ML20041E073

Interrogatories Directed to Util.Related Correspondence

ML20041E073
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/05/1982
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
ISSUANCES-OL, NUDOCS 8203100102
Download: ML20041E073 (29)

Text

~

D f -

WMESPO,g *

!9 RECEt4CC

-~ M) UNITED STATES OF AMERICA g MAR 091982b 1 NUCLEAR REGULATORY COMMISSION

~^ . - .

N meu usuen pungs

• ENEBI kamuni a: *8 $ W DDc

. EFORE THE ATOMIC SAFETY AND LICENSING BO N RECEIVED e- 3

) _: MAR 091982 m- :7 In the Matter of ) { 88Q8gy O

) sc LONG ISLAND LIGHTING COMPANY ) 7

) Docket No. 50-3 ,

(3horeham Nuclear Power ) ,

Station, Unit 1) I o

SUFFOLK COUNTY INTERROGATORIES -

TO LONG ISLAND LIGHTING COMPANY

Pursuant to 10 CFR $ 2.740b, LILCO is requested by Suffolk County to answer separately and fully, under oath, each of the interrogatories set forth below, within fourteen (14) days after service hereof. These interrogatories pertain to Suffolk County Contentions 1-5, 8-10, and 17. Interrogatories regarding the remaining Contentions will be filed shortly.

DEFINITIONS AND INSTRUCTIONS FOR ANSWERING INTERROGATORIES A. Wherever appropriate, the singular form of a word shall be interpreted as plural and vice versa.

B. "And" as well as "or" shall be construed either dis-junctively or conjunctively as necessary to bring within the scope hereof any information (as defined herein) which might otherwise be construed to be outside the scope of these discovery requests.

C. Wherever appropriate, the masculine form of a word shall be interpreted as feminine and vice versa.

8203100102 820305 PDR ADOCK 05000322 {

G PDR

~ '

~

D. The term " person" includes any natural person, firm, partnership, educational institution, joint venture, gorporation, and any foreign or domestic government organization (including military and civilian), or group of natural persons or such enti-ties.

E. The term "information" shall be expansively construed and shall include, but not be limited to, facts, data, theories, analyses, opinions, images, impressions, concepts and fo rmulae.

F. The term " document" means any tangible thing from or on which information can be stored, recorded, processed, transmit-ted, inscribed, or memorialized in any way by any means regard-less of technology or form and including but not being limited to: papers, books, accounts, newspaper and magazine articles, letters, photographs, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, drawings, blueprints, plans, specifications, manuals, procedures, transcripts, minutes, reports and recordings of telephone or other conversations, or of interviews, or of conferences, or of other meetings, occurrences, or transactions, a f fidavits, transcripts of depositions or hearings, statements, summaries, opinions, reports, tests, experiments, analyses, evaluations, contracts, agreements, ledgers, journals, books or records of account, receipts, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound

l. recordings, computer printouts, data processing input and output, microfilms, all other records kept by electronic, photographic or mechanical means, and things similar to any of the foregoing.

~ .

Each copy of a document which contains any separate notations or writings thereon, and each draft of a document which differs in any way from the final version of the document, shall be deemed to be a separate document for purposes of these discovery requests. [ Versions of a document which differ in clearly non-substantive and unimportant ways from other versions of the document do not need to be considered a separate document.]

G. The term " communication" includes every exchange of information by any means.

H. The term "LILCO," "you," or "LILCO personnel" means Long Island Lighting Company, and any affiliate, agent, employee, consultant, contractor, technical advisor, representative (including, without limitation, attorneys and accountants and their respective agents and employees), or other person acting for or on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.

I. The term "Shoreham" means the Shoreham Nuclear Power Station, Unit 1, any part thareof, or any structure, system, component, instrumentation, equipment, or materials included in, or intended to be included in Shoreham.

J. The term " contractor" means any person, not affiliated l

i with LILCO, who performed work relating to Shoreham, on behalf of LILCO and/or pursuant to a contract with LILCO. The term

" subcontractor" means any person, not affiliated with LILCO, who l

performed work at any kind relating to Shoreham, on behalf of a contractor with whom the person was not affiliated, and pursuant to a contract with such contractor. A person other than a l

l

contractor who contracts with a subcontractor shall be deemed a subcontractor.

