ML20042C306

Response to 820305 Interrogatories & 820306 Second Set of Interrogatories

ML20042C306
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/26/1982
From:	Flanagan D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SUFFOLK COUNTY, NY
Shared Package
ML20042C307	List: ML20042C306 ML20042C311 ML20042C314
References
ISSUANCES-OL, NUDOCS 8203310192
Download: ML20042C306 (88)

Text

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- ORE THE ATOMIC SAFETY AND LICENSING BOARD MAR 3 019325* @

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

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(Shoreham Nuclear Power Station, )

Unit 1) )

RESPONSE OF LONG ISLAND LIGHTING COMPANY TO SUFFOLK COUNTY INTERROGATORIES AND TO SUFFOLK COUNTY SECOND SET OF INTERROGATORIES Suffolk County (SC) addressed to Long Island Lighting Company (LILCO) certain discovery requests in its "Suffolk County Interrogatories to Long Island Lighting Company" and "Suffolk County Second Set of Interrogatories to Long Island Lighting Company," dated March 5, 1982 and March 6, 1982, re-spectively. Subsequently, SC and LILCO agreed to modify or delete certain discovery requests. Additionally, the Board ruled on LILCO'S objections to certain requests, ordering fur-ther responses. Responses to the discovery requests, as modi-fied by agreement and ordered by the Board, appear below.

Affidavits are attached.

1 8203310192 820326 PDRADOCK05000g hI e g.

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I. LILCO's RESPONSE TO SUFFOLK COUNTY INTERROGATORIES i

Suffolk Co. Contention 1.

1. Summarize LILCO's position with respect to Suffolk County Contention 1.

Response. LILCO's position is summarized in SNRC-638 (November.23, 1981). A copy is attached.

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

a. RHRS (SP Section 8.1.3)

b. SWS (SP Section 8.1.6)

c. RBCLCWS (SP Section 8.1.7)

Do the Shoreham Technical Specifications provide for contin-uous, 100 percent availability of the "B Loop" for each of the systems set forth-in (a) through (c)?

Resconse.

2a. Yes.

2b. Yes.

2c. No. ,

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

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

-).

3f. See 3a above.

3g. Revision is expected to be complete by June 1, 1982.

31. See 3g above.

3j. See 3g above.

4. Deleted by agreement of the parties.

5. For the RHR, RCIC and Service Water Systems, iden-tify all instrumentation located on or considered part of the RSP (indicators, alarms, etc.) and state the range displayed on each item of instrumentation.

Response.

Sa. RHR System Instrumentation (1E51) i l (1) RER Flow Indicator 8 COO GPM 1C61*FIOBl(C61-R005).

(2) RHR Flow Conductivity Meter 10 uMhos/CM 1C61-ClT016(C61-R013)

Sb. RCIC System Instrumentation (1E51).

(1) RCIC Turbine Speed Indicator 6000 RPM  !

1C61-5Il05(C61-R003)

(2) RCIC Flow Indicating Controller 400 GPM 1C61-FC-104 (C61-R001) 1C61- (C61-R001-1)

(3) Controller for Lube Oil Cooler Pressure Control Valve 150 PSIG (set at 60 PSIG) 1C61*PIC 142 RCIC System Indication for the following paramenters (1) Turbine tripped (amber)

(2) Turbine bearing oil low pressure (amber)

(3) Turbine governor end bearing oil temperature high (amber)

(4) Turbine coupling end bearing oil temperature high (amber)

(5) Barometric condenser pump running (red)

Sc. Service Water System Instrumentation (1P41)

(1) Service Water Pump discharge head pressure-a 1C61-PIO11 (C61-RO14) 0-200 PSIG

6. Deleted by agreement of the parties.

7. For each control switch for the RER, RCIC and

-Service Water System included on or considered part of the.RSP (listed in Appendix 12.2 of SP 23.133.01), identify the related

s

- measured variables / parameters that are also displayed in the RSP, and explain how the display correlates with the switch-controlled functions.

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] Response.

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1. RHR System Instrumentation (1E11)

a. RHR Flow Indication - 1C61*FI001 (C61-R005) is used by the operator to monitor the condition of the RHR Pump for proper discharge flow and i for proper valve line-up for the different modes of RHR.

b. RHR Conductivity Indication - 1C61 CIT 016 (C61-R013) is used by the operator to monitor the condition of the RHR System for a.possible tube rupture in the RHR heat exchanger which ,

would show up as an increase in the conductiv-ity.

Additional RSP instrumentation used by the operator to

. monitor the RHR system are:

a. Suppression Pool Level - 1C61-LIO26 (C61-R016)

b. Suppression Pool Temperature - 1C61-TIO22B (C61-R015)

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c. Service Water Pump Discharge Head Pressure 1C61-PIO11 (C61-R014).

Suppression pool level and temperature are used primar-ily to monitor the primary containment but are also relevant to RER system operation because the RHR pumps take their suction from the suppression pool before discharging through the heat exchangers back to the reactor vessel (LPCI mode).

Service water system discharge head pressure is also needed by the operator in certain modes of RHR System Operation. The service water system is used to cool the RHR flow as it passes through the RHR heat exchangers.

2. RCIC System Instrumentation (1E51)

a. RCIC turbine speed indication is needed by the operator to monitor the RCIC turbine spee'd at all times. 1C61-SIl05 (C61-RO83).

, b. RCIC turbine flow controller and flow indicator-IC61-FC 104, 1C61-FIl04 (1C61-R001, C61-R001-1) are used by'the operator to constantly monitor the-RCIC turbine output flow during RCIC system operation.

c. RCIC pressure indicating controller for lube

-oil co'oler pressure control valve 1C61*P1C142

4 i

is needed by the operator to monitor the pressure going into the_ lube oil cooler so as not to rupture the lube oil cooler seals and

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cause serious damage to RCIC turbine oil bear-ings.

In addition four amber and one red indicating lights are located on the RSP for direct indication to monitor the following parameters and for direct observation by the opera-tor:

a. Turbine tripped (amber)

b. Turbine bearing oil low pressure (amber)

c. Turbine governor and bearing oil temperature high (amber)

d. Turbine coupling and bearing oil temperature high (amber) ,

a

e. Barometric condenser pump running (red)

3. Service Water System Instrumentation-(1P41)

a. Service water pump discharge head pressure 1C61-PIO17 (C61-R014) is needed by the operator to monitor the operation of the service water pump and as an indication of the proper valve line-up for system operation.

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8. Deleted by agreement of the parties.

9. Deleted by agreement of the parties.

10. Deleted by agreement of the parties.

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11. Deleted by agreement of the parties.

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12. Describe how maintenance operations that impaEt,, / ,

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operator control ar.e designated at the RSP. -

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'O Response. Any maintenance operation that impact on 7 7

operater control is tagged out at the RSP in additionJto the

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main control board. I '

13. Explain LILCO's justification for the-dis 6repancy 7 between FSAR Section 7.5.1.4.5, [which states that the' RSP pro- - '

, is,.

cedure assumes that the Main Steam Line Isolation Valves ** '

(MSLIV) are closed (step 4)) and SP 29.022.01, Section'3. 9 - - .

[which states that the operator may choose to close or., leave -

open the MSLIV's]. . -

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Response. FSAA Section 7.5.1.4.5, Revision'22,.was Y r

written prior to the ' issuance of the' BWR Owner's Group emer ' ,- - -

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gency guideline procedures, and, therefore,.did not take them /

% f, 1 h j r into consideration. SP #29_. 022.Ol. has'- been revised ' based , on.- T_' , , ,

the BWR-Owner's Group guidelines sud is expected to be approved n r

by the plant Review of Operations Committee by the end of April. The procedure instructs the operator to leave the-e ,

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i-MSLIV's open and no longer gives the option to close or leave open the MSLIV's. FSAR Section 7.5.1.4.5 will be revised when the latest revision to SP #29.002.01 is approved.

14. Deleted by agreement of the parties.

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

Resconse. No.

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16. Will the RCIC and/or the RHR remain in operation if they are automatically initiated prior to the transfer from the f '/[.maincontrolpaneltotheRSP?

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Response. RHR will remain in operation if initiated t, ,,

automatically prior to transfer. RCIC may require manual re-1 cctart due to switching of controller signal.

, 17. Identify alarms for the RCIC, RHR and Service Water s', Systems provided on the RSP for Class 1E buses required to

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achi' eve cold shutdown (i.e., a list comparable to that for the za ..

' ,rs a mhin control room as presented in FSAR Table 223.90-4).

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Response. No alarms are provided at the remote shutdown

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4. s j . 18. Identify all indicators at remote equipment loca-

,, tions to be used by operators in the field assisting in remote ,

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shutdown, and i'dentify the range displayed by each such indica-tor. s s

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- Response. Instrumentation located other than on the RSP is not required for shutdown. i

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19. s Deleted by agreement of the parties.

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1 2d': Deleted by agreement of the parties.

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3 s Su'ffolk Co. Contention 2.

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, '21. Summarize LILCO's position with respect to Suffolk County Contention 2.

p-. Response. The steps taken to minimize the accumulation s

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• of dirt in relays located in the diesel generator rooms are I, -

sufficieht to preclude inadvertent trips or failures to start.

s x, i 22. Does LILCO intend to protect against an accumula-

't' ion iof dirt on the relays located in the diesel generator room -

y, control l panels by:

a. Relay panels in the diesel' generator room will w

have gasketed access doors and filtered venti-a-

\ - lation louvers; and s.

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b. The air intakes to the diesel generator venti-lation systems will have concrete directly under them, with crushed stone several inches l

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deep adjacent to the concrete?

If the answer is "yes," when does LILCO intend to implement the protective actions?

-Re spon s e .

a. Yes. The action has been implemented. }

b. Yes. The concrete beneath the diesel generator ventilation systems is in place. The crushed stone l is expected to be in place by fuel load.

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23. If the answer to Interrogatory No. 22 is no:

a. How does LILCO plan to comply with Regulatory Guide 1.39, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants," with re-spect to diesel generator maintenance?

Identify all documents concerning such compli-ance and diesel generator maintenance proce- I-dures.

b. State LILCO's rationale for failing to install i

gasketed access doors and filtered ventilation louvers in the relay panels in the diesel gen-erator rooms and identify all documents >

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concerning such rationale and any related analyses.

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c. State LILCO's rationale for its decision that the air intakes to the diesel generator venti-I lation systems will not have concrete directly under them, with crushed stone several inches a

deep adjacent to the concrete, and identify all i documents concerning such rationale and any

] related analyses.

i.

Response. Not applicable; answer 22 was "yes,"

24. Deleted by agreement of the parties.

Suffolk Co. Contention 3.

25. Summarize LILCO's position with respect to Suffolk i

County Contention 3.

Response. See LILCO's March 17, 1982 response to SOC's question 1 on SOC Contention ~8.

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

Response. No. See.LILCO's March 17, 1982 response to SOC's question 1 on Contention 8.

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27. Identify major LILCO, or the BWR Owner's Group or Licensing Review Group studies concerning the use of in-core thermocouplss to detect ICC.

Response. See LILCO's July 13, 1981 and March 17, 1981 response to SOC's questions on SOC Contention 8, both of which included reports concerning the use of in-core thermocouples.

