ML20076F711
| ML20076F711 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/23/1983 |
| From: | James Smith LONG ISLAND LIGHTING CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| SNRC-955, NUDOCS 8308260132 | |
| Download: ML20076F711 (6) | |
Text
. G y.,m -~.~n u , , e LONG ISLAND LIGHTING COM PANY
[
FLd'O SHOREHAM NUCLEAR POWER STATION
- ... + ..,e._ m P.O. DOX 618, NORTH COUNTRY ROAD e WADING RIVER, N.Y.11792 Direct Dial Number August 23, 1983 SNRC-955 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Response to NRC Request For Additional Information on Intergranular Stress Corrosion Cracking (IGSCC) in Recirculation / Residual Heat Removal System Piping Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322
References:
- 1) NRC letter (D.G. Eisenhut) to LILCO (M. 3. Pollock) dated July 27, 1983
- 2) LILCO letter, SNRC-566 (J. P. Novarro) to the NRC (H. R. Denton) dated May 15, 1981 regarding SER Issue No. 18 (Response to NUREG-0313)
- 3) LILCO letter, SNRC-727 (J. L. Smith) to the NRC (H. R. Denton) dated July 7, 1982 entitled " Induction Heating Stress Improve-ment Program"
- 4) LILCO Prefiled Testimony before the Atomic Safety and Licensing Board (Suffolk County Contention 24) regarding the Cracking of Materials (enclosed herein as Attachment 2)
- 5) Resolution Agreement before the Atomic Safety and Licensing Board (Suffolk County Contention 24) regarding the Cracking of Materials (enclosed herein as Attachment 3)
Dear Mr. Denton:
This letter is in response to your July 27, 1983 letter (Reference
- 1) which requested additional information on the Intergranular Stress Corrosion Cracking (IGSCC) issue for the Shoreham Nuclear Power Station. The IGSCC issue has been addressed during the gD 8308260132 830823 I I.1 PDR ADOCK 05000322 i A PDR l
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, e August 23, 1983 SNRC-955 Page 2 Shoreham licensing process resulting in the specific documentation cited above (as References 2 through 5).
The following addresses the specific questions raised in the referenced NRC letter:
Item 1 - MATERIALS AND SPECIAL FABRICATION METHODS Since 1975, LILCO has instituted many actions to limit the potential for IGSCC at Shoreham. Steps were taken in four main areas: welding controls, material modifications, solution heat treatment of certain shop welds, and Induction Heating Stress Improvement. These steps can be summarized as follows:
A. Welding Controls
- i. Shoreham implemented welding procedures using lower heat inputs to minimize sensitization which reduces the potential for stress corrosion cracking.
ii. Grinding control was instituted to mininize the formation of tensile residual stresses on pipe inside diameter surfaces.
B. Material Modifications !
- i. Core spray lines and safe-end material have been changed to low alloy steel which is not susceptible to IGSCC.
ii. The recirculation system discharge bypass lines were eliminated and existing weldolets were capped with 304L weld inlays ahich are not susceptible to IGSCC.
C. Solution Heat Treatment (SHT)
- i. All riser sections, including the suction and discharge risers, were solution heat-treated to eliminate the potential for stress corrosion cracking in shop welds.
D. Induction Heating Stress Improvement (IHSI)
- 1. All remaining accessible and/or technically feasible welds were treated by Induction Heating Stress Improvement Process.
1/ Residual Heat Removal systems and Reactor Water Cleanup systems were originally designed using low alloy steel in lieu of 304SS, thus reducing the potential for IGSCC.
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August 23, 1983
. SNRC-955 Page 3 The Shoreham recirculation system contains 120 type 304 stainless steel welds of interest. This includes nine (9) welds that are technically part of RHR and RWCU systems, but which are associated with tie-in points to the recirculation system. Of the one hundred twenty (120) welds, only twenty-two (22) welds have not received the IHSI or SHT post-weld treatment. These welds were not treated because either the weld geometry and/or serious physical access problems precluded the application of IHSI. These twenty-two (22) welds have been classified " service sensitive" and will receive augmented ISI per the requirements of NUREG-0313.
For the twenty-two (22) non-conforming welds, LILCO will continue to actively monitor potential remedies that, in the future, may be effective counter-measures to IGSCC. Potential applications under study include last pass heat sink welding and hydrogen water chemistry.
Research programs regarding these possible applications are in progress and LILCO will make Shoreham-specific evaluations upon completion of the research efforts.
LILCO has been, and will continue to be, very active in the BWR Materials Owners Group, the EPRI Nuclear Systems Task Fprce, and the EPRI Utility Plant Materials Subcommittee.
In the area of UT examination, LILCO also continues to support the BWR Owners Group and EPRI effort to develop improved field techniques for IGSCC detection. LILCO has received a sample of the cracked piping from the Nine Mile Point Station which is presently in storage at Brookhaven National Laboratory. This sample will be utilized, as appropriate, in future UT applications at Shoreham.
Item 2 - JUSTIFICATION FOR OPERATION As stated in Item 1, all feasible corrective actions have been taken to minimize the potential for stress corrosion cracking in the twenty-two (22) non-conforming welds. In addition (see Item 4),
LILCO is committed to a diligent water chemistry program that will minimize the potential for IGSCC.
The initiation of the IGSCC phenomenon is generally known to require many years of plant operation, even under adverse stress and environ-mental conditions. This will allow time for additional corrective actions to be implemented at a later date as the technology for these actions is further developed. In addition, since the number of welds susceptible to this phenomenon at Shoreham is small, the likelihood of these welds cracking, even without additional corrective actions, is very remote.
. 6 August 23, 1983 SNRC-955 Page 4 Item 3 - PRESERVICE INSPECTION During preserv_ce inspections of. service-sensitive configurations at the Shoreham Nuclear Power Station, ultrasonic examinations were performed utilizing NES procedure 80A0481. This procedure requires 0 degree and 45 degree examination angles for a minimum coverage of one pipe thickness (T) on each side of the weld.