K. The words "concerning," " concerns," or any other deriv-ative thereof, include referring to, responding to, relating to, pertaining to, connected with, comprising, memorializing, com-menting on, regarding, discussing, showing, describing, reflect-ing, analyzing, supporting, contradicting and constituting.

L. Whenever in the interrogatories there is a request to identify a person that is a natural person, set forth:

(1) his name; (2) his last known residence address; (3) his last known business address; (4) his last known employer; (5) his title or position; (6) his areas of responsibility; (7) his business, professional, or other relationship with LILCO; and (8) if any of the above information has changed subse-quent to the time period referenced in a particu-lar interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time refer-enced in the interrogatory.

s M. Whenever in the interrogatories there is a request to identify a person that is not a natural person, state:

(1) the full name of such person; (2) the nature or form of such person, if known; (3) the address of its principal place of business or the principal place where such person is to be found; (4) whether LILCO has or has had any relationship or affiliation with such person, its affiliates or subsidiaries, and, if so, a description of such relationship; and (5) if any of the above information has changed subsequent to the time period referenced in a particular interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time referenced in the interrogatory.

N. Whenever in the interrogatories there is a request to identify or describe a document:

(1) set fo rth:

(a) the date of the document; (b) the type or nature of the document; (c) the length of the document; (d) the location of the document; (e) a brief description of the contents of the document; and (2) identify:

(a) the author, signatories and any other person who originated, prepared or participated in

the preparation of the document; e

(b) all persons to whom the document was addressed and all persons to whom copies of the document were to be or have been sent; and (c) all persons whom LILCO knows or believes to have possession, custody or control of the document and of any copies thereof. <

0. Whenever in the interrogatories there is a request to identify a communication:

(1) states (a) the date of the communication; (b) the place of the making and the place of

! receipt of the communication; i

(c) the type and means of communication; (d) the substance of the commanication; and (2) identify:

(a) each person making the communication, and his a

location at the time the communication was i

nade; (b) each person to whom the communication was made, and his location at the time; (c) all other persons present during, participat-ing in, or receiving the communication and the location of each such person at the time; (d) each document concerning such communication; l

and l

l . . _ . _ _ _ _ . _.. .. - . - . - _ - . . - . - - . - . - . - - -_ ._-

(e) each document upon which the communication is based or which is referred to in the communi-cation.

P. With respect to each interrogatory answer, identify sach document which forms a basis for the answer given, is relied upon or which was reviewed, in whole or in part, in preparing the answers, or which in any way corroborates or concerns the answer given. A document to be so identified may be produced in lieu of the elements of such identification. In such case, however, please identify the document in the answer to the interrogatory in sufficient detail so that Suffolk County can readily locate the document among all documents produced by LILCO.

Q. Where exact information cannot be furnished, estimated information should be supplied to the extent possible. Where estimated information is used, the answer should so state and should indicate the basis upon which the estimate was made. If possible, the upper and lower boundaries of the estimate should be given.

R. If LILCO objects to or claims a privilege (attorney-client, work product, or otherwise) with respect to any inter-roga to ry , in whole or in part, or seeks to withold documents or information because of the alleged proprietary nature of the data, set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to pe rmit the Board to determine the validity of your objection or claim of privilege. This description by LILCO should include with respect to any document: the author, addressor, addressee,

-7 -

recipients of indicated and " blind" copies, date of preparation, i

subject matter, purpose for which it was prepared, number of pages, attachments or appendices, all persons to whom distrib-

, uted, shown or explained, present custodian, all persons believed to have a copy of the document, and the nature of the privilege

) or objection asserted.

S. If any document called for herein has been destroyed, that document is to be identified as in "R" above. LILCO also is requested to state tne date of destruction, place and manner of destruction, persons authorizing destruction, and person destroying the document.

