ML20042C311
| ML20042C311 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/26/1982 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SUFFOLK COUNTY, NY |
| Shared Package | |
| ML20042C307 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8203310197 | |
| Download: ML20042C311 (24) | |
Text
_ _ _
March 26, 1982 o
p.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station, )
Unit 1)
)
LILCO'S RESPONSE TO SUFFOLK COUNTY'S REQUESTS FOR PRODUCTION OF DOCUMENTS On March 5, 1982, Suffolk County filed its Request for Production of Documents by Long Island Lighting Company.
On March 6, 1982, Suffolk County filed its Second Request for Production of Documents by Long Island Lighting Company.
- And, on March 8, 1982, Suffolk County filed its Supplement to Suffolk County's Second Request for Production of Documents by Long Island Lighting Company.
Subsequent to these filings, Suffolk County and Long Island Lighting Company (LILCO) agreed to limit certain requests and to delete others.
Additionally, the Board ruled on certain of LILCO's objections to the re-quests, ordering further production of documents.
Below are Suffolk County's requests, as modified by agree-ment and the Board's order, and the corresponding LILCO re-sponses.
Where a response states that documents are available on site, those documents may be inspected at reasonable times 8203310197 82037.6 PDR ADOCK 05000322 o
I agreed upon by the parties beginning March 26, 1982, through April 2, 1982, at Shoreham Nuclear Power Station.
I.
SUFFOLK COUNTY REQUEST FOR PRODUCTION OF DOCUMENTS BY LONG ISLAND LIGHTING COMPANY MARCH 5, 1982 1.
All documents identified in response to Suffolk County's Interrogatories to LILCO, dated March 5, 1982.
Response.
Any documents identified in response to Suffolk County's interrogatories that are not included with LILCO's answer are available for inspection on site.
2.
All Shoreham Emergency Operating Procedures (the "29" l
Series).
Response.
These documents were forwarded to SOC and the County on March 17, 1982.
3.
The most recent and current version of the Shoreham Technical Specifications.
Response.
Available on site.
4.
The most recent and current engineering drawing of FSAR Fig. 7.4.1-5A through E,
" Remote Shutdown System IED."
Response.
Available on site..
5.
The most recent and current revision of " Remote Shutdown System Design Spec," noted as Reference 2 in FSAR Fig.
7.4.1-6A.
Response.
Available on site.
6.
Deleted by agreement of the parties.
7.
The most recent and current revision of each of the fol-lowing Shoreham Procedures:
(a) SP #23.133.01, " Remote Shutdown Panel Control System."
(b) SP #29.022.01, " Shutdown From Outside the Control Room Emergency Procedure."
(c) SP #29.010.01, " Emergency Shutdown Procedure."
(d) SP #29.015.01, " Loss of Electrical Power Emergency Procedure."
(e) Deleted by agreement of the parties.
(f) Deleted by agreement of the parties.
(g) SP #23.119.01, " Reactor Core Isolation Cooling System."
(h) Deleted by agreement of the parties.
(i) SP #23.122.01, " Service Water System."
(k) SP #21.006.01, " Station Operator Training and Qualification Program."
Response.
Available on site:
(a), (b), (c), (d),
(g),'(i) (j), and (k).
8.
The most recent and current revision of each of the fol-lowing Shoreham Alarm Response Procedures:
(a) ARP 1051, "RSDS Transfer Switch in Emergency Posiition Div.
1" (b) ARP 1364, "RSDS Transfer Switch in Emergency Position Div.
II."
F (c) ARP 1365, "RSDS Transfer Switch in Emergency Position Div. III."
(d) ARP (LTR) RSP Access Doors Open.
Response.
Available on site:
(a)-(c).
(d) ARP (LTR) RSP Access Doors Open is not yet complete.
LILCO will forward a copy of the final document at a later date.
9.
Deleted by agreement of the parties.
10.
All updated and current Remote Shutdown System, front view, panel drawing (s).