Scanning speeds were 6"/sec. Calibration was achieved utilizing holes to obtain the sensitivity levels (lh T if T< 1" or 3/4T if T21") . Recording levels for all indications, at reference sensi-tivity were 2t 50% of DAC. All evaluations of indications, if any, were performed in accordance with Section XI, IS-300, 1971 Edition.
Item 4 - WATER CHEMISTRY CONTROL PROGRAM The Shoreham Water Chemistry Control Program has been formulated to minimize the potential for IGSCC. Specifically, the program will:
Maintain the reactor water conductivity and chloride level well below the Technical Specification limits Control the level of dissolved oxygen in the reactor feedwater within the fuel warranty limits of 20 to 200 parts per billion Maintain the pH as close as possible to neutral and within the range of 5.6 to 8.6 during power operation as specified in Table 3.4.4-1 of the Technical Specifications.
The desired conductivity and chloride ranges can vary according to the plant operating mode (i.e. startup, normal operation). These ranges are specified in Station Procedure 74.010.02, " Chemical Surveillance Schedule" which is available for on-site review by the NRC Resident Inspector.
In addition, as previously stated, LILCO will evaluate the results of the ongoing hydrogen water chemistry experiment at Dresden, to determine the potential for further minimizing IGSCC at Shoreham.
I
b August 23, 1983 SNRC-955 Page 5 LILCO believes the responses contained herein should enable the NRC to close this generic issue for the Shoreham Nuclear Power Station. We will be available to discuss this submittal at your convenience. To make arrangements for a meeting or if additional information is required, please contact this office.
Very truly yours, J. L. Smith Manager, Special Projects Shoreham Nuclear Power Station RJT:mp cc: J. Higgins All Parties in Attachment 1
. s ATTACHMENT 1 Lawrence Brenner, Esq. Herbert H. Brown, Esq.
Administrative Judge Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
Board Panel Kirkpatrick, Lockhart, Hill U.S. Nuclear Regulatory Christopher & Phillips Commission 8th Floor Washington, D.C. 20555 1900 M. Street, N.W.
Washington, D.C. 20036 Dr. Peter A. Morris Administrative Judge Mr. Marc W. Goldsmith Atomic Safety and Licensing Energy Research Group Board Panel 4001 Totten Pond Road U.S. Nuclear Regulatory Waltham, Massachusetts 02154 Commission Washington, D.C. 20555 MHB Technical Associates 1723 Hamilton Avenue Dr. George A. Ferguson Suite K School of Engineering San Jose, California 95125 Howard University 2300 Fifth Street Washington, D.C. 20059 Stephen B. Latham, Esq.
Twomey, Latham & Shea 33 West Second Street Daniel F. Brown, Esq. P.O. Box 398 Attorney Riverhead, New York 11901 Atomic Safety and Licensing Board Panel i
,* U.S. Nuclear Regulatory Ralph Shapiro, Esq.
i Commission Cammer and Shapiro, P.C.
- Washington, D.C. 20555 9 East 40th Street New York, New York 10016 l
Bernard M. Bordenick, Esq.
David A. Repka, Esq. Matthew J. Kelly, Esq.
U.S. Nuclear Regulatory State of New York Commission Department of Public Service Washington, D.C. 20555 Three Empire State Plaza l Albany, New York 12223 Mr. James Dougherty 3045 Porter Street Washington, D.C. 20008
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Attachment 2 to SliRC-955 r.
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)
)
3 (Shoreham Nuclear Power Station, )
Unit 1) )
i .
TESTIMONY OF ROBERT M. KASCSAK i '
FOR THE LONG ISLAND LIGHTING COMPANY
{ ON SUFFOLK COUNTY CONTENTION 24 3
AND SOC CONTENTION 19(d) -- CRACKING OF MATERIALS PURPOSE This testimony shows that LILCO has been particularly sen-sitive to the problem of intergranular stress corrosion crack-ing. The requirements of NUREG-0313, Revision 1 have been fully incorporated into Shoreham and additional steps have been taken. NUREG-0619 requirements, including, but not limited to, ii the installation of a low-flow feedwater controller, have been implemented. Collectively these steps have minimized the po-
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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) )
TESTIMONY OF ROBERT M. KASCSAK FOR THE LONG ISLAND LIGHTING COMPANY ON SUFFOLK COUNTY CONTENTION 24 AND SOC CONTENTION 19(d) -- CRACKING OF MATERIALS
- 1. Q: What is your name and business addrecs?
A: My name is Robert M. Kascsak. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.
- 2. Q: By whom and in what capacity are you employed?
A: I am employed by LILCO and am currently Manager of the Nuclear Systems Engineering Division within the LILCO, Nuclear Engineering Department. This Depart-n ment is a Headquarters Engineering Organization that provides supp. ort to the Office of Nuclear. My Divisional responsibilities include overseeing an engineering staff organization capable cf analyzing and coordinating activities associated with nuclear i
plant design, operation, reliability and safety. '
s My current responsibilities include approval of Architect Engineer designs, vendor designs and de-velopment of an in-house support organization associated with future plant modifications. A com-i plete resume appears on pages 13-14.
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- 3. Q: Are you f.amiliar with SOC Contention 19(d) and SC f Contention 24?
9 A: Yes.
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- 4. Q: What is the issue involved?
A: The issue in soc 19(d)(1) and SC 24(a) is whether the reactor recirculation system and stainless steel to carbon steel transition welds between the .
reactor water clean-up, core spray and residual '
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, heat removal systems me.et the guidelines of NUREG-
-0313, Revision 1, " Technical Report on Material Selection and Processing Guidelines for BUR Coolant j
Pressure Boundary Piping" (October 1979).
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- 5. Q: What requirements does NUREG-0313, Revision 1 i
establish?
A: The NUREG provides methods to reduce intergranular stress corrosion cracking (IGSCC) susceptibility of BWR ASME III Code Class 1 and 2 pressure boundary f piping and safe-ends, and methods to detect'such i
cracking.
