ML20050C601

Statement of Contentions in OL Proceeding.Notices of Appearance & Certificate of Svc Encl

ML20050C601
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/31/1982
From:	HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20050C600	List: ML20050C598 ML20050C601
References
NUDOCS 8204090146
Download: ML20050C601 (39)

Text

.

c~e nirm STATEMENT OF CONTENTIONS IN THE OPERATING LICENSE PROCEEDING FOR SHOREHAM NUCLEAR POWER STATION, UNIT 1 March 31, 1982 8204090146 020406 PDR ADOCK 05000322 PDR O

INDEX OF CONTENTIONS Contention Subject Page SC 1 Remote Shutdown Panel 5 SC 2 Diesel Generator Relays 5 SC 3 Detection of Inadequate 5 Cole Cooling SC 4 llater Hammer 6 SC 5 Loose Parts Monitoring 6 SC 7B Methodology for Systems Interaction and System Classification 6 SC 8 Environmental Qualifi-cations 6 SC 9 ECCS Pump Blockage 7 SC 10 ECCS Core Spray 7 SC 11 Passive Mechanical Valve Failure 8 SC 12 QA/QC -- Design and Construction 8 SC 13 QA/QC -- Operations 8 SC 14 QA/QC -- NRC I&E Program 9 SC 15 QA/QC -- Review and Inspections 10 SC 16 ATWS 10 SC 17 Fire Protection 11 SC 18 Human Factors --

Equipment 11

SC 19 Hunan Factors --

Procedures 14 SC 20 Human Factors --

Simulator 15 SC 21 Mark II Containment 15 SC 22 SRV Test Program 17 SC 23 Containment Isolation 17 SC 24 Cracking of Materials 18 SC 25 ASME Section XI (PSI /ISI)

Program 18 SC 26 ALARA Radiation Exposures 19 SC 27 Post-Accident Monitoring 20 SC 28(a)(i) Cutoff of ECCS 21 SC 28(a)(iii) Iodine Monitoring 21 SC 28(a)(iv) Safety Parameter Display Panel 22 SC 28(a)(vi) Reduction of SRV Challenges 22 SC 31 Electrical Separation 22 SC 32 Electrical Penetrations 23 Contention Subject Pace SOC 3 Regulatory Guide 1.97 24 SOC 7.A(1) Cutoff of ECCS 24 SOC 7.A(3) Iodine Monitoring 24 SOC 7.A(4) Safety Parameter Display Console 24 SOC 7.A(6) Reduction of SRV l Challenges 24 i

J

1

] SOC 7.B Methodology for Systems Interaction and System l Classification 24 SOC 8 Detection of Inadequate Core Cooling 24 SOC 9 Notification of Disabled Safety System 25 SOC 16 Clad Swelling and Flow Blockage 26 SOC 19(a) Reg. Guides 1.2 and 1.150: RPV Integrity and Testing 28 SOC 19(b) Reg. Guides 1.26 and i

1.29: Classification of Equipment 28 SOC 19(c) Reg. Guide 1.31: Ferrite Content in Stainless Steel 29 SOC 79(d) Reg. Guide 1.44: Materials 30 SOC 19(e) Reg. Guides 1.60 and 1.61:

Seismic Design 31 SOC 19(f) Reg. Guide 1.63: Electrical Penetrations 31 SOC 19(g) Reg. Guide 1.75: Electrical Separation 31 SOC 19(h) Reg. Guide 1.89: Environmental Qualifications 32 SOC 19(i) Reg. Guide 1.100: Seismic Qualifications 33 SOC 19(j) Reg. Guide 1.115:

Turbine Orientation 33 I

l p x-- n.. -. , - ,- - - , - _ . . . . _ . , . - , . . - - ._

~

Contention Subject Page OHILI/NSC 7(j) Emergency Planning 34 1

4 SUFFOLK COUNTY CONTENTIONS SC 1: REMOTE SHUTDOWN PANEL Suffolk County contends that Shoreham's remote shutdown panel (RSP) ooes not have adequate instrumentation or controls

to meet 10 CFR 50, Appendix A, GDC 19. Specifically, the RSP instrumentation and controls for the following systems are in-adequate to provide an indication of operability of control valves and pumps with a potential for failures:

(a) Reactor Core Isolation System (valves, motor operators and pumps);

(b) Residual Heat Removal System (motor and air valve operators); and (c) Service Water System (motor and air valve operators).

SC 2: DIESEL GENERATOR RELAYS Suffolk County contends that Shoreham's onsite emer-gency generating system does not meet 10 CFR 50, Appendix A, CDC 17 because of the high probability of system failure due to accumulation of dirt in relays located in the diesel generator rooms.

SC 3: DETECTION OF INADEQUATE CORE COOLING Suffolk County contends that LILCO and the NRC Staff have not demonstrated and confirmed that Shoreham has adequate instrumentation and procedures to detect and monitor the onset of inadequate core cooling (ICC). NUREG-0737, item II.F.2 re-quires that instrumentation provide an unambiguous, easy-to-interpret indication of inadequate core cooling. LILCO has taken the position that no additional instruments are needed and that current water level instruments are sufficient. But these instruments are not a direct indication of core cooling and core temperature (as are in-core thermocouples) and thus may not provide an unambiguous, easy-to-interpret indication of ICC or fuel failure under certain conditions. There is insuf-ficient diversity of instrumentation to assure that a common event (e.g., drywell high temperature interfering with water level measurement) cannot cause a loss of direct measurement capability. Because there is no direct fuel temperature mea-surement and because other instruments (e.g., fission product detectors, steam line radiation monitors and hydrogen monitors) become inoperative under some accident conditions, there is no assurance of indication of the onset of ICC. Therefore,

l LILCO's design and instrumentation are inadequate to detect and monitor the onset of ICC and do not comply with 10 CFR 50, Appendix A, GDC 13, and 10 CFR 50.55a(h).

SC 4: WATER HAMMER i suffolk County contends that LILCO has not demonstrated adequate assurance of the operability of safety-related piping 4

to prevent or withstand the effects of water hammer because the Company has not considered the start-up experience at similar BWR plants. Therefore, Shoreham safety-related piping (e.g.,

EcCS, Reactor Decay Heat Removal Systems) does not meet 10 CFR 50, Appendix A, GDC 1, 31, and 46.

! SC 5: LOOSE PARTS MONITORING Suffolk County contends that Shoreham's Loose Parts Monitoring System could produce a large number of spurious (unwanted) alarms which, if not readily identified or ex-plained, could diminish operator performance and overall plant safety. This would violate 10 CFR 50, Appendix A, GDC 1 and 13, as well as 10 CFR 20.1(c), and 10 CFR 50.36(c)(2), (3) and 1 (5).

