Text

Testimony of Gc Minor on Behalf of Shoreham Opponents Coalition Re Contention 9 on Notification of Disabled Safety Sys.Certificate of Svc Encl.Related Correspondence
	ML20053D307
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Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/25/1982
From:	George Minor; MHB TECHNICAL ASSOCIATES, SHOREHAM OPPONENTS COALITION
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ML20053D302	List: ML20053D301; ML20053D307;
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mm m C:V.yiT UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING dOARDiij,I;f

)

In the Matter of

)

LONG ISLAND LIGHTING COMPANY.

)

Docket No. 50-322 (0.L.)

)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

PREPARED DIRECT TESTIMONY OF GREGORY C. MINOR ON BEHALF OF SHOREHAM OPPONENTS COALITION REGARDING SOC CONTENTION 9 NOTIFICATION OF DISABLED SAFETY SYSTEMS MAY'25, 1982 4

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SUMMARY

OUTLINE OF SOC CONTENTION 9 TESTIMONY The testimony demonstrates LILCO's failure to provide adequate indication of the status-(including bypass conditions) of systems and power sources on the Remote Shutdown. Panel ("RSP").

LILCO has failed to implement Regulatory Guide 1.47 or its equivalent for the RSP and, thus, does not comply with the applicable GDC, 10 CFR 50.55a(h) and 10 CFR 50 Appendix B.

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o PREPARED DIRECT TESTIMONY OF GREGORY C. MINOR ON BEHALF OF S!!OREHAM OPPONENTS C0ALITION REGARDING SOC CONTENTION 9 NOTIFICATION OF DISABLED SAFETY SYSTEMS Q.

State your name and company affiliation.

A.

My name is Gregory C. Minor and I am employed by MHB Technical Associates at 1723 Hamilton Avenue, Suite K, San Jose, California.

My resume and qualifications have been previously subn.itted in this hearing.

Q.

State the contention on which you are testifying.

A.

SOC Contention 9 was accepted by the Board as follows:

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, S0C contends that Shoreham does not contain an adequate system to inform the reactor operator when a safety. system has been de-liberately disabled because the plant does not meet the specifications of Regulatory Guide 1.47 or its equiva-lent.

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.

Spe-cifically, the plant does not meet Regulatory Guide 1.47 in the following respects:

(a) the system inoperative alarms for the screenwall pumphouse vent system relay, the emergency switchgear room exhaust air system, the battery room vent system, the RBSWS chiller equipment room vent sys-tem and the diesel rooms emergency vent system 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 sys tem's and power sources on the Remote Shutdown Panel.

Q.

What Specific Federal Regulations do you contend are not met'at Shoreham regarding this issue?

A.

Shoreham has not demonstrated that Criterion XIV 6f Ap-pendix B to 10 CFR Part 50, and Section 50.55a of 10 CFR 1

50, paragraph (h), as set forth in IEEE Standard 279-1971, Section 4.13, have been met.

Regulatory Guide 1.47 dea-cribes an acceptable method for complying with the above two regulations.

The re fore, LILCO also has not demonstrated that Shoreham complies with GDC 13,19, 20, 21, and 22.

Q.

What is the purpose of your testimony?

A.

The purpose is to show that LILCO has failed to app'y the J

requirements of GDC 13, 39, 20, 21 and 22 to the Remote Shutdown Panel (RSP) either by implemen ting Reg. Guide 1.47 or its equivalent.

Q.

Do the NRC Staff and LILCO agree that Reg. Guide 1.47 ap-

. plies to Shoreham?

A.

Yes, the NRC Staff agreed that Reg. Guide 1.47 applies to the safety-systems on the Shoreham plant-1/

1/

"NRC Staff Answers to SOC's First Set of Interrogatories

~

and Requests for Production of Documents", Augus t 12, 1981, Question 9-2.

The Shoreham FSAR Figure 7.1.1-22/, " Codes and Stand-ards Applicability Matrix", shows those systems where LILCO claims to have applied Reg. Guide 1.47.

The re fo r,e, there is general agreement that indication of bypassed safety systems is indeed necessary at Shoreham.

Q.

Are there areas in which LILCO's application of Reg. Guide 1.47 to Shoreham's safety systems is insufficient?'

7.3.2-5E/, " System Bypass Indicators",

A.

Yes.

FSAR Tabic lists the specific safety systems which have bypass indi-cation in the control room.

The table includes many of the important automatic safety systems at Shoreham.

While these systems have bypass indications in the control room, there is no evidence that similar bypass indication is provided at the remote shutdown panel.AI i

Q.

What makes bypass indication at the remote shutdown panel important?

A.

Bypass indication, in general, is important because it sup-plies the operator with information of safety.ystems which I

are bypassed or inoperative and, thus, unavailable,for.acci-l dent mitigation.

