ML20042A120
| ML20042A120 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/17/1982 |
| From: | Flanagan D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SHOREHAM OPPONENTS COALITION |
| References | |
| ISSUANCES-OL, NUDOCS 8203230110 | |
| Download: ML20042A120 (20) | |
Text
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March 17, 1982 2:7 re,
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'n,n 19 r 7.g3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
A LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322(
(Shoreham Nuclear Power Station, )
S (Unit 1)
)
RECElVED p
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MAR 2 21982m- :
' UICIiJ tear:n ew RESPONSE OF LONG ISLAND LIGHTING COMPANY TO SOC 'S MARCli 1, 1982 INTERROGATORI AND REQUESTS FOR PRODUCTION OF DOCUMENTS Ngw as
//
1) pi I.
The Shoreham Opponents Coalition (SOC) addressed to Long Island Lighting Company (LILCO) certain discovery requests in its Fourth Set of Interrogatories and Request for Production of Documents, dated March 1, 1982.
LILCO's response to those discovery requests appears below; an affidavit is attached.
II.
SOC Contention 3 As noted in LILCO's objections to SOC's discovery, filed on Furch 15, 1982, questions 1, 2,
3, 4,
15, 18 and 19 are overly broad.
Where the information requested by SOC was not readily available, LILCO's response has been limited to the eleven categories of instruments listed in the Contention.
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. 1.
The following correspondence is responsive to this requests (a)
GEC - 366, letter from Brian R. McCaf f rey (LILCO) to J. W. Blakely (GE) dated September 1, 1981 (a copy is attached).
(b) the material referenced below in response to SOC's interrogatories on contention 8.
2.
A new Table 1 dated March 3, 1982 has been developed to clarify and replace the tables that accompanied LILCO's July 13, 1981 motion for summary disposition.
LILCO has also pre-pare. a table cross-referencing the Revised Table 1 to a
Regulatory Guide 1.97, Revision 2, Table 1.
Copies of both tables prepared by LILCO are attached.
3.
See the attached Revised Table 1.
4.
Attached is a summary sheet of the Regulatory Guide 1.97, Revision 2, Table 1, Type A equipment requirements.
Further details on Type A equipment that is the subject of this conten-
[
tion will be made available for SOC's counsel and consultants to review at their convenience.
5.
Calibration of the Radiation Monitoring System, including the continuous iodine monitor, is currently is progress.
For continuous iodine monitoring on the station vent l
(RE-042), the system has an ultimate calibrated sensitivity of
~I1 7.17 x 10 Ci/cc.
This monitor would be able to detect a i
release of this concentration within one hour; higher i
. concentrations would be detected in proportionately shorter time periods.
Additionally, this monitor is provided with a derivative f unction which will alarm at an excessive rate of buildup of I-131 on the charcoal cartridge.
During calibration of this monitor, a standard I-131 source, having a certified activity with an accuracy of + 5 percent (traceable to the National Bureau of Standards) was deposited in a charcoal car-tridge.
In estimating the uncertainty for the amount of iodine released, an estimate of the variance of the relevant physical parameters must be known in addition to the accuracy of the sampling system.
For example, the variation in the exhaust flow must be known and will be determined as part of the pre-operational tests.
An error analysis program is used to obtain a probable upper bound on releases to the environment.
Attached is a copy of " Error Analysis Report," TDR -120.
For those ef fluent monitors with only a charcoal cartridge that must be measured off-line, a radiochemical laboratory is available on-site for rapid determination of iodine releases l
during an accident.
(See LILCO's responses concerning SOC Contention 7.A(3) for more detailed infonnation -'out iodine monitors.)
The frequency of sample-taking is deilne d within the site emergency procedures and is dependent on the maga.itude of the release.
I
. 6.
Iodine will be emitted from the plant either through the station vent or the RBSVS release point.
The monitors used for these release points are discussed in LILCO's responses con-cerning SOC Contention 7.A(3).
Potential leakage through paths such as venting from auxiliary detrainir.g tank, H seal oil 2
vacuum pump separator tank, or turbine lube oil reservoir tank is not considered to be any greater than through curtain walls I
in the radwaste or turbine buildings, or doors opening and closing.
These leakage quantities are genuinely insignificant j
compared to the building ventilation exhaust air flows (366,000 CFM) continuously monitored and sampled by the previously dis-cussed instruments.
7.
LILCO already has available adequate iodine monitoring equipment and does not believe new equipment is necessary.