SC 7B: METHODOLOGY FOR SYSTEMS INTERACTION AND SYSTEM CLASSIFICATION LILCO and the Staff have not applied an adequate meth-odology to Shoreham to analyze the reliability of systems tak-

) ing into account systems interactions and the classification and qualification of systems important to safety, to determine which sequences of accidents should be considered within the design basis of the plant, and if so, whether the design basis of the plant in fact adequately protects against every such sequence. In particular, proper systematic methodology such as the fault tree and event tree logic approach of the IREP pro-gram or a systematic failure modes and effect analysis has not been applied to Shoreham. Absent such a methodological ap-proach to defining the importance to safety of each piece of equipment, it is not possible to identify the items to which General Design Criteria 1, 2, 3, 4, 10, 13, 21, 22, 23, 24, 29, 35, 37 apply, and thus it is not possible to demonstrate com-

. pliance with these criteria.

SC 8: ENVIRONMENTAL QUALIFICATIONS Suffolk County contends that the TMI-2 accident demon-strated that the severity of the environment in which equipment important to safety must operate was underestimated and that equipment previously deemed to be environmentally qualified had

1 i

4 failed. Shoreham's safety-related equipment has not been i demonstrated to be capable of maintaining functional operabil-ity under all service conditions throughout its installed life, and during the time in which it is actually required to oper-ate, thereby violating 10 CFR 50, Appendix A, GDC 1, 2, 4 and 23, and 10 CFR 50, Appendix B, Sections II, III, and XI.

Deficiencies in the qualification of Shoreham's safety-related equipment must be eliminated before operation

, can be authorized. Specifically, (a) The limited test conditions posed in the Shoreham environmental qualification pro-gram are not sufficiently conservative; (b) Equipment has been qualified by grandfa-thering to older, less stringent stan-dards; (c) The list of emergency equipment to be qualified is inadequate; (d) There has been an inadequate demonstra-tion that all safety-related equipment

has been properly qualified to meet aging i and other life requirements; and 1

(e) There is insufficient information to evaluate the overall adequacy of Shoreham's satisfaction of environmental qualification requirements for safety-related equipment.

SC 9: ECCS PUMP BLOCKAGE Suffolk County contends that LILCO has not adequately demonstrated that drywell piping and equipment insulation loosened and/or damaged during a postulated loss of coolant accident will not unduly degrade the ECCS flow through the ECCS suction strainers located in the suppression pool. Therefore, the Shoreham design does not satisfy 10 CFR 50, Appendix A, GDC 35.

1 SC 10: ECCS CORE SPRAY Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated that the Emergency Core Cooling System for Shoreham meets the requirements of 10 CFR 50.46 and Appendix K with regard to core spray distribution and counter current flow, as shown by the recent Japanese test data described in BN-81-24.

1

,7 <- , . . , -. - , - - ,-..,4 - - - , , , , , - - . - - - , - - , ,c-- - . - - - - - . , , - - - ,-n.--. .,.- ,,

SC 11: PASSIVE MECHANICAL VALVE FAILURE Suffolk County contends that LILCO has not demonstrated that the valves used in the safety-related systems at Shoreham will not fail in an undetectable or unsafe mode, thereby jeop-ardizing the safe operation of Shoreham and violating 10 CFR 50, Appendix A, GDC 23, 34, 35, 37 and 40.

SC 12: QUALITY ASSURANCE / QUALITY CONTROL -- DESIGN AND CONSTRUCTION Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated that the quality assurance program for the design and inctallation of structures, systems, and components for Shoreham was conducted in a timely manner in compliance with the pertinent portions of 10 CFR 50, Appendix B, Sections I to XVIII, and 10 CFR 50, Appendix A, GDC 1. There has been a pattern of QA/QC breakdowns at Shoreham. This pat-tern has covered Appendix B Criteria 2, 3, and 5-18.

Accordingly, Suffolk County contends that LILCO has failed to comply with 10 CFR Part 50, Appendix B, as particularized in Appendix I attached hereto.

SC 13: QUALITY ASSURANCE / QUALITY CONTROL -- OPERATIONS Suffolk County contends that the QA program description for the operation of Shoreham, as provided in the FSAR, does not comply with 10 CFR 50.34(b)(6)(ii) and 10 CFR 50, Appendix B, Sections I to XVIII, with regard to:

(a) Failure to address, at a minimum, each of the criteria in Appendix B in sufficient detail to enable an independent reviewer to determine whether and how all the re-quirements of Appendix B will be satis-fied; (b) Failure to provide for the adequate iden-tification, reporting and analysis of all equipment failures discovered during op-eration and maintenance at Shoreham and at other operating BWR stations with similar equipment; (c) Failure to ensure that replacement mate-rials and parts of systems classified as components "important to safety" will be equivalent to the original equipment, that replacements will be installed in accordance with adequate process proce-dures, and that the repaired or reworked

_9_

structures, systems, or components will be adequately inspected, tested, and documented in "as-built" drawings; and (d) Failure to provide an adequate number of qualified QA/QC personnel on the oper-ating staff, including the availability of QC personnel on off-shifts, i SC 14: QUALITY ASSURANCE / QUALITY CONTROL - NRC I&E PROGRAM Suffolk County contends that the NRC Staff's Inspection and Enforcement (I&E) Program has not adequately verified that LILCO's quality assurance pregram for Shoreham has been imple-mented in accordance with the requirements of 10 CFR 50.34(a),

paragraph 7 and 10 CFR 50, Appendix B, Sections I through XVIII, in that:

(a) The I&E Program has identified only the symptoms of the Shoreham quality defi-ciencies as nonconformances, and has not required LILCO to initiate corrective action to resolve the root causes; (b) The I&E Program's reliance on LILCO for i primary inspections at Shoreham with NRC officials serving as auditors is not ade-quate because the same practice has recently proved to be inadequate in time-ly identifying quality deficiencies at other nuclear facilities (e.g., Browns Ferry, North Anna, Davis Besse, and Rancho Seco); and (c) The I&E Program has no baseline criteria against which to measure quantitatively the effectiveness of the Shoreham quality program. In order to draw conclusions from random inspections just such a sta-tistical base is desirable. In addition, the I&E program has no means of determin-ing improvements in, or the effectiveness of, corrections as no congarative mea-sures are used.

Therefore, no general conclusions as to the adequacy of the LILCO program can be drawn by I&E.

c ---- - - _

,,m---.- _ - _ - m -- - - y -----.

-, . -_ .-- ---. . . _ - . - . __ __ - - _ - . =.. - - -

1 j SC 15: QUALITY ASSURANCE / QUALITY CONTROL -- REVIEW AND INSPECTIONS Suffolk County contends that the Shoreham quality as-l surance/ quality control program has involved inadequate review and physical inspection to verify compliance with 10 CFR 50, Appendix B. The inability to verify full compliance with i

Appendix B is based on inadequacies discovered independently at Diablo Canyon, Zimmer, Midland and South Texas and on state-ments by NRC Chairman Palladino. Similarly, the random, non-systematic approach taken by NRC I&E to verify quality programs

, is inadequate to provide appropriate assurance of compliance.