Bypass conditions include any deliberate action which may have rendered the system inoperable.

The Bypass / Inoperative indicator may also be an indication of a 2/

Figure 7.1.1-2 is appended as Attachment 1.

3/

Figure 7.3.2-5, amended to show which safety systems are on L

the remote shutdown panel, is appended as Attachment 2.

1 1/

See especially FSAR pages 7.3-65 to 7.3-68, appended as At-l tachment 3.

In this description of LILCO's compliance with Reg. Guide 1.47, no mention is made of the remote shutdown panel.

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system which Nas failed but not the direct res0ltiof s F t s j-3.

deliberate action. Bypass indication may also aid the i

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s' seemingly in,related or insignificant events.

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Bypasp?inhicatihn at the remote shutdown pane); is

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important in 'th'e event of control room uninhabitabil-e s

ity, when the remote shutdown panel must be uned.'

In such an ' event, information on bypass status of hystems and power source availability is available only..in the control room and not at the remote shutdown panel t,

where it may be needed.

A O.

What Bypass / Inoperative indicators do not appear on i

the RSP?

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A. ' shows that there are six systeras which have Bypass / Inoperative indication in.the control room, consistent with Reg. Guide 1.47, but their backup control' station (RSP) does not.have the same indication.

O.

Are there other areas in which LILCO's application of Reg. Guide 1.47 is, insufficient?

s A.

Yes.

The FSAR Table 7.1.1-2 shows'several examples where a saf ety system.or their suppor, ting systems (per definition on Attachment 3, page A3 d): do not show:

- s Reg. Guide 1.47 as applicable.

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Although I have not addressed suparts (a) and (b) of contention 9 in this testimony, due to time constraints, the absence of comment on those issues does not imply any reduction in my, view of their importance or in the need to correct the deficiencies cited.

O.

Has the NRC Staf f indicated if Reg. Guide 1.47 has been met by LILCO?

A.

Their response to SOC's First Set of Interrogatories said the answer is no, Shoreham design does not comply with Regulatory Guide 1.47 in all details.

Further, it is my opinion that'LILCO has not demonstrated compliance with Reg. Guide 1.47 and, thus, has not demonstrated compliance with 10 CFR 50.S5(h) and 10 CFR 50 Appendix B, Criterion XIV and the applicable GDC.

O.

Does that complete your testimony?

A.

Yes.

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ATTACliMENT 1 FSAR TABLE 7.1.1-2 CODES AND STANDARDS APPLICABILITY MATRIX (llIGilLIGiiTING REGULATORY GUIDE 1.47 APPLICABILITY)

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CODES AND STANDARDS Al-2 APPLIC ABILITY M ATRIX SHOREHAM huCLEAR POWER STATION-Uhlf i FIN AL S AFETY AN ALYSIS REPORT REV:STON 2 2-JULY 19BJ t

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ATTACllMENT 2 FSAR TABLE 7.3.2-5 SYSTEM BYPASS INDICATORS (ANNOTATED FOR SYSTEMS APPEARING ON SHUTDOWN PANEL)

SUPS-1 FSAR TABLE 7.3.2-5 SYSTEM BYPASS INDICATORS BYPASS INDICATORS DESCRIOTION INOP DEGimDi.D Emergency Core Cooling System liigh Press Coolant Injection X

X Core Spray System A X

X Core Spray System B X

X Auto Depressurization System A X

Auto Depressurization System B X

Residual Ileat Removal System A X (LPCI)

X.

Residual llent Removal System B X (LPCI)

X Service Water System A X

X Service Water System B X

X Diesel Generator 101 X

X Diesel Generator 102 X

X Diesel Generator 103 X

X PRI Containment Atmos Control System A X

X PRI Containment Atmos Control System B X

X Reactor Core Isolation Cool.ing X

X Reactor Building Closed Loop Cooling Water System A X

X Reactor Building Closed Loop Cooling Water System B X

X RBSVS Chiller Equip Room Vent System A X

i RBSVS Chiller Equip Room Vent System B X

Diesel Gen Room 101 Emergency Vent X

Diesel Gen Room 102 Emergency Vent X

Diesel Gen Room 103 Emergency Vent X

Relay /Emer Swgr Room Vent Supply i

Air System A X

l Relay /Emer Swgr Room Vent Supply Air System B X

i Relay /Emer Swgr Room Vent Exh l

Air System A X

Relay /Emer Swgr Room Vent Exh Air System B X

s A2-1 Revision 22 - July 19 81

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TABLE 7.3.2-5 (CONT'D)

BYPASS INDICATORS DESCRIPTION IMOP DEGltADED Battery Room A Ventilation X

Battery Room B Ventilation X

Battery Room A Ventilation X

Battery Room B Ventilation X

Battery Room C Ventilation X

Screenwell Pumphouse Vent System A X

Screenwell Pumphouse Vent System B X

Reactor Building Standby Ventilation System (RBSVS) a RBSVS Chilled Water System A X

