ML20041E389
| ML20041E389 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/01/1982 |
| From: | SHOREHAM OPPONENTS COALITION |
| To: | LONG ISLAND LIGHTING CO. |
| Shared Package | |
| ML20041E388 | List: |
| References | |
| NUDOCS 8203100456 | |
| Download: ML20041E389 (14) | |
Text
Y,l, f & L
. se t m TED N
- 9
~
g2
..p, 4 EO. '-
el UNITED STATES OF AMERICA NUCLEAR REGULATORY' COMMISSION
)
In the Matter of
)
LONG ISLAND LIGHTING COMPANY-1 Docket No. 50-322
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
SOC's FOURTH SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY' I.
The Shoreham Opponents Coalition (SOC) serves on the Long Island Lighting Company (LILCO) the interrogatories and requests for production of documents that appear below.
A sworn response to,them must be provided to SOC in accordance with the terms of 10 CPR Section,2.740(b) and 2.741(d).
If the answer to any question is not known when the response is filed, the answer must be l
provided as soon as the missing information becomes available.
l l
As used in the interrogatories and request for production of l
documents, the following definitions apply as indicated:
1.
"LILCO," means Long Island Lighting Company, its
'officern, agents, employees, and consultants.
2.
" Facts," include the calculational or other assumptions, l
if any, underlying various assertions of fact.
" Including" and B203100456 820301 1
PDR ADOCK 05000322 l
G PDR
a ct. w wA,,c
" i ncl ud e", " as used in these interrogatories,' mean " incl,uding ~ but not limited to."
3.
" Doc" ment" or " documents," means any handwritten, typed, printed, recorded or graphic matter however produced or reproduced, including material stored for use in automatic data processing, systems, whether or not in the pocsession, custody or control of LILCO and whether or not claimed to be privileged against discovery on any ground, including:
reports; r,ecord s; lists; memoranda; correspondence; telegrams; schedules; photographs, sound recordings; films; hand, machine and computer calculationc; computer codes; data; and written statements of witnesses or other persons having knowledge of the facts.
~4~.
" Studies or observations," include physical, empirical, calculational, assumptional, and.other types of work, whether recorded in writing or not.
Please provide answers to the following questions which
~
pertain to specific. SOC contentions in Docket No. 50-322.
4 4.
tiarch 1, 1982 SOC CONTENTION 3 1
Please provide a copy of any and all correspondence,or other documents between LILCO and the NRC which relate
.to Regulatory Guide 1.97, Rev. 2 since date.of LILCO's motion for-summary disposition.
This should include out not be limited to any correspondence.between LILCO and GE equipment suppliers, NRC, ACRS and BWR owners' groups.
2 Please provide a cross-reference between the individual items in each of the two tables attached to the LILCO Motion for Summary Disposition on Contention 3 (Table 1 and Table 2), and the items listed in Regulatory Guide 1.97, Rev.
2.
3.
What is the,LILCO scheduled date of. implementation for each of the pieces of equipment identified in Regulatory Guide 1.97, Rev. 2 as applicable to BWR's?
4.
Please provide a description of each piece of equipment which is presently or planned to be provided to meet Regulatory Guide 1.97, Rev. 2, Table 1, Type A equipment requirements.
5.
For the systems which LILCO plans to use for measuring Iodine release from Shoreham, what is the overall accuracy of measuring the total release of particulate and gaseous forms of Iodine during an accident?
Please also give numerical values for sample accuracy, sample monitoring frequency, sample monitoring accuracy and model accuracy used to calculate the total discharge of Iod i ne. -
6.
nre the accuracies given in response to the above interrogatories applicable to all possible release pointo at Shoreham?
If not, specifically identify which i
release points they apply to and state the accuracy of measurement of Iodine release from other release points.
7 What, if any, effort is being made by LILCO to locate continuous Iodine monitoring equipment (see 0578, p.
A-38 and II.F 1-7 of 0737) ?
i 8.
Ider' 1[y all equipment located in the secondary containment which is classed as a) important-to-safety, or b) Class IE, or c) Design Class I?
~
j Ma:ch 1,
1982 J
t 9.
Nnat equipment in the secondary containment is required ny khe Emergency Operating Procedures tb be operated or
.nonitored by the operator during or following a transient or accident?
I 10 Please provide a copy of a11' Emergency Operating Procedures for the Sh'o,reham plant.