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I A: No., IGSCC concerns in BWR environments arose in 1975,with cracking incidents at the Commonwealth EdisSn Dresden Unit 2. I
- 7. Q: What did LILCO do to mitigate this problem at
'Shoreham?
Ii:
'sSince 1975, LILCO has instituted many actions to limit,the potential for IGSCC at Shoreham. Steps
{' were taken in three main areas: welding controls, material modifications, and colstion heat treatment J
2 of certain shop welds. These steps include the following:
^7 1. Welding Controls a) Shoreham implemented welding procedures using lower heat inputs to reduce the po-
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- 2. Material Modifications 4
a) Core spray lines and safe-end material have been changed to low alloy steel which is not susceptible to IGSCC.
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, b) The recirculation system discharge bypass
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which are not susceptible to IGSCC.
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.1 ,' a) All riser sections, including the suction and discharge risers, were solution heat-treated to reduce st,ress corrosion cracking in shop welds.
Why were these specific changes instituted?
- 8. Q:
- A: The IGSCC pipe cracking primarily occurs where low
, flow or stagnant areas exist. By these actions, LILCO has eliminated plant designs that pctentially allow those conditions, and used materials net sus-s.
ceptible to IGSCC.
4
. , 9. Q: Does Shoreham meet NUREG-0313, Revision 1 require-ments?
i A: Yes. NUREG-0313, Revision 1 establishes alterna-tive. sets of requirements: Part II requirements, l
and for plants which cannot meet Part II require-ments, Part III requirements are given.
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- 10. Q: Does Shoreham meet all Part.II guidelines?
A: No, certain materials do not meet Part II guide-lines. The guidelines provide, however, for exemp-tion from Part II compliance when it would result in " undue hardship." Shoreham is exempt because it was well under construction when NUREG-0313, Revision 1 was published in 1979. Shoreham must therefore comply with Part III.
- 11. Q: What are the Part III requirements?
A: These requirements are for augmented leak detection and inspection programs that go beyond those speci-fied in 10 CFR 50.55a(g) and in NRC Standard Technical Specifications. The degree of augmenta-tion depends upon whether the lines are
" service-sensitive" or not. Service-sensitive lines are those lines having a history cf cracking, and they are inspected more frequently than non-service-sensitive lines.
- 12. Q: Does Shoreham meet all the requirements of Part III?
A: Yes. All nonconforming welds will be inspected according to Part III requirements. LILCO has de-termined that presently it has no " service-sensitive" lines.
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- 13. Q Why did LILCO reach that determination?
A. Part III(B) identifies potential " service-sensitive" lines. Only two potential service-sensitive lines exist at Shoreham: the recircula-tion riser lines and the recirculation inlet-nozzle to thermal-sleeve welds. LILCO solution heat-treated the sections of the recirculation risers that had evidenced cracking in nuclear power plants in Japan. This treatment removes IGSCC as a con-cern. No other in-service evidence of cracking exists on these risers. For the recirculation inlet-nozzle to thermal .=leeve welds, LILCO's design is markedly different from the Duane Arnold design that exhibited cra'cking. Designs similar to Shoreham (e.g., Fitzpatrick) have been inspected and no evidence of cracking has been detected.
Accordingly, no service-sensitive lines exist at Shoreham.
{ 14. Q: Has the NRC accepted LILCO's position regarding l NUREG-0313, Revision 1 compliance?
A: Yes. Initially, in Open Item 18 of the Safety Evaluation Report (SER), the NRC reserved judgment
, on whether Shoreham met NOREG-0313 requirements.
y In LILCO's response, SNRC-566 (May 15, 1981), the o nonconforming items ware identified and the
augmented in-service inspection program was established according to Part III guidelines. In response to SNRC-566, Open Item 18 was resolved.
- 15. Q: Let's move on to SOC Contention 19(d)(2). What is the issue?
A. SOC first contends that the augmented in-service inspection program, discussed earlier, is insuffi-cient and, second, disagrees.with the classifica-tion of the recirculation riser lines and inlet lines at the safe-ends as non-service-sensitive.
- 16. Q: What is the particular issue with regard to the inspection program?
A: SOC contends that the inspection program is insufficient because the inspection of some items have been conditioned "to the extent practicable."
SOC further contends that LILCO has failed to iden-tify the number and the location of the items and
<a the justification for the limited inspection of those items.
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- 17. Q: Is the inspection program adequate?
A: Yes. The inservice inspection program for Shoreham
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j meets the ASME Code and requires that all Class I welds be inspected. NUREG-0313 increases the fre-quency of inspections. All welds will receive i
either a full, or in a very small number of cases, a partial inspection. A pr'ogram is underway to remove where practicable interferences that pre-clude complete inspection. When this program is complete, welds receiving partial inspections will be identified.
-18 . Q: You mentioned earlier.that SOC objects to the c'las- -
sification of recirculation riser lines and inlet lines at the safe-end as being non-l service-sensitive, and claims that Shoreham, there-fore, does not meet NUREG-0313. Is SOC correct in that regard?
A: No. First, as stated earlier, the recirculation riser lines and recirculation inlet lines at the safe-ends have been demonstrated not to be service-sensitive lines.
Second, solution heat-treating of all of the riser sections will eliminate IGSCC as a concern, except i
6 for the field welds at header and inlet nozzles.
The NUREG recognizes the efficacy of this process
- i at reducing IGSCC. ,
- 19. Q: Let's move on to the third part of the Contention.
What is the issue involved with SOC 19(d)(3)?
A: The Part III guidelines discussed above provide i
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that when there is no conformance with Part II guidelines, there must be an enhanced leak detec-tion program. SOC contends that the Shoreham pro-gram is inadequate.
- 20. Q: Is the leak detection program adequate?
A: Yes. The primary containment leakage detection and collection systems comply fully with Regulatory i
Guide 1.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems." NUREG-0313, Revision 1 I
l states that such systems are adequate. See FSAR, Appendix 3B 1.45. The systems will detect uniden-tified leakage to the primary containment and will provide acceptable detect. ion capability for reactor coolant pressure boundary leakage.
- 21. Q: How effective is the design at detecting leakage?