4

28. With respect to each of the following techniques, state the degree of accuracy to which the technique is able to +

measure fuel cladding temperature: I

a. Measurement of water level in the reactor ves-sel.

b. Use of thermocouples in in-core detector loca-tions.

c. Use of thermocouples attached to fuel.

d. Any other techniques being considered by LILCO 1 for use at Shoreham.

4 Response.

28a. Measurement of water level in the reactor vessel is discussed in the attached documents regarding SER Open Item #44. -

28b. See the Sol Levy, Inc. report (SLI-8121) attached to LILCO's March 17' responses to SOC.

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28c. The use of thermocouples attached to fuel has been considered impractical, therefore, no accuracy data is available. Attachment of thermocouples to fuel cladding would cause " hot spots" and possibly result in cladding failure. In addition, wiring removable fuel bundles is not practical.

28d. Alternative neans to monitor ICC are being ad-dressed in the BWR Owner's Group evaluation; see 25 above.

4

29. With respect to each response to Interrogatory No.

28, describe how the degree of accuracy was determined and identify all documents concerning such determination.

Response. See 28 above.

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

Response. A detailed description of how the onset of inadequate core cooling will be monitored is included in-( LILCO's July 13 responses to SOC's questions on SOC Contention 8. Relevant procedures are SP #29.023.01, SP

1. 29.023.04, and SP #29.023.09. These were attached to SNRC 623, sent out with LILCO's response to SOC interrogatories.

Further information is included in the attached documents addressing SER Open Item #44.

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31. Deleted by agreement of the parties.

32. Identify NRC submittals which concern the adequacy of the water level measurement technique of detecting the onset of ICC. .

Response. See 28a above.

Suffolk Co. Contention 4. -

33. Summarize LILCO's position with respect to Suffolk County Contention 4.

Resoonse. The Shoreham Station includes various design features to preclude the occurrences of water hammer in safety related systems. These include: steam line drains, pipe sup-pressors, slow valve operators, high point vents, and loop fill systems (to maintain ECCS systems so that they are always full of water), etc. In addition, analysis of water hammer loads was done for operating transients where necessary. A vibration monitoring test program will be implemented to verify piping and restraint design.

Also, LILCO is considering a program to monitor water hammer occurrences during start-up at other similar BWR plants in safety related systems.

34. Has LILCO contacted or does LILCO intend to con-tact, engineering or other personnel at other General Electric

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . J

BWR Mark II plants (U.S. or Caorso) to determine if any water hammer problems arose during their pre-operational testing or low power testing?

Response. No. LILCO has not yet contacted personnel at other plants, but is considering contacting such personnel in the future.

35. Does LILCO intend to evaluate, or has LILCO in fact evaluated, any problems identified at other General Electric BWR Mark II plants (U.S. or Caorso) to determine their rele-vance to Shoreham and to determine whether Shoreham's pre-operational testing program for water hammer should be mod-ified? If yes, identify all documents which evidence or con-cern this matter.

Response. GE is responsible for test procedures on ECCS systems and NSSS equipment. These procedures take into account information from previous testing and are basically the same for all plants, varying only to account for plant specific fea-tures. Procedures for non-NSSS safety related systems are Shoreham specific and cannot be related to the procedures at other plants.

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

a. Describe all differences between Shoreham's preoperational pipe system testing and the testing conducted at other plants,

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

Response. No.

37. Does LILCO agree to implement the provisions of 1

Section III.A. of the Settlement Agreement regarding the addi-tion of a County representative of LILCO's Nuclear Review Board?

Response. No.

38. Deleted by agreement of the parties, i

39. Deleted by agreement of the parties.

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

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Response. ECCS tests are being performed to verify proper component and integrated system dynamic operation.

System water leg pumps (pumps designed to ensure that ECCS dis-charge piping is maintained at a positive pressure) are tested to ensure they meet design requirements. Alarms associated with the loss of positive pressure in the ECCS discharge piping are both wire and functionally tested. ECCS pump and motor performance when operated from near zero to runout are moni-tored for: operating current a-d voltage, bearing tempera-tures, vibration (pump and motor), noise, motor temperature, seal temperatures) and smooth coastdown verification. After the equipment is verified as satisfactory at the component level the RHR and CS systems are transient tested (LOCA stimu-lation) to verify proper system response to provide rated flow to the reactor within design time limits. The HPCI and RCIC systems are transient tested (LOCA simulation) over the full design range of operation as part of the startup test program.

The tests performed are requirements of General Electric Company's (GE) generic BWR test requirements. They are being conducted at SNPS-1 and have proven satisfactory at other sites to ensure proper dynamic operation.

In addition, preoperational tests will include monitor-ing vibrational-dynamic effects in accordance with ASME III for all Class 1 and 2 piping. These tests will provide adequate assurance that the piping and piping restraints have been

designed to withstand dynamic effects due to valve closures, pump trips, and other operating modes associated with the design operational transients [from SER page B-8]. Results of these tests are not yet available.

Suffolk Co. Contention 5.

41. Summarize LILCO's position with respect to suffolk County Contention 5.

Response. The Shoreham loose parts monitoring (LPM) system design has features that minimize the number of spurious l

alarms.

42. Deleted by agreement of the parties.

43. Deleted by agreement of the parties.

44. Deleted by agreement of the parties.

I 45. Deleted by agreement of the parties.

46. Deleted by agreement of the parties.

47. Identify the alarm point for the LPM.

Response. The alarm point for the LPM System has not yet been established. After_ testing performed during the start-up procedures, the decision will ime made.

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

Response. LILCO does not consider any specific fre-quency of spurious alarms to represent the threshold of accep-tability for loose parts monitoring. The number of spurious alarms cannot be anticipated until after testing performed during the start-up program.

49. Deleted by agreement of the parties.

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

Response. Procedures to be followed by operators con-cerning the use of the LPM system will be issued after an LPM system start-up training program has been established.

51. Describe all training to be provided operators con-cerning the use of the LPM system.

Response. The LPM system start-up training program will include instruction in the operation of the LPM system as well as instruction for evaluating the data obtained. Also included in this start-up training will be specific instruction in the maintenance and calibration of.the LPM system hardware.

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52. Deleted by agreement of the parties.

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Suffolk Co. Contention 8. F

53. Summarize LILCO's position with respect to suffolk County Contention 8.  ;

Response. LILCO has established an Environmental i Qualification Program for Shoreham that will provide assurance i that all safety related Class IE electrical equipment and all electrical equipment required by Regulatory Guide 1.97 located {

in potentially harsh environments will be functionally operable following a postulated accident. The details of the program are set out in a document entitled " Environmental Qualification Report for Class IE Equipment," a copy of which was sent to i Suffolk County on February 18, 1982.

54. Identify the purpose and scope of LILCO's review of ,

Emergency Operating Procedures referenced in LILCO's Environmental Qualification Report for Class IE Equipment (at page 2-1) and state the schedule for such review.

t Respense. The Environmental Qualification Report for Class IE Equipment, Rev. 1,_ submitted to the NRC on January 25,  !

1982 states that the Shoreham Emergency Operating Procedures will be reviewed aqainst the computerized report (EQSR) to pro-vide' additional' assurance that the required _ electrical i

b equipment is identified. The EQSR is the list of Class IE electrical equipment required to be qualified for potentially 2

harsh accident-generated environments. The purpose of this review is to insure that the EQSR contains all safety related ,

equipment to be relied upon by the operator. The review will i t

look at the six Shoreham Emergency Operating Procedures that l call for the use of equipment during or after a harsh environ-j ment generating accident. The review is expected to be com-pleted by September, 1982.

55. Identify all procedures, criteria and/or standards i

+ used or to be used by LILCO in reviewing the Emergency Operating Procedures (see page 2-1) against the computerized Environmental Qualifications Status Report (EQSR) which is ,

l Appendix F to LILCO's Environmental Qualification Report for Class IE Equipment.

Response. The Emergency Operating Procedures (EOP's)~ ,

3

. review is parallel to and complementary of the system review described in Section 2 of the Environmental Qualification t i Report. As-such, the review involves the following procedure.

Electrical equipment and. systems indicated in the EOP's~are identified and classified according to the criteria of_whether

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they are-designated safety related,-located in a_potentially harsh-accident generated environment and listed in the EQSR.

If designated as safety rel'ated and located in a potentially

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• harsh environment, but not listed in the EQSR, the equipment is further reviewed to determine whether the design basis safety analysis requires the operator to rely on the equipment to mit-igate the consequences of the accident which may generate the harsh environment. If so, it will be added to the program.

Suffolk Co. Contention 9.

56. Summarize LILCO's position with respect to Suffolk County Contention 9.

Response. The Shoreham design has several features to minimize the possibility of screen blockage in the ECCS pump suction. They include: metal encapsulated insulation, suita-ble baffling and grating in the drywell to make passage of in-sulation into the suppression pool very difficult, and larger than necessary strainers. Thus, adequate precautions have been taken to ensure that ECCS pump suction screen blockage will not occur.

57. Deleted by agreement with the parties.

58. Deleted by agreement with the parties.

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

t Resoonse.

(a) The number of strainers is one per suction, based on operating experience; j (b) the size of the open surface area is designed to exceed 300 per cent of the pipe open area, based on operating experience; (c) the strainer grid size is designed to prevent clog-ging of the feedwater and core spray sparger noz-zles and containment spray and the RHR and core spray pump cyclone separator orifices, based on quantitative analysis.

Suffolk Co. Contention 10.

60. Summarize LILCO's position with respect to Suffolk County Contention 10.

Resoonse. There are no specific requirements in Appendix K regarding core spray distribution or counter current flow. See LILCO's March 17, 1982 response to SOC's question 3 on SOC Contention 16.

61. Deleted by agreement of the parties.

62. Deleted by agreement of the, parties.

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Suffolk Co. Contention 17.

63. Summarize LILCO's position with respect to Suffolk County Contention 17(a) and 17(b).

Response. Regarding Suffolk County Contention 17(a):

LILCO has committed to provide portable toxic gas monitoring in the control room.

Regarding Suffolk County Contention 17(b): see Items 66 and 67 below.

i

64. Deleted by agreement of the parties.

65. Deleted by agreement of the parties.

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

Response. No.

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

a. Is it LILCO's position that a significant num-ber of BWR fires to date have not been detected

by plant personnel, but rather by automatic detectors?

b. Deleted by agreement of the parties.

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

d. Deleted by agreement of the parties.

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

\

f. Deleted by agreement of the parties.

g. Describe LILCO's rationale for not placing man-ual fire alarms in the machine shop area at elevation 15'. l

h. Deleted by agreement of the parties.

i. Deleted by agreement of the parties.

Response.

-i8-

a. No.

c. Yes.

e. Fires in the machine shop will most likely be detected by personnel in the machine shop area,

g. Plant personnel stationed in and around the machine shop area will be able to use the intercom (Ga-tronics) system for direct notifi- l cation and description to control room in the event of a fire and to receive detailed in-structions on how to deal with the specific

. situation.

LILCO's RESPONSE TO SECOND SET OF SUFFOLK COUNTY INTERROGATORIES ,

Suffolk Co. Contention 11.