,11 A s s u.n i ng there were a need for operators to go to the secondary containment during or following an accident, how would the requirements of 1.97, Rev. 2, Table 1,
Type E, Radiation Exposure Rate Monitoring, be
. satisfied?
Describe the equipment to be used and the availability of the equipment.
12.
Please provide a copy of all documents which LILCO is i
relying upon to establish the state revised criteria for Environs and Radiation Exposure Rate Monitoring in the secondary containment.
13.
What will be the locar if the portable effluent monitoring equipment secondary containment (LILCO, Motion for Summary Diu ssition, Table 2, item 17)?
r 14.
What is the justification for not providing ARM in the secondary containment (LILCO Motion for Summary Disposition, Table 2, item 17)?
15.
Assuming LILCO meets its September,,1982 fuel load, schedule, what equipment in Reg. Guide 1.97, Rev. 2 will not be installed by that date?
16.
What."high range survey equipment" (as stated in LILCO's Motion for Summary Disposition, Table 2, Item 45) is b,ei ng added to the Shoreham design?
How many devices are provided?
Descr'ibe the devices and their range.
Ple$se provide the details which support the conclusions 17.
in SNRC 608 regarding the sampling system.
A.
Please include data on the_ sampling rate, reliability, measurement accuracy, and the specified environmental qualification.
~
H.
.;h a t' are > ttr6 shielding requirements for the Sampling Buildipq?
18.
For ear:h item in LILCO's Table 2 (attached to LILCO Motion for Summary Disposition for Contention 3) which staten,th.at the instrument is a) not being provided or, b) is to be a GE generic solution, provide the details of how 'and when the oquipment is neing implemented or the justification for not supplying the equipment.
~
1-w-
March :. 1982 19.
Pleas. identify all potential leak paths on Shoreham.
For each path, describe the instruments which will be used to monitor the release (and include an identification corresponding to the item numbers in.
LILCO's Table 2, Motion of Summary Disposition of SOC Contention 3.
9 0
A 4
a
March 1,
1982 l
l 50C CONTSNTION ofa)i 1
OA Program and Implementing Procedures l
Provide copies of the AQ program mannual and associated-implementation procedures for the following entities:
LILCO, Stone & Webster, Courter, Comstock & Jackson, and Dravo for the period beginning with the commencement of each entity's activities on the Shoreham project to 1982 year to date of the completion of each entity's activity on the Shoreham project, if earlier.
2.
Audit and Surveillance Results Provide all audit and surveillance findings and observations for the QA criteria set forth in Contention 6(a)i for the period 1977 to 1982 year to date which address:
a) QA program adequacy; b) Effectiveness of program implementation; for LILCO, Stone and Webster, Courter, Comstock and Jackson and Dravo.
~~
3.
P1 ease pro'ide nonconformance/ noncompliance logs o'r v
listings showing the dates at which each nonconformance/
noncompliance was entered and cleared for the following:
a.
LILCO's quality assurance program; b.
Stone & Webster's quality assurance program; c.
The. quality assurance program for the prime contractors (Courter, Comstock & Jackson and Dravo).
4 Please provide the audits and/or other documentation supporting the initiation and closing of any and all nonconformances/noncompliances listed in response to question 3 of this set of interrogatories.
5.
Please provide any and all monthly and yearly management audits concerning tne adequacy and/or effectiveness of the project quality assurance ' program, trends'in QA projram implementation of Stone & Weoster, LILCO and the prime contractors (Courter, Comstock & Jackson and Dravo).
6.
Please provide copies of any and all documents pertaining to the QA/QC audit and inspection performed by the NRC at the Shoreham site during February, 1982.
mJ
March 1, 1982 1
SOC CONTEN' TION 7A(1)_
1 Please provide the assumptions and details which are used in ansessing the resolution of NUREG-0373, item I'I.K.3.21 (restart of. low pressure injection.a6d core spray).
Also, for the conditions analyzed:
a.
What other systems are assumed available?
l b.
What equipment is assumed inoperative?
c.
What operator errors are assumed in the analyses?
l 2.
Please provide a copy of NEDO-24951 ( J une, 1981) which is stated to contain reference material pertinent to II.K.3.21.
SOC CONTENTION 7A(2) 1.