T. Information furnished in answer to an interrogatory may be furnished by reference to the answer provided for another interrogatory, provided the other referenced answer fully responds to each request for information contained in the interroga tory . Separate answers should be provided for each interrogatory and each subpart thereof, unless a complete answer to each interrogatory may best be presented through combining answers. The county is interested in this regard in receiving the relevant data asked for and any means of providing such data which is less time-consuming for the responder but which is nevertheless complete will satisfy the intent of these

! interrogatories.

U. Each interrogatory shall be construed to impose upon LILCO the continuing obligation to supplement the answer thereto

! as required by the NRC's Rules of Practice.

1 l

l V. As used herein:

(1) " Settlement Agreement" means the unexecuted Sixth Stipulation and Settlement Agreement between LILCO and Suffolk County.

(2) " Analysis" means research, investigation, audit, inspection, review, testing, monitoring, or any other method or form of examining data and/or forming conclusions or recommendations.

(3) "NRC" means the Nuclear Regulatory Commission and its staff, any division or section thereof, any staff member thereof, or any agent, consultant, contractor, technical advisor, employe e, or representative (including but not limited to attorneys and accountants and their employees and agents) of the NRC.

W. If LILCO is unable to answer any interrogatory or por-tion thereof, identify the person whom LILCO believes has the knowledge or information which the interrogatory addresses.

INTERROGATORIES Suffolk Co. Contention 1.

1. State LILCO's position with respect to Suffolk County Contention 1 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon

=

. 1 l

which LILCO relies for support of or which concern in any way its position.

2. In SP #23.133.01, Rev. O, each of the following systems is credited with only "B Loop" operation from the Remote Shutdown Panel ("RSP"):

a. RHRS (SP Section 8.1.3)

b. SWS (SP Section 8.1.6)

c. RBCLCWS (SP Section 8.1.7)

d. Reactor Recirculation Pump (SP Section 8.1.8)

Do the Shoreham Technical Specifications provide for continuous, 100 percent availability of the "B Loop" for each of the systems set forth in (a) through (d)? Identify all documents which substantiate or in any way concern the responses to each of (a) through (d).

3 At what stage of the review process is the most current revision of each of the following Shoreham Procedures

a. SP #23.133.01, " Remote Shutdown Panel Control System."

b. SP #29.022.01, " Shutdown From Outside the Control Room Emergency Procedure."

c. SP #29.010.01, " Emergency Shutdown Procedure. "

d. SP #29.015.01, " Loss of Electrical Power Emergency Procedure."

e. SP #29.101.01, " Auxiliary Boiler System."

f. SP #23.201.01, " Automatic Depressurization System."

g. SP #23.119.01, " Reactor Core Isolation Cooling System." >

h. SP #23.707.01, " Fuel Pool Cooling Sytem."

1. SP #23.122.01, " Service Water System. "

j. SP #23.118.01, "RBCLCWS."

I

k. SP #21.006.01, " Station Operator Training and Qualification Program."

4. At what stage of the review process is the most current revision of each of tha following Shoreham Alarm Procedures:

a. ARP 1051, "RSDS Transfer Switch in Emergency Position Div. I."

b. ARP 1364, "RSDS Transfer Switch in Emergency ,

Position Div. II."

c. ARP 1365, "RSDS Transfer Switch in Emergency Position Div. III."

d. ARP (LTR) "RSP Access Doors Open."

5. Identify all instrumentation located on or considered part of the RSP (indicators, alarms, etc.) and state the range displayed on each item of instrumentation.

6. On what basis have the conditions listed in FSAR i

~

Section 7.5.1.4.3, " Conditions Assumed to Exist if cne Control Room becomes Inaccessible," been determined. Identify all documents concerning such determination and upon which such determination was based.

I

7. For each of the control switches included on or considered part of the RSP (listed in Appendix 12.2 of SP l i l

23.133.01), identify the related measured variables / parameters that are also displayed on the RSP, and explain how the display correlates with the switch-controlled functions.

8. The NSAC-21 Report, " Fundamental Safety Parameter Set for BWR's, " December 1980, concludes that the fundamental parameters set forth in Table 7-1 of the Report (a copy of which is attached hereto as Attachment 1), are necessary to indicate the overull safety status of a BWR, based on the achievement of principal safety functions rather than on pre-analyzed plant events. Compare each of the parameters listed in Table 7-1 with those displayed on the Shoreham RLP, identify all discrepancies between the two, and explain the basis for LILCO 's position that each identified discrepancy is justified.

