ML20041G447

Forwards Corrected Copy of Restated Suffolk County Contention 18

ML20041G447
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/18/1982
From:	Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Brenner L Atomic Safety and Licensing Board Panel
References
NUDOCS 8203220311
Download: ML20041G447 (5)

Text

. t-  ? /

KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PAhindrs A PAmtmensurr Inctconwo A Paorses OmAs. COmPORATION 1900 M STREET, N. K 2 UAQ Jg pp , O WAI4HINGTON, D. C. 2OOOG TI3,IPHONE (SOS) 489 eTOOO IN FITTSBUBOE CABLE: NTFHI EIEEPATRIG IhGBASTedOWN00N & ECTCEISON Tsi.ex 4 0 0. nIF= or March 18, 1982 a* oss== =c="a WitTER'S DIRECT DIAL NUMBER FITTSBCEON, FENNETLTANIA 38998 (442) 866-8600 452-7064

.D k Lawrence Brenner, Esq., Chairman, #  %,

Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission p NECElygg g Washington, D. C. 20555 -

Re: In Re Long Island Lighting Company C a 44g1 B1982sh -

(Shoreham Nuclear Power Station) 4 Docket No. 50-322 g //

Dear Judge Brenner:

Inadvertently, the copy n'. restated Suffolk County Conten-tion 18 which was enclosed with our letter to you dated March 15, 1982, did not include the additional language inserted in sub-part (d) of that contention as reflected in our March 1 filing and approved by the Board at the Prehearing Conference. (See Suffolk County Response to Licensing Board Memorandum and Order dated February 8, 1982, at 17, and the Board's Memorandum and Order Confirming Rulings made at the Conference of the Parties (Regarding Remaining Contentions and Establishment of Hearing Schedule), dated March 15, 1982, at 21.) I have enclosed a corrected copy of restated Suffolk County Contention 18.

Sincerely,

/

/ '

C._ - 6 Karla J. Lets e' cc: Mr. Frederick J. Shon Dr. James H. Carpenter Service List - NRC Docket No. 50-322 h )

8203220311 820318 PDR ADOCK 05000322 O PDR

= .

SUFFOLK COUNTY CONTENTION 18: HUMAN FACTORS -- EQUIPMENT Suf folk County contends that LILCO and the NRC Staff have not adequately demonstrated and confirmed that the control room design at Shoreham is adequate to provide the timely control necessary to protect the health and safety of the public, and thus to satisfy 10 C.F.R. 50, Appendix A, GDC 13, 19, 20, 22 and

29. Specifically:

(a) There is no first-out alarm capability provided in the control room annunciator system that identifies the initiating events when multiple annunciator alarms occur. In view of this deficiency, the control room operator is forced to rely on the events computer for the needed information. The events computer is slow, not classified as safety-related, and not directly integrated with response procedures. Accordingly, a reliable and timely response to all plant failures cannot be guaranteed.

Further, the following, taken in conjunction with the above, are other defects such that the information for control room operators is not presented in a manner that facilitates the recognition of developing of f-nornal conditions and the mitigation of accidents:

(b) There is no audio or visual annunciator indication to l

t signal that an alarmed condition has cleared.

l (c) There is no indication why an annunciator is lit --

whether because the system is, in fact, inoperable due l

[

l L

s 4

to malfunction, or because it has been by-passed and is actually capable of functioning.

(d) The sequence of annunciator trips and events appears on the computer printer which is the only means available to communicate this information to the operator in the event of a major accident or transient. However, the events computer is slow, not classified as safety-related, and not directly integrated with response procedures. The non-redundant, low reliability plant computer has been shown to become overloaded by major accidents and to be incapable of supplying timely information on accident sequences. The computer print-t out is not readily visible and is poorly located for use by the operators under accident conditions.

Ac cordingly , a reliable and timely response to all plant failures cannot be guaranteed.

(e) The LILCO responses to the control room human factors audit report leave a considerable number of small l

equipment changes either delayed until fuel load, 1

deferred for long-term review or not made at all.

Individually, these equipment inadequacies do not appear to be significant; h oweve r, taken as a whole, l they could provide some serious operational l

l difficulties over time. Annunciator light failure f requency is unknown (Shoreham Safety Evaluation Report, Supp. No. 1 [SSER No. 13, Appendix C, Item 2.6) which, combined with lens problems (SSER No. 1,

Appendix C, Item 3.14), could lead to operator difficulties in visually detecting alarms. The following additional control room and control board problems, originally identified in the audit, have not yet been resolved:

(i) Ventilation in the control room (SSER No. 1, Appendix C, Item 2.1);

(ii) Background noise -levels in the control room

(" Human Factors Engineering Control Room Design Revi e# -- LILCO Response to NRC Audit Find-ings," dated 6/8/81 [ hereinafter referred to as

" Response to Human Factors Review"], NRC Find-ing 2.7);

(iii) Lighting level in the control room '(SSER No. 1, Appendix C, Item 2.2, and Reponse to Human l Factors Review, NRC Finding 2.3);

(iv) Security console in the control room (Response to Human Factors Review, NRC Finding 1.2);

(v) J-handled switches on the front row of control panels (SSER No. 1, Appendix C, Item 4.1);

(vi) Mirror image on IRM selectors (Reponse to Human Factors Review, NRC Finding 4.3);

(vii) Location of ADS service air controls (Response l to Human Factors Review, NRC Finding 6.12);

(viii) The range of the Reactor Water Level display (SSER No. 1, Appendix C, Item 6.17);

l _ _

t ... .

~, ,,

r (ix) Strip chart recorders (SSER No. 1, Appendix C, Items 10.1, 10.2, 10.3 and 10.4, and Response i to Human Factors Review, NRC Findings 10.1 through 10.9); and (x) Reactor mode switch and key location (SSER No.

1, Appendix C, Item 4.13).

t

(

i l

i f

i f

1 i

t f

1 i

a 1

l 1

1 I

e

_ _ . . _ . . . _ . . , . , _ _ _ _ _ _ , _ . . _ . _ _ _ _ _ . _ . _ _ _