Please provide the justification and reasoning applied for each of the high-priority items in the original control room audit report which has not yet been corrected, f
2.
What actions or changes have resulted from the recent (February, 1982) LILCO/NRC meeting on Human Factors?
Provide a copy of all correspondence or other documents between LILCO and the NRC which pertains to that meeting.
l 3.
Does LILCO intend to leave ADS and S/RV controls and pressure and teinperature indicators in their present positions despite the concerns expressed by the NRC Control Room / Human Factors Audit?
4.
If the answer to 3 is affirmative, state the reasons and justifications for doing so.
5.
If th.s answer to 4 is negative, state what changes will be made and provide new drawings showing the revised location o'f equipment.
6.
Provide up-to-date as-built drawings which show the ADS and s/RV equipment locations with sufficient information to determine the function of the device.
March 1,
1982 7.
What is the specifle l availability of GE supplied process compister at Shor'eham?
8.
Wnat indication of first-out annunciators is planned at Shoreham?
9.
Wnich
<>f the criteria.of NUREG-0700 were not applied d;rina tho e,ntrol r en aud i t at Shoreham?
lu.
Is it h il.co ' n position that the NRC Control Room Audit was adequat" to assess the liuman Factors design of the Sooreham O:ntrol Room?
11 Please pro /ide a copy of the full list of criteria applied to the NRC Contcol i.co.n Aud i t.
SOC CONTENTION 7A(3) 1 Pli>ase provide a copy of all recent documents and correnpondence regarding the location of the monitors for radiation release measurements at Shoreham.
2.
lias thes e been any change in the monitor locations?
If the answet is affirmative, please describe the equipment involved and the changes in location.
If the answer is negative, please provide the drawings which show the present or planned locations of the monitors.
SOC CONTENTION 7A(4) 1 What is the reliability and availability specified for the Safety Parameter Display Console (SPDC)?
2.
Does the~ interim design of the SPDC rely on the Plant P.rocess Computer for its dc.ta?
Explain the dependence of the SPDC on the Plant Process Computer, i'f any.
3.
Please provide a copy of SNRC 585 which is purported to describe the permanent SPDC design.
SOC CO';TENTION 7A(5) 1 t>1 ease pro /ide a copy of all docunentic and correspondence which doscribe the tests and results of th" Sa f.>ty/Rel ie f Va l ve testinq for BWR's and for the Chereham plant, spoeifically.
2.
P !"re prwi ie a copy of SNHC 647 (December, 1981).
m
March 1, 1982 3.
'Please provide a copy of any letters from McCaffrey to Denton regarding the S/RV tests.
Please also provide a copy of any BWR Owner's Group documents which pertain to the S/RV tests.
4.
What ATWS conditions 'are not covered in the tests completed to date for hWR S/RV's of the type used in the Shoreham design?
5.,
What ATWS conditions are covered in the present or past-S/HV tests?
6.
What. tests.have been performed to show that the BWR Owner's Group test results are applicable to the Shoreham-specific S/RV design?
SOC CONTENTION 7A(6) 1.
What steps have been taken to reduce the number of challenges to the S/R valves at Shoreham?
2.
What procedural steps, if any, have been taken to reduce the number of S/RV challenges?
Provide a copy of sny procedures used to reduce challenges.
3.
llave there been, any equipment or system changes to reduce the number of challenges to the S/RV's?
l O
March 1,
1982 l
I l
SOC COiJTENTION o 1
V;q a t is LILCO's current posi t ion regarding the installation of in-coce thermocouples to measure the oivt of Inadequate Core Cooling (ICC)?
l 2.
vih o t. provisions, if any, have been made in the design of St.oreham to esentually include in-core thermocouples?
3.
ilh a t action has been taken to improve the vessel water level-measurement technique' on Shoreham?
4.
Please provide a copy of LILCO's response to Board Notification 82-08, February 9, 1981, " Errors in BWR Vessel Water Level Indication."
5.
For each vessel level instrument state whether Shoreham uses a heated reference leg or cold reference leg design of the types described in BN 82-08.
1 e
i l
l t
I l
l l
l S
' March 1,
1982 SGC CONTI:NTION
'J_
1 On page 15 of LILCO's response to SOC's 6/24/81 interrogatories, LILCO identified exceptions,to compliance with Reg. Guide 1.47.