Also the random checks being conducted by the NRC resident in-spector at Shoreham indicate lapses, breakdowns and incon-sistencies that do not provide credible public assurance of an operable QA System. For example, see NRC Inspections

. 50-322/79-05, 80-03, 80-06, 80-08, 80-14 and 81-02. Because

, the NRC reports do not indicate what changes, if any, were made in procedures to correct for failures that have occurred, it is not possible to judge the adequacy of corrective actions.

Finally, there are r.o quantitative measures used to assure that

NRC T&E and LILCO audits can be correlated statistically to j provide verification of the adequacy of the QA system to detect system or equipment errors or distinguish between random errors and systematic failures.

Therefore, there is no assurance that LILCO has com-

]

i plied with 10 CFR 50.55(e) and 10 CFR 50, Appendix B, Sections XVII and XVIII. Suffolk County contends that NRC I&E and LILCO cannot provide assurance of compliance without systematically

auditing QA documentation against physically inspectable struc-i tures and components. This physical audit should be

sufficiently detailed to provide statistically valid data to permit projection of the audit results to systems beyond those systems and QA records inspected.

SC 16: ANTICIPATED TRANSIENTS WITHOUT SCRAM Although the anticipated transients without scram issue is generically before the Commission in a rulemaking proceed-ing, Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated that Shoreham meets the require-ments of 10 CFR Part 50, Appendix A, CDC 20, regarding correc-tion of the ATWS problem in the interim period of several years pending completion and implementation of the result of the rulemaking for Shoreham. This is because the interim measures to be taken at Shoreham, including operational procedures and operator training, will not compensate for the lack of an auto-matically initiated and totally redundant standby liquid con-trol system (SLCS) which meets the single failure criterion.

r SC 17: FIRE PROTECTION Suffolk County contends that:

(a) LILCO has not demonstrated that Shoreham meets 10 CFR 50, Appendix A, GDC 3 and 19, due to the lack of a toxic gas detec-- - -

tion and warning system in the control room. The Shoreham control room contains-many items, especially cable and ventilation-duct insulation material, which present a potential toxic gas hazard. Because one of the largest prob- '

lems during the BrcVns Ferry fire was the toxic gas given off by burning cable ma-terials, and because Shoreham has no de-tection or warning equipment for toxic gas in the control room, GDC's 3 and 19 '

have not been met.

J (b) Shoreham's Fire Protection Program does '

not meet 10 CFR 50, Appendix A, GDC 3 due -

to the lack of manual fire alarms in the machine shop area at elevation 15 feet.

In this area, it is expected that flamma-ble, toxic and hazardous materials will be stored and used. While automatic de-tectors are provided in the ventilation systems, a significant number of all BWR fires to date have been detected by plant personnel rather than automatic detection systems. Lack of manual alarms may impede rapid personnel notification of a fire.

SC 18: HUMAN FACTORS -- EQUIPMENT Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated and confirmed that the control room design at Shoreham is adequate to provide the timely con-trol necessary to protect the health and safety of the public, and thus to satisfy 10 CFR 50, Appendix A, GDC 13, 19, 20, 22 -i and 29. Specifically l

(a) There is no first-out alarm capability provided in the control room annunciator system that identifies the initiating events when multiple annunciator alarms I occur. In view of this deficiency, the control room operator is forced to rely

p,

$- on the events computer for the needed information. The events computer is slow, not classified as safety-related, and not'directly integrated with response proceduras. Accordingly, a reliable and timel'y recponse to all plant failures

, cannot be guaranteed.

Further, the following, taken in conjunction with the

above, are other defects such that the information for control room operators is not presented in a manner that facilitates the recognition of developing off-normal conditions and the mitigation of accidents:

(b) There is no audio or visual annunciator h[ indication to signal that an alarmed con-dition has cleared.

N (c) There is noLindication why an annunciator

^

is lit,-- whether because the. system is, in fact, inoperable due to malfunction, or because it has been by-passed and is actually capable of functioning.

(d) The sequeine of annunciator trips and events appears on the computer printer which is the only~means available to com-municate this information to the operator in the event of a ma'or accident or tran-

~ , sient. However,;the events computer is slow, not classif.ied as safety-related, and not directly integrated with response procedures. The non-redundant, low re-liability plant computer has been shown to become overloaded by major accidents and to be incapable'.of supplying timely information on acci' dent sequences. The

_ computer print-out is not readily visible

'and is poorly located for use by the operators under accident conditions.

Accordingly, a reliable and timely re-sponsd to all plant failures cannot be guaranteed.

/

-(e) The LILCO responses to the control room human, factors audit report leave a corisiderable ndmber of small equipment changes either:delnped until fuel load, deferr'ed for long-term review or not made at all. . Individually, these equipment

^

-t s .

3 ,

p' g, i

~

s x,

}

inadeqbiciesdonotappeartobe

' ' significant; however, taken as a whole, they could provide some serious opera-tional difficulties over time.

Annunciator light failure frequency is unknown (Shoreham Safety Evaluation Report,;Supp. No. 1 (SSER No. 1),

.. N ' Appendix C, Item 2.6) which, combined

." \ '

j with ibns problems (SSER No. 1, Appendix C, iten 3.14), could lead to operator

( , difficulties in visually detecting alarms. Many other control room and con-s trol beard problems, originally identi-

' fled in the audit have not yet been resolved.

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

(ii) Background noise levels in the s control room (" Human Factors Engineering Control Room Design Review -- LILCO Response to NRC Audit Findings," dated l 6/8/81 [ hereinafter referred to as

" Response to Human Factors Review"], ,

NRC Findings Review"], NRC Finding 2.7);

(iii) Lighting level in the control room (SSER No. 1, Appendix C, Item 2.2 and Response to Human Factors Review, NRC Finding 2,3);

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

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

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

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

1 l

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

(ix) Strip chart records (SSER No. 1, Appendix C, Items 10.1, 10.2, 10.3 and 10.4, and Response to Human Factors Review, NRC Findings 10.1 through 10.9); and (x) Reactor mode switch and key location (SSER No. 1, Appendix C, Item 4.13).

SC 19: HUMAN FACTORS -- PROCEDURES Suffolk County contends that 10 CFR 50.40 and 50.57 requirements have not been met because:

(a) LILCO has not demonstrated that Shoreham's training program and proce- f dures are both consistent and plant-specific. For example, fire protection equipment used in the control room is different than that discussed in the training manual and the procedure calls for use of equipment different than that available.

(b) In addition, Shoreham's procedures are inadequate (i) to respond to station blackout, shift turnover, and operation in protective clothing or equipment, and (ii) to assure knowledge of shutdown sys-tem operability.

(c) Further, the human factors implications of responding to emergency procedures have not been adequately checked. For l example, locations of emergency equipment l l

controls have not been checked for se-quential activities to assure proximity of controls or instruments used sequen-tially and to assure operators or super-visors are not overloaded.