A: Very effective. There are no design structures i
within the tywell that act as reservoirs which
!I must be filled before flow to the floor drain
~l occurs. The floor drain system collects leakage utilizing flush-mounted deck drains. Thus, the
, possibility of temporary collection prior to li leakage reaching the sumps is minimized.
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- 22. Q: Are you familiar with Suffolk County Contention 24(b)?
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.i A: Yes. ~
- 23. Q: What is the thrust of the contention?
A: Suffolk County contends that the recommendation made in NUREG-0619 "BWR Feedwater No =le and Control Rod Drive Return Line Nozzle Cracking" (April 1980), have not been, implemented because a
. low-flow controller to control feedwater flow h.as not been installed.
- 24. Q. What is the function of the low-flow feedwater con-trol system?
A. Its function, along with certain operating pro-cedures, is to minimite thermal fatigue of the feedwater nostle. It further ensures that crack growth, if cracking occurs, would be minimited.
- 25. Q: Has Shoreham implemented the guidelines of NUREG-0619?
-i t A: Yes. Shoreham has installed a low-flow feedwater controller and has taken several other steps recom-mended by the NUREG. Compliance with NUREG-0619 was Open Item 13 in the SSR. LILCO's response was presented in SNRC-566, and Open Item 13 was re-solved.
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- 26. Q: Will the low-flow feedwater controller installed at Shoreham meet NUREG-0619 requirements?
A: Yes. Shoreham's low-flow feedwater control system consists of two low-flow control valves in parallel with split-range control. The split-range control enables control within the 0.5% to 10% rated flow specified in the NUREG.
- 27. Q: How will LILCO verify that the Shoreham low-flow
, feedwater control design will comply with the spec-ifications of NUREG-0619?
l A: Low-flow feedwater controller operation will be verified by tests which monitor feedwater nozzle fluid temperatures during start-up, shutdewn and hot standby. The results of this test will be used to generate a crack growth analysis using the same methodology as that contained in NEDE-21821-A. Low-flow feedwater control system design modifications and/or system operating procedures modifications
- , will be made as necessary.
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.: 28. Q. Will you summarize your position regarding cracking of materials at Shoreham?
A: Shoreham has also implemented several steps to min-I imize the potential for stress corrosion cracking of materials including: implementation of welding i
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controls, modification of materials and solution heat treatment of materials. Shoreham has followed the guidelines established in NUREG-0313, Revision I and to the extent it cannot make material modifi-cations, will follow the augmented inspection and leak detection guidelines. The low-flow feedwater controller and other recommendations of NUREG-0619 have been implemented. Cracking of materials at Shoreham should not be a problem.
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PROFESSIONAL QUALIFICATIONS Robert M. Kascsak Nuclear Systems Engineering Division Manager Long Island Lignting Company My name is Robert M. Kascsak. My business adoress is Long l Island Lighting Company, 175 East Old Country hoad, Hicksv211e,
- t New York. I am currently the Nuclear Systems Engineering
- l Division Manager. My responsibilities incluoe overseeing an i .
-j engineering staff organization capable of analyzing ano coordi-t nating activites associated with nuclear plant design, opera-tion, reliability and safety, including approving Architect Engineer designs and vendor designs and developing an in-house support organization associated with future plant mooifica-tions.
I graduated from hanhattan College in 1969 with a Bachelor of Mechanical Engineering. In 1977 I received a Master of Science degree in Nuclear Engineering from Polytechnic Institute of New I
York. I have c.ompleted training courses in Bh'h and PKh tech-
- 1 j nology.
t 1 joinca LILCO in 1969 as an Assistant Engineer in the j Mechanical and Civil Engineering Department. I workeo on var-ious fossil fuel power station projects in the capacity of l Associate and Senior Engineer, incluolng tne Northport Power i
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.'- Station Unit 3 and Unit 4 mechanical engineering designs. From July 1974 to March 1975, I serveo as LILCO Lead Mechanical Engineer for Shoreham and for the Jamesport Nuclear Power Station. In March 1975 I joined the Shoreham Project Group as an Assistant Project Engineer, after which I assumeo the responsibilities of Project Engineer. From harch 1975 to January 1979, I was Project Engineer for Shoreham. In this position I was responsible for the review an6 approval or design activities preparea by our Arcnitect/ Engineer, Nuclear Steam Supply System Vendor and LILCO in-house engineering departments.
I am a registere6 Professional Engineer in New York State ano a member of the American Society of Mechanical Lngineers.
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( * ' gg[s ( c Attachment 3'to SNRC-955
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
Before the Atomic Safety and Licensina Board In'the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)
) .-
(Shoreham Nuclear Power. Station, ) -
Unit 1) .
RESOLUTION OF "
SC CONTENTION 24/ SOC CONTENTIONS 19(c) and (d) --
CRACKING OF MATERIALS AND MATERIAL SELECTION t
Suffolk County ("SC") Contention 24 and Shoreham Opponents Coalition.(" SOC") Contentions 19(c) and (d) allege thad LILCO ,
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has not taken adequate care in the selection and control of ma-terials used in the construction-of safety-related systems and components exposed to the eactor coolant environment. Because
.of this situation, SC and SOC believe that there is an in-creased risk of accidents at Shoreham and.'that increased worker ,-
. exposure.'to radiation is likely. ,
The parties have discussed these issues and have agreed th.a't with 'the exception of the area of concern described in
. Item 1 below, the SC and SOC concerns can be resolved, provided that the terms, conditions and actions described in Items 2-9 ,"
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, g y,ran*A ATTACHMENT 2
. 0 below are implemented. SC and SOC believe that the steps ,,
described in Items 2-9 will improve the safety of Shoreham and thus eliminate the need to pursue these matters in the hearing process. Accordingly, upon acceptance of this Agreement by the Licensing Board, and in accordance with the terms specified below, the concerns identified in Items 2-9 below are resolved.
The concerns identified in Item 1 are not resolved by this
. Agreement. ,.