1. Summarize LILCO's position with respect to Suffolk County Contention 11.

Response. LILCO will provide adequate operability test-

-ing as required by ASME.Section XI and the Technical Specifications to insure the operability of ASME III valves.

In addition, instrumentation to monitor system-performance and adequate-redundancy in both systems and equipment preclude any unsafe conditions from_ occurring due to an undetectable valve failure.

. 1-

i 2. What evaluations or analyses have been conducted by-or on behalf of LILCO to determine if mechanical valve failures similar to.those experienced in Brunswick Units Nos. 1 and 2 and/or Hatch No. 2 MSLIV's, between 1976 and 1981, are possible 4

in Shoreham valves? Describe and identify any evaluations, analyses or other documents which concern the relevance of these failures for the Shoreham valves.

Response. No evaluations or analyses have been per-formed. However, in response to IE Information Notice 81-28, LILCO has issued a purchase order for the necessary replacement parts for the Rockwell MSLIV's. Scheduled delivery is May, 1982.

3. What techniques are used to detect the separation of valve stem from stem disc or gate? Describe-them and iden-tify all documents which concern these cechniques.

Response. The testing program, described in 1 above, will detect separation of value stem from stem disc or gate'.

4. Deleted by agreement of the parties.

1 l

Suffolk Co. Contention 13-15.

5. Summarize LILCO's position with respect to Suffolk County Contention 13.

Response. The description of the QA program for the operation of Shoreham is adequately described in FSAR Chapter

17. Furthermore, the Shoreham QA program for operations com-plies with all applicable requirements of 10 CFR Part 50, Appendix B.

3. Summarize LILCO's position with respect to Suffolk County-Contention 14.

Response. LILCO's Quality Assurance program for Shoreham complies with all applicable requirements of 10 CFR Part 50, Appendix B. The NRC has conducted extensive reviews l of the Shoreham plant, including-those conducted by a full-time NRC Resident Inspector at Shoreham. The NRC's reviews confirm that an acceptable QA/QC program exists'for Shoreham. For those deficiencies that have been identified, appropriate cor-rective action has been or is being taken.

7. Summarize LILCO's position with respect to Suffolk County Contention 15.

Response. The QA/QC program for Shoreham has involved extensive' review and physical inspection of the plant by LILCO

and LILCO's contractors and consultants. The NRC has independently reviewed and inspected many aspects of the Shoreham plant and QA/QC program. In fact, the NRC has a Resident Inspector assigned full-time to the Shoreham project.

These multiple reviews ensure that LILCO has complied with 10 CFR Part 50, Appendix B.

Furthermore, in order to confirm compliance with appli-cable QA/QC requirements, LILCO was willing to have an indepen- '

dent inspection of Shoreham conducted in accordance with Section III.E of the proposed Settlement Agreement negotiated with Suffolk County but rejected by the County Legislature.

8. Deleted by agreement of the parties.

9. Describe and identify all LILCO procedures or other guidance or documents which are designed, in whole or in part, to ensure that replacement parts or materials installed during maintenance activities at Shoreham, related to items identified as important to safety (for example, the replacement of a tran-sistor or gasket in a Class IE Pressure Transmitter), will not degrade the quality or qualifidation of the original equipment item.

Response. #SP 12.019.01, " Procurement of Parts, Materials, Components and Services" provides both technical and quality requirements for procurement of spare and replacement parts, materials, components and services.

=

r QAP-S-04.1, " Operational Quality Assurance Review of Procurement Documents describes the quality assurance review performed on procureme nt of safety related items and services.

It assures that quality and technical requirements are cor-rectly incorporated into procurement documents. In addition, this procedure describes the " Deficient Item List" which is a listing of known deficient items. It is intended to preclude purchase of such items.

1. SP 12.019.03, " Storage of Spare Parts, Materials and Components" assures that safety related items are stored at their requisite level of quality in environments designed to prevent any deterioration prior to issuance.

1. SP 12.019.04, " Issue of Spare Parts, Materials and Components" assures that issue of safety related items from ,

stores is fully controlled and provides traceability from com-ponent to procurement document.

QAP-S-07.1, " Operational Quality Assurance Vendor Quality Evaluation and Source Selection" describes the' quality ,

review performed on prospective vendors of safety related items and services to assure that the quality assurance program is equivalent to original vendors.

The referenced documents or procedures will be available for Suffolk County's review.

10. Identify each member of LILCO's operations QA/QC staff, and with respect to each person identified, describe the-t

a .

qualifications that justify his or her designation as a member of the QA/QC staff.

Response. The qualifications of QA/QC staff members that justify his or her designation as a member of the QA/QC staff are attached.

11. State how many LILCO QA/QC personnel will be pre-sent during each operating shift at Shoreham when the plant is in operation. Explain the basis for LILCO' selection of this number and outline their respective duties.

Response. LILCO Operational Quality Assurance will be staffed with an Operating QA Engineer, QA Engineer, QC Engineer '

and 5 QC Inspectors during the regular work day. As workload requires (i.e., during scheduled, major maintenance overhauls or scheduled refueling outages) OQA personnel will work sched-uled overtime as necessary. During any emergency work at the station, OQA personnel will be on-call to provide QA/QC cover-age. It is expected that during station refueling outages, OQA may require outside QA/QC contractor assistance. Outside QA/QC contractor personnel will be qualified and certified to the LILCO QA program.

12. Describe the QA/QC support to Shoreham operations which is now being provided, or will be provided in the future, by general office personnel employed by LILCO.

=

Response. The LILCO QA department, located off-site, will be available to provide QA/QC support to the Shoreham op-erations. The current authorized personnel strength of this department includes 17 professional personnel and 3 techni-cal / clerical personnel.

f

13. Deleted by agreement of the parties.

14. Deleted by agreement of the parties.

15. Deleted by agreement of the parties.

i 16. Deleted by agreement of the parties.

17. Deleted by agreement of the parties.

u 18. Deleted by agreement of the parties.

19. Deleted by agreement of the parties.

20. Deleted by agreement of the parties.

21. Section 17.2 of the FSAR states " Audit frequency shall be based on the status, safety, and importance of the audited activity and results of prior audits." What are the specific criteria for determining " audit frequency."

i Response. The criteria for determining audit frequen-cies are derived from ANSI /ANS 3.2 Draft 8, 1981, and Regulatory Guide 1.144, September 1980. These criteria are

1 reflected on page 1 of Appendix A of the LILCO QA Manual. With regard to audit frequency following an initial audit, are as follows:

a. The results of actions taken to cor-rect deficiencies that affect nuclear safety and occur in facility equip-ment, structures, systems, or method t of operation - at least once per six months.

b. The conformance of facility operation to provisions contained within the Technical Specifications and appli-cable licence conditions - at least once per 12 months.

c. The performance, training, and quali-fications of the facility staff - at least once per 12 months.

d. The quality assurance programs of suppliers providing appropriate pro-ducts and/or services - at least once per 36 months.

The. referenced document will be made available for Suffolk County's review.

'22. Pleaae identify "those applicable elements of the QA Program in which quality-based related activities are more-

l

. . 1 intensive and impacting upon daily operation" (FSAR Section 17.2) which shall be audited at least annually (i.e., what are 4

the " applicable elements" and what are the " quality-related activities" referred to). I Response. The activities considered to be "more inten-sive and impacting upon daily operation" are those described in 21(a), (b) and (c) above.

23. What is the established procedure for correcting j errors or violations identified in audit reports? (Please i identify the documented procedure (s), qualifications of planned 1 reviewers, and information pertaining to any other organization other than LILCO which could be involved.)

Response. QAP 18.1 " Program Audit Procedure,"

QAP 18.2 " Quality Audit and Surveillance of Field Activities," and QAP-S-18.1 " Scheduling, Conduct, Reporting and Follow-up of Station OQA Audits" detail the methods used to ,

direct the correction of conditions described as audit find-ings. The personnel to be used as reviewers shall be qualified as required by QAP 2.3 " Training and Qualification of-Audit i Personnel" and QAP-S-02.2 "OQA Training, Qualification and Certification of Auditors". The referenced documents and pro-cedures will be made available for Suffolk County's review.  ;

If an organization external to1LILCO is contracted to perform. audits for LILCO, they will-have to operate in a manner that is compatible with and equal to the.LILCO requirements. :r

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24. Describo:'the training , criteria for the personnel ".

who will be con' ducting the audits referred to in Section 17 2>

of the ESAR wher'e it states'" Audits j u ll-be conducte'd~1n ac- e,

, - /- , ,

cordance with written, approved procedures, plans and check-lists by qualified pe'rconnel not di'fectly responsible for the, /

area being audited'." ,_. /

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, g, 1 Responso. The procedures listed below provide ,the cri-teria for training and qualification of a'dit, personnel. The-4 procedures conform to the requirements of ANSI /ASME N45.2.12, c ~

" Requirements for Auditing of Quality Assurance Programs",and f' ,

e - i ANSI /ASME N45.2.23, " Qualification of Quality Assurance drogram Audit Personnel for Nuclear Powe[ Plants". The procedures pro-

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vide for quality assurance program in,doctrination, formal ,,w ,r, # , . y W . ., _

training in auditing and on-this-job, training as a member of an ~f,. y e

audit team under the direct supervision of a qualified Ldad , , '%

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Auditor. ,

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w p OQA Training,gOualification and,",-

QAP-S-02.2 -

Certification of Auditors ,. p [ c r QAP 2.3 ^ Training and Certificationbf Audit Personnel. J, ' #

r The referenced procedures will be Snde avail'able' for Suffolk

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County's review. V

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25. Seetion 17c2.ol.the FSAR states: '" Resp'onsibility s

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, //7 and authority f'r oestablisNing .

and im3$lementing QA program / re-M,'

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quirements relating.to; audits'may be delegated, as deemed. ...

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-- naces,sa,ry by LILCO, to other organizations."

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'l Does LILCO plan I

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// ', to delegIte this responsibility and authority to other organi-

, .zations? If so, please list the organizations.

l1; ,

, < - Response. LILCO intends to maintain a sufficient com-p'lement.of quality assurance, engineering and specialist per-L" f sonnel to fulfill all normal, day-to-day audit responsibili-j -ties. The need may arise, due to major modifications or other I causes, to augment LILCO's auditor capabilities by " delegating"

.certain audit responsibilities to an external organization such as an archi'tect engineer, consultant, or other agent. Under r such circumstances, the responsible organization must implement a.i. /  !

f,.a Quality Assurance Program that is subject to review and ap-s

~' proval by LILCO prior to commencement of audit activities, or s .

must perform its activities in accordance with LILCO's program.

/ Under Section 17.2 of the FSAR, LILCO shall retain ultimate

;-- responsibility for assuring compliance with QA Program require-

,'A gents. .

a.

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l . 26. ' Identify the available supplemental QA support

's

.s , j sta f which may be required (and when it is anticipated it

1. 741,d s be required) from other areas within LILCO, consultants,

'6r#$6hpractbrs as stated in FSAR Section 17.2. Describe the

/,# required training of this supplemental support.