(d) Also, Shoreham's procedures are keyed tu annunciators, and this method may not be optimum in diagnosing accidents to deter-mine the appropriate response when multi-ple alarms occur.

4 SC 20: HUMAN FACTORS -- SIMULATOR TRAINING Sufiolk County contends that, in order to provide ade-quate training for Shoreham's operators during the interim period

• and to comply with 10 C.F.R. Part 55, Appendix A. LILCO must provide for operator training on one or more simulators that accurately reproduce the operating characteristics of Shoreham, and that closely parallel the instrumentation and controls arrangement of the Shoreham control room.

Suffolk County contends that LILCO's intended use of the Dresden and Limerick simulators is not adequate for Shereham operator training due to the dissimilarity in opera-tional characteristics (e.g., operator response time and dynamic characteristics) resulting from a different containment design, and dissimilarity in the arrangement of instrumentation and control, such as the emergency control systems and impor-tant balance of plant equipment. Thus, because LILCO intends to conduct Shoreham's operator training at the Dresden and Limerick simulators, Shoreham operators will not be trained to reproduce accurately those actions to be taken during actual abnormal and emergency conditions, and therefore, the require-ments of 10 CFR Part 55 Appendix A have not been satisfied.

• The " interim period" is that period of time commencing with initial Shoreham operator training activities and ending with the availability of a Shoreham-specific simulator for operator training.

SC 21: MARK II CONTAINMENT LILCO and the NRC Staff have not adequately demon-strated that Shoreham's primary containment, reactor pressure vessel supporting structure and attached and associated safety-related equipment mect the requirements of 10 CFR 50, Appendix A, GDC 4, 16, 50, 51 and 52. The specific concerns are as follows:

(a) Forces generated during the suppression pool LOCA dynamics have not been com-pletely and adequately determined and taken into account. Of the numerous Mark II Containment loads assessed on a ge-neric and on a plant unique basis under the Mark II reassessment program underway for the past six years, several LOCA forces have not yet been shown to have been suitably handled in the design of the structures, systems, and components important to plant safety. Included in

I this category are the forces due to Steam Condensation Downcomer Lateral Loads (Loads I.B.l.a & b in Table 6-1, NUREG-0420, Supp. No. 1), Steam Condensation Oscillation Loads (Loads I.B.2.a in Table 6-1, NUREG-0420, Supp.

No. 1), and Steam Condensation Chugging Loads (Loads I.B.2.c in Table 6-1, NUREG-0420, Supp. No. 1). 4 l

(b) Forces generated during safety relief  !

valve (SRV) actuation, continuing SRV l blowdown, and those due to suppression pool heatup resulting from such extended I blowdowns have not been demonstrated to  !

be adequate'y accommodated. Concern spe-  !

cifically remains for the Quencher Air Clearing Loads (Loads II.B in Table 6-1, NUREG-0420, Supp. No. 1), Steam Condensation Submerged Drag Loads (Loads III.C in Table 6-1, NUREG-0420, Supp. No.

1), and proper specification and accom-modation of the suppression pool tempera-ture limit (phenomenon II.A in Table 6-1, NUREG-0420, Supp. No. 1).

(c) The capability and adequacy of the test ,

procedure to periodically demonstrate an acceptable leakage rate of the drywell floor seal and downcomer vacuum breakers and other leakage paths that could lead to excessive steam bypass of the suppres-sion pool 1.as not been demonstrated.

(d) Adequacy of the design to insure, with sufficient margin, that the primary con-tainment and associated safety-related structure can accommodate the simultane-ously applied loads of transient and LOCA avents has not been demonstrated.

(e) Suffolk County further contends that the extent of the deficiencies resulting from the Mark II containment design program may be further exacerbated by the fact that an adequate and properly controlled experimental design verification program as required by 10 CFR 50, Appendix B, Sections III and XI has not been per-formed. The verification of the design i

4 adequacy of the primary containment, reactor pressure vessel supporting struc-ture, and associated safety-related sys-tems and components is deficient with specific regard to testing under the most adverse design conditions, performance of tests under suitable environmental condi-tions, documentation and evaluation of test results, and use of test data devel-oped under a non-controlled (foreign) test program. There is, therefore, lack of assurance that the acceptance criteria used by LILCO in evaluating the Shoreham design contains suitable conservatism.

SC 22: SRV TEST PROGRAM Suffolk County contends that LILCO has not adequately demonstrated that the safety / relief valves to be used at Shoreham meet the requirements of 10 CFR 50, Appendix A, GDC 4 and 30, and 10 CFR 50, Appendix B, Sections III and XI, in that the functionability of the valves, as-installed, has not been established by the generic test program results. Specifically, NUREG-0737, item II.D.1, performance testing of BWR relief and safety valves, requires that BWR SRV valves be tested to demon-strate that the valves will open and reclose under the expected flow conditions. It additionally requires that ATWS testing be considered.

LILCO has not yet provided a detailed plant specific evaluation of the Shoreham safety and relief valves, piping, and supports in accordance with the NUREG-0737 requirements.

Additionally, no commitment has been made on ATWS testing.

Therefore, it has not been demonstrated at this time that the specific requirements have been met.

SC 23: CONTAINMENT ISOLATION Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated that Shoreham meets the re-quirements of 10 CFR 50, Appendix A, GDC 54, 55, 56, and 57 regarding the adequacy of the containment isolation valves.

Valve configuration and functionability relating to leak rate and intersystem leakage testing have not been sufficiently dem-onstrated. Further, LILCO has not fully complied with NUREG-0737, item II.E.4.2 (containment isolation dependability) in that the automatic isolation and operability of the contain-ment purge valve have not been demonstrated. Further, LILCO has not demonstrated that the requirements of NUREG-0803 re-

, lated to a postulated break in the scram discharge volume have

! been met.

1

i SC 24: CRACKING OF MATERIALS Suffolk County contends that LILCO has not demon-strated, and the NRC Staff has not verified, that Shoreham meets the requirements of 10 CFR 50, Appendix A, GDC 4, 14, 30, 4

and 31, with regard to the adequacy of material selection and l control and system design as follows:

(a) The use of appropriate materials and pro-t cesses as specified by NUREG-0313, Revision 1, has not been fully followed in the design and construction of the Shoreham piping systems important to safety.

1 (b) Recommendations contained in NUREG-0619 (p. C-12) relating to the installation of a low flow controller to be used to con-trol feedwater flow over a range of flow from 0.5 percent to 10 percent of rated flow has not been implemented at Shoreham. Analytical evidence shows that such a flow controller is necessary'to limit crack growth in BWR feedwater noz-zles over the life of the plant.

SC 25: ASME SECTION XI (PSI /ISI) PROGRAM Suffolk County contends that LILCO has not adequately j demonstrated the effectiveness of the technology and methods available that are required to satisfy the inspection and tests specified by 10 CFR 50, Appendix A, GDC 32, 36,'39, and 45.

