and safe operation, and (b) the source documents relied upon for support of the contention.

7. Doesn't SNRC-605 (July 23, 1981) resolve the con-cern about the annunciator's location?

SOC 7.A(2)(b)

8. What is the basis for SOC's conclusion that Shoreham's computer is of " low reliability"?

9. Explain why SOC thinks Shoreham's computer would be

" overloaded" as the result of a major accident?

10. What exactly does SOC mean by " timely information"?

11. Precisely (a) what " computer printout is not readi-ly visible," and (b) where does SOC think the computer printout should be located?

SOC 7.A(3)

12. Which iodine monitors does SOC contend are inacces-sible?

13. Where does 300 think these monitors should be lo-cated?

14. Which iodine monitors does SOC contend must be powered by " vital bus power"?

15. Why does SOC believe that Item II.F.1 of NUREG-0737 requires " vital bus power"?

SOC 7.A(1)

16. Why does SOC think that GDC 13 requires a Safety Parameter Display Console?

17. Why does SOC think that Item I.O.2 of NUREG-0737 requires a " safety-related" computer system?

. . . - -. . . ~ . - - - _ . . . . . --

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18. Define exactly what SOC means by "high reliability" i in line 3 of the contention.

19. Please confirm that the term " safety-related" as used in line 5 of the contention refers to equipment that must meet Class IE requirements.

i SOC 7.A(5)

20. Doesn't SNRC-647 (Dec. 9,-1981) resolve the concern 4

stated in the first sentence of this contention?

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21. If not, precisely (a) what issue remains, and (b) why does it remain?

22. List all " worst case conditions" SOC refers to in i

lines 5 to 6 of the contention.

23. Why does SOC think that Item II.D.1 of NUREG-0737 requires testing SRV's for ATWS?

24. By what date does SOC think the SRV testing for

ATWS must be completed?

SOC 7.A(6)

25. Isn't this concern resolved by the fact that Shoreham has 2-stage valves, coupled with the procedures

, adopted by the BNR Owners for the " Reduction of Challenges and Failures of Relief Valves" (March 31, 1981)?

26. If not, precisely (a) what issue remains, and (b) why does it remain?

27. If not, state the basis for SOC's belief that "the reliability of [SRV's like Shoreham's] has been historically

poor."

l SOC 9(a)

28. Shouldn't "RSSWS" be "RBSVS" -- "V" standing'for

" Ventilation"?

l i

I i

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SOC 9(b) i

29. Is SOC's concern limited to the primary contain-

, ment? If not, define (a) the precise portions of the system in which SOC has an interest and (b) their location in the plant.

SOC 9(c)

30. Is the " inadequate indication" in the main control room or at the RSP itself?

31. Is SOC concerned about (a) the " systems and power ources" on the RSP or on something else? (b) Specify exactly (i) what-systems and power sources and (ii) their locations if other than the RSP.

I j SOC 16

32. Identify for the introduction and each subpart of this contention, any documentary evidence supporting SOC's claims, as well as any other basis for them.

SOC 16(a)(i)

33. Please confirm that " peak centerline temperature" j should be " peak clad temperature"?

SOC 16(a)(iii)  ;

! 34. Specify (a) why SOC thinks the analysis is "incom-plete," and (b) what further analysis is necessary, i SOC 16(a)(iv)

35. (a) Quantify what 300 .neans by "a large degree of uncertainty," and (b) provide the basis for the quantification.

SOC 16(a)(v) j 36. Identify the "new thermal-hydraulic models."

j SOC 16(a)(vii) i 37. (a) Identify what SOC means by "the base case flow l blockage," and (b) provide the basis for whatever definition

! SOC has in min 3.

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38. (a) Identify "some of the cases analyzed" referred to, and (b) provide the basis for the identifica'-ion.

J SOC 19(a) and 19(a)(1)

39. How do Regulatory Guides 1.2 and 1.150 relate to

"the design" of the Shoreham presauce vessel and vessel noz-i zles?

40. What requirements does Regulatory Guide 1.150 impose as to quality control of the ultrasonic testing equip-ment and transducers?