9. Identify all documents concerning any of the discrepancies identified in response to Interrogatory No. 8.

10. Identify all initiating events analyzed by or for LILCO that could cause the main control room to become inaccessible, state the relative probability of occurrence assigned by LILCO to each of such events, and identify all documents which concern your answer to this Interrogatory.

11. At what stage of the review process is the most current 1

j Shoreham Shift Turnover Procedure.

12. Describe how maintenance operations that impact operator control are designated at the RSP.

13. Explain LILCO's justification for the discrepancy between FSAR Section 7.5.1.4.5, [which states that the RSP i

procedure assumes that the Main Steam Line Isolation Valves

(MSLIV) are closed (step 4)] and SP 29.022.01, Section 3.9 [which states that the operator may choose to close or leave open the MSLIV's].

14. Identify all procedures to be followed by an operator in the event that either the Reactor Core Isolation Cooling system (RCIC) or the Residual Heat Removal system (RHR) or both 1 are in operation at the time of transfer from the main control 1

panel to the RSP.

15. Will the Shoreham RSP indicate that automatic initia-tion of the RCIC and/or the RHR has been requested by the reactor protection system?

16. Will the RCIC and/or the RHR retain in operation if they are automatically initiated prior to the transfer frori the main control panel to the RSP?

17. Identify all alarms provided on the RSP for Class lE buses required to achieve cold shutdown (i.e., a list comparable to that for the main control room as presented in FSAR Table 223.90-4).

18. Identify all indicators at remote equipment locations to be used by operators in the field assisting in remote shutdown, and identify the range displayed by each such indicator.

19. Identify all LILCO personnel, contractors, or subcon-tractors, who participated in, or have knowledge concerning, the preparation, promulgation, implementation, revision, or audit of emergency operating procedures concerning the RSP.

1 i

20. Identify ell LILCO personnel, contractors or 4

subcontractors who participated in preparing, or have knowledge concerning Remote Shutdown System design and/or panel drawings showing the layout of the RSP or revisions of such design or drawings.

Su f folk Co. Contention 2.

21. State LILCO's position with respect to Suffolk County contention 2 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which ccacern its position.

22. Does LILCO intend to protect agal.nst an accumulation of dirt on the relays located in the diesel generator room control panels by:

a. Relay panels in the diesel generator room will have gasketed access doors and filtered ventilation louvers; and

b. The air intakes to the diesel ge5.erator ventilation systems will have concrete directly under them, with crushed stone several inches deep adjacent to the concrete?

If the answer is "yes," when does LILCO intend to implement the protective actions? Identify all documents which concern I

protection agains. accumulation of dirt on the relays located in the diesel generator room control panels.

23. It the answer to Interrogatory No. 22 is no

a. How does LILCO plan to comply with Regulatory Guide 1.39, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants," with respect to diesel generator maintenance? Identify all documents concerning such compliance and diesel generator maintenance procedures.

b. State LILCO's rationale for failing to install gasketed access doors and filtered ventilation louvers in the relay panels in the diesel generator rooms and identify all documents concerning such rationale and any related analyses.

c. State LILCO's rationale for its decision that the air intakes to the diesel generator ventilation systems will not have concrete directly under them, with crushed stone several inches. deep adjacent to the concrete, and identify all documents concerning such rationale and any related analyses.

24. Identify all LILCO personnel, contractors or subcon-tractors who participated in or who have knowledge concerning LILCO's implementation of the actions set forth in Section III.1 of the Settlement Agreement, and concerning the operational l

capability of filters installed over diesel generator relay doors.

Su f folk Co. Contention 3.

25. State LILCO's position with respect to Suffolk County contention 3 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test esults, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

26. Does LILCO intend to install in-core thermocouples to detect Inadequate Core Cooling (ICC) at Shoreham?

27. Identify all studies, analyses, or research and any documents concerning such studies, analysis or research conducted by or on behalf of LILCO, or the BWR Owners Group or Licensing Review Group or in the possession, custody, or control of LILCO, concerning the use of in-core thermocouples to detect ICC.