The technology used for the PSI inspection for the reactor pressure boundary cannot be correlated to that used for the ISI program. And, further, the results from inspected areas of the reactor pressure boundary cannot be extended to non-inspectable areas. Suffolk County further contends that the Shoreham plant does not comply with 10 CFR 50.55a(g) which requires, for the ISI P"ogram, use of the Edition and Addenda of Section XI of the adME Code in effect 12 months prior to the date of issuance of the operating license. Because the Shoreham piping config-uration and reactor vessel design substantially pre-date the latest code, LILCO has already identified some Section XI in-spection requirements for which exemption has been requested.

Additional exemptions and/or waivers will undoubtedly be iden-i tified. The impact of these deficiencies has not been speci- '

fied'and analysis has not been presented to demonstrate the effectiveness of the ISI program.

4 I

I

SC 26: ALARA RADIATION EXPOSURES Suffolk County contends that LILCO has not adequately demonstrated that Shoreham meets the requirements of 10 CFR 20.1(c), with regard to provisions for maintaining occupational radiation exposure as low as is reasonably achievable (ALARA).

Demonstration of compliance is inadequate as follows:

(a) Plant and equipment design has not been shown to be optimally developed for mini-mization of radiation exposure during maintenance of the plant by:

(i) Selection of low cobalt materials;

(ii) Separation or isolation of various components and piping systems; (iii) Provisions for flushing or decontamination; (iv) Equipment layout and arrangement for ease and automation of mainte-nance and refueling; and (v) Condenser design utilizing the minimum number of shell connections.

(b) Procedures have not been developed and emplaced to provide:

(i) Limitation of iron-cobalt buildup in the primary system through water chemistry control; (ii) Monitoring and control of individual and plant total annual occupational radiation doses, with individual exceedance of three rem per quarter and five rem per year occurring only on an emergency basis and requiring special management approval; and (iii) Action to reduce radiation levels and/or exposure if the in-plant total significantly exceed U.S.

plant averages.

I j s t' 27: POST-ACCIDENT MONITORING i

The recent Revision 2 of Reg. Guide 1.97,

" Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant Environs Conditions During and Following an Accident" details needed devices and qualifications of instru-ments. Shoreham is deficient in the following areas:

(a) Radiation Exposure Rate Monitoring (Item 18, Table 1; Items 20 and 41, Table 2);*

(b) Radioactivity Concentration or Radiation Level in Circulating Primary Coolant (Item 11, Table 1; Item 14, Table 2);

(c) Continuous On-Line Monitoring of Halogen in Effluent (Item 39, Table 1; Item 43, Table 2);

(d) Secondary Containment Area Radiation Monitor (Item 36, Table 1; Item 17, Table 2);

(e) Reactor Coolant System Soluble Boron Concentration (Item 3, Table 1; Item 4, Table 2);

(f) Analysis of Primary Coolant (Gamma Spectrum) (Item 12, Table 1; Item 15, Table 2);

(g) Drywell Spray Flow and Suppression Chamber Spray Flow (Items 21 and 24, Table 1; Items 23 and 23A, Table 2);

(h) Standby Liquid Control System Flow (Item 28, Table 1; Item 37, Table 2);

(1) Plant and Environment Radiation Monitoring (Item 40, Table 1: Item 45, Table 2);

(j) Post-Accident Sampling Capability (Item 42, Table 1; Item 47, Table 2); and (k) BWR Core Thermocouples (Item 5, Table 1; Item 13, Table 2).

l l

• The item and table numbers used in this contention refer to the information provided in the Affidavit of Brian R.

McCaffre; submitted in support of LILCO's Motion for Summary Dispositic._ of SOC Contention 3, dated July 13, 1981.

SC 28(a)(1): CUTOFF OF ECCS Suffolk County contends that the NRC Staff has not ade-quately assessed and LILCO has not adequately resolved, both singularly and cumulatively, the generic unresolved issues ap-plicable to a BWR of the Shoreham design. As a result, the Staff has not required the Shoreham structures, systems, and components to be backfit to current regulatory practices as required by 10 CFR S 50.55(a), S 50.57, and 6 50.109, with regard to the following:

A. LILCO has failed to resolve adequately certain generic safety items identified as a result of the TMI-2 accident and contained in NUREG-0737, Clarification of TMI Action Plan Recuirements (1980).

(1) The operator's decision to cut off coolant injection at TMI-2 contributed to the accident se-quence and fuel damage. NUREG-0737, Item II.K.3.21 requires that the major low pressure emergency cooling systems for BWR's (core spray (CS) and low pressure coolant injection (LPCI)) incorporate an automatic restart on loss of water level if an ini-t1ation signal is still present. Since the opera-tor can shut off the flow from these systems at any time, there are conditions where it may be neces-sary to override the operator's action. LILCO has not demonstrated that proper core cooling capa-bility will be available for all plant conditions, namely, shutdown of the CS or LPCI systems by the operator. Thus, it has not ensured compliance with 10 CFR 5 50.46 and S 50.55a(h).

SC 28(a)(iii): IODINE MONITORING (3) The monitoring of ioc ine releases in the TMI-2 accident was both untimely and complicated by the iodine sampling and measuring techniques used. The equipment needed for continuous en-line iodine gaseous effluent monitoring is not presently avail-able at Shoreham. NUREG-0737, Item II.B.F. allows the alternative of vent release sampling, provided it is powered by vital bus power and is accessible during an accident. The Shoreham design does not

satisfy either of these alternatives. LILCO proposes instead to measure two other streams, those from the turbine building and radwaste build-ing, while assuming the reactor building ventila-tion contribution is zero. These two sampling in-struments are not powered by vital bus power.

Thus, LILCO's iodine measurement system cannot account for leakage, incomplete isolation, or sys-tem misoperation and thus may not be capable of accurately assessing the quantity of iodine re-leased in the station vent. The design is, there-fore, not in compliance with 10 CFR Part 50, Appendix A, Criteria 13 and 64.

SC 28(a)(iv): SAFETY PARAMETER DISPLAY CONSOLE (4) The short-term design of the Safety Parameters Display Console (NUREG-0737, Item I.D.2) proposed by LILCO does not provide a high reliability dis-play console in that the CRT and plant computer are not safety-related equipment and cannot be relied upon to function during and following an accident.

For this reason, Shoreham violates 10 CFR Part 50, Appendix A, Criterion 13.

SC 28(a)(vi): REDUCTION OF SRV CHALLENGES (6) LILCO hopes to accomplish a reduction in chal-lenges to safety / relief valves (NUREG-0737, Item II.K.3.16) by procedural techniques, rather than by system modifications. But the reliability of the SRV's chosen for Shoreham has been historically poor. Thus, LILCO has not demonstrated SRV compli-ance with 10 CFR Part 50, Apper. dix A, Criterion 30.