4 SOC 19(a)(2) i 41. What requirement does Regulatory Guide 1.150 con-tain as to "UT examination travel time"?

1 SOC-19(a)(3)

42. What ALARA requirements are contained in Regulatory Guides 1.2 and 1.150?

SOC 19(b)(1) 4

43. What requirements of Revision 3-to Regulatory Guide i 1.26 does SOC think are not complied with?

44. Precisely what safety-related components have not been properly classified?

45. Does SOC agree that Shoreham meets Revision 1 to i Regulatory Guide 1.26?

SOC 19(b)(2)

46. What specific " radioactive waste systems" is SOC referring to?

! 47. Precisely why does SOC think that control room

! habitability and radioactive waste systems do not meet Revision 3 to Regulatory Guide 1.29?

SOC 19(b)(3)

48. Haven't SOC's concerns been resolved by amendment of Table 3.2.1-1 in Revision 23 to the FSAR (Oct. 1981)?

_. _ ._ _ _ .-_._ _ _ _ ._. _ . _ _ _ _ . _- ~_ _. _ _

49. If not, (a) precisely what else does SCC think be-longs on the list, and (b) why?

SOC 19(b)(4)

50. What specific equipment that plant operators will rely on "in response to accidents outlined in the Shoreham Emergency Operating Procedures" is not contained in FSAR Table 3.2.1-l?

SOC 19(c) l 51. (a) what requirement does SOC think Revision 3 imposes "with regard to delta ferrite content of filler mate-

rials and to examination for ferrite content by a magnetic mea-suring instrument" that Revision 1 does not, and (b) what safety significance for Shoreham does any such difference in requirements have?

i SOC 19(d)(1)

52. What portions of the reactor recirculation system does SOC think do not meet "the guidelines set forth in NUREG-0313, Revision 1"?

t 1

SOC 19(d)(2) a

53. What " inlet lines at the safe-end curves" is SOC referring to?

SOC 19(d)(3)

54. Please explain what is meant be "[t] he limiting conditions for leakage . . . has not been demonstrated." What has not-been demonstrated? Please explain why SOC thinks the leak detection system may not enhance discovery of unidentified leakage.

SOC 19(f)

55. (a) At what plants and (b) in what sorts of uses have " General Electric containment electrical penetrations" experienced cracking and peeling of the epoxy filler? (c)

Identify all documentary evidence, if any, so indicating.

56. '4h a t is SOC's basis, including documents, for as-i suming that the same failure of the electrical penetrations l

would occur at Shoreham?

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57. Precisely (a) what aspects of Revision 2 of Regulatory Guide'l.63 have not been met at Shoreham, in SOC's opinion, and (b) what is the safety significance of any such noncompliance?

58. SOC's consultants, MHB Technical Associates, have indicated a personal knowledge of deficiencies relating to con-tainment electrical penetrations. To the extent not answered in response to questions 55 to 57 above, please set out all the facts and supporting documentation that SOC intends to use to support this contention.

SOC 19(g)

59. Precisely (a) what aspects of Revision 2 of Regulatory Guide 1.75 have not been met at Shoreham, in. SOC's opinion, and (b) what is the safety significance of any such noncompliance?

SOC 19(h)

60. In light of the " Environmental Qualification Report for Class IE Equipment for 5NPS-Unit 1," Revision 1 (Jan. 15, 1982), precisely:

(a) How are the proposed test conditions "not sufficiently ccnservative"?

(b) What equipment "has been qualified by grandfathering to older, less strin-gent standards"?

(c) In what way is the list of emergency operating equipment to be qualified "in-adequate"?

(d) What safety-related equipment has not been properly qualified to meet

" aging and other life requirements," and

' (e) What additional information does SOC need to evaluate LILCO's qualification j

program?

! 61. (a) Would Shoreham's compliance with NUREG-0588 4

resolve SOC's concerns about Regulatory Guide 1.39? (b) If not, set out the reasons why.

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SOC 19(i)

62. Doesn't Attachment I to SNRC-535 (March 5, 1981) show that Shoreham satisfies Regulatory Guide 1.100?

53. If not, precisely (a) what asp? cts of Regulatory Guide 1.100 have not been met at Shoreham, in SOC's opinion, and (b) what is the safety significance of any such noncom-pliance?

SOC 19(i)

64. What does SOC suggest be done to remedy the "unfa-vorable" turbine orientation?

QUESTIONS TO SUFFOLK COUNTY SC 1

1. Exactly how does SC think the " instrumentation" and

" controls" for the specified systems are " inadequate," focusing on each affected instrument and control and its alleged inca-pacity.

