ML20041G445
| ML20041G445 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/17/1982 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8203220308 | |
| Download: ML20041G445 (51) | |
Text
n e,
1, C0f ET~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAlb? U 18 D1 :0}
}
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (O N
)
e (Shoreham Nuclear Power Station,
)
D Unit 1)
)
)
RECEh/ED 9
67 I'1AR 1 9 1ggg en 79 Suf folk County Answers M mm anuweg to LILCO's Interrogatories
(
yFMiu
/
//
Pursuant to 10 C.F.R.
I 2.740b and the agreement of c s
p for Suf folk County and for LILCO, Suffolk County ("SC") responds to LILCO's Interrogatories, dated February 23, 1982, as follows:
S.C.
Contention 1 Interrogatory No. 1 1.
Exactly how does SC think the "instrume.tation" and
" controls" for the specified systems are " inadequate," focusing on each affected instrument and control and its alleged incapacity.
Answer The remote shutdown panel ("RSP") lacks the instrumenta' tion necessary to assure the functional response of pumps and valves required to effect a safe shutdown, particularly if a single failure is assumed.
Specifically, the County is conc 6rned with instrumentation in the following systems:
(a) reactor core isoletion cooling; (b) residual heat removal; (c) service water; and (d) additional supporting systems necessary to assure 8203220308 920317 d
{DRADOCK 05000322 h?l
^
-.e
e, t,
integrated systems operability (e.g.,
electrical buses, instrument air).
As can best be determined from materials that the County has been provided to date, only the nine following parameters can be directly monitored at the RSP:
(1)
Reactor Vessel level, LI-004 (2)
Reactor Vessel pressure, PI-006 (3)
Suppression Pool level, LI-026 (4)
Suppression Pool Temperature, TI-022 A/B (5)
Drywell pressure, PI-012 (6)
Drywell temperature, TI-021 (7)
RCIC flow (8)
RHR flow
'(9)
Service Water pump discharge pressure Specifically with regard to the Service Water System, the monitoring of pump discharge head pressure at the RSP is insuf-ficient to enable an operator to determine either (a) system operability or (b) whether or not the service water function is being provided throughout the system as necessary.
The County believes that without an indication of pump shutof f head pressure in the pressure gauge, the measurement of discharge pressure at i
the RSP may mislead an operator.
Furthermore, assuming a single failure occurs in the service water system such that the service water pump is limited in its function, there is no additional measurement currently available on the RSP, such as Service Water flow and/or heat exchanger outlet temperature (s), by which system functionability can be ascertained.
RSP instrumentation is also inadequate to detect single t
i failures or to mitigate the consequences of single failures in the above-named systems.
For instance, although indicating l
lights are provided for various turbine-related parameters on the l
{
m
1, RCIC panel, such indicating lights are insufficient to provide the information necessary for RCIC utilization in the event of a
~
single failure.
Similarly, there is no available electrical bus indication for any of the electrical systems associated with the RSP.
As a final example, there is nothing in the RSP procedures currently available to the County to assure (a) that the B loop of the RHR system is available, although B loop operability is assumed in the procedures, or (b) that the operator knows whether or not the B loop is available and what actions should be taken in the event that it is unavailable.
Interrogatory No. 2 2.
As 'to each inadequacy identi fied in response to Question l', what remedy does SC propose?
Answer I
SC is under no obligation to provide LILCO with " remedies" for inadequacies and/or deficiencies at Shoreham and thus has performed no detailed analysis designed to remedy the defi-ciencies.
However, in general SC would suggest that at a minimum, the RSP should be equipped with additional instru-mentation, including, but not limited to the following:
(a)
Safety relief valve closure indication by temperature or pressure in the discharge pipe; (b)
Service water flow; (c)
Temperature measurements at inlets and outlets of heat exchangers in the RCIC, RHR and service water systems; (d)
Availability indication of electrical buses and instrument air system; and, (e)
Additional procedures to deal with the possibilities that (i) the RHR B loop is unavailable, _-.--____-._j
\\
t I,
(ii) the safety relief valve does not shut, or (iii)
RCIC does not function.
SC Contention 2 Interrogatory No. 3 3.
If LILCO takes the steps set out in Section III. I.
(Diesel Generator Relay Reliability) of the abortive County-LILCO Scttlement, will that resolve this concern?
Answer If LILCO documents to the County's satisfaction (including inspection now and in the future) that it will take the steps set out in Section III.I (Diesel Generator Relay Reliability) of the Sixth Stipulation and Settlement of Suf folk County Contentions, the County would consider the concern set forth in SC contention 2 to be resolved.
Interrogatory No. 4 4.
If not, state precisely (a) what other steps the County thinks are important to safety, and (b) why they're important.
Answer See Answer to Interrogatory No. 3.
SC Contention 4 Interrogatory No. 5 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?
Answer If LILCO documents to the County's satisfaction (including possible inspections and observation of testing programs) that it will take all the steps set out in Section III.L (Water Hammer) e, County's satisfaction that it will take the steps set out in Section III.N (Loose Parts Monitoring) of the Sixth Stipulation and Settlement of Suffolk County Contentions.
SC Contention 8 Interrogatory No. 9 9.
Please answer Questions 60(a)-(e) and 61 on page 8 above, concerning SOC Contention 19(h).
60.
In light of the " Environmental Qualification Report for Class IE Equipment for SNPS-Unit 1, Revision 1 (Jan. 15, 1982),
precisely:
(a)
How are the proposed test conditions "not sufficiently conservative"?
(b)
What equipment "has been qualified by grandfathering to older, less stringent standards"?
(c)
In what way is the list of emergency operating equipment to be qualified " inadequate"?
(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 program?
61.
(a) Would Shoreham's compliance with NUREG-0588 resolve SOC's concerns about Regulatory Guide 1.897 (b) If not, set out the reasons why.
Answer SC believes that environmental qualification, including seismic qualification of equipment important to safety, has not yet been demonstrated by LILCO for the Shoreham equipment.
Further, the NRC Staf f's supplement to the Shoreham SER lists environmental qualification (SER, Supp.
1, at pp. 1-4 and 3-4; _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Supp.
2, at p.
1-2) as an open issue.
In addition, LILCO has not yet submitted the detailed Shoreham emergency operating proce-l a
dures 180 days prior to fuel load as contemplated by Section V to Appendix E to 10 C.F.R. Part 50.
Thus, the NRC Staff's review of the adequacy to the Shoreham emergency operating procedures, including the operator's reliance on qualified equipment during an accident, is also an open item in the SER. (SER Supp. 1 at pp.
1-5 to 1-7 and p. 13-38).