?;

, ( Response. For periods of greater than normal activity such as during major modification or shut down for_ refueling,-

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% 1 s < i the OQA Section may be'd.upplemented by personnel from other ,

LILCO, organizations, con'sultants or contractors. For example, contractor or consultant personnel may be used to perform audits and inspections. Such support personnel will meet the

).JI s requirements of a Level II' Inspector per ANSI N45.2.6 - 1973, and/orAudibbrperANSI/ASMEN45.2.23 1978. For.each individ-ual, documentation including up-to-date resume, copy of eye

[:^3 s examination, letter from employer stating individual is physi-

? :

d; 'g Ah)dJ,+"cally

, A capable of performing assigned inspection tasks at the g >

c station, and current Inspector, Audit and/or NDE Certifications y.

• E shabisbe provided to LILCO OQA.in order to certify the individ-f^; e t ' '*:- y ~,

J.. , , udl. 'Esch individual will complete the LILCO QA Indoctrination a  %

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f and Tra'iningsProgram prior to work assignment.

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Eersonnel f'r,om other LILCO organizations, such as the QA b.g Maintenance, E$7p$eering, or Meter & Test Departments, may be

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<~ called upon provided they are qualified as described above or IS' are.givenVspecial training to meet the requirements for their 5: 1

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. 27. Please provide ~~a list of responsibilities of the A ,

.Opetating Quality Assurance Engineer when supplemental support-

'i-J ;i s - used .

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-~ >' y"Resoonse. The Operating Quality Assurance Engineer is 1'.3 . ..

'h'respo'nSibleforsupervisinganddirectingsupplementalstation

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EJ- QA support personnel. His~ responsibilities are described in

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a FSAR.a 1732.-l.

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28.1* Interrogatories 28-38 concern primarily Contention 15.* Does LILCO intend to hire an independent consultant to perform a non-NRC, third-party physical inspection and review of the quality assurance / quality control program for Shoreham?

If the answer is yes, please describe the scope of the review, the qualifications of consultants being considered and pro-jected schedules.

Response. LILCO has met with the NRC Staff to review the QA/QC program for Shoreham. The Company is currently con-sidering how best to demonstrate the effectiveness of its pro-gram. One of the options under consideration is a physical inspection and review of Shoreham's QA/QC program.

29. Deleted by agreement of the parties.

30. Deleted by agreement of the parties.

31. Identify LILCO's QA procedure governing plant modi-fications.

Response. Cross-checking between documentation and equipment at Shoreham is covered in FQC procedure QC-9.1, Receiving Inspection, and OQA Procedure QAP-S-17.3, Station OQA Review of Vendor (and Installation) Documentation for Startup.

These procedures will be available for Suffolk County's review.

32. Deleted by agreement of the parties.

l

33. Describe the approximate total number of hours of LILCO audits of Shoreham, the number of noncompliances found, the number of violations discovered, and the approximate number of hours spent closing out audit violations and noncompliances.

Identify all documents concerning these matters.

Response. LILCO will make available nonconformance re-ports, Engineering and Design Coordination Reports, and LILCO's Field Audits for Suffolk County's review.

34. Describe the qualifications of the LILCO inspection staff primarily responsible for inspecting Shoreham.

Resoonse. LILCO station inspection personnel are quali-fied in accordance with ANSI /ASME N45.2.6-1973, " Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants".

35. What is the LILCO procedure for insuring that all construction QA violations and noncompliances are closed out and all corrective actions have occurred satisfactorily prior to operation? Please provide examples of cases where correc-tive actions have been satisfactorily closed out.

Response. LILCO procedures'for insuring that all con-struction QA violations and noncompliances are clcsed out and all corrective actions have occurred satisfactorily prior to operation are contained in documents such as QAP 16.1, l

l

Corrective Action Requests, QAP 18.1, Program Audit Procedures, QAP 18.2, Quality Audit and Surveillance of Field Activities, QAP-S-16.1, Operation Quality Assurance Corrective Action and QAP-S-18-1, Scheduling Conduct, Reporting and Follow-up of Station OQA Audits. All these procedures will be made avail-able for suffolk County's review. Examples of where corrective actions have been satisfactorily closed out will be also made available at the site. .

36. Does LILCO believe it has identified and resolved all quality deficiencies and root causes of nonconformances at Shoreham to date? If yes, please provide a list of all quality deficiencies and root causes discovered, including the respec-tive corrective actions. If no, what quality deficiencies and/or root causes does LILCO believe it has not identified and resolved, what action is planned to investigate these, and on what basis does LILCO justify that its QA program has been implemented in accordance with the requirements of 10 C.F.R. 50.34(a)(7) and 10 C.F.R. 50 Appendix B? Identify all docu-ments which concern identification of quality deficiencies and root causes of nonconformances.

Response. Yes. All quality deficiencies and root causes of nonconformances have been identified and are.in the process of'being resolved. The relevant _ documents will be made available for_Suffolk County's review.

l 1

+ .

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37. Deleted by agreement of the parties.

l

38. Have comparative measures been used in the LILCO

-program as a means of determining improvements in, or the l

effectiveness of, corrective actions at Shoreham? If so, l

please describe them. If not, what are the means used to de-l l termine that corrective actions are effective?

L f

Response. LILCO does not use direct comparative mea-sures to determine effectiveness of corrective actions and sub-sequent improvement of the program. Instead, the LILCO methods of review, audit inspection and surveillance contain inherent

{

controls that require formal identification of condi tions re-

l. quiring correction or improvement, documentation of the correc-I tive actions or necessary changes, and subsequent verification of implemention to determine effectiveness of the actions l

I L taken.

l Suffolk Co. Contentions 18-19.

l t

39. Summarize LILCO's position with respect to Suffolk County Contention 18.

! Resoonse.

l 39a. The'new high speed sequence of events printer will provide an adequate alternative to a "first out" annunciator. It is-not required to be safety re--

lated.and is not slow. See SNRC-605, Finding 3.3, i

o .

which was attached to LILCO's March 17, 1982 response to SOC.

39b. A " ring-back" feature is not desirable since it would serve to confuse the operator with additional audio and visual alarms possibly causing other alarms to go unrecognized. See SER, Supp. 1, App.

C, Item 3.2 and SNRC-605, Finding 3.2 and 3'.4.

39c. The reason that an alarm is lit will be determined by the operator through the Alarm Response Procedures.

39d. See 39a above; and SER Supp. 1, App. C, Item 9.6.

39e. LILCO's responses or technical justifications for each item listed are in SNRC-585 or SER Supp.

1, App. C. SNRC-585 was attached to LILCO's March 17, 1982 response to SOC.

40. Summarize LILCO's position with respect to Suffolk County Contention 19.

Response. The training program and plant procedures are both plant specific and adequate to address all postulated events. The equipment listed in each procedure is accurate and identifies both its type and location.

I The Emergency Procedures for Shoreham have been devel-oped from the BWR Owner's Group Guidelines id are symptom oriented. They.were tested at the Limerick simulator by LILCO t-

__.~-_.__m__- - _ _ - - - - - - - - - - - - - - -

and tested independently by the NRC and verified by the NRC at Shoreham. Additional review of operator activities while per-forming Emergency Procedures will be a part of the NUREG-0700 review.

41. Identify the changes related to equipment included in SC 18, proposed or implemented, to control room equipment or other equipment or to Shoreham procedures, which have been made or proposed in response, in whole or in part, to any control room audit, including any by the NRC Staff.

1 Response. All changes, proposed or implemented, in re-sponse to the NRC and General Physics control room audits, have been documented in SNRC-585, SNRC-605 and SER Supp. 1, App. C and D (See 39 sbove), except for the following items which a

resulted from LILCO's February 1982 meeting with the NRC:

41a. Communications equipment will be added to the secu-rity console in the main ~ control room. (See 4

SNRC-585, Finding 1.2). SNRC-585 was attached to LILCO's March 17, 1982 response to SOC.

41b. The flashing -99.99 on computer CRT displays will be. changed. (See SER Supp. I, App. C, Item 9.7).

41c, Certain annunciator windows on Panel G on the main i

control board will be reengraved to' remove-refer-ences to SRV's. (See SNRC-605, Finding-7.7).

SNRC-605 was attached to LILCO's March 17, 1982:

. response to SOC. .

Additional details of this meeting will be included in a letter to the NRC.

42. Document the proposed or implemented changes iden-tified in response to the preceding Interrogatory.

4 4

Response. See 39 and 41 above.

Suffolk Co. Contention 21.

43. Summarize LILCO's position with respect to Suffolk County Contention 21.

Response. LILCO has been a leading participant in the Mark II Owner's Group program to (1) evaluate the dynamic-effects on the primary containment of (a) a postulated loss of coolant accident and (b) safety relief valve discharges; and

- (2) define the appropriate load definitions to be used in eva-luating the ability of a given plant to withstand poten ial static and dynamic forces. In conjunction with the industry.

effort, LILCO applied.the results of the Mark II program to Shoreham to determine whether the plant and its components could withstand the postulated static and dynamic loads. The results of LILCO's plant specific review are included in the1 Design Assessment Report. The latest revision of this docu-ment, revision 5, was sent tx>' Suffolk County on January 15,-

1982.

With respect to each subsection of SOC Contention 21, LILCO believes that (a) LOCA loads have been adequately defined and taken into account at Shoreham; (b) SRV loads have been adequately defined and taken into account at Shoreham; (c) there is a program in place to ensure that unacceptable steam bypass of the suppression pool does not occur; (d) the primary containment and safety related structures have been evaluated to ensure that they can withstand simultaneous. loads; and (e) there is adequate assurance of the validity of test results used in the Mark II program.

44. Identify any LILCO acceptance criteria different that the acceptance criteria generated by and for the Mark II.

containment long-term generic program. For each different cri-terion, provide justification for its use on Shoreham and iden-tify any documents related thereLU.

Response. The Mark II Containment Long Term Program (LTP) Acceptance Criteria are given in Section 5 of draft NUREG

-0783 for pool temperature transients, Appendix A to draft NUREG-0802 for safety / relief valve discharge loads and Appendix A to NUREG-0808 (August, 1981) for LOCA-related loads.

With respect to NUREG-0783, all NRC LTP acceptance cri-teria apply to Shoreham and compliance is documented in Section 10 of the Shroeham DAR Revision 5 with the exception of:

)

1

1. postulation of a stuck open relief' valve (SORV) concurrent with loss of one RHR heat exchanger for isolation / SCRAM and small break accident cases;

2. postulation of loss of offsite power;

3. the assumption that no single failure will result in loss of shutdown cooling mode;

4. the assumption that no heat is absorbed ,

in the containment atmosphere and struc-tures.

Justification for not postulating loss of the RHR heat exchanger concurrent with SORV (other than for the case with the main condenser available) is included in NUREG-0783 itself.

Justification for not assuming loss of offsite power, for loss of shutdown cooling mode by single failure and for use of heat sinks in the pool temperature transient analysis is provided in Section 10 of the Shoreham DAR Revision 5. NRC concurrence with the Shoreham position is presented in NUREG-0420, Supplement 1 (September 1981) (Section 6.2.1.8, " Pool Temperature Limit (Phenomena II.A in Table 6-A) and Safety Relief Valve In-plant Test").