LILCO is aware that Science Applications, Inc. has developed an on-line t real-time) Isotope Ef fluent Monitor.
Further research l
is needed to determine if this unit meets applicable regulatory requirements.
8.
Objected to, for the reasons stated in LILCO's Objections i
to SOC 's Discovery Requests and Motion for a Protective Order, dated March 15, 1982, at 2.
9.
Attached is SNRC-623, dated October 3, 1981, forwarding LILCO's Emergency Operating Procedures for Shoreham to the NRC
. Staff.
As can be seen from the Emergency Operating Procedures, none of them require entry into the Reactor Building.
10.
See 9 above.
11.
Two types of radiation monitoring equipment will be available in the secondary containment:
(a)
Nineteen normal range ARM's that read out in the main control room will be provided.
If these main meters are off-scale on the high end of their range, entry into the secondary containment will not be permitted.
(b)
The portable instrumentation included in Regulatory Guide 1.97 will be provided.
See the Revised Table 1 (items 44, 45 and 46) referenced in 2 above, the FSAR Table 12. 5 -5, and the response to 16 below.
12.
It is not at all clear what SCC means by "the state revised criteria."
It appears SOC may be asking LILCO about its criteria for deciding Whether or not to put ARM's in the l
LILCO believes that ARM's are not needed for Shoreham because entry into the secondary contain-ment is not required during an accident.
Normal range ARM's are provided at Shoreham.
Further information will be available when the BWR Owners Group completes its review of l
l this issue.
13.
The portable equipment used for sanpling halogens and par-ticulates on site will be stored in various health physics con-trolled access locations, not in the Reactor Building.
l l
I I
l
. 14.
See 12 above.
15.
See the information on implementation dates included in Revised Table 1, referenced in 2 above.
16.
One (1) portable high range monitor, Technical Associates Model CP-TP-10K or an equivalent, will be availabic.
Its ranges will be 0-10, 0-100, 0-1000 and 0 -10,000 R/hr.
17.
( a)
Design information for Chloride, Pli, and Baron Analyzers is presented in FSAR Section II.B.3 for measurement range and accuracy.
Reliability of these instruments is re-stricted by the f act that black power (non 1E) is used.
Consequently, no special reliability requirements were incor-porated into procurement technical requirements.
Radiation resistance requirements (10 rads t.I.D.) were included in these procurement documents.
The vendor for these instruments (Orion) has not performed testing to verify reliability under radiation conditions, since such testing is not called for in NUREG-0737 or Regulatory Guide 1.97.
The equipment is, how-ever, constructed of materials with proven radiation resis-tance, so that no constituent part would be expected to dete-riorate in a manner detrimental to operation following an acci-dent.
The sampling rates for the Boron /Ph Analyzer and Chloride Analyzer are 40 ml/ min and 50 ml/ rain, respectively.
. Certification of compliance with the requirements of the procurement document is obtained from the vendor.
(b)
The shiciding for the Post Accident sampling facility was developed in accordance with radiation exposure limitations committed to in FSAR Section II.B.3 for habitability (5 rem whole body, 75 rem to extremities).
In satisfying this requirement it is found that background levels for proper oper-ation of radiological equipment are also maintained (after accounting for self-contained shieldir.g). -In addition, maintainability and operation of cohtrol panels and valving has been considered with respect to shielding.
18.
As limited to the scope of this contention, this question involves items 14, 17, 17A, 23, 23A, 37 and 41 on Revised Table 1,
referenced in 2 above.
As to item 14, see the answers con-cerning SOC Contention 8 below.
As to items 17 and 17A, see 9 and 12 above.
And as to the remainder, the BWR Owners ' Group position has not yet been completed.
19.
As noted in LILCO's objections to these interrogatories, g
filed March 15, 1982, SCC Contention 3 is limited to eleven specific types of instrumentation.
In looking at that list, it appears the question may be directed towards SOC's previously expressed concerns about radioactive noble gas emissions f rom the plant.
For the answer to this question, see 6 above.
. SOC Contention 6(a)(1) 1.
through 6.
Objected to for the reasons stated in LILCO's Objections to SOC's Discovery Requests and Motion for a Protective Order, dated March 15, 1982, at 2 -3.
SOC Contention 7.A(1)
- 1. and 2.
A discussion of the resolution of NUREG-0737, Itera II.K.3.21, is contained in a BWR Owners Group Evaluation enti-tied " Core Spray and Low Pressure Coolant Injection Systems Low Level Initiation."