In addition, in a letter dated February 26, 1982, from Mr. Schwencer of the NRC Staff to Mr.
Pollock of LILCO, the Staff requested that LILCO provide addi-tional information to the Staff to assist the Staff in forming a judgment regarding the adequacy of the LILCO seismic dynamic qualification program.
In Appendix 3B of the Shoreham FSAR, LILCO states that the environmental qualification of Class IE equipment as set forth in Regulatory Guide 1.89 is not applicable to Shoreham since the Shoreham SER date for the PSAR (February 20, 1970) precedes the implementation date given in Section D of the Guide.
LILCO further states that due to the advanced stage of procurement when the Guide was issued, most Class IE equipment was purchased prior to November, 1974.
Although LILCO believes that full compliance with the Guide for the quantity of Class IE equipment outstanding is not significant, LILCO proposes to attempt to procure equip-ment to IEEE 323-1974, whenever practical, for purchases made after November, 1974.
Thus, there is substantial uncertainty in the actual qualification level achieved by LILCO for Shoreham equipment.
Further, other BWR owners with equipment purchased directly for the Balance of Plant (BOP) or supplied by General Electric for the NSSS, have in response to NRC Bulletins 79-01 and 79-OlB identified equipment with inadequate environmental qualification.
The relevance to Shoreham of the preceding general deficiencies in BWR equipment qualification is currently being evaluated by the County's experts.
The current status of environmental qualification of Shoreham equipment was set forth in the " Environmental Quali-fication Report for Class lE Equipment for SNPS-Unit 1" Revision 1,
dated January 15, 1982.
The January 15th report documents examples of equipment qualified to test conditions that are not properly conservative, equipment qualified to older, less strin-gent standards, and equipment not qualified to aging and other life requirements.
Unresolved issues identified by LILCO were summarized for the following classes of deficiencies in Appendix F of the January 15, 1982 submittal:
Category Description of De ficiency QG Qualified except for aging FT Documentation has been reviewed; further tests / analyses recommended MR Modification of equipment is recommended for qualification RR Replacement is recommended; test report for qualified replacement will be evaluated DR Documentation is in review TA Testing / Analyses program has been initiated IJ Qualification documentation not expected to be completed prior to fuel load; refer to Appendix G of January 15 report for status l
1 e,
t, In summa ry, environmental qualification was incomplete for approximately 70 percent of the items.
In addition, Appendix G of the January 15 submittal lists equipment important to safety which LILCO projects will have incomplete qualification docu-mentation prior to fuel load.
Thirty-one (31) items are listed, including containment electrical penetration seals, pressure transmitters, vessel level instruments, Terry turbines, switches, terminal blocks, flow transmitters, cables, and motor control centers.
Suffolk County believes that nuclear plant equipment impor-tant to safety must be able to perform the requisite safety functions throughout its installed life.
This requirement is embodied in GDC 1, 2,
4 and 23 of Appendix A to 10 C.F.R. Part 50; in Criteria 3 and 11 of Appendix B to 10 C.F.R. Part 50; and in 10 C.F.R. 50.55a(h), which incorporates by reference IEEE 279-1971.
This requirement is applicable to equipment located inside as well as outside the containment.
In the past, the NRC has used a variety of methods to ensure that these general require-ments are met for equipment important to safety.
Prior to 1971, qualification was generally based on the fact that the electrical components were of high industrial quality.
Later, qualification was judged on the bases of IEEE 323-1971 and IEEE 323-1974.
Currently, the NRC has underway a program to reevaluate the qualification of equipment important to safety and as part of this program, more definitive criteria for environmental qualifi-cation have been developed by the NRC including: -
(a)
DOR Guidelines " Guidelines For Evaluating Environmental Qualification of Class lE Equipment in Operating Reactors," dated November 1979.
(b)
NUREG-0588, " Interim Staff Position On Environmental Qualification of Safety Related Electrical Equipment."
(Revision O and Revision 1).
(c)
Commission Memorandum and Order CLI-80-21, dated May 23, 1980.
(d)
Proposed Rule, " Environmental Qualification of Electric Equipment for Nuclear Power Plants,"
Fed. Reg. January 20, 1982, at pp. 2876 to 2879.
(e)
Proposed Revision 1 to Regulatory Guide 1.89, dated February, 1982.
Thus, even if LILCO could demonstrate compliance with Revision 1 of NUREG-0588, which has not occurred to date, the Shoreham environmental qualification program may still be inade-quate as compared to the practices set forth in the preceding items a, c,
d, and e.
Finally, the additional'information which the County will need to review in order to evaluate LILCO's qualification program is generally described in the foregoing.
Clearly, at this time, environmental and seismic qualification of Shoreham equipment important to safety has not been demonstrated by LILCO nor has the assessment of such equipment been completed by the NRC Staf f.
SC Contention 10.
Interrogatory No. 10 10.
Define exactly what SC means by " counter current flow."
Answer When core spray is turned on, it is intended to flow down the flow channels and over the fuel bundles, thereby creating a source of cooling for the fuel.
If there is an updraft of steam l 1
e, e,
which is moving up the same fuel channel, it may force water out of the channel and create a counter current flow.
Interrogatory No. 11 11.
How does counter current flow, as defined in response to Question 10, affect " core spray distribution"?
Answer Core spray may not be capable of entering a fuel channel where counter current flow is occurring.
Thus, the core spray would not distribute equally over the fuel bundles.
Interrogatory No. 12 12.
Isn't it "BN-81-49," not "BN-81-29"?
Answer Yes.
Note also the information related to BN-81-49 sent from Robert Tedesco to the ASLB for Shoreham to provide further
" clarification".
SC Contention 11.
Interrogatory No. 13 13.
(a) Define exactly which type of " valves" (e.g.,
manual, air-operated, check) SC is talking about, and (b) explain precisely why the County believes that a problem may exist at Shoreham with such valves.
Answer The nature of the valve failures is more important than the type of operator on the valves.
The concern is for failures where there is a failure resulting in separation of the valve stem from the gate or disk which will allow the operator to perform its task but will not result in proper valve action.
For. _ _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _ _. -. _ _ _ _ _ _ _. _.
_J
e, example, the failures of MSLIV's at Brunswick 1 and 2 and Hatch 2 between 1976 and 1981 exemplify the type of failures the con-tention addresses, but the contention is not limited to MSLIV's or this particular model of valves.
SC Contention 13 (a)
Interrogatory No. 14 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.