With respect to NUREG-0802,- all NRC LTP acceptance Criteria apply to Shoreham and compliance is documented in Section 3 of the.Shoreham DAR Revision 5. NRC concurrence with

-the Shoreham position is presented in NUREG-0420,_ Supplement 1, Section 6,.2.1.8, " Quencher. Air-Clearing Load" and " Quencher ~ Arm

.and: Tie-Down Load."

l With respect to NUREG-0808, all NRC LTP acceptance Criteria apply to Shoreham and compliance is documented in Section 4 of the Shoreham DAR Revision 5 with the exception of impact loads on small structures. Shoreham makes use of wedge-shaped flow deflectors not covered by NUREG-0808, Appendix A, Criterion A.S. The Shoreham criterion is to use the methods of NUREG-0661 (July 1980) to verify the calculation of loads on the deflectors as described in Section 4 of the Shoreham DAR Revision 5. NRC concurrence with the Shoreham position is pre-sented in NUREG-0420 (April 1981), Table 6-2, items I.B.1(b),

I.B.l(c), I.B.5 and I.B.3(a) and NUREG-0420, Supplement 1, Section 6.2.1.8 " Steam Condensation Downcomer Lateral Loads" and " Impact Loads on Crating Supports."

45. If no different acceptance criterion is identified i in response to the preceding Interrogatory, is it LILCO's1posi-l tion that all of the Mark II long-term generic program accep-i tance criteria apply to Shoreham? If the answer is yes, does the Shoreham Mark II comply with all the acceptance criteria?

Please provide the basis for your position. If not, describe ,

each difference or noncompliance and justify each noncom-t pliance.

Response. See 44 above.

c i

=

-Suffolk Co. Contention 23.

46. Summarize LILCO's position with respect to Suffolk County Contention 23.

Response. SC Contention 23 raises three issues: (1) the adequacy of leak rate and intersystem leakage testing for containment isolation valves; (2) compliance with NUREG-0737, item II.E.4.2 for containment purge valves; and (3) compliance with the recommendations of NUREG-0803 related to a postulated break in the scram discharge volume.

Suffolk County's March 17, 1982 responses to LILCO's interrogatories indicated that the first issue involved Type C leak rate testing for containment isolatien valves located below the suppression pool level. In SNRC-534, dated February 24, 1981, LILCO committed to add these valves to the Type C leak test program. SNRC-534 will be made available for Suffolk County's review.

The second issue, involving the operability of contain-ment purge valves was addressed in SNRC-624, dated October.13, 1981, and SNRC-636, dated November 23, 1981. These submittals show the operability of the purge valves and indicate a willin-gness <nt the part of LILCO to conduct a proposed operability test if that will satisfy the NRC. SMRC-624 and SNRC-636_will be made available for_Suffolk County's review.

Finally, LILCO has addressed NUREG-0803 in SNRC-659, dated January 11, 1982, a copy of which is attached.

47. What is the planned refueling schedule for Shoreham (i.e., 12 month or 18 month fuel cycle)? To what extent has this fuel cycle been committed?

Response. The planned refueling schedule for Shoreham is 12 months. The commitment is based on a fuel fabrication contract for four fuel loads based on an annual cycle.

48-54. Deleted by agreement of the parties. LILCO-will provide slides and transcript from full ACRS meeting if ERG does not have them.

55. Provide LILCO's responses made to the NRC regarding the NUREG-0803 study (Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping).

Response. A LILCO's responses are summarized in SNRC-659, dated-January 11, 1982, which is attached.

Suffolk Co. Contention 24.

56. Summarize LILCO's position with respect to Suffolk County Contention 24.

-Response. The SNPS design' incorporates the use of ap-propriate< materials. processss, modifications, and augmented

i inservice inspection as recommended by NUREG-0313, Rev. 1, to minimize the possibility of cracking in the reactor coolant pressure boundary. A low flow feedwater controller has been installed as recommended by NUREG-0619.

57. Identify each piping system where the Shoreham design is not in full compliance with the NUREG-0313 Revision 1.

a. Provide the justification for each noncom-pliance identified; and

b. Identify documents which concern the noncom-pliance and/or LILCO's determination of which items comply and which do not comply.

Response. There are no piping systems which are not in full compliance with NUREG-0313, Rev. 1. Compliance is discus-sed in SNRC-566, dated May 15, 1981. SNRC-566 will be made available for Suffolk County's review.

58. Describe the Shoreham system for feedwater control

-at low flow conditions. Does the Shoreham feedwater design and feedwater flow control system design comply with NUREG-0619?

If not, describe each difference.

Response. The Shoreham Nuclear Power Station low flow feedwater control system consists of two low flow control 4

valves in parallel with split range control. The split range z

control enables control to below 0.1% of rated flow. The basic purpose of utilizing a dual element control scheme is to limit feedwater temperature fluctuations to within 50 F peak-to-peak on a continuous basis. The Shoreham feedwater design and feed-I water flow control system design complies with NUREG-0619.

I 59. Deleted by agreement of the parties.

Suffolk Co. Contention 25.

60. Summarize LILCO's position with respect to Suffolk County Contention 25.

Response. The Shoreham plant satisfies the inspection and tests specified by 10 CFR 50, Appendix A, GDC 32, 36, 39 and 45. The Shoreham plant complies with 10 CFR 50.55a(g) in that the edition and addenda of Section XI of the ASME Code in effect 12 months prior to the date of issuance of the operating license will be used for the ISI program.

Suffolk Co. Contention 26.

61. Summarize LILCO's position with respect to Suffolk County Contention 26.

Resconse. The plant and equipment design criteria and the use of appropriate procedures, ensures that Shoreham meets the requirements of 10 CFR 20.1(c) and maintains occupational radiation. exposure ALARA.

l

62. Deleted by agreement of the parties.

63. Identify'specifically where low cobalt steels were used in the reactor vessel and internals, coolant boundary, reactor water cleanup water system, spent fuel pool cooling and cleanup system, demineralized water systems, tanks, and control rod drives and drive water system.

f Recponse. Low cobalt steels were generally used throughout the plant, e.g., reactor vessel and internals, coolant boundary main steam, feedwater, residual heat removal system, reactor waster cleanup system, spent fuel cooling and cleanup system, demineralized water systems, tank control rod drive and drive water system. Exceptions are the control rod-roller pins and collet fingers, and the jet pump throat in the reactor vessel and generally the valve seats in piping systems.

64. Deleted by agreement of the parties.

65. Describe philosophy on selection of low cobalt steels for replacement of piping, valves, and components.

Respose. When replace. ment of piping, valves and compo-nents becomes necessary, cor. sideration will be given to order-ing.the replacement materials with a low cobalt content, to.the degree-practicable.

e I

66. Describe and identify LILCO's ALARA design criteria for separation or isolation of components and piping systems in the reactor and radwaste buildings.

Response. The general criterion.used by LILCO is that shielding will be provided for those systems that could trans-fer radioactive fluids. Shielding is accomplished by putting potentially radioactive piping in pipe tunnels (e.g., main steam and spent fuel pool cooling and clean up piping tunnels),

by using localized shielding of pipe routing (e.g., resin slurry lines), and by general cubicalization of components (e.g., RWCU pump.and filter /demineralizers). The reactor pres-sure vessel is shielded by a biological shield wall and by re-movable shields at penetration openings.

67. Has LILCO incorporated into its design, provisions for decontamination of the reactor water cleanup system.

Response. Yes, provisions are provided by decontamina-tion connections for flushing purposes around all major pieces of equipment.

68. Have provisions for decontamination of the reactor water cleanup system been incorporated in Shoreham design and procedures? '

Resoonse. Yes; see 67-above. Procedures will be devel-oped as required when the desirability for decontamination has been established.

69. Identify LILCO's criteria for flushing or decontamination procedures. Also, identify and describe the bases upon which these procedures are to be implemented, e.g.,

fixed schedules, radiation levels, maintenance requirements?

Response. LILCO's criterion for flushing or decontamin-ating procedures is maintaining doses ALARA. The bases on which these procedures are to be implemented are dictated by the particular conditions existing for specific components when a maintenance task must be performed, the nature of the task, and an assessment of the effects of flushing or decontamina-tion.

70. Identify the systems that have taps for flushing purposes, including the RWCS, recirculation piping system, rad-waste systems, etc. In addition, do the reactor cleanup, con-densate, and radwaste demineralizers, tanks, pumps and evapora-tors also have taps for flushing?

Response. The systems that have taps for flushing pur-1 poses are main recirculation system, RWCU system, radwaste fil-  !

l ter systems, and the fuel pool cleanup system. The RWCU system

-has complete flushing capability, including taps. Radwaste l systems have flushing capability, including taps around all pumps and filters. The condensate system does not have taps for-flushing because this function is continuously performed-during normal operation.

e

71. Deleted by agreement of the parties.

72. .Has LILCO established water chemistry procedures to limit iron-cobalt radiation buildup in order to reduce primary system radiation exposure rates? If yes, identify the proce-dures. If no, identify LILCO analyses or other documents which concern whether such water chemistry procedures are necessary and describe the alternatives to water chemistry procedures for minimizing iron-cobalt radiation build-up which LILCO intends to use at Shoreham.

Response. Although there are several procedures rele-vant to this process, there are three primary procedures:

SP #22.101.01 Start up-Cold Shutdown to 20%

SP #23.103.01 Condensate SP #23.109.01 Feedwater systems These procedures will be made available for Suffolk County's review.

73. Identify the most recent LILCO procedures for moni-toring and control of individual'and plant total annual occupa-tional radiation doses. Also identify documents that concern whether individual exceedance of three rem per quarter will.

occur only on an emergency basis and require special management approval. Provide the bases upon which special management ap-proval would occur.

Resoonse. The relevant procedures are:

l SP #61.012.01 Personnel Dose Limits and Guides l SP #61.012.05 Authorization to Exceed Dose Guides SP #61.070.01 ALARA Review Committee SP #61.071.01 ALARA Goals and Measurement SP #61.071.03 ALARA Job Review SP #61.071.05 Procedure and Design ALARA Reviews SP #69.050.01, " Radiation Doses During an Emergency" provides instructions on personnel doses during an emergency.

Shoreham's policy does not allow an individual to exceed the current NRC limit of 3 rem per quarter, during normal operating periods. Management approval of personnel doses in excess of 3 rem per quarter'are based upon NCRP Report No. 39, " Basic Radiation Protection Criteria" and EPA-520/1-75-0001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" guidance. Management approval for personnel to re-ceive in excess of 3 rem.in the quarter may be given for situa-tions that involve life saving activities or the protection of facility systems and components from damage. These procedures will be made available for Suffolk County's review.

.74. Identify documents or other data which ensure that a review of individual and plant exposure totals will be per-formed at least annually by LILCO's Review of Operations Committee and every two years-by the Nuclear Review Board.

Please also explain what actions will be taken to reduce

s o

radiation levels and/or exposure if the in-plant totals exceed 1000 man-rem in two successive years.

Response. The Shoreham ALARA Review Committee, which consists of station and corporate management personnel, will perform the annual review of the station's ALARA activities.

The ALARA program and actions taken to reduce collective doses within the plant are not based solely upon total annual collec-tive doses. Rather, design, job and procedure ALARA reviews are established to ensure maximization of dose reduction tech-niques. Consequently, an arbitrary value of 1000 " person-rem" is not a teneficial indicator or action point for ALARA deci-sions.