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,,.. ' Item 1. Sensitization of Reactor Internal Comconents
, Subsequent.to the-prefiling of direct testimony on SC Contention 24/ SOC Contentions 19('c) and (d), URC Board ,
Notification 82-70 identifying a Differing Professional Opinion (DPO) was issued. This DPO was submitted by an NRC Staff mem-ber and relates to the potenti.al sensitization of reactor in ~
ternal components during the fabrication process. It calls into question the material properties of the components pro-duced'by the GE process. The parties have been unable to reach agreement on the resolution of $hese concerns, Although efforts to do so are continuing. In the event the parties are unable
, to r.esolve th'e.DPO concerns through their ongoing discussions, ;
the parties will promptly notify the Board. ~
SC and SOC beli.sve that the conce,rns raised by the DPO are.
with'in the, scope of SC Contention.24/ SOC Contentions 19(c) and (d) and .may be litigated in this proceeding; LILCO believes l
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_that they are not.'within the scope of the contentions and are j ,
not litigable. The parties intend that the availability'of l
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.. .. 3 this matter'for litigation, whether within the context of SC Contentio'n 24/ SOC Contentions 19(c) and (d) or as a new conten-tion,'shall b'e' governed by the Commission's rules of practice and the applicable law. However, ifSCorSOCmovestoadmitA new contention within two weeks of the Board's ruling on whether the issu'e- is' litigable in the context of SC Contention ,
24/ SOC Contentions 19(c) and (d), or within such other time as will have been prescribed by the Board, neither LILCO nor the Staff will raise the issue of timeliness. SC and SOC retain
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the right to argue that'any litigation of this issue must be completed prior to initial criticality. "This Agreement is not intended to resolve the concerns raised by the DPO.
Item 2. Leak Detection -
SC 'and SOC have identified as a major concern under these contention.s the problem of potential failure of type 304 stain-
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less steel ("SS") piping due to i tergranular stress corrosion cracking ("IbSCC") in those systems exposed to the primary re-actor coolant. NUREG-0313, Revision 1, (hereinafter, "NUREG-0313") specifies that such systems should either be con-structed of materials resistant'to ICSCC or that the heat affected ' zones of the welds or of other sensitized areas ,should be subjected to post-weld treatment protection by the use of i solution hbat treatment ("SHT") or corrosion resistant cladding I
(." CRC"). Under NUREG-0313 standards the 304 material in use on h .
t l the Shoreham recirculation system is not considered to be a '
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" conforming" material and thus is classified as "non-conforming" in the non-treated condition. NUREG-0313 ad-ditionally discusses the post-weld treatment process of induc-tion heat stress improvement ("IHSI") but does not accept it on a generic basis and specifies that IHSI will be assessed on a case-by-case basis if proposed by a licensee. Nevertheless, the C'ounty recommended that LILCO perform such treatment, and LILCO, unknown to SC, had in fact planned to do so. LILCO does
, not agree that NUREG-0313 requires po.st-weld heat treatment.
. The Parties agre.e that NUREG-0313 requires augmented In-service Inspection (ISI) for welds classified as "non-conforming."
In SC's and SOC's opinion, but not LILCO's, the Shoreham recirculation system as presently constructed does no't fully comply with the NUREG-0313 guidelines, cnd the potential for, failures due to IGSCC is thus grc~ater than desirable. Such failures could result in an increased risk of LOCAs and the re- .
. pair of such. failures could cause increased occupational ra.dia-tion exposure of the plant stafd and contract personnel. .
LILCO has subjected all possible and applicable recircula-tien system welds to the post-weld process of IHSI, and has .
notified the NRC of the -action.
The NRC is evaluating qualifi-cationoftheIhSIprocessasaconformingpiecessunder'
~
. NUREG-0313 for the Susquehanna p.1 ant.
LILCObekievesthatIHSI will be generically approved as a result of th'is review. If so, those portiony of the Shoreham recirculation system that
. ' have received SHT,or IHSI tre atment will be reclassified as e
Sm . 6 m m *
.M m.$M a o ee..m , .m..
-O*
- onforming mate, rial per NUREG-0313. If the NRC does not approve IRSI, the IHSI welds will continue to be classified as "non-donforming " .
LILCO has' additionally provided to SC and SOC consultants:
(1) An 8-page listing of all recirculation sys-tem welds, showing the IHSI applicability of ,,
each; (2) Isometric sketches of the system showing weld locations; and. ,
(3) A list of PSI Class 1 Relief Requests which identifies 10 recirculation and RER system welds for which full PSI and ISI. capability does not presently exist due to geometry or
', access problems (see.SNRC-759, Attachment 1 .
hereto). .
i ,
SC and SOC consultants have. reviewed this documentation, ,
have discussed the matter with LILCO personnel, and have per-sonally viewed the location and configuration at the facility of typical and significant welds. SC and SOC consultants and l
L
'LILCO have' agreed on the following facts:
(1)'The Shoreham rdeirculation system contains
- l
. . 120 SS 304 welds of interest. This includes
the recirculation system.
. . g O
e
, - , . . - - . . - , - , e--
.s.
-.. (2) Of the 120 welds, 24 have already received SHT. SC and SOC agree that these welds are acceptable.
, (3) LILCO has treated 74 of the welds with IHSI, i
f and SC and SOC agree that these welds are acceptable.
(4) A total of 22 welds will not receive the I post-weld treatment that SC and SOC believe
.e- is.needed(includedinbhe22weldsare3 RHR sys' tem welds). The reasons for not treating these welds ar'e piping configura-tion, weld geometry and/or lack of physical ,
access for IHSI equipment. SC and SOC con-sultants have reviewed the LILCO data and l agree that IHSI ;is not practical on these
' joints. SC, SOC and LILCO further agree that internal application of CRC is not practical for these joints and that removal of the radial beams to improve the access is l . not a practical solution. .
- s .
Accordingly, in SC.s and SOC _'s view, but not LILCO's, 3
~
l there appear to be 22 welds that will.not fully comply with ,
f 3
.' NUREG-0313. Nevertheless, LILCO. agrees to install an augmented 4
leak detection system in accordance with terms identified below j- *
.for welds meeting the criteria discussed below".
l1 .' -
4 .