The information contained in this eval-uation is found in NEDO-24951, a copy of which was sent to SOC on February 23, 1982.
SOC Contention 7.A(2) 1.
The justification and reasoning applied for the high-priority items in the original control room audit report is explained in SNRC-585 and SNRC-605, sent to SOC on February 23, i
1982.
2.
As a result of the recent LILCO/NRC meeting on Humen
- Factors, (a) communication equipment will be added to the security I
l console to eliminate physical interference between the control room operator and the security console operator; t
I l
f
. (b) the flashing -99.99 on CRT displays will be changed; and (c) certain annunciators on Panel G on the main control board will be re-engraved to eliminate confusion with the SRV's.
These changes will be detailed in a letter to the NRC, presently being drafted.
A copy of that letter will be forwarded to SOC.
3.
Yes.
4.
Sec SNRC-585, Findings 7.3 and 7.6, sent to SOC on February 23, 1982.
5.
Not applicable.
6.
Up-to-date, as-built drawings of the ADS and SRV equipment locations are attached.
7.
The availability of the process computer was not speci-fied.
I 8.
A new high speed printer will provide a sequence of events.
See SER, Supplement 1, Appendix C, Item 9.6.
9.
The Shoreham Nuclear Power Station is not required to meet l
the criteria of NUREG-0700.
Accordingly, the question of which 0700 criteria were applied to the Shoreham Control Room audit I
f is irrelevant.
We do not know the extent tc which the NRC incorporated NUREG-0700 criteria into its Control Room audit; L
n i
i
. the General Physics audit was conducted before the advent of NUREG-0700.
A supplement to the General Physics audit, attached, shows which design criteria were not explicitly con-sidered.
That they wcre not considered does not mean that SNPS does not meet them.
10.
The General Physics audit together with the NRC audit pro-vides an adequate basis to assess the Human Factors design of the Shoreham Control Room.
11.
We do not have a list of criteria applied in the NRC Control Room audit.
SOC Contention 7.A(3) 1.
LILCO's position on the location of iodine monitors is contained in SNRC-655, dated January 7, 1982, sent to SOC on February 23, 1962, and SNRC-669, dated February 17, 1982, attached.
2.
As indicated in the material attached to SNRC-669, a new l
post-accident monitor for the station vent (RE-126) and the post-accident monitor for the RBSVS (RE -139 ) are now located in i
the Turbine Building.
SOC 7. A(4 )
i 1.
The reliability and availability of the plant computer, 1
which runs the interim SPDS, is unspecified.
l
. 2.
Yes.
The interim.SPDS is dependent on the plant process computer for data acquisition, processing, and display genera-tion.
3.
The description of the permanent SPDS was attached to SNRC-643, not SNRC-5d5.
That attachment is enclosed.
SOC Contention 7A(5) 1.
Copies of documents and correspondence that describe the tests and results of the Safety / Relief Valve testing for BWR's and for the Shoreham plant were sent to SOC on February 23, 1982 and Fbrch 5, 1982.
2.
and 3.
The appropriate documents were sent to SOC on February 23, 1982 and Furch 5, 1982.
)
4.
No ATWS conditions are required, therefore none were included in the SRV tests.
5.
See 4 above.
6.
See 2 and 3 above.
SOC Contention 7A(6) l 1.
The steps taken by Shoreham Nuclear Power Station to reduce the frequency of a stuck-open relief valve are outlined in the FSAR response to NUREG-0737 (II.K.3.16).
2.
See 1 above.
The procedures have not yet been -finalized, and therefore are not available at this time.
-12 3.
See 3 above.
SOC Contention 8 1.
LILCO does not intend to install core thermocouples at Shoreham.
The Company's position is set out is LILCO's July 13, 1981 responses to SOC's interrogatories.
Fur ther in fo rma-tion will be available upon the completion of the BWR Owners Group Inadequate Core Cooling (ICC) Instrumentation Evaluation Progrmn, which has been agreed to by the NRC as an alternative to immediate installation of thermocouples.
Ba sed upon the conclusions of that progrma, LILCO will re-evaluate the Shoreham design and take appropriate actions, if any, to ensure reliable detection of ICC.
The results of part of the program were submitted in a report prepared by Sol Levy, Inc., entitled
" Thermal Analysis of In-Core Thermocouples in Boiling Water Reactors," dated December, 1981.
A copy is attached.
2.
None.
3.