Response.
The Remote Shutdown System front view panel i
drawings are included in the response to 4 above.
F.-
11.
A synopsis of operator training regarding emergency use of the Remote Shutdown Panel.
Response.
Available on site.
12.
The current Shoreham Shift Turnover Procedure.
Reaponse.
Available on site.
13.
Letter #SNRC-638 and a copy of LILCO's forthcoming re-sponse to NRC request numbers 223.93 through.99.
Response.
SNRC-638 is available on site.
LILCO's response to NRC request numbers 223.93 through.99 will be forwarded when it is complete.
14.
Report by Reinhart & Associates, Inc. concerning 1981/1982 pre-service inspection tests of the Shoreham Reactor Pressure Vessel (RPV).
Response.
Reinhart & Associates has not completed its report.
A copy will be forwarded when the report is re-ceived by LILCO.
15.
Report by Nuclear Energy Services, Inc. concerning 1981/1982 pre-service inspection tests of the Shoreham RPV.
Response.
NES, Inc. has not completed its report.
A copy will be forwarded when the report is received by LILCO.
16.
Deleted by agreement of the parties.
17.
All pre-operational test results of water hammer-related tests performed on Shoreham's ECCS.
Response.
See LILCO's March 26, 1982 response to question 40 in SC's March 5 interrogatories to LILCO for a description of the tests to be conducted.
Results of these tests are not yet available.
18.
Deleted by agreement of the parties.
19.
The purchase spec and successful vendor proposal for the LPM.
Response.
Available on site, 20.
Deleted by agreement of the parties.
21.
Deleted by agreement of the parties.
22.
Deleted by agreement of the parties.
23.
Deleted by agreement of the parties.
24.
A copy of the following correspondence from LILCO to the NRC regarding ECCS pump blockage:
(a) SNRC-598 (b) SNRC-602 Response.
Available on site.
i 1
o 25.
Provide the supporting information package and specs for:
(a) Level Transmitter for Reactor Level Trip, manufactured by Rosemount, Model 1151, (Equipment ID:
- 1B21*LT154C; vendor ID: B21-N080C);
(b) Deleted by an agreement of the parties.
(c) Fuel Zone Level Indicating Transmitter, manufactured by Barton Model 760 (equipment ID:.1B21* LIT 007A; ven-dor ID: B21-NO37A);
(d) Reactor Containment Electrical Penetrations, manufac-tured by General Electric, Series 200 low voltage, (equipment ID:.lT23*Z-EB2);
(e) Deleted by an agreement of the parties.
(f) Radiation Detector / Containment High Range, manufac-tured by Kamen (equipment ID: *1D21*RE085A).
Response.
Available on site.
l 26.
Deleted by agreement of the parties.
27.
Deleted by agreement of the parties.
28.
Describe the location and mounting of radioactive effluent sampling points for monitoring releases at each potential release points at Shoreham.
Response.
See SNRC-669 attached to LILCO's March'17, i
1982 responses to SOC's' interrogatories.
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29.
No item 29 was received in the original request.
,)'
30.
Deleted by agreement of the parties.
j, 31.f All emergency operating procedures used by LILCO to de-scribe recommended actions with regard to post-accident monitoring instruments and systems.
Response.
The post-accident monitoring system is a new addition to the Shoreham Nuclear Power Station.
At the present time, LILCO is reviewing a draft copy of the system description.
LILCO will write a procedure for the i
post-accident monitoring system once the system descrip-tion has be9n issued as a revision.
32.
Provide information on the 401 Fahrenheit penalty in Peak Clad Temperature (PCT) limits to be justified or unwa ran-ted as an interim resolution of tP concerns set forth in
Response.
Available on < Ate.
(
ThemosthecentandcurrentrevisionofLILCO's. operations 33.
QA program manual and all implementing procedures and
./
4 i
other, documents which concern whether and how the require-ments,of'10.CFR 250 Appendix B will be satisfied.