29. With respect to each of the following techniques, state the degree of accuracy to which the technique is able to measure fuel cladding temperature

a. Measurement of water level in the reactor vessel.

b. Use of thermocouples in in-core detector locations,

c. Use of thermocouples attached to fuel.

d. Any other techniques being considered by LILCO for use at Shoreham.

29. With respect to each response to Interrogatory No. 28, describe how the degree of accuracy was determined and identify all documents concerning such determination.

30. Describe in detail (including identification of relevant procedures and other documents) the precise method by which LILCO intends to detect the onset of ICC at Shoreham.

31. Identify all LILCO personnel, contractors or subcon-tractors who participated in, or have knowledge concerning, any research, analysis or studies of the use of in-core thermo-couples, or any other techniques, to detect ICC at Shoreham.

32. Identify all documents, including any concerning research, analysis, or testing, which concern the adequacy of the water level measurement technique of detecting the onset of ICC.

Suffolk Co. Contention 4.

33. State LILCO's position with respect to Suffolk County Contention 4 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

34. Has LILCO contacted or does LILCO intend to contact, engineering or other personnel at ot er General Electric BWR Mark II plants to determine if any water hammer problems arose during their pre-operational testing or low power testing? If so, C maribe all conmunications and documents concerning such l

1

contacts. If not, provide LILCO's rationale for failing to make such inquiries.

35. Does LILCO intend to evaluate, or has LILCO in fact evaluated, any problems identified at other General Electric BWR Mark II plants to determine their relevance to Shoreham and to determine whether Shoreham's pre-operational testing program for water hammer should be modified? If yes, identify all documents which evidence or concern this matter.

36. Has LILCO reviewed start-up procedures at BWR plants similar to Shoreham for water hammer events (i.e. the Zimmer and LaSalle plants)? If yes:

a. Describe all differences between Shoreham's pre-operational pipe system testing and the testing conducted at other plants.

b. Identify all reports, analyses or other documents concerning start-up water hammer events and differences between the Shoreham testing and the testing conducted at other plants.

37. Does LILCO agree to implement the provisions of Section III.A. of the Settlement Agreement regarding the addition of a County representative to LILCO's Nuclear Review Board?

38. Identify all LILCO personnel and contractors or subcontractors who participated in or have knowledge concerning any pre-operational testing at Shoreham relating to water hammer.

39. Identify all documents concerning research, analyses, or pre-operational testing at Shoreham relating to water hammer.

J

40. Identify the criteria to be used in evaluating the results of Shoreham's pre-operational tests for water hammer in the ECCS and steam system piping. Also identify all documents concerning the foregoing criteria.

Su f folk Co. Contention 5.

t

41. State LILCO's position with respect to Suffolk County Contention 5 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

42. Does LILCO intend to install a Loose Parts Monitoring (LPM) system having a modular acoustic detection, analog processing, and annunciation system providing real time detection and recording of impact noises in Shoreham's primary coolant system?

a. If so, please describe the proposed LPM system and 1 identify all documents which concern that system.

b. If not, please explain why not, and identify all documents which concern this position.

43. Describe how the Shoreham LPM system's frequency range, signal-to-background noise ratios, and rate of occurrence of impact events will be programmed, particularly with respect to system sensitivity and alarm logic.

44. State whether the Shoreham LPM system will contain each of the following design features:

a. Low pass and high pass filters that will attenuate signals due to spurious electrical, mechanical, or hydraulic transients;

b. Automatic adjustment of the alert threshold above the background noise that will result in detection of only those signals that rise above the changing average;

c. A system alarm that will not activate unless a minimum rate of alerts (indicated when the alert threshold is exceeded) occurs.

45. Will the Shoreham LPM system have the capability automatically to inhibit alarms during specific plant maneuvers that are found by experience to create spurious alarms? If so, please describe how this capability will be achieved.

46. The Settlement Agreement,Section III.K, states "The (LPMS) system alarm will not activate unless a minimum rate of alerts . . . occurs." Define what LILCO intended by the term

" minimum rate" and explain specifically how the alert threshold will be determined.