75. Identify LILCO's procedure or other means to reduce radiation levels and/or exposure if the in-plant totals signif-icantly exceed U.S. plant averages.

Response. The response to 73 above lists the procedures that govern the conduct of the Shoreham ALARA program.

76. According to procedure SF 61.016.03, LILCO's policy is ALARA. The FSAR (12.1) states LILCO's policy as'ALAP.

Please state whether ALARA or ALAP has been or will be the op-erative policy. ,

i Response. ALARA will be the operative. policy.

l l

a

77. Section 12.1.3 of FSAR commits LILCO to Regulatory Guide 8.8 (July 1973). Is this still LILCO's only commitment in this regard?

Response. Regulatory Guide 8.8 is primarily concerned with design objectives to ensure that occupational radiation exposures are ALARA. In addition to the proper design of the-plant, LILCO is committed to the careful preparation of plant operating and maintenance procedures, the review of these pro-cedures, the review of equipment design to feedback, the results of operating experience, and most importantly, the establishment of on-going training programs, as required by Regulatory Guide 8.10.

78. Please provide the basis for the ISI-drywell. piping estimates of annual dose listed in Table 12.4.3-1 of the FSAR.

Response. The basis for the ISI-drywell piping is Table 3.1 in Section 3 of the Study of the Effects of Reduced Radiation xposure Limits on the Commercial Nuclear Power Industry (July 1979), Atomic Industrial Forum. Table 3.1 will be made available for Suffolk County's review.

79. Deleted by agreement of the parties.

80. Deleted by-agreement of the parties.

81. Deleted by agreement of theparties.

82. Deleted by agreement of the parties.

Suffolk Co. Contention 27.

83. Summarize LILCO's position with respect to Suffolk.

County Contention 27.

Response. See LILCO's March 17, 1982 responses to SOC questions on Contention 3, particularly Revised Table 1 setting out the Company's position on each Reguatory Guide 1.97 item.

Suffolk Co. Contention 28.

84. Summarize LILCO's position with respect to Suffolk County Contention 28(a)(1).

Response. See.LILCO's March 17, 1982, responses to SOC's questions on SOC Contention 7.A(1).

85. Summarize LILCO's position with respect to Suffolk County Contention 28(a)(iii).

Response. See LILCO's March 17, 1982 response to SOC's questions on SOC contention 7.A(3).

86. Sumarize LILCO's position with respect to Suffolk County Contention 28(a)(iv).

Response. It is LILCO's position that:

l

1. a 86a. In accordance with NUREG-0696, the total SPDS sys-tem need not be Class IE (safety related).

86b. There is no specific NRC requirement for a fully qualified SPDS prior to June 1983.

86c. The new SPDS will be in compliance with 0696 and, in fact, exceed certain requirements. The imple-mentation date is April 1983. _

87. Summarize LILCO's position with respect to Suffolk County Contention 28(a)(vi).

Response. Based on a BWR Owner's Group evaluation in response to NUREG-0737, Item II.K.3.16, " Reduction of Challenges and Failures of Relief Valves," LILCO has reduced P

the likelihood of an SORV event by a factor of ten when com-3 pared to a " benchmark" BWR/4 plant. This was accomplished by both procedural changes and improved equipment, including the use of Target Rock 2-stage SR/VS. It is LILCO's position that

~

the goal of NUREG-0737, Item II.K.3.16 has been met.

Suffolk Co. Contention 31.

88. Summarize LILCO's position with respect to Suffolk County Contention 31.

Response. The design.of the Shoreham electrical system provides adequate physicalfindependence of electrical cables and raceways in order to comply with 10 C.F.R. 5 50.55(a) and

(. . s Response. No.

91. Does LILCO contend the physical separation of elec-trical cables and conduits in the steam tunnel complies with Reg. Guide 1.75 Rev. 2?

Response. Yes.

92. Identify the design criteria which LILCO applied to the physical separation of electrical cables in (a) the cable spreading room and (b) the steam tunnel at Shoreham.

Resoonse. Design criteria is stated in FSAR and Specification SH1-159.

93. Deleted by agreement of the parties.

94. Deleted by agreement of the parties.

95. Deleted by agreement of the parties.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

( LN%

W. Taylor Reveley,,III-Anthony F. Earley, Jr.

(

Daniel O. Flanagan Hunton & Williams 707 East Main Street

'P.O. Box 1535 _.

Richmond,' Virginia. 23212 1

DATED: March 26, 1982

UNITED STATES OF AMERICA NU CLEAR -REC U LATCR T -COMMISSIOt Before the Atom'ic Saf ety and Licensina Board.. - - - _

In the Matter of .) -

i ) ~~ ~ ~

LONG ISLAND LICHTING COMPANY )  %

~ ~ Docket No . ' 5 0,. 3 2 2. ..'.. J ^ . . - . .

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. 9 s,;w:r., - ah... .

i (Shorehen Nuclear Power. Station.  ; w. . & < n Unit 1) )- " ' l-

??!MICMNNU

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AFFIDAVTT OF' JOHN D. LYNCH. . y,.

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John D. Lynch, being duly swoia, states as f ollowstE l' l. y+2d-i

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I an a Licensing Engineer with the Nt: clear Operation.scr @;c.~. ': zk ;=I

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ne j Any,g. ,,

i Support Department for 'the Long ,; Island Lighting Company-forjp ,

s , y r. .f.

.g.n.f-preparation of material for the Shoreham Operating License.. .

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.3 .

2. The Response of Long Island Lighting Company to 3C's March 5, 1982 Request for. Produc tion of Documents (13, 14, 34b .d, -e, 37a, 's, s, h. 38f); SC's March 5,1982 Interrogatorias i

, (2a-c, 3a-d , 3 f, 33, 31, 3j, 5, 7, 12, 13, 15 thru 18, 53, 54, 55)

SC's March 6,1982 Second set of Interrogatories (5, 6, 7, 9-12,  ;

21-28, 31, 34, 35, 38) and SC's March 8, 1982 Supplement to Second Request for Froduction of Documents (1c iv) were prepared under my supervision and direction. To the best of my._inf.ormation w i knowledge and belief, the answers contained in thos,e responses: -

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f. $&O UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COE!ISSION Before the Atomic Safety and Licensine Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (Shoreham Nuclear Power Station, ) '

Unit 1) )

t AFFIDAVIT OF MICHAEL L. SANDE 9 Michael L. Sande, being duly sworn, states as follows: .

i

1. I am an Instrumentation and Controls Engineer fcr the long Island Lighting Con.pany with the Pcreer Engineering Department.

I have been assigned to the Nuc1 car Operations Support Department for preparation of. material for the .Shorcham Operating License) " .,

2. The Response of Long Island Lighting Company to SC's March 5, 1982 Request for Production of Documents (17, 28 and 31)i SC's March 5,1982 Interrogatories (25 through 30, 32 i

through 37, 56, 59 and 60); SC's March 6, 1982 Second Set of Interrogatories (1, 2, 3, 39 through 42, and 83 through 87) and w-SC's March 8,1982 Suppicment to Second Request for' Production '  ;

of Documents (3, 4, 6, 9,12,18 and 20) were prepared under my.  ;

supervision and direction. To the best of my information,  !

r knowledge and belief, the answers contained in those respaises -  !

are true and correct.  ;,.

[//b!d- / tstb Michael L. Sande l

i Subscribed and sworn to before me c this 26th day of March,1982.

d2/u.n . ;f fJ*.

l- - Lstl4cr<x.s -u +' C-> - en Notary Public ik6:t .S.Ja. ::::n;;;m yo

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NUCLEAR R850LATORY COMMISSION: 4.pp ig.geg:,.ggf.7,4  ;

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. Before the Atomic Safety and' Licensing. Board ?. N.W

• mmu T..l..'c m. -

v[.' 3 h*73.[ % k.I-In the Matter of

) ' '.N e2 - P W . .; c j . *t -

IDNG ISIAND LIGHTING COMPANY ) Docket No. 50-322 . j

)

(shoreham Nucle.tr Power Station, ) - --

l Unit 1) )  ;

i

/ AFFIDAVIT OF ALFRED J. GREENFELD j i

Alfred J. Greenfeld, being duly sworn, states as follows: ,

1. I an a Supervisor, Licensing' for the Stone s ' Webster -

l

> i Engineering Company, New York. I have been assigned to the "

Nuclear Operations Support Department of the Long Island I.ighting ..

Company for the preparation of materials for the' Shoreham Operating *

- . . s . . ,, .,

License. -

2- . s... . c.g .

?.

2. The Response of Ieng Island Lighting Company *to.-SC'st.M_. .Q

.:r March 5,.1982 request for Production of Documents, (2,. l14,?15W$.4@p.r- v* n l

- r ve gM..a.

and 19); SC's March 5,1982 Interrogatories (21,. 22',_23i ,41%wam 477W

' < ~ --

w.y 48, ' 50 and 51) : SC's March 6[1982 'second request for' Production 57f

.-..w. a*+ -

n of Documents (4); and SC's March. 6,1982 second set of Interro. .. . . -

'.k; m e

gatories (46, 47, 48 through 58, 60, 61, 63, 65 through. 70, and q ', ,

72 through 78) were prepared under my supervision and direction.

're the best of my information, knowledge 'and belief, the answers contained in these responses are true and correct. ,

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re"t J. Greenf. eld >

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. Subscribed and sworn to before me . . - - -

this 26 th day of March,1982 y.} y"yy4l($, . .

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• SC Contention 23, #46 &

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<-* LONG ISLAND LIGHTING COMPANY

' * ;..'.~ ,F M@

amoyemur SHOREHAM NUCLEAR POWER STATION

. .. . P.O. ECLX S$3. NOMTM COUNTRY Mc AD e WAOlNG MtVER. N.Y.11792 January 11, 1982 SNRC-659- - -

Mr. Harold R. Denton, Director

• Office of Nuclear Reactor Regulation . .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

Shoreham Nuclear Power Station - Unit'l ,

Docket No. 50-322 9

Dear Mr.. Denton:

In response to Generic Letter 81-35, "Gafety Concerns Associated with Pipe Breaks in the BWR Scram System", the enclosed informa-

, tion is hereby transmitted for your review. This informarion addresses NUREG 0303, " Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping", as well as opon item number 61 of Supplement No.1 to tho Shoreham SER.

should you have any questions, please do not hesitate to contact ,

this office. ,

, Very truly yours, . .

- - .; w i.-.- :. - ~r -

l 5 Manager, Special Projects . .

l Shoreham yuclear Power Station -

RHG:mp .

Enclosure '

ocs J. Higgins '

ese e

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SER CPEN IIEM 61 RFESPONSE TO MUREG 0803 - GENERIC SAFETY EVALUATIOM REPORT R

_BWR SCPAM SYSTEM PIPING . .