Response.
Available on site.
II e -
+
- _ _f
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34.
Copies of the QA Manuals for Shoreham, and implementing procedures of each of the following:
(a) Stone & Webster; (b) Comstock/ Jackson; (c) Courter; (d) Jackson; (e) Dravo; and (f) Deleted by agreement of the parties.
Response.
Available on site:
(a)-and (c).
(b) Comstock/ Jackson works under Stone & Webster's QA pro-gram.
(d) " Jackson" is part of Comstock/ Jackson.
(e) Dravo works under Stone & Webster's QA program.
35.
Deleted by agreement 6f the parties.
36.
The most current revision of LILCO's QA manual and proce-drues for non-operational activities (including design, construction and procurement).
Response.
Available on site.
37.
All audits required by Appendix B or committed to in the ESAR, prepared or conducted by or on behalf of any person, concerning the effectiveness of the QA programs of:
_9
J (a) Comstock/ Jackson; (b) Stone & Webster; (c) Courter; (d) Deleted by agreement of the parties.
(e) Dravo; (f) LILCO; (g) other contractors; and (h) other subcontractors Response.
Available on site:
(b)l/ and (c).
(a) Comstock/ Jackson does not have its own QA program.
See LILCO site audits, available on site.
(e) Dravo does not have its own QA program.
See LILCO site audits, available on site.
(g),(h) LILCO has not required other contractors and sub-contractors to submit their QA audits as part of their final documentation package to LILCO.
LILCO has sear-ched its files and has found no copies of other con-tractors' or subcontractors' audits except those of Keasbey/ Bisco, which are available on site.
A list of the contractors and subcontractors who performed safety-related work at Shoreham is available on site.
-l 1
1/
Stone & Webster has not provided its internal corporate audits. These reviews are not related to Shoreham and have not been released or shown to LILCO.
According to S&W, they are not of the type requested here.
38.
All non-conformance/non-compliance logs or listings, showing the dates on which each non-conformance/non-compliance was entered and cleared for (this will be the same material produced for the PSC Phase II investiga-tion):
(a) LILCO's QA program; (b) Stone & Webster's QA program; (c) Comstock/ Jackson's QA program; (d) Courter's QA program; (e) Deleted by agreement of the parties.
(f) Dravo's QA program; and (g) Deleted by agreement of the parties.
Response.
Available on site:
(a), (b) and (d).
(f) See Stone & Webster's logs.
39.
LILCO will explain whether there has been a programmatic evaluation (audit) of the system for initiating and clos-ing out non-conformances.
Response.
Audits of the S&W and Courter Nonconformance Control Program are performed twice annually.
These audits encompass the systems for initiat-ing and closing out noncenformances.
Audits of the non-conformance control area have been performed by LILCO since 1973.
These documents are available on site..
40.
Deleted by agreement of the parties.
II.
SUFFOLK COUNTY'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS BY LONG ISLAND LIGHTING COMPANY MARCH 6, 1982
.l.
Deleted by agreement of the parties.
2.
With regard to Section 17.2 of the FSAR where it states
" Audits shall be conducted.to predetermined schedules,"
please provide a copy of the current " predetermined" audit schedules.
Response.
LILCO Quality Assurance Manual Appendix A contains a list of organizations and auditable functions that will be used as guidance to formulate planned spe-cific audit schedules during the operational phase.
The
" January 1982 - December 1982 OQA Audit Schedule" is the current schedule of OQA audits planned for the 1982 tran-l
{
sition phase and the early operations phase activities at the station.
It is available on site.
Also see LILCO's March 26 response to question 21 of SC's second set of interrogatories.
1 I
I _ _ _ _ _ _ - _ _ _ _
3.
Does LILCO have a procedure or program that provides for inspection strategy and implementation schedule for the OQA program?
If so, make a copy availabe on site.
Response.
Yes.
Available on site.
3A.