Please describe the justification for not having the equipment comply with Reg. Guide 1.47 in each of the following examples:
(a) system inoperative alarms for the screenwell pumphouse vent systems relay, l
(b) the emergency switchgear toom exhause air systems, (c) the battery room vent systems, (d) the HBSWS chiller equipment room vent systems, (e) diesel rooms emergency vent system.
2.
Describe why there is no compliance with Reg. Guide 1.47 on the following systems (ref. PSAR Fig. 7.1.1 -2, J uly,
1981 revision):
1 a )-
RCIC?
b)
Standy Liquid Control?
c)
Puel pool cooling?
d)
SRV (air system)?
3.
How is the " system degraded" alarm and/or "value (valve) i Loss of Control" alarms (as cited in response number 1 to SOC 6/24/81 interrogatories on Contention 9), able to sat isfy -the Reg. Guide 1.47 criteria?
4 I's the J uly, 1981 re' vision of PSAR Fig. 7.1.-1-2 the latest revision?
If not, please provide a copy of the latest revision.
5.
What bypass indications are available on the remote shutdown panel?
6 As a resul.t of Rev. 2 of Reg. Guide 1.97, what systems were added to the list of systems required to comply with Reg. Guide 1.47?
a e
O O
w y
,-wm.g-
,-----..e----,.-a-.--7 s-
,n
~
March 1,
1982
_SO_C CONTENTION 16 1
Please provide a copy of all GE and LILCO documents prepared since September, 1981 regarding the issues addressed in NUREG-0630.
Please provide both generic information and Shoreham specific information.
2.
Please provide a description of how the problems identified in NUREG-0630 have been resolved for the S hor eh a;n f uel design.
3.
Please p ovide a copy of all correspondence between LILCO and GE, NRC, ACRS, and BWR Owner's Group regarding tne Japanese core spray tests as described in the Board Notification dated 12/3/81.
4 What analysis or testing has LILCO performed to show that the deficiencies identified in the Japanese tests are not applicable to Shoreham?
O 9
F e
J.
~~
March 1, 1982 SOC CONTENTION 19 On July 29, 1981, SOC served on,LILCO its " Third set of Interrogatories and Request for' Product ion o f Documents" pertaining to SOC Contention 19.
Formal answers to those interrogatories were deferred pending the outcome of informal discovery meetings between the parties and a ruling by the Board on the December 2, 1981 Motion for Acceptance of SOC Contentions.
In view of the Board's acceptance of Content, ion 19 as stated by the ' parties in that Motion, SOC hereby formally requests answers to its July 29, 1981 interrogatories and documents requests.
In addition, SOC hereby submits the following additional discovery request.
SOC CONTENTION 19(a) 1 Provide copies of any and all correspondence,, studies, reports and analyses which pertain to the pre-service i nspection of the Shoreham reactor pressure vessel conducted during December of 1981, including any and all reports prepared by any outside consultants retained by LILCO or the NRC for the PSI.
e w m
I l
e 8
,c
Request,for Site Visit To Inspect Shoreham Systems and Components Pursuant to 10 CPR Part 2.741, SOC requests permission for' its consultants, Greg Minor, Richard flubbard and Dale Bridenbaugh and its attorneys, Stephen Latham and John Shea, to inspect, measure, survey, test and sample the following areas, systems and components at the Shoreham', Nuclear Station:
Contention Area, System or Companent 3
Sampling Station Remote Shutdown Panel Secondary Containment Penetration Exit Points Portable Monitor Locations 6(a)i QA Records Center As Built Drawing System 7a(2)
Control Room Front & Back Row Panels 7a(3)
Iodine Monitoring - Plant Vent Sampling & Measuring Locations 7a(5)
S/RV Mounting and Piping 8
Control Room--Equipment for ICC Indications 9
Remote Shutdown Panel 19(a)
RPV Accessibility for ISI 19(g)
Cable Spreading Room Steam Tunnel 19(j)
Turbine Room - For Missile Barriers fif any)
Emergency Dnergency Response Facilities & Equipment -
In view of the' conference of parties scheduled for Mar,ch 9.
and 10 by the Licensing Board in Docket No. 50-322, SOC requests
.that the date for this inspection be scheduled to begin shortly after the conclusion of that conference on March 10, continuing on March 11 and March 12, if necessary, and b'eginning_at 9:00 a.m.
in the morning of each day.
e wb m
-