Answer The QA/QC program requirements mandated by the NRC for commercial nuclear power plants in the 18 QA criteria set fo rth in Appendix B to 10 C.F.R. Part 50 are intended to assure that the important safety features specified by the NRC regulations and prescribed by the safety system designers during construction of Shoreham are in fact implemented and maintained during the operating life of the plant.
A number of Regulatory Guides also set forth practices that, when implemented, result in QA/QC program compliance with the Appendix B criteria.
Thus, the QA/QC program presented in Section 17.2 of the FSAR should describe in detail whether and how all the requirements of Appendix B will be satisfied.
Contrary to this requirement, Suffolk County believes that the LILCO presentation in the FSAR is deficient in that the description sets forth only a cursory commitment to meet the regulations.
No detailed description of how the program will be implemented is presented by LILCO.
e While detailed implementing QA/QC procedures may, in fact, exist, the level of detail in the FSAR, particularly with regard to replacement parts and materials, is inadequate to demonstrate how the criteria of Appendix B will be implemented.
Conclusions on the adequacy of the implementing QA/QC policies, procedures, and instructions for operations cannot be any more specific until the County has had an opportunity to review the LILCO operating QA program manuals which have been requested through discovery.
Further, SC notes that LILCO has not committed itself to compliance with the regulatory posit _ons of a number of the more recent revisions of the Regulatory Guides applicable to QA/QC l
during operations.
Until discovery is complete, the County is unable to assess whether the LILCO QA/QC program will provide a level of safety equivalent to that which would be achieved through compliance with the current provisions of Appendix B and the applicable Regulatory Guides.
SC Contentions 13(b)
Interrogatory No. 15 15.
List (a) each significant element that must be addressed in an " adequate" provision for the processes in ques-tion; and (b) explain why.
Answer An " adequate" corrective action system as required by Criterion 16 of Appendix B, would provide for the identification, reporting, and analysis of all failures of equipment important to safety discovered during operation and maintenance activities at Shoreham, as well as a similar evaluation for those types of failures which occur at other operating BWR stations with com-parable equipment.
The corrective action system should identify failures of Class IE items, as well as parts (i.e.,
semicon-ductors, coils, gaskets, bellows, etc.) of Class IE items.
Implementation of a thorough field feedback corrective action system is one essential element in the defense in depth intended to be provided by the QA/QC program.
SC Contention 13(c)
Interrogatory No. 16 16.
List (a) each significant element that must be addressed in an " adequate" provision for the processes in.2ues-tion and (b) explain why.
Answer Replacement parts and material for Class IE items identified as important to safety should be designed, procured, installed, inspected, and tested in compliance with the level of safety provided by compliance with the 18 criteria of Appendix B as implemented for the original equipment.
This contention addresses the QA/QC controls for replacement parts and materials as previously identified in Response 15 herein.
The purpose of the QA/QC control of materials and replacement parts is to ensure that replacements installed during maintenance activities provide a comparable level of safety as provided by the parts installed in the original equipment.
Proper control of replacement of materials and parts is one of the major QA/QC activities which will occur during maintenance and repair of equipment important to safety during the life of the plant.
SC Contention 13(d)
Interrogatory No. 17 (a)
Quantify an " adequate number" (i) on shift and (ii) off-shift and (b) provide the basis for the numbers chosen.
Answer An " adequate number" for Shoreham cannot yet be quantified by the County because such staffing is based on the fulfillment of functional requirements of 10 C.F.R. 50, Appendix B,.which are not adequately addressed in the FSAR.
The FSAR does not distin-guish between numbers of off-shift /on-shift Operating OA (OOA) staff planned for Shoreham, does not include the detailed respon-sibilities of the OOA staff, does not include the qualifications of the OOA staff, and does not explain the basis for the number of OOA staff it plans to use.
However, SC believes that the number and qualification of the OA/OC personnel on each shift should be based upon the type of activities being performed at the plant site and the number of personnel involved in construc-tion, maintenance, or refueling activities.
Further, SC believes tha t QA/OC personnel should be provided on all shifts where construction, maintenance, or refueling activities are scheduled.
SC Contention 14(a)
Interrogatory 18 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 been left to linger while " symptoms" alone were treated.
(c) List all docu-mentary evidence that SC has to support its conclusions..
Answer The NRC's I&E program has concentrated on correction of specific, identified QA/QC breakdowns at Shoreham.
A review of the I&E reports identified in the particularization of SC Contention 12 reveals that I&E has not undertaken a broad review of all LILCO QA/QC activities in areas of multiple QA/QC break-downs.
For instance, there have been at least 45 identified QA/QC breakdowns concerning Appendix B Criterion 5.
Notwith-standing this pattern which suggests an uncorrected LILCO failure to comply with Criterion 5, I&E has not established a systematic review mechanism to determine the extent of LILCO's failure to meet Criterion 5 or to determine how and why this repeated failure has been allowed to persist.
The root causes of LILCO's breakdowns appear to be LILCO's failure to implement systema-tically a QA/QC program under each Appendix B criterion.
The County has not yet determined whether these root causes relate primarily to broad failures of the LILCO QA program (such as manuals which do not, even on paper, adequately implement Appendix B, although the cursory FSAR treatment of QA suggests such a generic failure), to personnel deficiencies at LILCO or among LILCO contractors, or whether the causes involve other bases.
The County emphasizes, however, its concern that the Staff's program has been deficient because it has failed to seek the root causes but, rather merely addresses specific errors which happen to be identified.
Such a superficial approach provides no confidence that the Staff in fact has provided satisfactory assurance that the LILCO program meets Appendix B.. - - - - - _ - - - _ - - - - -
J
u.
SC Contention 14(c)
Interrogatory No. 19 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."
Answe r (a) The term " baseline criteria," as used by the County, refers to a statistical basis for measuring the effectiveness of the NRC's Shoreham inspection program.
Currently, the NRC does not use any kind of statistical, quantitative or comparative basis for measuring or determining the effectiveness of its enforcement and inspection program.
Examples of such statistical bases or standard procedures abound in the military and industry.
One example of such " base-line criteria" which SC has previously raised in discussions with LILCO and the Staff is MIL-STD-105D, " Military Standard:
Sampling Procedures and Tables for Inspection by Attributes. "
While the County does not necessarily propose this standard as the preferred or the single recommended basis for NRC inspections at Shoreham, it serves to illustrate explicitly and to define concretly what the County means by " baseline criteria."
(b) The means of determining improvements in or the effec-tiveness of corrections should include a statistical basis for reinspection of determined nonconformances.
Presently, no such means exist at Shoreham for determining whether determined nonconformances have been ef fectively corrected, particularly.-
0 with respect to the correction or resolution of fundamental or i
underlying cause(s) of such nonconformances.
