ML20050C118
| ML20050C118 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/02/1982 |
| From: | Flanagan D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SHOREHAM OPPONENTS COALITION |
| References | |
| NUDOCS 8204080155 | |
| Download: ML20050C118 (10) | |
Text
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'82 Ua -5 N1 :07 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322 C) IQ i
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E (Shoreham Nuclear Power Station,
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Y Unit 1)
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N E C E J:j g* '
T Af>R y S
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LILCO'S RESPONSE TO SOC'S T'!IRD SET OF ra
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INTERROGATORIES AND REQUEST N R PRODUCTION 73" 6 ? ' s/
l OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY 4
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On March 19, 1982, the Board ordered LILCO to respond to " SOC's Third Set of Interrogatories And Request for Production of Documents to Long Island Lighting Company," which was incorporated by reference into " SOC's Fourth Set of Interrogatories and Request for Production of Documents to Long l
Island Lighting Company."
The interrogatories, however, were modified as follows:
l 1._
For each Regulatory Guide identified in SOC Contention 19, state whether or not the applicant is in full compliance.
2.
Deleted.
3.
For each Regulatory Guide identified in question 1 to which the answer is negative:
a.
Describe the alternative (s) to the Regulatory position g
implemented by the Applicant;
g) >
58 #
B204080155 820402 PDR ADOCK 05000322 O
b.
Is it the Applicant's position that the alternative (s) identi-Zied in 3(a) provide an equiva-lent level of safety to that specified in the Regulatory posi-tion?
c.
Provide documents upon which the Applicant relies to support its i
position in 3(a) and 3(b).
This Document contains LILCO's response to the modified inter-rogatories.
An affidavit is attached.
I.
SOC CONTENTION 19(a)
A.
Yes.
Shoreham Nuclear Power Station complies with Reg. Guide 1.2.
3a.
Not applicable.
3b.
Not applicable.
3c.
Not applicable.
B.
No.
3a.
The preservice inspection (PSI) was completed be-fore the specified implementation date of Reg.
Guide 1.150.
The PSI program is based on ASME Section XI 1971 edition including addenda through the summer of 1972.
It was submitted to NRC on January 23, 1978 (SNRC-148) and revised periodi-cally.
The PSI program meets the requirements of 10 CFR 50.55(a)(g).
Ultrasonic examinations were performed by certified personnel using properly certified equipment and transducers.
The inservice inspection program will comply, to.
the maximum extent practicable, with Reg. Guide 1.150.
3b.
Yes.
. 3c.
The appropriate documents will be sent under sepa-rate cover.
II.
SOC CONTENTION 19(b)
A.
No.
Shoreham Nuclear Power Station does not com-ply with all requirements of Reg. Guide 1.26, Rev.
3.
3a.
Reg. Guide 1.26, Revision 1 guidelines form the basis for quality classifications of water, steam, and radioactive waste containing components of the plant.
A comparison of Revision 3 to, Revision 1 is undergoing review and should be completed soon.
It has found no significant dif ferences which would affect or alter the classifications applied to Shoreham under Revision 1.
3b.
Yes.
3c.
A copy of the referenced comparison will be made available upon completion.
B.
No.
3a.
The guidelines of Reg. Guide 1.29, Revision 1 form the basis for classification of plant features that must be designed to withstand the effects of the design basis earthquake.
A comparison of Revision 3 to Revision 1 or Reg. Guide 1.29 is undergoing review and should be completed soon.
It has found no significant differences which would affect or alter the classifications applied to Shoreham under Revision 1.
3b.
Yes.
3c.
A copy of the referenced comparison will be made available upon completion.
III.
SOC CONTENTION 19(c)
A.
No.
L
, 3a.
Shoreham complies with Reg. Guide 1.31, Rev. 3, except that the weld pads used to measure delta ferrite in stainless steel filler materials were prepared in accordance with MTEB 5-1, as required by the NRC interim position on Reg. Guide 1.31.
3b.
Yes 3c.
IV.
SOC 19(d)
A.
The Shoreham Nuclear Power Plant does not comply with every aspect of Reg. Guide 1.44.
3a.
Shoreham meets the intent of Reg. Guide 1.44.
For t: lose items which are not in full compliance, suitable alternatives have been used.
- Moreover, the plant also complies with NUREG-0313, Rev. I which addresses the failure of piping from inter-granular stress corrosion cracking.
3b.
Yes.
3c.
FSAR Appendix 3B Section 3B 1.44 and the sections that it references.
V.
SOC 19(e)
As Reg. Guide 1.60 1.
The design response spectra used in the Shoreham Nuclear Power Station seismic design is not iden-tical to that proposed by Reg. Guide 1.60.
However, Reg. Guide 1.60 has provision for site-specific design response spectra.
3a.
The design response spectra for Shoreham was de-veloped, prior to the issuance of Reg. Guide 1.60, by using site-specific information as well as rec-om.nendations suggested by Newmark, whose studies were used to develop Reg. Guide 1.60.
3b.
Yes.
3c.
FSAR Section 3.7 and SER Section 3.7
l l B.
The Shoreham seismic analysis does not use the component damping values recommended by Reg. Guide 1.61.
3a.
The modal analysis used for Shoreham seismic design incorporated damping values representing the coupled effects of structures, components and soil.