2. As to each inadequacy identified in response to Question 1, what remedy does SC propose?

SC 2

3. If LILCO takes the steps set out in Section III.I.

(Diesel Generator Relay Reliability) of the abortive County-LILCO Settlement, will that resolve this concern?

4. If not, state precisely (a) what other steps the County thinks are important to safety, and (b) why they're important.

SC 4

5. If LILCO takes the steps set out in Section III.L (Water Hammer) of the abortive County-LILCO Settlement, will that resolve this concern?

6. If not, state precisely (a) what other steps the County thinks are important to safety, and (b) why they're important.

SC 5

7. If LILCO takes the steps set out in Section III.N (Loose Parts Monitoring) of the abortive County-LILCO Settlement, will that resolve this concern?

8. If not, state precisely (a) what other steps the County thinks are important to safety, and (b) why they're important.

SC 3

9. Please answer Questions 60(a)-(e) and 61 on page 8 above, concerning SOC Contention 19(h).

SC 10

10. Define exactly what SC means by " counter current flow."

11. How does countar current flow, as defined in re-sponse to Question 10, affect " core spray distribution"?

12. Isn't it "3N-81-49," not "BN-31-29"?

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3C 11

13. (a) Define exactly which type of " valves" (e.g.,

manual, air-operated, check) SC is talking about, and (b) ex-plain precisely why the County believes that a problem may exist at Shoreham with such valves.

SC 13(a)

14. List each significant aspect of QA compliance that SC believes is (a) not addressed at all, or (b) addressed in too little detail to be meaningful.

SC 13(b)

15. List (a) each significant element that must be ad-dressed in an " adequate" provision for the processes in ques-tion; and (b) explain why.

SC 13(c)

16. List (a) each significant element that must be ad-dressed in an "adequata" provision for the processes in question, and (b) explain why.

SC 13(d)

17. (a) Quantify an " adequate number" (i) on shift and

(ii) off shift, and (b) provide the basis for the numbers cho-sen.

SC 14(a)

18. Identify (a) each " root cause" that the County thinks has gone uncorrected at Shoreham, and (b) specify each occasion on which SC believes that each such root cause has i been left to linger while " symptoms" alone were treated. (c)

List all documentary evidence that SC has to support its con-clusions.

, SC 14(c)

19. Define concretely (a) the " baseline criteria" that the County thinks should be used, and (b) "the means [that SC thinks should be adopted] of determining improvements in, or the effectiveness of, corrections."

SC 15 4

20. (a) Quantify "sufficiently detailed to provide sta-tistically valid data," and (b) set out the basis for the quan-tification.

SC 16

21. (a) What specific changes in Shoreham's equipment I

and/or procedures does the County want; (b) why would each such change enhance Shoreham's safety; and (c) what NRC regulation calls for it?

SC 17

22. If LILCO takes the steps set out in Section III.J.

(Fire Protection) of the abortive County-LILCO Settlement, will that resolve this concern?

23. If not, state precisely (a) what other steps the County thinks are important to safety, and (b) why they're

important.

i

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- , , . _ -m. ,- - - - . _ , , _ - - . - - . - . . . - _ - - - --- . _ , . . . . , . - . - . -.

1 SC 18(b)

' 24. What is the safety significance of knowing why an annuciator is lit.

SC 18(d)

25. Please aswer Questions 8-11 on page 3 above, con-cerning SOC Contention 7.A(2).

SC 19(a)

26. List each procedure by title and number that the County thinks (a) is inconsistent with the " training program" and/or (b) not " plant-specific."

SC 19(b)

27. List each procedure by title and number that the County thinks deals with " station blackout, shift turnover, operation in protective clothing or equipment," and " knowledge of shutdown system operability."

28. Explain why each of the procedures identified in response to Question 27 is " inadequate."

SC 19(c)

29. Identify (a) each instance in which the County thinks the " human factors implications of responding to emer-gency procedures have not been adequately checked," and (b) explain the basis for each such conclusion.

SC 19(d)

30. List the procedures by title and number that the County thinks "are keyed to annunciators."

SC 21(a)-(e)

31. In light of Shoreham's Design Analysis Report, Revision 5 (December 16, 1981), which was sent to the County on i (January 15, 1982), which of the concerns set out in subparts (a) to (e) of this contention remain,.if any?