SC 31: ELECTRICAL SEPARATION Suffolk County contends that 10 CFR S 50.57 and 5 50.109 requirements have not been made because:

(a) Regulatory Guide 1.75 -- The design of the Shoreham electrical system faile to provide adequate physi-cal independence of electrical cables and raceways as set forth in Revision 2 to Regulatory Guide 1.75 and therefore does not comply with 10 CFR S 50.55a and Part 50, Appendix A, Criteria 3, 17 and 21. In addition, the minimum separation criteria for Shoreham stated in Section 3.12 of the ESAR have not been followed as noted in Inspection Report

50-322/79-07 dated August 21, 1979 and subsequent reports from t.ie Office of Inspection and Enforcement. Accordingly, each deficiency in sepa-ration for Shoreham electrical cables and raceways must be adequately demonstrated using one of the following options:

. 1. correct the deficiency by meeting the electrical equipment separation criteria set forth in Section 3.12 of the Shoreham Final Safety Analysis Report;

2. correct the deficiency by meeting Regulatory Guide 1.75, " Physical Independence of Electric Systems,"

Revision 2 dated September, 1978;

3. correct the deficiency by installing an acceptable barrier; or

4. justify the deficiency by performing a specific analysis for each cable or raceway where the minimum separation is not met to demonstrate that a failure will not propagate because of the insuf-ficient separation.

SC 32: ELECTRICAL PENETRATIONS Shoreham has installed General Electric containment electrical penetrations which utilize epoxy as a pressure sealant and as an insulator. The GE-furnished epoxy has cracked and peeled due to aging and has deteriorated due to moisture absorption. In addition, the electrical penetrations at Shoreham have not been qualified to current regulatory re-quirements. For these reasons, Shoreham violates 10 CFR Part 50, Appendix A, Criteria 4 and 50.

Further, the GE series 100 and 200 qualification docu-mentation is incomplete in that the qualified life is not I

established and the LOCA test duration was insufficient to di-rectly demonstrate post-accident operability of 180 days.*

Thus, the equipment qualification and associated records are not in compliance with Criteria 3 and 17 of Appendix B to 10 CFR Part 50.

,

• See " Environmental Qualification Report for Class IE Equipment for Shoreham Nuclear Power Station," Revision 1, 4

January 15, 1982, at Appendix G.

1 I

SHOREHAM OPPONENTS COALITION CONTENTIONS SOC 3: REGULATORY GUIDE 1.97 The text of SOC 3 is identical to that of SC 27. See page 20, above.

SOC 7.A(1): CUTOFF OF ECCS The text of SOC 7.A(1) is identical to that of SC 28(a)(i) if " SOC contends" is substituted for "Suffolk County contends." See page 21, above.

SOC 7.A(3): IODINE MONITORING The text of SOC 7.A(3) is identical to that of SC 28(a)(iii). See page 21, above.

SOC 7.A(4) SAFETY PARAMETER DISPLAY CONSOLE The text of SOC 7.A(4) is identical to SC 28(a)(iv).

page 22, above.

See SOC 7.A(6): REDUCTION OF SRV CHALLENGES The text of SOC 7.A(6) is identical to that of SC l 28(a)(vi). See page 24, above, i

SOC 7B: METHODOLOGY FOR SYSTEMS INTERACTION AND l SYSTEM CLASSIFICATION SOC 7B is identical to SC 7B. See page 6, above.

SOC 8: DETECTION OF INADEOUATE CORE COOLING TMI-2 demonstrated the need to measure fuel cladding temperatures during accident conditions. Criterion 13 of 10 CFR Part 50, Appendix A, requires that:

Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal

operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure ade-quate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure bound-ary, and the containment and its associated systems.

Appropriate controls shall be provided to maintain

, these variables and systems within prescribed operating ranges.

f

--c,- , _ . _ -

---r- ,- -

y -, y - - . - . . _ , - - . - - - + - . -

..--,._r.-- .

SOC contends that the Shoreham plant design does not have instrumentation to permit measurement of fuel clad temperature, in the range experienced at TMI-2, as required by 10 CFR Part 50, Appendix A, Criterion 13. Further, the Shoreham design does not provide adequate means to detect the onset of inade-quate core cooling (ICC) and this poses a threat to public health and safety similar to that posed at TMI-2. TMI-2 opera-tors did not immediately detect the onset of ICC partly because there was no direct indication of it. NUREG-0737, Item II.F.2 requires that each plant have instrumentation to provide an unambiguous, easy-to-interpret indication of ICC. The Shoreham design is deficient in this area for the following reasons:

(a) LILCO has decided that no additional in-struments, including in-core thermocou-ples, are needed to detect ICC; it be-lieves that water level instruments will suffice. But these instruments are not a direct indication of core cooling and core temperature and thus cannot provide an easy-to-interpret indication of ICC or fuel failure.

(b) The other instruments upon which LILCO will rely for detection of fuel failure include fission product, steam line radiation and hydrogen monitors. These instruments may be ef fec cive af ter fuel failure but do not indicate the onset of ICC.

Thus, Shoreham's design does not comply with 10 CFR S 50.55a(h) and Part 50, Appendix A, Criterion 13.

SOC 9: NOTIFICATION OF DISABLED SAFETY SYSTEM As evidenced by the accident at Three Mile Island Unit 2, accident conditions can be aggravated by the operation of the plant while one or more safety systems are inoperable. At Three Mile Island, two auxiliary feedwater system valves were closed when they should have been open. As specified below, SOC contends that Shoreham does not contain an adequate system to inform the reactor operator when a safety system has been deliberately disabled because the plant does not meet the spec-ifications of Regulatory Guide 1.47 or its equivalent.

Therefore, it does not adequately protect the public health and safety and does not comply with 10 CFR Part 50, Appendix A, Criteria 20, 21 and 22. Specifically, the plant does not meet Regulatory Guide 1.47 in the following respects:

(a) the system inoperative alarms for the screenwell pumphouse vent system relay, the emergency switchgear room exhaust air system, the battery room vent system, the RBSWS chiller equipment room vent system and the diesel rooms emergency vent sys-tem cannot be manually activated in the control room; (b) the portion of the compressed air system serving the SRV's does not have a unique

, system inoperative alarm; and (c) there is inadequate indication of the status (including bypass conditions) of systems and power sources on the Remote Shutdown Panel.

i l SOC 16: CLAD SWELLING AND FLOW BLOCKAGE l

j The ECCS at Shoreham may not meet the requirements of 10 CFR Part 50 because of clad swelling and flow blockage. In SOC's view, new test results obtained by the NRC Staff and re-ported in NUREG-0630 show that modeling of clad swelling and flow blockage is inadequate. Subsequent to the publication of NUREG-0630, the NRC Staff reviewed information submitted by LILCO and General Electric and concluded that operation of Shoreham during the first cycle will be acceptable. SOC dis-l agrees and contends that:

(a) There is inadequate assurance that the ECCS system at Shoreham is acceptable because of clad swelling and flow block-age problems in that: l (1) there is no margin in the calculated ,

LOCA peak clad temperature (PCT);

(ii) the LOCA analysis used assumed unpressurized fuel but Shoreham will use pressurized fuel; (iii) the PCT increases due to enhanced fission gas release are only esti-i mates and the analysis is incomplete; (iv) the calculated net increase in PCT  ;

l (increase caused by deficiencies in I the fission gas model less decrease l i l 1

i

due to improved thermal-hydraulic models) is the difference between two large, approximate numbers and there-fore may have a large degree of uncertainty; (v) the decreases in PCT cssumed as a i result of using new thermal-hydraulic models are only estimates; (vi) the burst-strain censitivity study neglected the effects of Zircaloy oxidation heat; and (vii) in the burst-strain sensitivity study, the base case flow blockage was not used in some of the cases analyzed.