X RBSVS Chilled Water System 3 X

X RBSVS Filter Train A X

RBSVS Filter Train B X

RDSVS Unit Coolers System A X

X RBSVS Unit Coolers System B X

X Reactor Building Exhaust Fans X

Reactor Building Exhaust Dampers x

Control Room Air Conditioning System A X

Control Room Air Conditioning System B X

MCC Room A Ventilation X

MCC Room B Ventilation X

MG Room 111 Ventilation X

MG Room 112 Ventilation X

MG Room 113A Ventilation X

MG Roum 113B Ventilation X

Compressed Air System (SRV Accumulators)

X

- These systems have controls and instrumentatidn located on the remote shutdown panel.

A2-2 Revision 22 - July 1981 j

ATTACHMENT 3 FSAR SECTION 7.3.2.1.1 (REGULATORY GUIDE 1.47 IMPLEMENTATION SECTION ONLY)

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)

,7.3.2.1.2 Specitic Regulatory Requirements Conformance Tho ECCS control systems conforms to industry sta ndards,

regulatory guidos, and criteria as listed on Fig. 7.1.1-2 in the mr.ncr shown h61ow.

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Reculatory Guide 1.47 Conformance of the

ECCS, and those other systems discussed in paragraph b below and on Fig. 7.1.1-2, to Regulatory Guide 1.47 is implemented in the to11owing manner:

a.

An indicator of bypass /inoperat111ty will.be provided for each safety system.

(Bypass includes any deliberate action which renders a sarety. system inoperable.)

Notes:

SAFETY SYSTEMS:

As used in Section 7.3.2.1.2.16,i supporting systems are considered to ne ' distinct from an individual safeti system.

Tni s, nowever, does not imply that supporting systems are not safety

related, nor does it imply t~.at supporting systems are not provided with indication to satisry the requirements of Regulatory Guice 1.847.

SAFETY RELATED: Those plant features, inclucing tne auxiliary support systems, necessary to assure, the integrity of the reactor coolant pressure coundary, tne capability to shut down,the reactor and maintain it in a safe shutdown condition, or tne capability to prevent or mitigate the consequences A3-1

'i.7-65 novisioA 22 - Ju',y 1991

SNPS-1 FSAR of accidents which could resul,t in offsite exposures comparable to the guideline exposures of 10CFR100.

b.

The indicator is at the system level, not the channel or component level.

(There is a

separate indicator for each train or division.

.Two levels of system bypass indication are provided,. one or more of which may be provided for a particular safety or supporting system.

Where a

deliberate action renders one division of a system incapable of performing its safety-related f unction, a system level inoperative (INOP) alarm is provided.

Where a deliberate action does not render one division ot a

system inoperable,

but rather potentially incapable of performing its safety-related

function, a systen level degraded (DEGaADED) alarm is provided.

The safety systems and supporting systems provided with these indications, along with those indicators provided in each' instance, are listed in Table 7.3.2-5.

In sane instances, alarms in each category are provided for a single system.

This is done where deliberate actions of each type discussed above are possible f or the same system.)

c.

The indicator will be operateo automatically only by actions which meet all these criteria:

i.

The a ction is deliberate.

(Component failures may be indicated by component failure Inoicators but need not operate the system bypass indicator.

It is not the intent of the indicator to show operator errors or component f ailures.)

ii.

The action is expected to occur more otten than once a year.

The "more orten than once a

year" criterion will ne applied as described below:

aa. Equipment designed and installed to permit bypassing for purposes of periodic testing during normal operation will be included in this category.

bb. If permanently installed electrical control devices in accessible locations are capable of bypassing a

safety system, it will be assumed to occur more than once a year.

The term " permanently installed" does not include the portable handle required to rackt out a circuit breaker.

Devices within the containment or devices requiring an aaministratively A3-2 7.3-66 P.evision 22 - July 1981

SNPS '. FSAR controlled key to operate are not considered accessible.

The term

" control devices" applies to equ2pment intended to be acted upon by an

operator, such as control

switches, pushbuttons or toggle switches.

It does not include equipment which might be manipulated by prodding, such as relays.

111.

The action is expected when the safety system must be operable.

iv.

Some deliberate action has taken place in the safety system or a necessary supporting system.

(For example, it a given valve has to be open for operation of a safety system and the valve is deliberately closed, the bypass indicator tor that safety system will be operated.

Ilowever,

it.an a ctivation signal will override the deliberate

action, then the bypass indicator will not be operated.)

d.

Some nondeliberate conditions may initia.te indication of bypassed / inoperable status.