Did an inspection plan outlining auditing frequency, in-spection strategy and management review exist for con-struction QA.
If so, make available on site.
Response.
Yes.
Available on site.
4.
S&W Topical Report RP-8A " Radiation Shielding Design and Analysis Approach for Light Water Reactor Power Plants,"
May 1975.
Response.
Available on site.
5.
Deleted by agreement of the parties.
III.
l SUPPLEMENT TO SUFFOLK COUNTY'S REQUEST FOR PRODUCTION OF DOCUMENTS BY LONG ISLAND LIGHTING COMPANY MARCH 8, 1982 Suffolk Co. Contentions 13-15 1.
On March 22, 1978, LILCO provided an "index of Shoreham quality assurance (QA) records that 10 CFR Part 50, Appendix B, Criterion XVII requires LILCO to retain...."
Letter from F.
C. Whittemore to I.
Like, March 22, 1978". _ - _ _ _
(a) Deleted by agreement of the parties.
(b) Provide the following categories of documents identi-fied in the previously supplied index, in each case provide documents listed in the index of the same cat-egory, which ha/e been added to the index in the period March 15, 1978 to the present:
(i) p.85 QAP-S-06.2 Control of Site OQANS OQAPS OQAI CONT SOQC Proc. & INST 08-31-733 (ii) p.85 SPI-IN-003 GE/NSS Spare Part Receipt Inspect. (Including 7 MPL items listed on p.85)
(iii) p.85 SPI-IN-039 BOP Spare Pts Receiving Inspect. (Including 4 items listed on p.85)
(iv) p.88 1A21.200 Reportable Items; SYS-200 (Including 5 categories listed on p.88)
(v) p.183-4 1A95 Personnel (Including all 1A95.220 startup_ rec. qual. &
cert. plus all updates for new personnel)
(vi) p.185-199 1B11.
Reactor Assembly System-(Included are RPV, Internals, l
Nozzles, CRD Housings)
(vii) p.200 1B21.010 System Wide Des. Info.
(viii) p.206-219 1B21.220 Shop Fabricated Pipe (Include all radiographs of 4 in. pipe, 12 in. pipe, and 24 in. pipe only)
(ix) p.
231 1B21.320 Non-mechanical valves B21-F013L Main Steam r,ine B S/R P
valve (x) p.251-53 1C41 Standby Liquid Control System (Include all documents)
(xi) p.255 1C61 Reactor Remote Shutdown System (all documents)
(xii)
.p.257 1C91 Plant Computer System (all documents)
(xiii) p.334 1E21.010 System Wide Information/ Core Spray System (xiv) p.340 1E21.220 Shop Fabricated Pipe / Core spray (Include all items pertaining to Wr2-2-04, and WR2-2-05, and WR21-2-01)
(xv) p.345 1E21.250 Field Welds / Core Spray (xvi) p.346 1821.250 1C065-FW-01 SPl-WR2-2-5 to VLV-MOVO35A (xvii) p.459-464 IM43.010 System Wide Design Info./ Fire Protection (All documents)
(xviii) p.568 IN32 Turbine Control System (All documents)
(xvix) p.614-15 1P33 Sample System (All docu-ments)
(xx) p.616 1P41-110 Pumps / Service Water System (All documents in this section)
(xxi) p.739 1R3G AC Uninterruptable-Vital-Power Supply (All documents)
(xxii) p.797 1T23.010 Systemwide Design Info./ Reactor Primary Containment Liner System (All documents)-
(xxiii) p.797.
1T23.310 Manual valves / Suppression Chamber (All documents)
(xxiv) p.834 1T48-150 Primary Containment Atmosphere - Hydrogen Control l
(All documents) l (xxv) p.909 1Y30.010 Systemwide Design l
l Info./Concr. Batch (All docu-
)
f ments)
(xxvi) p.911 1Y30.200 Concrete Test Reports (All documents) c.
Provide all copies, including, but not limited to to the most recent versions, of the following documents not listed in the index:
(i)
Deleted by agreement of the parties.