(b) There is inadequate assurance that the reanalysis requested by the NRC Staff for Shoreham's second fuel cycle and beyond will show that the ECCS system meets 10 CFR 5 50.46 and Part 50, Appendix K with respect to clad swelling and flow block-age.

i SOC CONTENTION 19: COMPLIANCE WITH REGULATORY GUIDES A major contributing factor in the TMI-2 accident was that operating plants were not required by the NRC Staff (Staff) to be in compliance with current regulatory practices (i.e., Regulatory Guides, Branch Technical Positions, and Standard Review Plans). The TMI-2 accident also demonstrated that the current regulatory practices, practices similar to those being applied by the Staff in their safety evaluation of Shoreham, were in a number of cases not suitably conservative

to properly protect the health and safety of the public (i.e.,

hydrogen generation, radiation shielding, source terms, and single failure criterion).

SOC contends that the NRC Staff has not required LILCO to in-corporate measures to assure that Shoreham conforms with the standards or goals of safety criteria contained in recent regu-I latory guides. As a result, the Staff has not required that Shoreham structures, systems, and components be backfit as re-

quired by 10 CFR $ 50.55a, 5 50.57, and S 50.109 with regard to

SOC 19(a): REG. GUIDES 1.2 AND 1.150: RPV INTEGRITY AND 4

TESTING (a) Regulatory Guides 1.2 and 1.150. -- LILCO

has not adequately demonstrated that the design, pre-service examinat. ion, and in-service examination of the Shoreham reac-tor pressure vessel and vessel nozzles is in compliance with the requirements of 10 CFR Part 50, Appendix A, Criteria 1 and 31, 10 CFR $ 50.55a, and 10 CFR Part 50, Appendix B, Criteria XII and XVII, in that

1. Quality control of the ultrasonic testing (UT) equipment including the UT transducers does not meet Regulatory Guide 1.150 and thus is inadequate to provide reliable and reproducible UT results.

2. UT examination travel time does not I

meet Regulatory Guide 1.150 and thus is inadequate to assure detection of defects j of significant length (larger than the standard calibration holes) or signifi-cant depth.

3. Radiation exposure to examination personnel has not been demonstrated as meeting ALARA.

4. Structural integrity of the pressure vessel has not been demonstrated in ac-cordance with Regulatory Guide 1.2 and thus there is inadequate assurance that failure of the vessel by brittle fracture as a result of the design basis accident

will not occur.

f SOC 19(b): REG. GUIDES 1.26 AND 1.29: CLASSIFICATION OF EQUIPMENT

. (b) Regulatory Guides 1.26 and 1.29. -- LILCO's general list of quality group and seismic design classifi-cations listed in FSAR Table 3.2.1-1 is not in com-j pliance with 10 CFR Part 50, Appendix A, Criteria 1 and 2, 10 CFR $ 50.55a, and 10 CFR Part 100, Appendix A in that:

i I:

i

1. the quality group classifications contained in FSAR Table 3.2.1-1 do not comply with the regula-tory position of Revision 3 of Regulatory Guide 1.26 for safety-related components containing water, steam or radioactive materials;

2. the seismic design classifications contained in FSAR Table 3.2.1-1 do not comply with the regula-tory position of Revision 3 of Regulatory Guide 1.29 with regard to control room habitability and radioactive waste systems;

3. LILCO has not revised the FSAR Table 3.2.1-1 to expand the list of safety-related equipment as re-flected in NUREG-0737 and as a result of the NRC Staff review of the Q-List as set forth in Supplement 1 of the SER on page 17-1; and

4. LILCO's list of safety related equipment con-

tained in FSAR Table 3.2.1-1 does not include i

equipment upon which the plant operators will rely in response to accidents outlined in the Shoreham a emergency operating procedures.

SOC 19(c): REG. GUIDE 1.31: FERRITE CONTENT IN STAINLESS STEEL i

(c) Regulatory Guide 1.31. -- The control of ferrite content in stainless steel weld metal by LILCO com-plies with Revision 1 of the guide rather than Revision 3, with regard to verification of delta ferrite content of filler materials and to examina-tion for ferrite content by a magnetic measuring instrument. Therefore, Shoreham does not comply with 10 CFR Part 50, Appendix A, Criteria 1 and 14.

(

v - -. -- - _ . ,,- - , - , . - .-.. -,__..---.,----4

i SOC 19(d): REG. GUIDE 1.44: MATERIALS (d) Regulatory Guide 1.44. -- LILCO has not adequately demonstrated control of the application and pro-cessing of stainless steel to avoid severe sensiti-zation that could lead to stress corrosion cracking as required by 10 CFR Part 50, Appendix A, Criteria 1 and 4 anc 10 CFR Part 50, Appendix B in that Shoreham has fr.iled to comply with the NRC Staff position described in NUREG-0313, Revision 1 as follows:*

1. Portions of the reactor recirculation system (B31) and stainless steel to carbon steel transi-tion welds between the reactor recirculation system and the reactor water clean-up, core spray, and residual heat removal systems do not meet the guidelines set forth in NUREG-0313, Revision 1, for ASME code class I and II reactor coolant pressure boundary piping.

2. The commitment to inspect portions of the reac-tor recirculation system and transition welds that have been classified as "non-conforming" per NUREG-0313, Revision 1, has been conditioned by LILCO to be limited "to the extent practicable" due to phys-ical interference in some 1.ocations. NUREG-0313 does not specifically allow for such deviations.

Also, LILCO has failed to identify specifically the number, location, and detailed justification for these deviations. Further, LILCO's objection to the " service sensitive" classification of recircu-lation riser lines and inlet lines at the safe-end curves demonstrates a failure to comply with the i

requirements of NUREG-0313.

3. The limiting conditions for leakage included as part of the technical specifications has not been demonstrated in that the leak detection system may not adequately enhance the discovery of unidenti-fled leakage as required by NUREG-0313.

• It should be noted that LILCO's use of alphanumeric designations is not in compliance with the nomenclature set forth in NUREG-0313, Revision 1. This discrepancy makes LILCO's commitment inscrutable.