The Shoreham design includes cold reference legs and re-duced vertical instrument line drops in the drywell to reduce susceptibility to large errors due to reference leg flashing and boiling.
In addition, emergency procedures will provide special consideration for potential water level errors and direct appropriate operatcr action.
'13-4.
Board Notification 82-08 does not require responses from individual licensees; LILCO has not prepared a response.
In addition, the Board Notification contains no new information.
All facts and recommendations contained in it have appeared in other documents.
All aspects of this Board Noti fication are within the scope of the EUR Owners Group ICC Instrumentation Evaluation Program discussed above.
5.
Shoreham uses only cold reference legs in the vessel water level instruments.-
SOC Contention 9 1.
(a) through (e).
Shoreham does not include manual capabil-ity to activate the system inoperable alarm because the automa-tic alarm monitors all credible operations which could render the system inoperable.
2.
The RCIC, the Standby Liquidated Control, and the Fuel See Pool Cooling systems are not engineered safety systems.
l FSAR 7.3.
l The critical portions of the SRV are monitored by the sys-tem degraded alarms.
See FSAR 7.3.1.10 and 7.3.2.10.1 & 2.
l 3.
The automatic alarm function monitors all credible opera-tions that could degrade the system.
4.
Yes.
1
..e
- 5.
None.
6.
None.
SOC Contention 16 1.
General Electric has generated two reports responsive to this requests (a) a letter frora J.
F. Quirk (GE) to L.S.
Rubenstein (NRC), dated September 14, 1981; and f
(b) a letter from J.
F. Quirk (GE) to L.S.
Rubenstein 1
(NRC), dated October 19, 1981.
While General Electric may also have produced working-1 documents in the course of its work on NUREG-0630, the perti-nent information is included in these two letters, copies of which are attached.
2.
A response to NOREG-0630 is being prepared by LILCO.
It will be forwarded to SOC when it is completed.
3.
See the attached memorandum from G.
G. Sherwood (GE) enti-l l
tied " Core Spray Distribution," dated December 8, 1981.
4.
None.
SOC Contention 19 i.
Objected to for the reasons stated in LILCO's Objections to SOC's Discovery Requests and Motion for a Protective Order, dated March 15, 1982, at 3-4.
L
,e
. SOC Contention 19(a) 1.
The document pertaining to Inspection No. 50-322/81 -23 of the Shoreham reuctor pressure vessel, conducted during December 1981, is attached.
Two reports will be sent to you under separate cover: "Preservice Inspection of the Shoreham Nuclear Power Station Unit 1 Reactor Pressure Vessel" by Nuclear Encrgy Services, Inc., Document No. 81A0448 Rev. O, and " Reactor Pressure Vessel Inspection" by Reinhart & Associates, Inc. In addition, there is also a two volume binder set, " Reactor Pressure Vessel Preservice Examination."
This set will be made available for your inspection at a mutually convenient time and location.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
%*C M
1 W.
Taylor Reveley, IIh Daniel O.
Flanagan l
Hunton & Williams 707 East Main Street Richmond, Virginia 23212 l
DATED:
March 17, 1982 l
l l
's "th UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 I!M 19 M0 MS Before the Atomic Safety and Licensing Board.
~
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF BRIAN R. MCCAFFREY Brian R. McCaffrey, being duly sworn, states as follows:
1.
I am Regulatory Supervisor for the Long Island Lighting Company.
A statement of my professional qualifications is attached to this affidavit.
2.
The " Response of Long Island Lighting Company to SOC's March 1, 1982 Interrogateries and Requests for Production of Documents", were prepared under my supervision and direction.
To the best of my information, knowledge and belief, the answers con-tained in that response are true and correct.
& $ Wb d-BrianR.McCaffrey Subscribed and sworn to before me this 16th day of March, 1982.
I w h u" h.d bp< s.*-s /
Notary Public My Commission Expires:
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s Brian R. McCaffrey Regulatory Supervisor Long Island Lighting Company My name is Brian R. McCaffrey.
My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York.
I have been Regulatory Supervisor for Long Island Lighting Company since November, 1981, responsible for managing the Nuclear Regulation Division of the Nuclear Operations Support Department.
In addition, I am responsible for managing and coordinating the Company's efforts in the ASL3 Licensing Proceedings.
The Nuclear Regulation Division will support the operation of the Shoreham Station in coordination of all NRC licensing activities, Nuclear Review Board and management of the Independent Safety Engineering Group.