For the most part, this is more conserva-tive than a Req. Guide 1.61 analysis.
3b.
Yes.
l
-3c.
FSAR Section 3.7 and SER Section 3.7 VI.
SOC CONTENTION 19(f)
A.
1.
Shoreham Nuclear Power Station complies with Reg.
l Guide 1.63.
3a.
Not applicable.
3b.
Not applicable.
3c.
Not applicable.
VII.
SOC CONTENTION 19(g)
A.
The Shoreham Nuclear Power Station does not comply with Reg. Guide 1.75 in every detail.
3a.
SNPS substantially complies with Reg. Guide 1.75.
Areas of noncompliances are more than adequately offset by the use of halogenated cables, total flooding CO2 fire protection systems in the cable spreading / relay room, diesel generator rooms and battery rooms.
A very conservative Cable Separation Study (SNRC-526, December 31, 1981) confirms our judgment that a level of safety equivalent to that of Reg. Guide 1.75 is achieved at Shoreham.
3b.
Yes.
, 3c.
FSAR Appendix 3B-1.75 and Table 223.12-3; and SNRC-526 which will be forwarded under separate Cover.
VIII.
SOC CONTENTION 19(h) 1.
Shoreham Nuclear Power Station does not comply with Reg. Guide 1.89.
3a.
LILCO's position on Environmental Qualification for Class IE equipment is summarized in SNRC-663,
" Environmental Qualification Report for Class IE Equipment for SNPS-Unit 1" (January 15, 1982),
which was transmitted to SOC on February 18, 1982.
3b.
Yes.
3c.
SNRC-663; FSAR Section 3.10 & 11, and Chapter 7 &
8.
IX.
SOC Contention 19(i)
A.
Shoreham Nuclear Power Station does not meet Reg.
Guide 1.100.
3a.
The Shoreham seismic qualification program for safety-related Class IE electrical equipment com-plies with SRP Section 3.10.II.1 which provides an acceptable method for meeting General Design Criteria 2.
3b.
Yes.
3c.
FSAR Section 3.10.
X.
SOC CONTENTION 19(j)
A.
Shoreham Nuclear Power Station complies with Reg.
Guide 1.115.
3a.
Not applicable.
3b.
Not applicable.
3c.
Not applicable.
. = '.
, Respectfully submitted, LONG ISLAND LIGHTING COMPANY
<f 1 4 u 9 O h -
l W.
Taylor Reveley, IQI Anthony F.
Earley, Jr.
Daniel O.
Flanagan Hunton & Williams 707 East Main Street Richmond, Virginia 23212 DATED:
April 2, 1982
o 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
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF JOHN P.
MORIN John P. Morin, being duly sworn, states as follows:
1.
I am the Sr. Licensing Engineer for the Nuclear Operations Support Department, Long Island Lighting Company.
2.
The Response of Long Island Lighting Company to the discovery request concerning SOC Contention 19, as reiterated in their fourth set of interrogatories and as modified by the Board on March 19, 1982, and the responses filed in LILCO's FURTHER RESPONSE TO SOC'S MARCH 1, 1982 INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS filed March 26, 1982, were prepared under my supervision and direction.
To the best of my information, knowledge and belief, answers contained in that response are true and correct.
b s
ohn P.
Morin Subscribed and sworn to before me this 31st day of March, 1982.
&f Notary Public 3/Ad((/
My Commission Expires:
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l In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
CERTIFICATE OF SERVICE i
I hereby certify that copies of LILCO's RESPONSE TO SOC's THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY were served upon the following people by first-class mail, postage prepaid, on April 2, 1982, except for the asterisked people, who were served by hand on April 2, 1982.
Lawrence Brenner, Esq.*
Atomic Safety and Licensing Administrative Judge Appeal Board Panel l
Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris
- U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Bernard M. Bordenick, Esq.
Commission David A.
Repka, Esq.
Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter
- Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.
Board Panel Attn:
Patricia A. Dempsey, Esq.
U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C.
20555 Veterans Memorial Highway Hauppauge, New York 11787 Secretary of the Commission U.S.. Nuclear Regulatory Commission Washing ton, D.C.
20555
o s
a
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Herbert H.
Brown, Esq.
Howard L.
Blau, Esq.
s Lawrence Coe Lanpher, Esq.
217 Newbridge Road Karla J.
Letsche, Esq.
Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Matthew J.
Kelly, Esq.
8th Floor Staff Counsel, New York 1900 M Street, N.W.
State Public Service Commission Washington, D.C.
20036 3 Rockefeller Plaza Albany, New York 12223 Mr. Mark W.
Goldsmith Energy Research Group Mr. Jay Dunkleberger 400-1 Totten Pond Road New York State Energy Office Waltham, Massachusetts 02154 Agency Building 2 Empire State Plaza NHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue Suite K San Jose, California 95125 Stephen B.
Latham, Esq.*
Twomey, Latham & Shea 33 West Second Street P.
O.
Box 398 Riverhead, New York 11901 Ralph Shapiro, Esq.
Cammer and Shapiro, P.C.
9 East 40th Street New York, New York 10016 53d o %w
" Daniel O.
Planagap Hunton & Williams 707 East Main Street P.
O. Box 1535 Richmond, Virginia 23212 DATED:
April 2, 1982 1
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