(ii)
Deleted by agreement of the parties.
(iii)
Deleted by agreement of the parties.
(iv)
Qualification Records (of sys-tem / components identified in (b))
(v)
As-built drawings (of systems / components /
structures identified in (b))
(vi)
Resoluton of E&DCRS (of sys-tems/ components / structures identified in (b))
(vi. )
Resolutions of I&E Reports / Findings (of systems / components / structures identified in (b))
l l _ ___-___________ ________
Response.
Available on site.
2.
The most recent and current revision of the following Shoreham procedures as described in FSAR Table 13.5.1-1:
(a) Administrative Procedures #2, 4,
6, and 9; (b) Operating Procedures #2(b), (c), (d), (1), (m), (n),
(o), (p), (q), (t), (u), (w), (y), (z), (aa), (ae),
(ag), (ah), (am), (as), (at), (au), (ba), (bg), (bi),
and (bk); and (c) Operating Procedures #3(g), (k), (m), (n), (p), (q),
(r), (s), (t), (u).
Response.
Available on site:
(a) and (b).
(c) These procedures were sent to Suffolk County on March 17, 1982.
3.
Provide INPO criteria for developing procedures.
Response.
LILCO has ANSI, not INPO, procedures.
They are available on site.
4.
Describe operating procedures that have been subject to Control Room walk-through tests.
Recponse.
Control Room walk-through tests of proce-dures were performed at Shoreham as part of both the NRC Human Factors Control Room Audit and the NRC Evaluation of Emergency Procedures based on the BWR Owners Group Emergency Procedure Guidelines.
The latter was preceeded..
.by a demonstration at the Limerick simulator.
These two walk-throughs and the simulator demonstration included loss of coolant accidents, the emergency shutdown proce-dure, and loss of component cooling water system acci-dents.
In addition the Shoreham operators are trained at the Limerick simulator using Shoreham Nuclear Power Station Operating Procedures and Alarm Response Procedures whenev-er possible.
Many of the Shoreham procedures can be used since the ECCS systems at Limerick are similar to those at Shoreham.
5.
Explain LILCO's proposed or actual schedule for " periodic" procedure reviews after initial approval as required by FSAR Section 13.5.1, and how plant and/or personnel re-lated events that would necessitate unscheduled review of procedures.
Response.
SP12.006.01 defines the requirement for periodic review of station procedures.
The review fre-quency of each procedure is determined by the initial reviewers.
The preplanned interval between reviews is published in the' Plant Procedure Status Listing (PPSL).
Any unusual incident such as an accident, an unexpected transient, a significant operator error, or equipment 1
malfunction necessitates the unscheduled review of the applicable procedure (s).
6.
Describe the means by which operators (both in the main control room and at the remote shutdown panel), are made aware of field modifications requiring the issuance of a temporary procedure.
Response.
SP12.010.02, Station Assigned Design Modification Activities, establishes the requirements for control of station assigned modification activities.
Included in this procedure is the requirement for a review to determine if a procedure change is required.
If a tem-porary procedure change is required due to a field modifi-cation, the change will be made in accordance with SP12.006.01.
This procedure requires any temporary proce-dure to be placed in the Temporary Procedure Change Log Book.
All licensed operators are required to review this log prior to watch relief.
7.
The General Physics Corporation Report, concerning the Shoreham Control Room audit performed by the General Physics Corporation.
Response.
Available on site.
8.
Deleted by agreement of the parties. -
9.
Describe the use of any INPO Task Analysis techniques in the evaluation of operator and shift supervisor activities during various plant events at Shoreham.
Response.
INPO Task Analysis Techniques Guidelines f
have yet to be issued in final form.
When received.from l
INPO, these guidelines will be evaluated for implementa-tion at Shoreham.
10.
