ML20063N666

Notice of Relevant & Matl New Info Re Type of Accident Involving Internal Flooding Which May Lead to Higher Probability than Calculated in Draft Probabilistic Risk Assessment.Certificate of Svc Encl

ML20063N666
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	09/30/1982
From:	Brown H KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:
References
ISSUANCES-OL, NUDOCS 8210050189
Download: ML20063N666 (6)

Text

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DOCKETED USNRC ,

UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION OTTICE OF SECniDy DOCKETINC & SERVir:

BRANCH Before the Atomic Safety and Licensing Board

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (OL)

(Shoreham Nuclear Power Station, )

Unit 1) )

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NOTIFICATION OF RELEVANT AND MATERIAL NEW INFORMATION Pursuant to the rule established in the Appeal Board's McGuire decision, Suffolk County hereby submits a letter sent by the County's consultant, Dr. Robert J. Budnitz, to i

Mr. Harold Denton, Director of the NRC's Office of Nuclear Reactor Regulation, concerning a type of accident involving l

l Internal flooding that may lead to higher probability than l

l calculated in the draft PRA prepared for Shoreham by LILCO's

( consultant.

l j Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788

• / "In all future proceedings, parties must inform the presiding i board and other parties of new information which is relevant and material to the matters being adjudicated. " Duke Power Company, ALAB - 143, 6 AEC 623, 625-26 (1973).

8210050189 820930 PDR ADOCK 35000322 O PDn }

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G erbert H. Brown Cherif Sedky -

i Christopher M. McMurray i KIRKPATRICK, LOCKHART, HILL, CHRISTOPiiER & PHILLIPS 1900 M Street, N.W.

Washington, D.C. 20036 Attorneys for Suffolk County Dated: September 30, 1982 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD *

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY )

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

(Shoreham Nuclear Power Station, )

Unit 1) .)

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CERTIFICATE OF SERVICE I hereby certify that copies of the " NOTIFICATION OF RELEVANT AND MATERIAL NEW INFORMATION" have been served to the following by U.S. Mail, first class, this 30th day of September, 1982.

i Lawrence Brenner, Esq. Ralph Shapiro, Esq.

Administrative Judge Cammer'and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Howard L. Blau, Esq.

Dr. James L. Carpenter 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W. Taylor Reveley III, Esq.-

Washington, D.C. 20555 Hunton & Williams P.O. Box 1535 707 East Main St.

Dr. Peter A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C. 20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Mineola, New York 11501 Stephen B. Latham, Esq.

Twomey, Latham & Shea Mr. Brian McCaffrey Attorneys at Law Long Island Lighting Company P.O. Box 398 175 East Old Country Road 33 West Second Street Hicksville r New York 11801 Riverhead, New York 11901 I

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Marc W. Goldsmith Mr. Jeff Smith e Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New To,rk 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David H. Gilmartin, Esq. County Executive / Legislative Suffolk County A 'ttorney Building County Executive / Legislative Bldg. Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauga, New York 11788 Ezra I. Bialik, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D.C. 20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Bernard M. Bordenick, Esq. Commission Datid A. Repka, Esq. Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Matthew J. Kelly, Esq..

Staff Counsel, New York Stuart Diamond State Public Service Comm.

Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223

Long Island, New York 11747 l

! Cherif Sedky, Esq.

Kirkpatrick, Lockhart, Johnson & Hutchison i 1500 Oliver Building Pittsburgh, Pennsylvania 15222 Herbert H. Brown, Esq.

KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILI1 ?S DATE: September 30, 1982 1900 M Street, N.W., 8th Floor Washington, D.C. 20036

FutureResources A.uociates,Inc.

Derkeley. CA 04704 415-526-5111 e 2000 Conter Street Suite -118 24 September 1982 ,

Mr. Harold R. Denton Director, Office of Nuclear Reactor Regulation t U.S. Nuclear Regulatory Commission -

Washington, DC 20555 r

Dear Mr. Denton:

For the past th'ree months my company has been analyzing the Shoreham Nuclear Power Station under contract to Suffolk County, New York. Specifically. we have been contracted to provide an independent opinion as to the validity of the reactor accident sequence probabilities and releasa magnitudes that are dontained in a preliminary draft report carried out by Science Applications, Inc. and supported by Shoreham's owner, Long Island Lighting Company, entitled "Probabi-listic Risk Assessment, Shoreham Nuclear Power Station". This draft PRA analysis, which we have reviewed, contains calculations of internal accident sequence probabilities,. discussion of accident phenomena, and calculations of magnitudes of potential releases. The County's interest in these issues stems from their need to have an acceptable technical basis for their emergency planning activities.

In the course of our review, we have concluded that one type of accident involving internal flooding may lead to important plant damage states with a significantly higher probability than is calculated in the draft PRA. Indeed, this group of sequences might, in our opinion, be among the dominant sequences contributing to .

residual public risk at Shoreham. The sequences under discussion were analyzed by SAI in the draft PRA, but we believe that because of an error the accident l probabilities have been underestimated. The sequences involve routine on-line maintenance of important safety equipment at level 8, the bottom level of the Shoreham reactor building where much important safety equipment is located. If during on-line maintenance there were to be an accidental opening of t'e isolation valve that separates the specific component being maintained from the rest of the system, then under some circumstances a local flood would result, which could become a serious and disabling flood if the isolation valve cannot be reclosed in adequate time. This flood, while it would disable emergency equipment, still would not cause an accident unless there were to be an additional loss of heat removal capability through loss of the power conversion system. The issue is how probable these types of sequences are.

We have done a rough calculation of our own of the likelihood of the sequences.

The results are found in our draft report (attached) prepared for Suffolk County.

Section 3.3 and Appendix D of our report contain our technical discussion.

(However, a copy of SAI's draft PRA report on Shoreham is probably needed to put our discussion in the proper context.) While we believe that this set of

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H.R. Denton --

page 2 i 24 September 1982 _

l sequences could be an important contributor to overall residual risk at Shoreham, we have been unable to quantify the risks ourselves, because '

i we haven't done a complete analysis (either probabilistic or deterministic), (

nor were we able to test the sensitivity of our conclusions .to various. . (

engineering assumptions. Furthermore, while we suspect that this issue might t be important also at other reactors, especially at other BWR-Mark 2 reactors with similar designs but possibly at other reactors too, we have not addressed that issue ourselves.

I do not believe that the internal flooding sequences under discussion have b:en adequately analyzed either deterministically or probabilistically. It ;  !

is possible, in fact, that Shoreham contains features not yet uncovered that I would compound the severity of a minor iriternal flooding incident, turning?

a relatively benign event into one with severe consequences to the, reactor of [

even to the public: for example, there may be operator procedures, hardware,  !

or control system features that mi',ht erroneously isolate the power ccnversion  ;

system upon inception of some internal flooding scenarios, thereby compromising ,

an important heat sink exactly when it is needed most.  :

If careful analysis reveals that these sequences pose problems not yet considered, we can think of several easy fixes that could provide added protection to the  :

utility's investment and to the public at relatively low cost. In any event, I  !

believe that the issue requires additional analysis which has been beyond the i scope of my own company's work for Suffolk County. If I can be on hny assistance -

to NRC, please do not hesitate to contact me.

Sincerely yours, h Robert J. Budn tz '

President l

Enclosure:

as stated ,

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cc: F. Jones, Suffolk County  !)

R. DeYoung, NRC/IE I

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