SC Contention 15.
Interrogatory No. 20 20.
(a) Quantify "sufficiently detailed to provide statis-tically valid data," and (b) set out the basis for the quan-tification.
Answer The phrase "sufficiently detailed to provide statistically valid data" refers to the systematic physical audit of design and QA documentation against physically inspectable structures and components.
This physical audit and design verification should be sufficiently detailed to provide statistically valid data to permit projection of the audit results to reactor systems beyond those systems and QA records inspected.
SC contends that an independent audit should be performed that provides quantitative measures to assure that NRC I&E audits can be statistically correlated to provide verification of the adequacy of the QA system to detect systematic failures.
The sample size should be at least sufficient to permit 95 percent confidence of 95 percent reliability (i.e.,
the Marble Hill criteria accepted by the Staff).
The County does not propose any one quantitative measurement process as uniquely preferable over others; however, it believes that the types and/or methodologies used for systematic product quality control would serve as appropriate guidance for the Shoreham QA and Inspection programs.
A SC Contention 16 Interrogatory No. 21 21.
(a) What specific changes in Shoreham's equipment 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?
Answer The discussion at the Prehearing Conference and the revision to this Contention adopted by the Board completely answers this Interroga to ry.
SC Contention 17 Interrogatory No. 22 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?
Answer If LILCO documents to the County's satisfaction (including necessary inspections) that it will take the steps set out in Section III.J (Fire Protection) of the Sixth Stipulation and Settlement of Suffolk County Contentions, the concerns set forth in subpart(a) of SC Contention 17 would be resolved; however, those set forth in subpart(b) of that Contention would not be resolved.
Interrogatory No. 23 23.
If not, state precisely (a) what other steps the County thinks are important to safety, and (b) why they're important..
o.
4 Answer The concerns set forth in contention 17(b) would be resolved if LILCO were to install manual fire alarms in the machine shop area at elevation 15 feet.
The County's position as to why manual fire alarms in the machine shop area are important to safety is clearly outlined in the language of Contention 17(b).
To reiterate, the County is concerned that a lack of manual alarms in this area of the plant may impede rapid personnel notification of a fire.
This area of the plant contains flammable, toxic and hazardous materials since it includes the paint room, oil room, welding room, and blast area and is immediately adjacent to Shoreham's battery switchgear room.
The County does not consider telephone reporting to be an adequate substitute for manual fire alarms in this area.
Further, the County has not been provided with any evidence that without the presence of manual fire alarms, a fire in the machine shop could not or would not adversely affect any structure, system or component important to safety at Shoreham.
SC Contention 18(b)
Interrogatory 24 24.
What is the safety significance of knowing why an annunciator is lit?
Answer Annunciator warning systems are the primary means of alerting the control room operator to out-of-tolerance changes in plant conditions.
Annunciatory warning systems consist of three. - _ _ -
major subsystems:
(1) an auditory alert subsystem; (2) a visual alarm subsystem; and (3 ) an operatory response subsystem.
Because the primary task of an operator is to maintain cognizance of plant status and processes, the annunciator system must alert him in a timely manner to major and minor changes in plant conditions.
Once the operator's attention is obtained, he must be given the means to determine the nature of anomalies or transient conditions, to diagnose symptoms, to assign priorities to corrective courses of action, and to take corrective control actions.
Beyond this he must confirm the effectiveness of his actions and restore the warning systems to a state of readiness to respond to any subsequent problems.
Because operator e f fectivenes s is directly related to the annunciator warning system, it is of crucial safety significance that an operator know why an annunciator is lit.
Experience has shown that, in a major accident, Shoreham's annunciators could come on in such numbers that it would be difficult if not impossible for an operator to read, much less absorb, the meaning of all the annunciators, and that as a result, they may be deliberately ignored. (Kemeny, 1979).
During such transient conditions, shifts to different power levels, shutdowns, startups, and other out-of-the ordinary conditions, the large number of annunciators that would come on could easily mislead or confuse the operator ac to which situation requires immediate response.
This situation is compounded because Shoreham's annunciators have no first-out capability and safety-related annunciators could be masked by annunciators not requiring action.
Further, some annunciated indicators tell the operator that either a high or a low setpoint has been exceeded, but not which one.
In some cases, an annunciated indicator could mean that one of four possible conditions exists.
Acknowledgment of a flashing annunciator light will cause the annunciator to go to a steady-on state and to blend in with all the others in the steady-on state.
This can result in a loss of information and operator error.
Since annunciator status changes over time both during the course of a shift and even while licensed operators are out of the control room, when they resume operation it is sometimes difficult to determine at an instantaneous glance which annunciator was previously lit.
If multiple alarms causing more than one annunciator to flash at a single time, or the operator presses the acknowledge button without thinking, annunciator alarm importance is lost.
- Thus, the potential exists for both an under response to something that is potentially more serious or an over response to something that is significantly less serious.
SC Contention 18(d)
Interrogatory No. 25 25.
Please answer Questions 8-11 on page 3 above, concerning SOC Contention 7.A(2).
8.
What is the basis for SOC's conclusion that Shoreham's computer is of " low reliability"? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
i.
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 readily visible," and (b) where does SOC think the computer printout should be located?
Answer 8.
The computer system described in the Shoreham FSAR is a non-redundant, single main frame computer of a G.E./Honeywell design dating back to the
'60's.
It does not have the advantage of large scale integration and fewer number of components which tends to improve reliability and availability of modern computers.
The system has been in operation for many years, despite the fact that the plant has not reached fuel load.
9.
The G.E.
process computers have had problems in tracking the progress of accidents in other plants.
Their priorities and output rate have been such that they are not able to keep up with the sequence-of-events log print out that would be required to permit full operator access to the accident s eque nce.
10.
" Timely information" refers to the operator having quick access to the print out of the sequence of events log following a major transient or accident.
If the computer buffers are filled, there may be information which would not be added
- .o the log with its time of occurrence and, therefore, would be lost.
This, in effect, would preclude timely access to the data..-
o.
i 11.
It is the computer printout located on the row of tables in front of the bench boards but behind an operator's normal operating stations at the panel which is referenced in this Contention.
In addition, the operator must go around behind the table to be facing the printout.
The County has not taken a position on where to relocate the printer, nor is it our place to propose design details for LILCO.
SC Contention 19(a)
Interrogatory No. 26 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."
Answer The County is unable at this time to list each procedure believed to be inconsistent with the training program and/or not plant-specific, because the County has not yet received from LILCO the relevant updated procedures.