!1 ,
\
7_
... Two* levels of crack detection for welds already exist ,
~
at Shoreh'am. The first level involves the Drywell Leak DetectionSyst'emsdescribekinSection5.2.7oftheFSAR. The second level involves augmented inservice inspection to be coni ducted in accordance with NUREG-0313 and committed to by LILCO' i
in its acceptance. of NUREG-0313 guidance (see SNRC-566). SC and SOC have expressed the view that a third level of detection may be appropriate for certain "high risk" welds, that is, those welds from among the 22 welds described above, with the
. highest potential for un~ detectable cracking.
Three factors should be considered in determining "high' risk" welds. ' The first consideration should be whether the weld has received any post-weld treatment.
The second consideration is the stress level in the weld..
Research indicates that for cracking to be initiated in,the BWR .
environment, a weld must be expos,ed to a tensile stress above ,
the yield stress. GE has developed a formula called the Stress l Rule Index (SRI) which evaluates'the weld for this condition.
~
L The formula predicts the potential for initiation of cracking
'i f the SRT' exceeds 1.0. Field experience to date has shown this rule to be conservative for the 140 crackirg incidents ,
l where the SRI has been calculated'(out of a population of'292 known cracking incidents).
~
In all cases evaluated by GE, the
/ -
oy $ YeaT{h r.
SRI was gr;:tn ':._.. 1.2 for welds that actually cracked in ep-y.
. .erating plants. It is LILCO's position that welds having a SRI
-' jis 4 less than 1.2 5- and' certainly a SRI less than 1.0 -- lack a -
l l
- m. .*,A . . E ~ * = , es houde em -. m e ^
-M -*
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technical basis for being considered "high risk." SC and Soc, however,'do not agree with this proposition because of the faEt that the SRIs have not been quantified for all cracking inci-dents and because there is a degree of uncertainty in the SRI quantification.
The third important variab'le for "high risk" categori-zation is inspectability of the weld. Some of the 22 welds are not now totally inspectable (See. Attachment 1). ,
LILCO proposes to do tho'following about a third level of leak detection for "high risk" welds at Shoreham:
(1) LILCO will systematically identify "high risk" .
welds, which would be those that meet the following criteria:
(a) no post-weld treatment; (b) a SRI greater than 1.0, which is to be veri-fied by an inde' pendent third party analysis; and' ,
~
'(c) less than 90% inspectability.
In applying these "high risk" criteria, the following pro-cedures will be,used:
'(a) The, weld SRIs shall be initially calculated for l .
l ,
~
.LILCO by GE,in acccrdance with GE's SRI methodology._
~
- Included in the quantification sh,all be identification of the error bands. LILCO will'also make arrangements for a l ,
ll . third party independently to quantify the SRIs and the I ~
error bands..' The third party shall be either Sol. Levy
- Associates or' Failure Analysis Associates, or shall be
,i .
g
- -- ,s. - _ e ._.--m
~
. . . sele:ted from a list of potential, candidates mutually agrsed upon by LILCO and SC and SOC. LILCO shall make' .
fully available to SC and SOC all the calculati'ons, methods, assumptions, and results. If requested by SC or7 SOC, appropriate LILCO and/or GE and third party represen2 tatives will.be~available to discuss these results with SC and SOC consultants. The SRI acceptance criteria will re-quire that the welds' SRI must be shown to be 1 css than l.0 ass,uming the most conservative use of the error bands. ,
All obligations of-LILCO set forth in this paragraph will be completed prior to March 1, 1983 or two months after commenc'e' ment of fuel load, whichever is later. In no event will they be completed later than June 1, 1983.
(b) The 90% inspectabilit,y will be judged based upon the -PSI or the ISI completed results. This means that the
,. percentages currently achieved in the PSI program will govern the "high risk" classification until such time as a different percentage is determined to be actually achieved in the ISI program approved in the future.
- 12) LILCO will perform an engineering review of the Techmark'/Nutec Leak Detsetion Sys, tem. Although,-the system ,
appears promising, ,it has not yet' been tested for reliability in a BWR c,ontainment. An earlier hardwired, version of the sys.-
tem has been installed in the secondary containment at Nor.th
. Anna Units 1 and 2, and is being installed at Fermi Unit 2.
l l
, 10
, The Techmark System is currently being evaluated under an EPRI-sponsored effort, of which Phase One has already been com-pleted. The EPRI con' tractor for the program is Acton Environmental Testing Corporation (AETC) of Acton, Massachusetts. Phase One of the program developed an on-line functional test of the system. This test was conducted on MarcW 1, 1982. Phase Two of the program will proceed with environmental qualification of the system in accordance with c 'IEEE-323. This test -is sched.uled for, the fall of 1982. .
After
, results of these.two phases are completed, EPRI will evaluate what additional testing (e.g., in situ) may be required. .
LINCO proposes to monitor the EPRI program and use its results to perform a shoreham-specific evaluation as to whether the Techmark System's reliability is such that it could meaningfully augment the two existing levels of Icak detection at Shoreham.
. The evaluation will consider: (a) environmental
. qualification -(limited to early warning system, normal oper-j ating environment); (b) reliability of the system to detect -
pipe leakage only; (c) electrical system reliability to avoid spurious alarms,; and (d) the design and installation of a ' -
Shoreham-specific system. The EP.RI program shculd provide'suf-ficient information.to address all the.above points except (d);
a if the program does not provide'such'information,. LILCO will l .
pursue other means of obtaining these data. LILCO will com-( plete the Shoreham-specific study in time to permit installa-tion of the system; if appropriate, at the first refueling l
i 9
t . -
_11
'... outage. LILCO wi11 promptly provide'SC and Soc with the I
results 6f the EPRI study and the Shoreham-specific study ref-erence.d in'this p'aragraph. LILCO will also promptly advise SC of its conclusions regarding " qualification" .of the system for'>
power reactor application. If, in LILCO's view, the system is' not adequate, LILC,0 will advise SC.and SOC of the technical bas $s for this position and of additional efforts needed or underway to suitably improve the system for subsequent use at Shoreham. -
(3) If the results of_the investigation in (2) above
? ,
t indicate that the Techmark System is " qualified," LILCO will install the Techmark System on all welds cstablished as "high risk" in accordance with (1). If not initially " qualified" but if additional efforts subsequently result in " qualification".of the system, LILCO will install' the system on the "high risk" weld's at t'he next regularly scheduled refueling outage. This ,
! system, if installed, will be used as additional operator information, not as.a Limiting Co'ndition for Operation in the
. Technical. Specifications.