(i. e.,

common sensors for deliberate and nondeliberate bypass / inoperable status are acceptable.)

e.

The indicators will be grouped in logical fashion.

All indicators associated with a particular system are located above the group of controls tor that system.

f.

The capability is provided to operate each inoperative indicator manually.

(This lets the operator provide inoperative indication for an event that renders a satety system inoperable but does not automatically operate the system inoperative indicator.)

9 There is no capability to -defeat the automatic operation of an inoperative indicator.

(Audible l

alarms may be silenced, however.)

h.

The inoperative indicators are accompanieo by audible alarm unless the design and location or tne indicators will inherently attract the operator to a change in system status.

i.

No immediate operator action should be required as a result of any system bypass inpicatior..

j.

The bypass inaicators are not considered safety related.

(They need not be designed to safety A3-3 7.3-67 Revision 22 - July 1981

6 o

r SNPS-1 FSAR system criteria such as IEEE-279-1971.

However, no' '

f ault in the indication system shall impair the ability of the safety syatem to perform its safety function.

Application of ImC Regulatory, Guide 1,75 is set forth in Appendix 3b-1.75).

k.

The operator will be able to determine wny a particular system bypass is indicated.

(This inf ormation can be determined from such indications as channel status indicators, component or equipment status indicators,

and, failure indicators.

These indicators are included-in the plant and are clearly different from the system bypass indicators under discussion.

In

addition, administrative procedures such as logs and tags can ne used by the operator in conjunction with nanual operation of a

bypass indicator to document the basis for a particular indication.)

1.

The above represents an interpretation or the stated positions ot this regulatory guide with regard to philosophy and definitions of terms.

As such, it describes in detail how the regulatory guide has been implemented.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'82 EY 28 N0:19 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.,

In the Matter of

)

Tiibf '

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322

)

(Shoreham Nuclear Power Station,)

Unit 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Direct Testimony of Gregory C. Minor on behalf of the Shoreham Opponents Coalition Regarding SOC Contention No.

9", dated May 25, 1982, submitted by the Shoreham opponents Coalition, in the above captioned proceeding, have been served on the following by hand this 25th day of May,1982, and by deposit in the United States mail, first class, this 25th day of May,1982 on those parties whose names are preceded by an asterisk.

Lawrence Brenner, Chairman

Samuel J.

Chilk, Secretary Administrative Judge Docketing and Service Station Atomic Safety and Licensing U.S. Nuclear Regulatory Comm.

Board Panel Washington, D.C.

20555 U.S.

Nuclear Regulatory Comm.

Washington, D.C.

20555 Ralph Shapiro, Esq.

Cammer and Shapiro, P.C.

Dr. Peter A. Morris 9 East 40th Street Administrative Judge New York, N.Y.

10016 Atomic Safety and Licensing Board Panel W. Taylor Reveley, III, Esq.

U.S. Nuclear Regulatory Comm.

Hunton & Williams Washington, D.C.

20555 707 East Main Street P.O. Box 1535 Administrative Judge 23212 Dr. James H. Carpenter Richmond, Va.

Atomic Safety and Licensing

Jeffrey Cohen, Esq.

Board Panel Deputy Commissioner & Counsel U.S.

Nuclear Regulatory Comm.

New York State Energy Office Washington, D.C.

20555 Agency Building 2 Empire State Plaza

Edward M.

Barrett, Esq.

Albany, N.Y.

12223 General Counsel j

Long Island Lighting Co.

Atomic Safety and Licensing 250 Old Country Road Appeal Board Panel

Mineola, N.Y.

11501 U.S.

Nuclear Regulatory Comm.

Washington, D.C.

20555

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" Atomic Safety & Licensing Herbert H. Brown Board Panel Lawrence Coe Lanpher U.S. Nuclear Regulatory Comm.

Karla J.

Letsche Washing ton, D.C. 20555 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Howard L.

Blau, Esq.

190v M Street, N.W.

217 Newbridge Road 8th Floor Hicksville, N.Y.

11801 Washington, D.C.

20036 David J. Gilmartin, Esq.

Brian McCaffrey Attn Patricia Dempsey, Esq.

Charles Daverro County Attorney Long Island Lighting Company Suffolk Co. Dept. of Law 175 East Old Country Road Veterans Memorial Highway Hicks ville, N.Y.

11801 Hauppauge, N.Y.

11787 Energy Research Group, Inc.

MHB Technical Associates 400-1 Totten Pond Road 1723 Hamilton Avenue Waltham, Mass.

02154 Suite K San Jose, Ca.

95125 Bernard M.

Bordenick, Esq.

Counsel for NRC Staff Nora Bredes U.S. Nuclear Regulatory Comm.

SOC Coordinator Washington, D.C.

20555 195 E. Main Street Smithtown, N.Y.

11787 b/

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SUMMARY

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