However, a specific example of such a procedure that has been made available to the t
County is described below.
l Shoreham Procedure 39.005.05 (08/07/78) Control Room Pre-l Fire Plan (the " effective" procedure provided to the County in 1980) states at 5.2.4 that CO 2 is the most desirable extinguish-ing material in order-of-preference; dry chemical is second; and I
water is the least desirable for a control room fire.
Although CO2 is stated in the procedure as the preferred extinguishing material for control room fires, CO2 is not listed in the Firefighter's Basic Course Training Manual (p. E-28, the " Fire,
o, s
o Extinguisher Selection Guide") as the correct extinguisher for Class A fires (ordinary combustibles such as wood, paper, etc.,
which are listed as primary control room combustibles in Table 1 of the Fire Hazard Analysis Report).
Rather, dry or wet chemical extinguishers are listed in the training manual as the correct extinguishing method.
However, Appendix 7.1 "Available Fire Fighting and Emergency Equipment" of the same procedure does not list any dry chemical extinguishers in the control room.
[ Note:
The County acknowledges that LILCO has since stated its intention to provide dry chemical extinguishers in the Control Room; however LILCO has not provided documentation of this to the County, nor of any other training or procedural changes in this regard.]
Furthermore, except for the 4 CO2 extinguishers listed in Appendix 7.1 of the procedure, the only other extinguisher listed for the control room is water, which is stated to be the water hose reels located at elevation 44 feet (the Control Room is at elevation 63 feet).
[ Note:
The County acknowledges that LILCO has since provided water hose reels at the Control Room eleva-tion; however LILCO has not provided any updated procedural documents in this regard.]
In addition, not all fire protection procedures seem to be current or completely adequate.
For example, in NRC I &E Ins pe ction 50-322/82-03 2 (a) and (b), numerous fire protection /
prevention procedures wara identified as still being in the process of development and several were determined by the inspection to be inadequate.
More specifically, I & E 50-322/82-25 -
03b states, "The inspector determined the following procedures to be inadequate as follows:
SP-39.500.03 entitled " Fire Protection Program Training".
The procedure does not address firefighting strategies for safety-related areas and the use thereof in brigade training.
SC Contention 19(b)
Interrogatory Nos. 27 and No. 28 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."
Answer SC is unable to answer these Interrogatories at this time because LILCO has not yet provided the County with copies of the procedures that are relevant to these issues.
SC Contention 19(c)
Interrogatory No. 29 29.
Identify (a) each instance in which the County thinks the " human factors" implications of responding to emergency procedures have not been adequately checked," and (b) explain the basis for each such conclusion.
Answer Based on documentation currently available to SC, such as the Control Room Design Review conducted by the NRC Human Factors Engineering Branch, Suffolk County believes that there are s
numerous instances in which the human factors implications of responding to emergency procedures have not been adequately checked.
The County is unable at this time to provide a complete and specific listing of each such instance because LILCO has noc made the pertinent documents available to the County.
l SC Contention 19(d)
Interrogatory No. 30 30.
List the procedures by title and number that the County thinks, "are keyed to annunciators."
Answer Based on documentation currently available to Suffolk County, such as the Control Room Design Review conducted by the NRC Human Factors Engineering Branch, the County has substantial reason to believe that various Shoreham procedures are keyed to annunciators; however, at this time the County is unable to provide a complete and specific listing of such procedures because LILCO has not yet made the pertinent documents available to the County.
SC Contention 21(a) - (e)
Interrogatory No. 31 31.
In light of Shoreham's Design Analysis Report, Revision 5 (December 16, 1981), which was sent to the County or. (January 15, 1982), which of the concerns set out in subparts (a) to (e) of this contention remain, if any?
Answer The concerns set out in subparts a, c,
d, and e remain.
Interrogatory No. 32 32.
If any remain, as to each, why does the County think that it has safety significance?
Answer The NRC's SER Supplement No.
2, NUREG-0420, issued March 12, 1982, still lists several " outstanding Issues" related to Mark II Containment adequacy.
These include pool dynamic loads and suppression pool bypass.
In addition, downcomer fatigue analysis, seismic and LOCA loadings, steam condensation oscillation and chugging loads, and steam condensation submeged drag loads are all listed as resolved, "pending confirmation."
Additionally, SC is aware of a Board Notification, BN82-09, advising of concerns expressed by an NRC consultant on Mark II loads.
SC also is advised of an April 8, 1982 Mark II owners '
meeting in Bethesda to discuss with the NRC their response to the consultant's concern.
These facts document the unresolved nature o f the Mark II LOCA loads, as well as their safety significance.
Interrogatory No. 33 33.
Identify any documentary evidence known to the County that supports this claim.
Answer Omitted by agreement of counsel.
SC Contention 23 Interrogatory Nos. 34 and 35 34.
What is the basis for the claim that "[v]alve configuration and functionability relating to leak rate and inter-system leakage testing have not been sufficiently demonstrated"?
35.
Precisely which valves and penetrations are of concern?
Answer Suffolk County believes that sufficient leak rate and inter-system leakage testing has not been demonstrated based on information currently available concerning the resolution of 10 C.F.R. Part 50, Appendix J, Type C Leak rate testing for isolation valves located below the suppression pool water level.
LILCO met with the NRC Staff on March 5, 1981 to discuss the addition of 45 valves located below the suppression pool level to the Leak Test Category C per 10 C.F.R. 50, Appendix J.
The presentation made by LILCO at that meeting was preliminary and unconvincing.
To our knowledge, this issue has not been demonstrated to have been adequately resolved.
See notice of meeting transmitted by J.
Wilson's March 3, 1981 Memo to B. J.
Youngblood for reference to this topic.
The County is unable to provide a more specific response to this interrogatory because it has not yet received from LILCO updated information on this issue.
SC Contention 24(b)
Interrogatorv No. 36 36.
Identify the " analytical evidence" referenced in the second sentence of this contention.
Answer This is a quotation from NUREG-0619,
- p. C-12, and refers to the evidence discussed in that document.
e SC Contention 25 Interrogatory No. 37 37.
Identify all of the documentary evidence, if any, thct the County has to support the claims made'in this contention.
Answer Omitted by agreement of counsel.
Interrogatory Nos. 38 and 39 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 pressure boundary do not provide an adequate baseline to which the ISI results can be correlated?
Answer SC does not know what exemptions LILCO.has or will seek because the details of the ISI program have not yet been issued in the FSAR (no Technical Specification issued).
SC repeatedly 4
has requested copies of draft Technical Specifications in informal discovery meetings during 1981 but LILCO refused to respond until the final Specifications become available.