47. Identify the limits on rate of occurrence of impact events and the alert threshold of the LPM system hardware.

48. State how many spurious alarms are considered acceptable by LILCO with respect to Shoreham's LPM system and state how many are anticipated based on prior performance of systems similar to that to be installed at Shoreham.

49. State the basis for LILCO's selection of the Technology for Energy Corporation LPM system, particularly with respect to reliability, sensitivity and ease of operation.

50. Describe the procedures to be followed by operators upon each LPM system alarm.

51. Describe all training to be provided operators concerning the use of the LPM system.

52. Identify all LILCO employees, contractors and subcontractors who have participated in or have knowledge concerning the testing of, or research or analysis concerning the LPM system at Shoreham.

Su f fo lk Co . Contention 8.

53. State LILCO's position with respect to Suffolk County Contention 8 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

54. Identify the purpose and scope of LILCO's review of Emergency Operating Procedures referenced in LILCO's Environmental Qualification Report for Class IE Equipment (at page 2-1), state the schedule for such review, and identify all persons who will participate in such review. Identify all analyses, test results and other documents concerning such revies.

55. Identify all procedures, criteria and/or standa rds used or to be used by LILCO in reviewing the Emergency Operating Procedures against the computerized Environmental Qualifications Status Report (EOSR) which is Appendix F to LILCO's Environmental Qualification Report for Class IE Equipment, and identify all analyses, test results and other documents concertaing such review.

Su f folk Co. Contention 9.

56. State LILCO's position with respect to Suffolk County Contention 9 and with respect to such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

57. Identify all analyses used by LILCO to identify potential sources of ECCS pump suction strainer flow blockage occurring as a result of a LOCA, and explain how the results or conclusions of each such analysis were incorporated into the design of the ECCS pump suction strainers.

58. Has LILCO performed a drywell piping and insulation survey or analysis to identify the potential for, and the consequences of, insulation failure (as it relates to strainer flow blockage) durina and after a LOCA? If yes, identify all documents concerning such survey or analysis. If the answer to

{

]

i this Interrogatory is no, explain why such survey or analysis has not been performed.

59. State the facts or other considerations upon which LILCO based its decisions as to the number, size of surface area, and strainer grid size of the ECCS pump suction strainers, and state whether such facts or considerations are the result of operating experience or quantitative analysis. Identify all documents which concern these decisions.

Su ffolk Co. Contention 10.

l

60. State LILCO's position with respect to Suffolk County Contention 10 and with respect to such position identify:

a. The bases for such position. Include in your response LILCO's position concerning the applicability of the Japenese ECCS core spray test results (see Board Notification BN8-149) to the Shoreham design.

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

61. Identify all documents concerning tests conducted of the Shoreham ECCS core spray, and all documents concerning any review or analysis of any such tests.

62. Identify all LILCO personnel, contractors or subcon-tractors who participated in or have knowledge concerning any testing of the Shoreham ECCS Core Spray System.

Suffolk Co. Contention 17.

63. State separately LILCO's position with respect to Suffolk County Contention 17(a) and 17(b) and with respect to each such position identify:

a. The bases for such position;

b. All analyses, correspondence, and other documents, including but not limited to test results, research, audits, investigations or reports, upon which LILCO relies for support of or which concern its position.

64. Does LILCO intend to install a toxic gas detector in the Shoreham control room? If yes:

a. Describe the detector which LILCO intends to install and identify all documents which concern the detector; and

b. Identify all documents which concern whether the detector will have the capabilities (i) to sense hazardous products of combustion, including those from cable insulation, and (ii) to alert operators to their presence; and

c. Describe the schedule for installation of the detector.