I have been employed by Long Island Lighting Company since 1973 Graduated from the University of Notre Dame in 1967 with a Bachelor of Science Degree in Aerospace Engineering.
Received a Master of Science Degree in Aerospace Engineering in 1972 from the Pennsylvania State _ University and a Master of Science Degree in Nuclear Engineering in 1978 from the Polytechnic Institute of New York.
Completed a General Electric BWR Design Orientation Course in 1978.
A member of the American Society of Mechanical Engineers and the Long Island Section of the American Nuclear Society.
Registered Professional Engineer in the State of New York.
My Professional Experience follows:
Assigned cs Assistant Project Manager - Engineering and Licensing (in July 1981 retitled Manager - Project Engineering) of the Shoreham l
Nuclear Power Station in 1980.
Responsible for the overc11 engineer-ing and licensing of the Shoreham Station.
In this capacity, my organization directed and approved the engineering efforts of the Architect Engineer and Nuclear Steam Supplier.
This organization was also responsible for directing the activities leading to an l
Operating License from the NRC.
From January 1979 to April 1980 held the position of Project Engineer l
for the Shoreham Nuclear Project.
Responsibilities included directing the activites of Project Engineering and the Architect Engineer j
in the engineering and procurement for the Shoreham Nuclear Power j
)
Station.
From October 1977 to December 1978 held the position of Senior Licensing Engineer for the Shoreham Nuclear Project.
Responsible for the licensing activities leading to an Operating License.
l l
l
(
, From June 1975 to September 1977 held the position of senior Engineer in the Power Engineering Department with responsibilities as Project Coordinator for gas turbine installations and Lead Mechanical Engineer for nuclear projects.
From January 1973 to May 1975 held the positions of Associate Engineer and Engineer in the Power Engineering Department involved with balance of plant engineering on both fossil and nuclear power stations.
1968 - 1972 Employed by Grumman Aerospace Corporation.
Primary responsibilities were in the areas of aircraft aerodynamics and flight test stability and control.
~
In the Matter of
- 32) l:g 19 N0:45 LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1
Docket No. 50-322 (OL)
- iY' fi CERTIFICATE OF SERVICE 1 hereby certify that copies of RESPONSE OF LONG ISLAND LIGHTING COMPANY TO SOC'S March 1, 1982 INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS and the accanpanying AFFIDAVIT were served upon the following people by first-class mail, postage prepaid, on March 17, 1982, except for the aster-isked people, were' served by Federal Express on March 17, 1982:
Lawrence Brenner, Esq.*
Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S.
Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Mr. Frederick J.
Shon*
U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Bernard M.
Bordenick, Esq.*
Commission David A. Repka, Esq.
Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter
- Wa shing ton,
D.C.
20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.
Board Panel Attn:
Patricia A.
Dempsey, Esq.
U.S. Nuclear Regulatory County Attorney Commission Suf folk County Department of Law Washington, D.C.
20555 Veterans Memorial highway Hauppauge, NY 11788 Secretary of the Commission U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
4 A
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Herbert H. Jro'Wh Esq.*
Howard L.
Elau, Esq.
z La wr ence Coe ? Lanpr.er, Esq.
217 Newbridge Road Karla J.
Letsche,'Esq.
Hi ck sv il'J e, New York 11001 Kirkpatrick, Lockhart. Hill, Christopher & Phillips Jeffery C. Cohen, Esq.
8th Floor New York Etate Energy Of fice 1900 M Street, N.W.
Swan' Street Building, Core 1 Washington, D.C.
20036 Dupire State Plaza
~
Albany, New York 12223
~
Mr. Mark W. Goldsmith *
\\
.3 s
Energy Research Group ;-
-Er. U4y Dunkleberger 400-1 Totten Pond Road '
Nes York State Energy Of fice Waltham, Massachusetts 02154 Agency; Building 2 Empire State Plaza s
MHE Technical Associates
- Albany, New York 12223
-I 1723 Hamilton Avenue
^E
\\
Suite K San Jose, California 95125
^
Stephen B.
La tham, Esq.*
,t Twomey, Latham & Shea 33 West Second Street P.
O. Box 398 Riverhead, New York 11901
$ 9 Ralph Shapiro, Esq.
-hs Cammer and Shapiro, P.C.
}?
i 9 East 40th Street I
W. Taylor Revelcy. III Daniel O.
Flanagan 4
i Hunton & Williams 707 East Main Street P. O. Box 1535 Ri'chmond, Virginia 23212 DATED:
March 17, 1982
.