LILCO did provide the NRC Staff some preliminary information on this in response to Request 121.21 (June 1980).
This response stated that compliance to ASME Section XI would be committed "to the extent practical".
Exemptions known at that time were identified t
in Appendix A, Table A-1.
If the ISI exemptions have not yet been fully identified, adequacy of the PSI to assist in overcoming such shortcomings cannot be judged.
o, SC' Contention 26 (a)(i) ~
Interrogatory No. 40 40.
In what relevant areas does the County think " low cobalt materials" were not used?
Answer SC believes that the use of low-cobalt materials has not been specified in any of the components making up the reactor coolant pressure boundary or in reactor interval components, such as, for example, control rod drive tubes.
This is also true of valve seats and discs located within the coolant boundary and of piping, valves, pumps, and feedwater heaters in the feedwater flow path.
The result.is that input of cobalt and other isotope production m.aterials to the reactor core has not been minimized.
SC Contention 26(a)(ii)_
Interrogatory No. 41 41.
Precisely identify the "various components and piping systems" that'the County has in mind.
Answer SC is specifically concerned that LILCO has not demonstrated that a' complete and thorough study of maintenance requirements on primsry system components has been performed and physical arrangements of the plant have been optimized to maintain occupa-tional exposure to the ALARA level.
Components of concern include nozzles and safe-ends, recirculation piping, valves and pumps, control rod drives, safety and safety relief valves, isolation and maintenance valves in and out of primary.
containment, and mechanical and electrical components requiring periodic maintenance and located in the drywell and steam tunnel.
In addition, components and piping in the radwaste system that are of concern to SC relative to isolation and separation are those components and pieces of equipment delineated in the figures included in Sections 11.2 and 9.3 of the FSAR.
Our concern is the inability to isolate these components or piping systems.
As a result, there is no assurance that maintenance personnel will be protected against sudden radiation doses or contamination resulting from inadvertent discharges through components and piping systems in the areas where they are working due to insufficient isolation due to lack of block valves.
SC Contention 26(a) (iii)
Interrogatory No. 42 42.
Precisely identify (a) which " provisions for flushing i
or decontamination" of (b) what aspects of Shoreham.
Answer The provisions for decontamination and flushing at Shoreham that should be identified are those specific taps, drains and i
vents that are provided for cleaning " stagnant" piping connecting systems to the reactor, the reactor water coolant clean-up system lines, liquid radwaste system components, and fuel pool clean-up lines.
Included in those provisions should be any specific taps for cleaning elbows, stainers, difficult position valves or other pieces of equipment that might require special attention as a result of past experience in other plants (such as recirculation...- -.
e i
loop low points).
The design provisions should be coordinated with the flushing or decontamination procedures that are currently in existence for those systems for Shoreham.
SC Contention 26(a)(iv)
Interrogatory No. 43 43.
Precisely identify the County's " equipment layout and a rrangement" concerns.
Answer The County is concerned specifically about equipment that is doubled or tripled up within cubicles and therefore is less accessible for maintenance than equipment that is separately isolated.
Examples of equipment that could present potential 1
maintenance problems with respect to ALARA are (1) the fuel pool clean-up pumps, (2) the reactor coolant water clean-up system heat exchangers, (3) pumps in the radwaste building, (4) certain valves within valve stations that are less accessible or tightly located behind shield walls or block walls and mechanical and electrical equipment that requires periodic maintenance and is located in the drywell or steam tunnel.
The valves of primary concern are those in the liquid radwaste system, the reactor, or spent fuel pool clean-up systems.
SC Contention 26(a)(v)
Interroga tory No. 44 44.
(a)
Quantify the " minimum number of shell connections" referenced in the Contention, and (b) explain why Shoreham's actual number of shell connections poses a problem.
Answer (a)
Suffolk County is currently reviewing similar plants to determine a quantified minimum number.
(b)
Shell connections add to the potential for air in leakage.
Air in leakage can increase corrosion.
SC Contention 26(b)(i)-(iii)
Interrogatory No. 45 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.
Answer (i)
Water Chemistry Controls SC contends that water chemistry control measures similar to those taken at the Tsuruga plant should be incorporated into Shoreham's procedures.
The Tsuruga procedures which SC finds I
acceptable were established to accomplish the following:
(a)
To control dissolved oxygen in the feedwater.
The iron concentration in the feedwater at the Tsuruga plant was suppressed to 2 to 3 g/kg by controlling the dissolved oxygen concentration in the range of 20 to 100 g/kg.
(b)
To prevent corrosion during long outages, including procedures for re-start, shutdown of the feedwater system and storage during an extended shutdown.
The recirculation of the coolant through the condensate demineralizer and hot drainoff of the feedwater system for the dry storage were adopted. _.
0 (c)
To control the operation of the reactor water cleanup system, which would assure a removal efficiency of over 90 percent.
(d)
To control the operation of the condensate demineralizers so as to assure a removal efficiency of over 90 percent.
The implementation at the Tsuruga plant of these measures against corrosion reduced the concentration of corrosion products in the reactor and cut the radiation doses significantly.
(ii) monitoring and control of occupation radiation.
(iii) Action to reduce radiation levels and/or exposure if the in-plant totals significantly exceed U.S.
plant averages.
(ii) & (iii)
This subject was discussed with LILCO in discussions concerning the " Sixth-Stipulation."
The limits SC feels are applicable are contained in the contention wording; the basis of SC's concern is lack of demonstration that minimization of dose to each individual worker will not be ensured unless LILCO commits to such a program in advance, and agrees to monitor same as the radiation levels increase with plant operation.
Procedures should be implemented at Shoreham for routine study of changes in radiation doses during Shoreham specific maintenance.
Actions to modify procedures to decrease radiation doses should be documented and evaluated against potential exposures.
Procedures should also be implemented to determine the trigger levels for the decontamination of systems or components l !
i if required based on changes in design working dose levels, (i.e.
if an area changes from a level three to a level four area).
SC Contention 28(a)(i)
Interrogatory No. 46 46.
Please answer questions 1-3 on page 2 above, regarding SOC Contention 7.A(1).
i 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" in line 13?
Answer 1.
No.
2.
The responses referenced in SSER-1 and the NEDO document discuss why LILCO feels there is no need to change the existing logic.
However, the arguments put forth by LILCO for not changing the system logic are limited as to the number of outstanding influences, equipment failures, operator errors, and equipment access problems which are considered.
The automatic logic is needed to assure safe operation under the above conditions and the unexpected conditions which may not have been analyzed.
3.
The plant conditions referred to are those including outs ide influences, equipment failures, operator errors, and difficulty in obtaining access to necessary equipment..