32. If any remain, as to each, why does the County think that it has safety significance?

SC 21(c)

33. Identify any documentary evidence known to the County that supports this claim.

SC 23

34. What is the basis for the claim that " [vl alve con-figuration and functionability relating to leak rate and inter-system leakage testing have not been sufficiently demon-strated"?

35. Precisely which valves and penetrations are of con-cern?

SC 24(b)

36. Identify the " analytical evidence" referenced in the second sentence of this contention.

SC 25

37. Identify all of the documentary evidence, if any, that the County has to support the claims made in this conten-tion.

38. Precisely what exemptions from ASME XI inspection requirements does the County think that Shoreham (a) already has or (b) will seek?

39. Explain why the PSI results for the reactor pres-

, sure boundary do not provide an adequate baseline to which the ISI results can be correlated?

SC 26(a)(i)

40. In what relevant areas does the County think " low cobalt materials" were not used?

SC 26(a)(ii)

41. Precisely identify the "various components and pip-ing systems" that the County has in mind.

l SC 26(a)(iii)

42. Precisely identify (a) which " provisions for flush-

ing or decontamination" of (b) what aspects of Shoreham.

.. - . - . _ _ . - - ~ . .

SC 26(a)(iv)

43. Precisely identify the County's " equipment layout

, and arrangement" concerns.

SC 26(a)(v)

, 44. (a) Quantify the " minimum number.of shell connec-

tions" referenced in the contention, and (b) explain why Shoreham's actual number of shell connections poses a problem.

SC 26(b)(i)-(iii)

45. For each of subparts (i)-(iii), (a) itemize the essential elements of procedures that the County would find acceptable, and (b) explain the basis for each such element.

SC 28(a)(i)

46. Please answer Questions 1-3 on page 2 above, re-garding SOC Contention 7.A(1).

SC 28(a)(ii)

47. Please answer Questions 4-11 on page 3 above, re-j garding SOC Contention 7.A(2).

l SC 29(a)(iii)

48. Please answer Questions 12-15 on page 3 above, regarding SOC Contention 7.A(3).

SC 28(a)(iv)

49. Please answer Questions 16-19 on pages 3 and 4 above, regarding SOC Contention 7.A(4).

j SC 28(a)(v)

50. Please answer Questions 20-24 on page 4 above, re-garding SOC Contention 7.A(5).

SC 28(a)(vi) i l 51. Please answer Questions 25-27 on page 4 above, re-j garding SOC Contention 7.A(6).

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SC 31

52. Please answer Question 59 on page 8 above, regard-ing SOC Contention 19(g).

Respectfully submitted, LONG ISLAND LIGHTING CO'iPANY

_ O -

W.L Taylor fveleyf III Anthony F. Earley, Jr.

Daniel O. Flanagan Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: February 23, 1982

00tgETp m.s e2 Fco 25 PI OU In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

CERTIFICATE OF SERVICE I hereby certify that copies of INTERROGATORIES TO SHOREHAM'S OPPONENT COALITION AND SUFFOLK COUNTY were served upon the following either by Federal Express (indicated by an asterisk) or by first-class mail, postage prepaid, on February 23, 1982:

Lawrence Brenner, Esq. Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Mr. Frederick T. Shon U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U. S. Nuclear Regulatory Bernard M. Bordenick, Esq.

Commission David A. Repka, Esq.

Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.*

Board Panel Attn: Patricia A. Dempsey, Esq.

U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787

s c *. .

l Secretary of the Commission Mr. Mark W. Goldsmith U.S. Nuclear Regulatory Energy Research Group, Inc.

Commission 400-1 Totten Pond Road Washington, D.C. 20555 Waltham, Massachusetts 02154 MHB Technical Associates Howard L. Blau, Esq.

1723 Hamilton Avenue 217 Newbridge Road suite K Hicksville, New York 11801 San Jose, California 95125 Jeffrey C. Cohen, Esq.

Stephen B. Latham, Esq.* New York State Energy Office Twomey, Latham & Schmitt Swan Street Building, Core 1 33 West Second Street Empire State Plaza P. O. Box 398 Albany, New York 12223 Riverhead, New York 11901 Mr. Jay Dunkleberger Ralph Shapiro, Esq. New York State Energy Office Cammer and Shapiro, P.C. Agency Building 2 9 East 40th Street Empire State Plaza New York, New York 10016 Albany, New York 12223 b

Daniel O.

DMWe$

Flanagan 2 W

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 23, 1982