SOC 19(e): REG. GUIDES 1.60 AND 1.61: SEISMIC DESIGN (e) Regulatory Guides 1.60 and 1.61. -- The design re-sponse spectra for the seismic design of Shoreham are not based on the standards in Regulatory Guide 1.60. Thus, the spectra have not been demonstrated to be sufficiently conservative to comply with 10 CFR Part 50, Appendix A, Criterion 2, and 10 CFR Part 100, Appendix A. In addition, LILCO did not use the Regulatory Guide 1.61 value of damping (4%)

for the operating basis earthquake analysis of Category I reinforced concrete structures, but rather utilized a higher value of damping (5%),

thereby also violating the regulations just cited.

SOC 19(f): REG. GUIDE 1.63: ELECTRICAL PENETRATIONS (f) Regulatory Guide 1.63. -- Shoreham has installed General Electric containment electrical penetra-tions which utilize epoxy as a pressure sealant and as an insulator. The GE-furnished epoxy has cracked and peeled due to aging and has deteriora-ted due to moisture absorption. Therefore, it does not comply with Revision 0 of the guide. In addi-tion, the electrical penetrations at Shoreham have been qualified to Revision 0 of the guide rather than the current Revision 2. For these reasons Shoreham violates 10 CFR Part 50, Appendix A, Criteria 4 and 50.

SOC 19(g): REG. GUIDE 1.75: ELECTRICAL SEPARATION (g) Regulatory Guide 1.75 -- the design of the Shoreham electrical system fails to provide adequate physi-cal independence of electrical cables and raceways as set forth in Revision 2 to Regulatory Guide 1.75 and therefore does not comply with 10 CFR S 50.55a and Part 50, Appendix A, Criteria 3, 17 and 21. In addition, the minimum separation criteria for Shoreham stated in Section 3.12 of the FSAR have not been followed as noted in Inspection Report 50-322/79-07 dated August 21, 1979 and subsequent i report from the Office of Inspection and Enforcement. Accordingly, each deficiency in sepa-  !

ration for Shoreham electrical cables and raceways  !

e must be adequately demonstrated using one of the following options:

1. correct the deficiency by meeting the electrical equipment separation criteria set forth in Section 3.12 of the Shoreham Final Safety Analysis Report;

2. correct the deficiency by meeting  !

Regulatory Guide 1.75, " Physical '

Independence of Electric Systems," i Revision 2 dated September, 1978; l

3. correct the deficiency by installing an acceptable barrier; or

4. justify the deficiency by performing a specific analysis for each cable or raceway where the minimum separation is not met to demonstrate that a failure will not propagate because of the insuf-ficient separation.

SOC 19(h): REG. GUIDE 1.89: ENVIRONMENTAL QUALIFICATIONS (h) Regulatory Guide 1.89. -- LILCO, in its response to NUREG-0588, failed to demon-strate adequate qualification of Class IE electrical equipment as described in this regulatory guide, and as specified in IEEE Standard 323-1974. Therefore, Shoreham does not comply with 10 CFR Part 50, Appendix A, Criteria 1, 2, 4 and 23, and Appendix B, Criteria II and III, in that:

1. The limited test conditions posed in the Shoreham environmental qualification program are not sufficiently conserva-tive.

2. Equipment has been qualified by grandfathering to o1. der, less stringent standards. Inadequate consideration has been given to the deteriorating effects of component aging, accuracy of instru-ment setpoints, test documentation re-quirements, and tolerance margins.

3. The list of emergency operating equipment to be qualified is inadequate.

4. There has been an inadequate demon-stration that all safety-related equip-ment has been properly qualified to meet aging and other life requirements.

5. There is insufficient information to evaluate the overall adequacy of Shoreham's satisfaction of environmental qualifications requirements for safety-related equipment.

SOC 19(i): REG. GUIDE 1.100: SEISMIC QUALIFICATIONS (1) Regulatory Guide 1.100. -- LILCO has f ailed to commit to cor. ducting a seismic qualification program for Class IE elec-trical equipment as prescribed by Revision 0 and Revicion 1 of this guide and therefore does not comply with 10 CFR Part 50, Appendix A, Criterion 2 and Appendix B, Criterion III, with partic-ular regard to the testing program, in-cluding multi-axis multi-frequency test-ing and the effects of aging prior to

testing.

SOC 19(j): REG. GUIDE 1.115: TURBINE ORIENTATION (j) Regulatory Guide 1.115. -- The turbine orientation with respect to safety-related structures is unfavorable in the Shoreham design and thus results in addi-tional probability of a turbine missile accident endangering public health and safety. LILCO's design for protection against low-trajectory turbine missiles, as described in Section 10.2.3 of the FSAR, is not in conformance with the latest procedures outlined in Revision 1  ;

of this guide and therefore does not com- ,

ply with 10 CFR Part 50, Appendix A, j Criterion 4.

l I

l l

l l

1 OIL HEAT INSTITUTE OF LONG ISLAND / NORTH SHORE COALITION CONTENTION OHILI/NSC 7(j): Emergency Planning The evacuation and emergercy plans proposed by the ap-plicant are inadequate as evidencad by the failure of those plans.to comply with 10 CFR Part 50, Appendix E.

i i

i

!4 1

+

1

)

i r

i e y , .~ > . - - c,-.---- v,----+ -, ,. ---- , . , _ . - - - - . - - . . - - - - .- - - - - m. - - ,. --- --- ,-- -- -

l 1

6

.g7 py?,-l IM 2 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) )

NOTICE._OF APPEARANCE The undersigned attorney enters an appearance in this proceeding. In accordance with 10 CFR S 2.713, the fvilowing information is provided:

Name T.S. Ellis, III Address: Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 Telephone 804-788-8453 Admission Virginia Supreme Court Name of Party Long Islena Lighting Company

/

r r$ t t Y'7&x T.$i Eklis, III DATED: April 5, 1982

I f L

'82 fB -7 UI #

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS, ION. ..

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) )

NOTICE OF APPEARANCE l The undersigned attorney enters an appearance in this proceeding. In accordance with 10 CFR S 2.713, the following information is provided:

Name Donald P. Irwin Address: Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 Telephone 804-788-8357 Admission Virginia Supreme Court and District of Columbia Court of Appeals Name of Party Long Island Lighting Company c .t 1--

A- A Donald P. Irwin i

DATED: April 5, 1982

,,- . . - - . - - _ _ . .. . , _ . _ . . , - . _n,. ,. .-

--_,y. ,

?

In the Matter of LONG ISLAND LIGHTING COMPANYpa .7 [1] :04 (Shoreham Nuclear Power Station',' Unit 1)

Docket No. 50-322 (OL)

CERTIFICATE OF SERVICE I hereby certify that copies of NOTICES OF APPEARANCE of T.S. Ellis, III and Donald P. Irwin were served upon the following people by first-class mail, postage prepaid, on April 6, 1982.

Lawrence Brenner, Esq. Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel 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 Secretar/ of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555

t Herbert H. Brown, Esq. Howard L. Blau, Esq.

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 MHB 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

/ f l AV W. Ta lor neveley,'II In Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 DATED: April 6, 1982