Item 3. ISI Accessibility In i.ts pre-filed testimony SC identified a5 a second con-
'~
cern the fact that*all welds are not fully accessible for ISI.
Th1,s concern is also expressed in SOC Contentions 19(d).
The t
't
' welds for which this is true have been discussed in Item 2-lj above. LILCO has identified 10 recirculation and RHR welds of '
ll . -
i S
h
&m -
- - . - "w. . _ _;_.- ._ --- nn- -- -
_ ._ q . ._ . . _ ,
. .~- ,
. . . , concern (see Attachme;1t 1). None of the 10 currently meet,the 90% criteria in the PSI program, but LILCO believes that six of the 10 will be able to meet the 90% ISI inspectability criter-ion. The remaining four are currently projected to be 21%,
64%, 63% and 65% inspectable for the ISI program.
LILCO has committed to attempt prior to fuel load to im-prove the inspectability of the ten welds referred to in the
. .preceding paragraph by using new. calibration standards where
, , ' applicable and practicable. .SC nnd SOC accept this commitment to resolve the l.SI accessibility concern expressed in.SC Contention 24 and SOC Contentions 19(d) ' subject to the imple- ,
mentation of the augmented leak detection commitment in Item 2.
No later than 20 days prior to commencement of fuel load or by r, J o uvy 3
~
(, 1: . ...L c 1 5 , 19g), whichever i,s earlier, LILCO will report in -
(,9 writing to SC and SOC regarding its implementation of this com-k mitment and the technical basis for any actions taken or deci- :
, sions' that no actions are necessary.
In addition, LILCO'will cI'ssify, a in accordance with .
NUREG-0313, as " service sensitive" and accordingly, subject to augmented inspection as defined in NUREG-0313, those welds' ;
meeting the foll,owing critek-ia: ,
(1) Be larger than four inches in diameter:
,' (2) Not have received post-weld treatment (SHT or IHSI);
and ,
~ '
(3)'Have a ski.' greater than 1.0, or ISI UT inspectability
(
,- of less t'han 90%.
( - .
~. ~ ~
[
- ~
... Item 4. Pipe Replacement ,
SC identified as a concern the potential problem of large scale.repl'acement of failed SS 304 pipe after operation, which the County believes may create significant radiation levels.
SC recommended that a contingency plan be developed by LILCO to prepare for such eventualities.
LILCO has provided the following data to SC fo'r review:
s.
(1) A description of the Pooled Inventory Management (PIM) program presently being implemented by GE; (2) LILCO's PIM notes, indicating that LILCO e cts piping to be considered in PIM; exp ~
(3) A discussion of the BWR Owners' Group Remedy
- Development Center es,tablished at Charlotte, North Carolina. Piping replacement tools and methods are being developed at this fa-cility.
In addition, LILCO and NC consultants have discussed the major piping replacement program currently underway at the
. Nine Mile. Point, Unit 1 plant. It is anticipated that this ex-perien'ce will provide viluable experience'and input for possi- ~
~
..- ble future programs, .
.. SC agrees to resolution of this concern based on LILCO's
. agreement to: .
~
,- (1) Participare in the PIM or ecuivalent pooled inventory. program; ,
14_-
(2) Sponsor inc,1usion of piping materials in the program;'
-(3) Participate in and encourage on an ongoing basis, applicable developments in the Group Remedy Development Center; and *
(4) Closely. follow the plan and implementation of the large recirculation pipe replacement program currently unde {say at Nine Mile Point, Unit 1. ,,
4 LILCO will,, advise SC of its implementation of its Item 4 commitment no later than 20 days.. prior to commencement of fuel y load or by N. . _..im.-
J3ww.vy 15, 198},whicheveri,searlier.
3 -
~
fY3\ . - Item'5. Regulatorv Guide 1. 31 pjW-SC and SOC identified as'a concern the potential degrada-tion of SS 304 welds due.to the fact that the latest revision of Regulatory Guide 1.31 was not in use during the construction of Shoreham piping. systems. In response to this concern, LILCO
.. has provided the following information to SC an'd SOC consul-tants:
- (1) A su dary report by.GE, dated November 26, 1975, cbvering delta ferrite measurements of
. GE responsibility welds at.fi've plants / con- .
structed per the GE methods. This report
, verifies acceptable experience with the GE procedures used ar Shoreham.
- , - - , , - , _ , - - - + - - - . , . , , - ---- - - - - - - - - - - - --
,,,,---,,n,
. . . , (2) Delta ferrite measurement data taken by
'LILCO at Shoreham on weld srmples as speci-fied by NRC's MTEB S-1. Results reported showed that for the G-41 and P-21 systems, the 43 welds tested were found acceptable.
Based on review of the above information, SC and SOC are satis ~fied that this concern has been resolved.
Item 6. Weld Sensitization Test's SC and SOC identified th'e desirability of utilizing the ,
electrochemical'potentiokinetic reactivation method ("EPR") as a check to ensure that weld sensitization was not excessive. -
Subsequent to the filing of testimony on'SC Contention 24/ SOC -
Cont'entions 19(c) and 19(d), LILCO.has identified the locations of the non post-weld treated joints and has demonstrated to SC and SOC consultants' satisfaction that EPR is not a practical method for the welds in question' SC and SOC therefore agree
- that this concern is resolved.
l .