Copies of the following correspondence from LILCO to the l
NRC in which LILCO responded to the requirements of TMI Action Plan, item I.C.:
(a) Item I.C.3 - May 15, 1981 submittal; l
(b) Items I.C.2, I.C.4, I.C.5, and I.C.6 - Jul; 31 and l
l August 7, 1981 submittals.
Response.
Available on site.
l 11.
Describe the system that has been proposed and/or establi-shed at Shoreham to evaluate the effectiveness of the shift and relief turnover procedures, as required by TMI i
l Action Item I.C.2.
l j
Response.
Available on site.
12.
A copy of the fo: lowing checklists:
(a) The checklist for the oncoming and offgoing control room operators and the oncoming shift supervisor to complete and sign; (b) The checklist or log for the oncoming and offgoing auxiliary operators and technicians to complete and sign.
Response.
These checklists are contained in SP21.002.01, available on site.
13.
A copy of LILCO's response to the July 31, 1980 NRC letter on the subject:
" Interim Criteria of Shift Staffing."
Response.
Available on site.
14.
Deleted by agreement of the parties.
15.
A copy of LILCO's response to the NRC Generic Letter L1-04 of 2/25/81 concerning emergency procedures and training for station blackout events.
Response.
Available on site.
16.
Deleted by agreement of the parties.
17.
Describe the means by which LILCO has-indexed and/or cross-referenced the Shoreham operating procedures, in-cluding a copy of any such index or-cross-references; in addition, describe the diagnostic guidance available to an operator. _.
Response.
Available on site.
18.
Describe the organization of reference materials, includ-ing procedure, in the Shoreham control room and remote shutdown room.
Response.
The Shoreham control room contains a master copy (MC-2) of all station procedures in addition to con-trolled and working copies of required precedures and copies of other appropriate documents such as Technical Specifications, FSAR, etc.
A set of the appropriate sta-tion procedures (29.xxx.xx, 22.xxx.xx, 23.xxx.xx, and 69.xxx.xx) are stored in the Remote Shutdown Panel room for reference by the operator.
These include emergency procedures, radiation protection procedures, shutdown pro-cedures and system operating procedures for systems con-trolled at the RSP and/or required for safe shutdown of the plant.
19.
A copy of each of the following procedures:
(a) SP62.032.60, " Respiratory Equipment Cleaning and Inspection" (b) SP62.032.70, " Control of Respiratory Equipment" (c) SP69.062.01, " Emergency Response Facilities Equipment Control and Readiness Check"
+
(d) SP69.064.01, " Inventory of Emergency Kits" (e) SP69.060.01, " Emergency Response Training" (f) (Unnumbered SP) " Drills and Exercises" (g) SP62.032.01, " Respiratory Protection Program".
Response.
Available on site:
(a), (b), (c), (d) and (g).
(e) This is a training manual that is not completed yet.
(f) This procedure is not completed yet.
20.
A copy of the procedure that addresses the once-per-shift panel walkdown to be conducted by control room operators to detect failed lamps on the control panels.
Response.
These procedures are included in SP21.002, available on site.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
> >/f *
.' Taylor veleff'iII,
~7 Anthony F.
arley, Jr.
Daniel O.
Flanagan HUNTON & WILLIAMS 707 East Main Street P.O.
Box 1535 Richmond, Virginia 23212 DATED:
March 26, 1982,
l b
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S FURTHER RESPONSE TO SOC'S MARCH 1, 1982 INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS I.
On March 17, 1982, LILCO responded to SOC's March 1, 1982 discovery requests.
As indicated there, i
LILCO objected to some of the requests.
Subsequently, in a conference call with the parties on March 19, 1982, the Board ordered LILCO to respond to certain of the re-quests to which it had objected.
The ordered responses appear below~along with supplementary responses to SOC Contentions 7. A(2) and 16.
The appropriate affidavit will be sent under separate cover.
II.
SOC Contention 3 8.
The Board directed LILCO to respond to this question by either providing a list of the requested equipment if it exists or, if not, providing the as built drawings 9