65. If the answer to Interrogatory No. 64 is no:

a. Describe and identify all operator training and procedures for Shoreham control room personnel for detection and control of a toxic gas hazard in the control room. Identify all docutents concerning such training and procedures.

b. Describe the specific training to be received by the fire brigade leader which will allow him to determine or to suspect that quantities of toxic gas are present in the control room. Identify all documents concerning such training.

c. Identify the types of toxic gases which the fire brigade leader is trained to suspect are present in the control room and describe how he will recognize and distinguish each.

d. Describe the specific training to be received by the fire brigade leader which will allow him to determine the level at which quantities of toxic 1

gas may present a hazard to control room personnel, and identify the amounts of toxic gases

, he is trained to determine "present a hazard" to personnel.

e. Will the fire brigade leader always be present in the control room? If not, describe the procedures by which operators will become aware of a toxic gas problem and know to use respirators, if the fire brigade leader is not present in the control room.

f. Describe and identify all equipment and/or methods to detect toxic gas hazards in the Shoreham con-trol room. Identify all analyses and other i

documents that concern the adequacy of each such item of equipment or methode.

. g. Identify every item in the control room which constitutes a potential toxic gas hazard to control room operators, and identify the specific toxic gases each could release.

h. Identify all research, test results or analyses concerning the fire loading of combustibles in the control room as set forth in Table 1 " Fire Analysis Summary Sheet," of the Shoreham Fire Hazard Analysis Report and in each revision thereof, and identify all documents concerning such research, testing and analyses.

i. Identify all research, testing, or analyses of the potential toxic gas hazards (i.e. types of gases) for the control room resulting from cable, cable insulation, and ventilation-duct insulation material in the control room, and identify all documents concerning such research, testing or analysis.

66. Does LILCO intend to install manual fire alarms in the machine shop area at elevation 15 feet? (Note: the machine shop area for purposes of these interrogatories includes the oil room, paint room, welding room, blast area, receiving and storage room). If the answer is yes, identify all documents concerning the type and location of the alarms and when they will be installed.

67. If the answer to Interrogatory No. 66 is no

a. Is it LILCO's position that a significant number of BWR fires to date have not been detected by plant personnel, but rather by automatic detectors?

b. Identify all documents which concern the position stated in response to (a).

c. Is it LILCO's position that a lack of manual alarms will not impede rapid personnel notification of a fire?

d. Identify all documents which concern the position stated in response to (c).

e. Is it LILCO's position that most fires in the machine shop area will be detected more rapidly by automatic detectors than by plant personnel in the area?

f. Identify all documents which concern the position stated in response to (e).

g. Describe LILCO's rationale for not placing manual fire alarns in the machine shop area it elevation 15'.

h. Identify all analyses and documents which concern the position stated in response to (g).

i. Identify all documents which concern whether a fire in the machine shop area will affect the safety of Shoreham.

Respecv. fully submitted, l

DAVID J. G I L:.*a R T I N Suffolk County Attorney PATRICIA A. DEMP5LY Assistant Suffolk County Attorney Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 us ??' ~~

Herbert H. Brown ~

Lawrence Coe Lanpt.4r Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, NW, 8th Floor Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County March 5, 1982 f

&hWdd9;8saMMCX HEAT SARRIER INTECRITY TRANSPCRT U

E k M v ~ w w d d d e d d 2 ~ E  % 2 - 5 2 E 4 5 *E *g 4 5@  !

u5

% 8 M 8 -

g #  : g a u u =

~ C g' ce o C  % @ t 3 t E E E E C fundamental Parameters 8 y- ~

& S g g g g u A @ 4 e  % s s =

Plant Ventilation Monitors X X Main Stack Monitor X Primary Coolant System Activity X X Primary Containment Activity X X

Orywell Floor Orain Sumo X X .

Drywell Pressure X X Primary Coolant System Pressure X X X X Primary Coolant System Water Level X X Safety Relief Valve Positions I Leakage Isolation Demand X

+ L,9pression Pool Level X X hydrogen Concentratton (if not inerted) X Seu,wy Containment Pressure X Orn ell T M erature X X l Average Ac= ,

84. ige Monitor X X l

• Core Flow '

X l Sucoression Pool fe*arature X

! Source Range Mon:L c- X Source Range Monitor Position X

Scram Demand Signal , X Mode Switch Position X l

l l

Teole 7-1 RELytS bin FUNDAMENTAL SAFE f Y PAPA"ETER SET 7-6 -

i y Ww - * ~