SC Contention 28(a)(ii)
Interrogatory No. 47 47.
Please answer Questions 4-11 on page 3 above, regarding SOC Contention 7.A(2).
4.
Shouldn' t the second sentence of this subpart be rewriten to state:
The SRV pressure and temperature indicators and the annunciator are not located in a manner consistent with reliable and safe operation?
5.
Is the contention based soley on Findings 7.3, 7.6 and 7.7 of the NRC Control Room Design Audit?
6.
If the answer to question 5 is other than an unqualified yes, specify (a) how the pressure and temperature indicators and the annunciator's locations are not consistent with reliable and safe operation, and the source documents relied upon for support of the contention.
7.
Doesn't SNRC-605 (July 23, 1981) resolve the concern about the annunciator's location?
8-11 See Interrogatory No. 25.
Answer 4.
Yes.
5.
No, it is based on the personal review of the control room by SC consultants, as well as the findings of the control room audit.
6.
The concern is that the SRV controls are on the left hand side of the benchboard, but the related annunciators and indicators are not in the area above the controls.
Thus, the operator must move between several stations at the panels to
- --. _ =
=,
obtain related information or rely on verbally relayed information.
These observations were corroborated at the most recent site tour on March 11, 1982.
We have asked for up-to-date I
panel drawings but have not yet received them.
I 7.
If LILCO is referring to NRC Finding 7.5 as addressed in SNRC-605, there is insufficient information to conclude that it resolves the concern about location of SRV annunciators.
It states:
NRC Finding 7.5 Controls related to annunciators on annunciator panel "E" MCB are located remotely on Panel MXP. (2) (5.4)
LILCO Response Controls will be relocated prior to Fuel Load using the guidance of the final issued version of NUREG-0700.
However, ' there is no indication that SRV controls or annunciators will be relocated or, if they are, where they will be finally located.
8-11 See Answer to Interrogatory No. 25.
i SC Contention 28(a)(iii)
Interrogatory No. 48 48.
Please answer Questions 12-15 on page 3 above, regarding SOC Contention 7. A. (3 ).
12.
Which iodine monitors does SOC contend are inaccessible?
13.
Where does SOC think these monitors should be located?
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"?
Answer 12.
The Intervenors are concerned with the iodine sampling and with the monitors provided to measure iodine releases in the gaseous effluent streams, particularly the plant vent or the vents leading the main plant vent.
However, recent changes in the location of these sampling and monitor locations have been identified in SSER-2, although also, on the March 11, 1982 site tour, no drawings were available to show the new location, but LILCO promised to provide such drawings to the County.
Pending review of these documents, SC reserves its judgment on the
' adequacy of the new design and location.
13.
The Intervenors are under no obligation to provide LILCO with design details regarding monitor locations.
14.-15.
The iodine monitors identified in II.F.1 of NUREG-0737 are required by Appendix B of NUREG-0737 to be powered by a Class IE bus and to be available following accident conditions.
The vital bus meets these conditions.
SC Contention 28(a) (iv)
Interrogatory No. 49 49.
Please answer Questions 16-19 on pages 3 and 4 above, regarding SOC Contention 7.A(4).
16.
Why does SOC think that GDC 13 requires a Safety Parameter Display Console?
17.
Why does SOC think that Item I.D.2 of NUREG-0737 requires a " safety-related" computer system?
a, i
18.
Define exactly what SOC means by "high reliability" 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.
Answer 16.
GDC 13 requires, in essence, that adequate instrumentation be provided to permit safe operation of the plant under nornal and accident conditions.
The Safety Parameter Display Console is one means of accessing plant data for use in the decision process during or following an accident.
The decisions must be based on reliable and readily available information.
Since the SPDC may be the source of information used in mitigating an accident or its consequences, it too is covered by the GDC 13 requirement.
17.
Instruments required "to assess plant Safety status" (NUREG-0737, Item I.D.2) during and following an accident may serve the function of helping to decide upon the actions required to protect the reactor coolant boundary or to bring the plant to safe shutdown.
These are functions worthy of a high reliability, safety-relateu system, even as an interim resolution.
18.
The normal techniques of assuring the reliability of systems or components serving a role of safety significance is to provide redundant and/or diverse devices with appropriately high reliability power supplies.
LILCO's proposed interim SPDC is an add-on to the existing process computer which is not safety-grade nor is it redundant.
l 19.
The term " safety-related" is used as defined in Harold Denton's Memorandum of November 20, 1981.
[See Exhibit 1 to March 1, 1982 Suffolk County Response to Licensing Board Memorandum and Order dated February 8, 1982].
SC Contention 28(a)(v)
' Interrogatory No. 50 50.
Please answer Questions 20-24 on page 4 above, regarding SOC Contention 7.A(5).
20.
Doesn't SNRC-647 (Dec. 9, 1981) resolve the concern stated in the first sentence of this contention?
21.
If not, precisely (a) what issue remains, and (b) why docs it remain?
22.
List all " worst case conditions" SOC refers to in 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?
Answer 20.
SNRC-617 references NEDO-24988.
However, the non-proprietary version of the NEDO has been altered considerably by removing most of the numerical data and leaving the conclusions without supporting information.
Thus, it is not postible to conclude that all the necessary tests were successfully completed.
However, the document does assert that tests are completed for a Target-Rock 2-stage valve.
21.
SNRC-647 contains little or no comparison to Shoreham as-built configurations nor are ATWS conditions covered.
i 22.
The worst case conditions would include ATWS, overpressure, LOCA, seismic and environmental extremes.
23.
The II.D.1 requirements require facilities for testing to ATWS conditions.
The ATWS resolution proposed by LILCO includes operation of the SRV's.
The valves must be tested to these conditions if credit is to be taken for their use as an ATWS mitigation technique.
24.
This is a matter for the Board to decide in conjunction with SC Contention 16.
SC believes that adequate ATWS protection for the interim period must be demonstrated before any operating license can be issued.
SC Contention 28(a) (vi)
Interrogatory No. 51 51.
Please answer Questions 25-27 on page 4 above, regarding SOC Contention 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 BWR 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."
Answer 25.
No.
26.
The main issue is that there is a need to reduce the number of times the reactor conditions require operation of the SRV's.
This is different from changing the design of the valve for more reliable operation when called upon to operate.
27.
The SRV's have traditionally been poor performers in terms of sticking open, leaking, or misoperating.
In addition, Target-Rock valves have had a lower than average performance among S RV 's.
SC Contention 31 Interrogatory No. 52 52.