The The following is provided in response to SER open item 61 and Nt' REC 0803. i Bhoreham design meets the intent of Nt'nEC 0803 concerning postulated cracks  :

in the seras discharge volunes (SDV) even though the event is beyond the

'dssign basis for high (or modcrate) energy Theline failurcs latter outlined document in thethat requires Shorehan FSAR and MEB 3-1 and APCSS 3-1.

f ailures be postulated only durins normal reactor conditions of startup, Cperation at power, hot standby, or reactor cooldown to cold shutdown '

conditions. ,

In response to item A, page 6-17 of the SER supplement, the SDV piping is f abricated to AS!!E III Code Class 2 requirements per the 1971 Codes through Winter of'73 addendum. The SDV totals approximately 200 feet of piping of

- which only 20' is 10-inch dianeter and the remainder is 8", both scetions Schedule 80. The piping has been stress analyzed in'accordance with all cpplicable codes. Installation per applicable designInspcetion dr'awings will also be of the piping -

verified as part of the Shoreham as-built program.

will be in accordance with the requirements of ASMK XI as applicable to ASME III Code Class 2 piping.

Concerning item B of the SER item, the development of Emergoney Procedures is LILCO is a member of that currently being evaluated by the BWR owners' group.proceduren for this event after the ow group and will develop Emergency group effort is conplete. These procedurcs will specify the .npprop.riata opeytor. __

action.to be taken to accomodate on SDV failure. .

Based upon preliminary evaluations, at least 10 minutes is available for operator ,

response prior to initiating scram reset or, if required, an RPV depressurizacion.

Action during this time fraco would ensure that equipment qualification tempera- ,

tures are not impacted by an SDV failure. ,

Deprassurising the RPV greatly reduces the leakage flow but does not terminate it. Therefore, an additional 4-hour period is assumed for a " search team" to = c . -.e.. .l .. J locate, identify and isolate the now reduced leak.sge via the manual iscintion valves. At the end of 4-hour period, the temperature at the location of the  ;

valves (el 78-7) is calculated to be no higher than 135 F; in addition, all of ,

the valves are located in close proximity to the Hydraulic Control Units GICUs).

LILCO is continuing to evaluate hardware and instrumentation aspects which could have a favorable impact upon opm tor reaction ti:ne. If required, system modifications or additional ineamentation, although not feasible at this time, could be imple=ented at the first refueling outasc. t

• Concerning item C(2). the plant would be depressurized and brought to cold shutdown conditions via Shutdow (meched) III as outlined in Appendix C of the FSA1, Section 3C.3.4.3.2. Note that this method does not require HPCI or RCIC to be available and takes no credit for their use.

An analysis of the SDV crack cf f t:ts hhs bacn performed which takes credit for' only saicty related ven:.11ac W. .md & li:q >y : tem for certain 2rcas of the

, reactor building. The SDV crack becomes the limiting pipe failure for peak aren

. s

_ 1/11/82

g/g ae O

• temperatures. For other factors, the SDV crack offects are less severe than those from previously analyzed pipe f ailures. The SDV crack is limiting for certain ,

tesperature zones on elevations 40 and 63.  !

l All equipment required to support a pinut shutdown via Method III which is I 1ccated on these elevations vill bo qualified for the crack temperatura effects. l Fressure and humidity ef f ects arc not applicable since these conditions are bounded by other events. t Since the SDV crack occurs on el 78-7, water vill flow via various paths to the basement, el 8 A review of the various leakage paths showed that sufficient ECCS equipment for safe shutdown veuld be unaffected by spraying cr flooding ef f ects f rom the crack and the casending water. The actual flood depth on el 8 vould be less severe than that from a moderate (or high) energy line failure as described in Appendix 3C.4 and 3c.5. The el 8 area is capable .

l cf storing approximately 90,000 gal of water prior to impacting any safety .3.--- -

related equipment. The accumulated unter in the first 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> In prior to isolation addition, as out-of the crack is estimated to be less than 36,000 gallons.  ;

lined in Appendix 3C, redundant safety grade Icvel detection equipment exists on.-

Cl B which alarms whon the water level exceeds 1/2".

l The off site doses essociated with this event are expected to be below the 10CFR part 100 guideline since Shoreham is committed to using the Standard

- Technical Specification limits for primary coolant activity. . ,,  ;

_ . . . . .y o

• e e f l

. 1 g

@ 8 6

W SC REQ FOR PROD OF DOC BY LILCO

_ _ . . _ ~

.* A - # 13 SC Contention 1, Question 1 e n e_,,(p ,, n.

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• te

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• W A ct NG r.'/ C A. *4. e. 917 9 2  ;

l a

j Nove: .ber 23, 1931 SNRC-638 i

4r. Harold 3. Centon, Dircetor '

of fice ci :: :1a:: 7.eactor Re:ul: tion U.S. ::: clear Regulatcry Co.r.ission r Washington, DC 20555 i Shoreham Muclear ?cwer Station - Unit i

, Docke: Mc. 50-322 ,

i P

Reference:

(1) Letter US::RC t0 LILCO , 24r. Robert L. Tcdesco to Mr. M. S. Pollock, August 31, 19c.1, Staff 3

Positions - Shoreham ::uclear ?cwer S taticn .

h (2) Letter S:!RC-599 dated July _20, 1931 l l.

Dear :

• c. Denton: .

I

!' Enclosed horewith are sir.ty (60) copies of the items listed below,  !

subnitted in response to concerns identified in the SER Supplement i No. 1 and in Ref. 1:

(1) NUPIG-0737 Item II.B.3 - Post Accident Sampling -  ;

Loss of Offsite ?cwor; t 1

(2) NUREG-0737 Itcm II.K.3.28 - Qualification of ADS  !

Accumulators - Leak Testinc; -

k (3) SSER No. 1 Open Ite= No. 62 - Remote Shutdown Panel  ;

Single Failure; and ,,

, (4) 'NUREG-0737 Item I.C.8 - Emerg'ency Procedures Revised [

as a follcw-up to SRC review and simulator verification. l It should be noted that NRC letter dated Aucust 31,- 1981 establishes i D the staff position that tha' remote shutde.c.' system must be canable of achieving cold shutdown assumine a single failure in the systens ~

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Design Cr .:crion 13 c f 1. . .enf:.:.: A to 10CFR30) as described in the FSAR which was firs: ssu ; in September 1975. To our knowledge, the only area where this :.ssue is discussed is Standard Revie*.i Plan (SEP) Section 7..; unich was subsecuently issucd in ::cyc ber  ;=

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as being app'i:able t the remote shutdcun panel. This section of the SRP was recently revised in July 1951 where, for the first time, t h e ".. o." .

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capability is acnievable as describcd in cur response : SEE Open Item :;o. 62.

The Shoreham Nuclear Power Station Emergency Precedures (as listed in Attach ent 1) have been revised since last submitted via Ref. 2 to account for the folicwins.:

1. Incorporation of : RC cc:r.cnts based on the simulator demonstration at the inerick simulater on 10/16/31 and the S:!PS Control Roca walk through cn 10/17/51;

2. Rew. 4 *... ' ~. .~ o.# ' b. . a. o...cenA"..o.s ~~ ". , '".c' -.ccedu-a

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3. Incorporation of changes required per Revision 13 of the BWR Owners' Group Z ergency Procedure Guidelines. .

If you require additional information or clarification, please do

'not hesitate to contact this office.

Verv. truly -vours o

_'f.f ,

A .)Q:W.H '

J. L. Smith Manager Special Projects

.Shoreham Nuclear' Power Station RWG::p

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SC Contention 3, #28 j SNRC-614 I l

SER OPE.M ITEM 044,_ , LEVEL MEASURU*1ENT ERROR Revicu of Reactor Uater Level Measurement Instrumentation:

The cold reference leg reactor water level measurement desien for Shoreham in illustrated in Figuro 1. Reactor vessel watcr level is measured by differential pressurc transmitters uhich measure the difference in static head botueen two columns of water. One column is a " cold" (anbient temperaturc) reference leg outside the reactor vessel; the other is the reactor water inside the reactor vessel.

The measured differential pressure is a function of reactor water level.

The cold reference log is filled and maintained full of condensate by a condensing chamber at its top which contiruously condenses reactor steam and drains excess condensate back to the reactor vessel through the upper level. tap connection to the condensing chamber.

Tho. upper vessel level tap connection is located in the steam zone above the normal wat?r level inside the vessel. Thus, the reforcnc:

leg presents a constant reference static head of water to the high pressure tap on the d/p transmitter. The low-pressure tap of the transmitter is piped to a lower-level tap on the reactor vessel which is located in the water znne below the normal water level in the

, vessel. The low-pressure side of the transmitter thus senses the static head of water / steam inside the vessel above the lower vcusel level tap. This head varies as a function of reactor water level above the tap and is the " variable leg" in the differential pressurc measured by the transmitter. Lower taps for various instruments are located at various levels in the vessel water zone to accc:enodate both narrow- and wide-range lovel measurements (see Figure 2).

Typical reactor level indicators and recorders are shown on Figure

,3. This figure also shows the condensing chamber. Shoreham level instrumentation, including elevations and set points, is shoun in Figure 4. .

Problem

Description:

Small (e.g., . 01 f t2 ) and intermediate (e.g., .04 ft )2 break accidents (LOCA's) that discharge steam into the drywell (at temperatures as high as 3400P) for an extended time period result in substantial heat-up of components / air in the drywell (including reactor water level sensing lines) . If the reactor is subsequently depressurized below 118 psia, water in the drywell vill flash.

the reactor water level sensing lines located in General Electric has conservatively evaluated many steam break acci-gg dents and has determined that, for the worst case scenario -(small break accident with ADS operation af ter 1800 seconds) , flashing will result g y 1 0 s'-,

. .NN".<-] FSAll in a loss of up to 200 of the water in the sensing lines. Water in

(.. the variable leg denning line will be replenished by drain back trom the reactor, while unter in the reference leg sensing line will continue to be gradually depleted due to boil-off. If no operator action is taken, all of thi s water could, for the worst case, boil off after more than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the accident. Loss of water from the reference leg results in a sensed reactor water level that is higher than the actual reactor water 1cvel. Shorcham renctor water level instrumentation utilizes tuo reference legs for the narrow and vide-range level instracentaiton. Utilizing instrumentation kgye to the longer leg (vorst case), a level error of approximatel 9.1 ' -

could occur. It should bc noted that all reactor water level (adtibated safety trips will occur since they would initiate before the reactor is depressurized below 118 psia.

Operator Actions and Conditions that Prevent and/or E]iminato Flashinc/

Boil-Off:

Flashing /Doil-off will not occur if:

a) The break dischargen two-phase fluid ~cn3y; b) The drywell achieves the higher temperatures before level is recovered such that the saturated liquid spilling out of the break and cooling the steam lines and drywell environment terminates the hentup transient; i'

c) The operator initiates drywell spray before the reactor is depressurized below 118 psia; d) The reactor pressure is maintained above 118 psia.

In addition, even if flashing / boil-off were to occur, it would not be a concern if the operator follows the emergency procedure guidelines (EPG) and maintains reactor level in the normal water level range.

Furthermore, the error due to flashing / boil-off will be eliminated if:

. a) The ope'rator follows the EPG and takes action to refill the reference leg after reactor depressurization if the temperature near the reference leg has exceeded the reactor saturation temperature and continues reactor injection until the temper-ature near the reference leg is below 2120 F; or b) The operator determines that a flashing / boil-off condition exists and takes corrective action to refill the reference leg. Indications available to the operator that indicato reference leg flashing / boil-off are:

1) erratic level indication

2) mismatch between narrow, wide and upset range level indi-cators and recorders (Note: Since EPG requires the oper-ator to monitor water level from multiple indications, he should be aware of level instrument mismatch and hence Ib flashing / boil-off conditionc.)