Please answer Question 59 on page 8 above, regarding SOC Contention 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 7 Answer The physical independence of Class IE electrical systems as set forth in Revision 2 of Regulatory Guide 1.75 has not been demonstrated by LILCO for Shoreham.
First, in Appendix 3B of the FSAR, LILCO acknowledges that the electrical systems do not fully comply with even the earlier revisions of Regulatory Guide 1.75 due to the advanced stage of the Shoreham design at the time of issuance of the Guide in January, 1975.
Further, the NRC Staff's Safety Evaluation Report dated February 20, 1970 for the Shoreham PSAR precedes the implementation date provided in Section D of
- 43
3 the Guide.
However, LILCO did state that within the limitations imposed by the systens and equipment design, an effort was made, to the maximum extent nracticable, to comply with the Guide.
Suffolk County has requested LILCO, in the currently pending d iscove ry, to document the extent to which the Shoreham design conforms to the regulatory position (Paragraph C) of the Guide.
Second, the minimum separation criteria for Shoreham, as set forth in Section 3.12 of the FSAR, has not been uniformely complied with as documented in NRC Inspection Report 50-322/79-07, dated August 21, 1979, and subsequent reports from the office of Inspection and Enforcement.
The subsequent reports are set forth in the illustrations provided by SC in Appendix I to SC Contention 12.
Third, the NRC Staff acknowledged in a letter dated August 31, 1981, from Mr. Tedesco of the NRC to Mr. Pollock of LILCO, that deficiencies exist at Shoreham in the separation of electrical cables and raceways.
Options for resolving the deficiencies, as set forth in the four subparts of SC Contention 31, were suggested to LILCO by the NRC in the August 31 letter.
Most recently, in a March 15 letter from Mr. Schwencer of the NRC to Mr. Pollock of LILCO, the Staff suggested that LILCO adapt Options 1, 2,
or 3 as outlined in the August 31 letter rather than Option 4 which will require a specific analysis for each deficiency.
The potential safety significance of any deficiencies in achieving physical independence of electrical systems is obvious.
For example, Section 50.55a of 10 C.F.R. 50, requires.
in paragraph (h) that reactor protection systems must meet the requirements set forth in IEEE 279.
Section 4.6 of IEEE 279-1971 requires, in part, that channels that provide signals for the same protective function must be independent and physically separated.
In addition, GDC 3 of Appendix A to 10 C.F.R. 50 requires, in part, that structures, systems, and components important to safety must be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires.
Further, GDC 17 requires, in part, that the onsite electric power supplies, including the batteries, and the onsite electric distribution system, must have sufficient independence to perform their safety functions assuming a single failure.
Finally, GDC 21 requires, in part, that independence designed into protection systems must be sufficient to ensure that no single failure results in loss of protective function.
Thus, any noncompliance with the preceding requirements, could increase the probability of multiple failures which might initiate or contribute to increasing the severity of an accident.
Respectfully submitted, DAVID J.
GILMARTIN Suf folk County Attorney PATRICIA A.
DEMPSEY Assistant Suffolk County Attorney Suffolk County Department of Law Veteians Memorial Highway Hauppauge, New York 11788 a
e herbert H.
Brown Lawrence Coe Lanpher 3
Karla J.
Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036 (202) 452-7000 Attorneys for Suffolk County March 17, 1982 i
J 4
I l
.s UNITED STATES OF AMERICA NUCLEAR REGULATORY COhMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
)
Docket No. 50-322 (OL)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the "SUFFOLK COUNTY ANSWERS TO LILCO'S INTERROGATORIES" in the above-referenced matter have been mailed to the following on March 17, 1982 by U.S.
- Mail, first class, except as otherwise noted.
Lawrence Brenner, Esq.*
Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S.
Nuclear Regulatory Commission New York, New York 10016 Washington, D.C.
20555 Howard L.
Blau, Esq.
Dr. James L.
Ca rpente r
- 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission W.
Taylor Reveley III, Esq.*
Washington, D.C.
20555 Hunton & Williams 1919 Pennsylvania Ave.,
N.W.
Mr. Frederick J. Shon*
Washington, D.C.
20036 Administrative Judge Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Jeffrey Cohen, Esq.
Washington, D.C.
20555 Deputy Commissioner & Counsel New York State Energy Of fice Edward M.
Barrett, Esq.
Agency Building 2 Administrative Judge Empire State Plaza Atomic Safety and Licensing Board Albany, New York 12223 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Stephen B.
- Latham, Esq.**
Twomey, Latham & Shea Mr. Brian McCaffrey**
Attorneys at Law Long Island Lighting Company P.O.
Box 398 175 East Old Country Road 33 West Second Street Hicksville, New York 11801 Riverhead, New York 11901 i
o, Marc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc.
Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O.
Box 618
~
Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.
MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A.
Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David H.
Gilmartin, Esq.
County Executive / Legislative Suffolk County Attorney Building County Executive / Legislative Bldg.
Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I.
Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protectin Bureau U.S.
Nuclear Regulatory Commission New York State Department of Washington, D.C.
20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 of fice of the Secretary U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board U.S.
Nuclear Regulatory Bernard M.
Bordernick, Esq.*
Commission David A.
Repka, Esq.
Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 March 17, 1982 h
j v
Lawrence Coe LanpM'er KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036
- By hand
- Federal Express.
o.,,,,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
)
Docket No. 50-322 0.L.
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
AFFIDAVIT OF MARC W. GOLDSMITH The undersigned states under oath that he has reviewed and assisted in preparing the following Suffolk County answers to LILCO Interrogatories 1-8, 17, 22-30, 40-45.
To the best of my knowledge and belief, the foregoing is true and correct.
' // b!C. k-(I'}?ff/
Marc W. Goldsmith DISTRICT OF COLUMBIA:
Subscribed and sworn to before me this day of j) h k, 1982.
(
'\\
JJA9$
1 i
a 1
ev, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 0.L.
a
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
AFFIDAVIT OF RICHARD B. HUBBARD The undersigned states under oath that he has reviewed and assisted in preparing the following suffolk County answers to LILCO Interrogatories 9, 14-20, and 52.
To the best of my knowledge and belief, the foregoing is true and correct.
..;;.r i..S-i /;,,i Richard B.
Hubbard DISTRICT OF COLUMBIA:
Subscribed and sworn to before me h day of lAA Ow Lb,1982.
this I
\\
]A11A$
Y
~
t)
e TIIE AFFIDAVIT OF MESSRS. BRIDENBAUGli AND MINOR WAS DELAYED IN TIIE MAIL.
IT WILL BE SEPARATELY SERVED AS SOON AS IT IIAS BEEN RECEIVED.
1 l
l l
l l
!