SNPS-1 FSI R Conclusior!:

Considering the limited nunber of events, operator errors and conservative analynin assurptiens described above, the probabil-  ;

ity of reference 1e; flaching/ boil-off resulting in core uncovery i ir. considered extremely lo,r. Even if one assumes that the worst caso scenario described above occurs, the operator would receive i i

a Icyc1 2 alarm ();cyed to the shorter reference.Icg) approximately 54 minutes prior to initial core uncovery. If this uere disrc- ,

garded, he 'ciculd receive another Icyc1 2 alarm (): eyed.to.the longer ,

reference log) appr? <imately 12 minutes prior to initial core ,

uncovery. -

Based on the above, it is concluded that the Shorcham reactor water [

1evel measurement instrumentation is acceptable.

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SC Contention 3, #28 Shorchan Out' standing SER in,ua M4 SNRC-614 Level I;casurement Errors

(

LEVEL f!EASllREllEl!T ERRORS (due to environmental teuperature effects on level instrument reference legs)

Reactor vessel water icvel is measured by means of a produced differential pressure between a reference leg and a variable leg. The reference leg is connected to the upper part of the vessel (steam zone) and provides the constant head usir.g an overflow type condensing chamber. The variable leg is connected to the lower part of the vessel. The produced differential pressure is therefore a function of water level.

General Electric has conducted a review of the effects of high drywell temperature on reactor vessel water level instrumentation. Although instrument accuracy is affected by varying drywell temperature and boil-off in the reference leg, there would be no impact on the scram or other level trip functions, nor would post-accident operator action be impaired.

The worst case scenario evaluated was as follows:

o Small break LOCA occurs in drywell o Scram and auto ECCS (ADS and LPCI/CS) are actuated i o Some time af ter LPCI/ Core Spray have reestablished normal RPV water level, operator diverts or shuts off LPCI/Ccre Spray from RPV o 10-12 hours after the initiating event, PRV water level error is at it_ maximum o Upon receipt of low level alarm (Level 2), operator must re-initiate LPCI/ Core Spray injection.

Were this unlikely series of events to occur it would be necessary for the operator to restart or redirect low pressure ECCS to the PRV in order to avoid core uncovery. Shoreham specific analysis verified that the operator would have from 10-15 minutes to redirect low pressure ECCS for the worst case scenario presented above, even with a nonconservative water level indication associated with long term boiloff. Operating procedures and training will specifically address the need to be aware of this phenomenon in this small break long term LOCA. Emergency procedure 29.023.09, Reactor Pressure Vessel Flooding, was submitted in S!4RC-599 dated July 20, 1981, specifically assuring a conservative response to this phenomenon.

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, SC Contention 15, #10 POSITION

~

Operating QA Engineer EDUCATION Bachelor of Science Associate of Arts EXPERIENCE QA/QC or Nuclear - 7 years Engineering - 8 years

, Construction - 16. years CERTIFICATION Level III Inspector Auditor TRAINING a) Boiling Water Reactor (BUR) 0'peration - General Electric b) Boiling Water Reactor (BWR) Plant Design - General Electric c) Advanced Supervisory Workshop - LILCO d) Quality Assurance Audit Techniqus - L. Marvin Johnson e) Welding Seminar - LILCO Shoreham Nuclear Projects f) Industrial Radiotraphy - Eastman Kodak Co.

g) Ultrasonics - Automation Industries.

h) Nuclear Quality Assurance Engineering - STAT-A-MATRIX

1) ASME Quality Assurance - STAT-A-MATRIX j) Magnetic Particle & Liquid Penetrant Inspection - Magnaflux k) Warehousing Seminar - New School for Social Research

1) Principals of Nuclear Power - LILCO Evening Institute m) Readings in Managerial Psychology - LILCO n) Mark IV Computer Programming - LILCO o) QA Indoctrination - LILCO p)

QAP-S-02.1, QA Indoctrination and Training Reading - LILCO OQA n

, / .

POSITION QC Engineer

• EDUCATION M.B.A.

B.E.E.

EXPERIENCE QA/QC or Nuclear - 5 years Engineering - 2 years Construction - 2 years

_ CERTIFICATION Level III Auditor Level III Inspector TRAINIhG r

a) GE - BWR Design Orientation b) NDT Level II-R (Liquid Penetrant c) NDT Level II-R (Magnetic Penetrant) d)

• e) Qualification of Safety Related Equipment - Drexel University f) Welding ASNT -

per ASME Section IX - Center / Prof. Advancement Ultrasonics - American Society NDT g) NDE - Radiography - Eastman Kcdak h) Fundamentals of Welding Inspection - LILCO

1) Qualified Pressure Test Supervisor - LILCO j) Quality Auditor Orientation - Stone & Webster k) OQA Indoctrination & Training - LILCO OQA m) n) OQA Training Basic Weldingon System Release Turnover Packages - LILCO OQA Course o) p) Electrical Power System Instrumentation - Center for Prof. Advancement Liquid Penetrant - Magnaflux q) Magnetic Particle - S&W ,

r) 10CFR21, 50.55 (e) Training - S&W  ;

s) Cable Terminations - LILCO OQA t) Valves - LILC0 e

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POSITION QA Engineer EDUCATION

~

-- - 71. S . E . E .

B.E.E.

M.S.N.E. (50% Complete)

EXPERIENCE QA/QC or Nuclear - 2 years Engineering - 4 years

, Construction - 5 years CERTIFICATION Level III Auditor Level II Inspector NDT Level II-R (Liquid Penetrant)

NDT Level II-R (Magnetic Particle)

TRAINING a) Nuclear Engineering I, Polytechnic Institute of New York b) Nuclear Engineering II, Polytechnic Institute of New York c) Nuclear Engineerings Labs I & II involving operation of Brookhaven National Lab's Research Reactor - BWR d) Ultrasonics - LILCO e) Magnetic Particle and Liquid, Penetrant - NDT Course - LILCO f) Qualified Pressure Test Snpervisor - LILCO g) Radiation Protection, Polytechnic Institute of New York h) Qualification i) Nuclear of -Safety-Related Welding General Physics Equipment for Nuclear Power Generating j) QA for the Operating Nuclear Facility, Stat-A-Matrix k) Lead Auditor Training, General Atomic

1) Stations - Drexel University and IEEE m) Electrical Crimping Course - AMP Special Industries n) Computer Science, Polytechnic Institute of New York o) Urban Systems Analysis, Polytechnic Institute of New York p) OQA Indoctrination and Training - LILCO OQA q) OQA Training on System Release Turnover Packages - LILCO OQA r) Spare Parts Procurement - LILCO OQA s) Cable Terminations - LILCO OQA

s ,

1 POSITION

. QC Inspector "A"

_ EDUCATION Licensed BWR Operator Associate of Arts B.S. Physics (95% complete)

EXPERIENCE

' QA/QC or Nuclear - 9 years Engineering - none Construction - 2 years CERTIFICATION Level III Auditor Level II Inspector TRAINING i

Academic Refresher Course - General Physics Nuclear Power Prep. Course - NUS Printreading - LILCO Pumps, Turbines, and Auxiliaries - LILCO Electrical Equipment - LILCO BWR Technology - GE Instrumentation and Control - LILCO Diesel Engines - LILCO Reactor Operations Experiences - LILCO Nuclear Physics I - LILCO Nuclear Physics II - LILCO Basic Applied Health Physics - Brookhaven Lab Research Reactor Training - NUS, LILCO and Brookhaven Lab.

Applied Chemistry - NUS QA Indoctrination and Training - LILCO Operation Certification (Simulator) - CE BWR Observer Training - GE Onsite Training I - LILCO Associate of Arts - Suffolk County Community College Ultrasonic. Testing Course - LILCO OQA Training.on System Release Turnover Packages - OQA Crimping Qualification Course - AMP Special Industries Welding Insoection Course - LILCO Magnetic Particle Testing Course - LILCO Penetrant Testing Course - LILCO Lead Auditor Training Course - L. Marvin Johnson Assoc.

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_P_0S ITION QC Inspector "B"

_,_ _ EDUCATION High School Diploma EXPERIENCE QA/QC or Nuclear - 6 years Engineering - none Construction - 131s years

_ CERTIFICATION l Level II Inspector ~

NDT LevelLevel II (Magnetic Particle, Ultrasonic, Liquid Penetrant)

I Auditor EXPERIENCE Magnetic Particle Inspector - Dyna Empire, Inc.

Liquid Penetrant Inspector - Dyna Empire, Inc.

Hydraulic, Mechanical and Pneumatic Inspector - Dyna Empire, Inc.

Magnetic Particle Inspector - Magnaflux Corp.

Liquid Penetrant Inspector - Magnaflux Corp.

Radiographic Inspector - Magnaflux Corp.

Ultrasonic Eddy Current Inspector - Magnaflux Corp.

"B" Mechanic - LILCO M.S.D.(Probalog) Inspector - Magnaflux Corp.

"A-1" Mechanic - M111vright - LILCO, M.S.D.

MT, Level II - LILCO FQA Ultrasonic Testing, Level II - LILCO FQA Liquid Penetrant, Level II - LILCO FQA OQA Training on System Release Turnover Packages - CQA Crimping Qualification Course - AMP Special Industries BWR Familiarization Course - NUS Welding Inspection Course - LILCO Blueprint Reading - LILCO Principles of Nuclear Power - LILCO Basic Business Writing - LILCO OQA Indoctrinatinn and Training - I.II.C0 OQA e

POSITION

___ _ QC Inspec tor "C"

• EDUCATION B.S. in Natural Sciences .

EXPERIENCE QA/QC or Nuclear - year Engineering - none Construction - 1 year CERTIFICATION Level I Inspector Auditor NDT Level II-R (Liquid Penetrant)

_ TRAINING OQA Indoctrination and Training - LT!.C0 0QA OQA Training on System Release Turnover Packages - LILCO OQA Crimping Qualification Course - AMP Special Industries BWR Familiarization Course - NUS Welding Inspection Course - LILCO FQA Magnetic Particle Testing Course - LILCO FQA Penetrant Testing Course - LILCO FQA Basic Business Writing - LILCO

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POSITION QC Inspector "D" EDUCATION M. S. Education B. A.

Industrial Management - 12 credits EXPERIENCE QA/QC or Nuclear - 5 years

, Engineering - None Construction - None CERTIFICATION Level II Inspector Auditor TRAINING QA Indoctrination & Training - LILCO Audit / Survey Orientation - S&W IBM 370 Presentation - LILCO QA Indoctrination & Training - LILCO OQA Documentation 10CFR21, 50.55 (e)Reviewer Training Indoc.

- S&W & Training /C&IO Testing (480V MCC) - LILCO OQ Review of New & Revised Procedures - LILCO OQA Cable Terminations - LILCO OQA Electrical Crimping Course - AMP Special Industries Valves - LILCO OQA OQA Training on System Release Turnover Packages - LILCO 0QA Pressure Test Supervisor - UNICO BWR Familiarization Course - NUS Welding Inspection Course - LILCO FQA

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