Item 7. Cobalt and Carbon Levels i
SC and SOC. identified a need for LILCO to verify the suit-l ~
i ability'of carbon and c6balt levels in the RCPB materials and -
..' thus to' demonstrate minimization 'of sensitization and of-radia-l . tion level buildup. Subsequent to the filing of testimony on i : .
SC Contention 24/ SOC Contentions 19(c) and (d), LILCO has docu~-
1
., .mented that cobalt levels in alternate piping materials are i . commonly no lower than in SS 304. SC and SOC consultants l
l l
i
.. J c - _.___n_ _ . _ _ m .
.d, . "I ,
/
- ~
~
- ~
agree. LILCO has also provided'to SC.and SOC a compilation of , ,
carbon content in IHSI treated recirculation piping spools. SC and SO.C consultan,ts have reviewed'those data and find that no
~
~
unusually hign percentages exist. In view of LILCO's perform -
ance of<IHSI on all applicable welds, SC and SOC agree that this' concern,has been satisfied.
j Item 8. Furnace Sensitized Materials SC and SOC identified as an additional materials failure concern'the potential failure' of furface sensitized materials in the RCPB and'of reactor internal components. LILCO has pro ,
vided SC and SOC consultants with a copy of GE specifications -
-21A9242, " Reactor Pressure Level," and 21h3319, "
Standard '
These documents verify -thit
~
Requirements for Core Structure."
furnace sensitized materials a're not utilized at Shoreham and i .
that internals are requir.ed to be solution heat treated, Based on these, data, SC and SOC agree that furnace sensitized mate-rials are not an issue at the Shoreham reactor.
- , . Item-9. Commitment to NUREG-0619
- SC. also identified as a concern LILCO's f ailure to commit i
(o comply with NUREG-0619 by, installing.the tri-is .unequivocall , ,
^
pie sleeve sparger and a low feedwater ficw controller be,, fore
.j fuel load. LILCO ha's now installed.th'ese components and has .
com,mitted to demonstrate, during.startup tests, the compliance d Il . .
'of the low flow controller with NUREG-0619 requirements.
i i
. . , , . . _ _ . - _ , . + , 4 a _ . _ . _ _ , _ . . . - . .
t 17
~ '
. SC therefore agrees that the NUREG-0619 issues have been
~
resolvid ; subject to satisfactory test of the controller. -
-LILCO~ agrees to'take appropriate corrective action' prior to fuel load if the controller does not prove to be acceptable under the NUREG-0619 criteria. LILCO will provide SC with.the results -of the startup test of the low flow controller as soon .
as the data become available. LTLCO will also prov'ide SC with in' formation on what corrective action is required, if any, as soon as.'possible, but no later than the first refueling outage.
f -
-) , N ~
41WJ
\ l 6/ __
Counsel for' Ccunsel for /
LONG ISLAND LIGHTING SUFFOLK COUNTY ,.
COMPAIU 11 > ^ % .0 t t m c il.Yd*.----
Couns'el for ///P] Counsel for \
~
SHOREHid1 OPPONENTS -
NUCLEAR REGULATORY .
COALITION COMMISSION STAFF nk 50 -
Dated' Cet-ebm __,, 1982 -
e e
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e b
- yyy- - - -- , - - - _ -- ,vr ,, -" -- -- '" ~ " - - - ' * '
/
. ,e ,, ,. . -..- - - . - - . p
- sf ., t 7 - -
UNITED STATES OF AMERICA
/, .
~
NUCLEAR REGULATORY CCMMISSION .
BEFORE,THE ATOMIC SAFETY AND LICENSING BOARD
.~ .
.s
~
In the Matter of
)
), -
)
LONG ISLAND ' LIGHTING COMPANY
' * ' )
, ) Decket No. 50-312,(0.L.)
. (Shoreham Nuclear Power Station, )
i I
Unit 1) >
)
) ,
, CERTIFICATE OF SERVICE I hereby certify that copies of,the Statement of Suffolk County
- Concerning Sensitization of Reactor Internals Issue -- Halapatz Concerns, were, on January- 21, 1983, sirved upon the followihg by first class mail, postage pre-paid, or by hand or tel2 copier and Federal Express, as indicated..
> +
4 3' >l - Lawrence Brenner, Esq.
- Ralph Shapiro, Esq.
- Administrative Judge Cammer and Shapiro Atomic Safety andiLicensing Board . 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington,. D.C. 20555 i -
Howard L. Bicu, Esq.
Dr. James L.' Carpenter * * ~
217 Newbridge Road
- Administrative Judge Hicksville, New York 11801 -
1 Atomic Safety and Licensing. Board U.S. Nuclear Regulatory Commission W. Taylor Reveley III, Esq. **
Washington, D.C. 20$55 .
Hunton &, Williams ,
, P.O. Box 1535 707 East Main St.
- Dr . Pe t e r A'. Morris
- Richmond, Virginia 23212 Administrative Judge ~
' A,tomic Safety'an'd Licensing B,oard
- U.S. Nuclear Regulatory Commission Mr.' Jay Dunkleber'ger
- Washington., D.C., 20555 New York State Energy Office Agency Building 2-Edward M. Barrett, E s'q . .
Empire State Plaza .
General Counsel Albany, New York 12223 Long, Island Lighting Company ' '
250 Old Country Road
- Mineola, New York 11501 Stephen B. Letham, Esq.
, Twomey, Latham & Shea Mr. Brian McCaffrey Attorneys at Law ,
Long Island Lighting Company P.O. Box 398 .
' 175 Eas: Old Country Road *
, 33 West Second Street Hicksville, New York 11S0.1 fiyerhead, New York 11901
^- - ^ - - 7 * ,6 J . ems ad t .6% A M A "" " " ' ~ ~ ~ ' '
+e6 e _mg, e ,h t.d
, .c .
Marc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc. Shoreham Nuclear Power Station P.O. Box 618 '
400-1 Totten' Pend Road North Country Road * .
Maltham, Massachusetts' 02154 Wading River, New Yor't "11792 Joel Blau, Esq'. _
MHB Technical Associates 1723 Hamilton Avenue .
New York Public' Service Commiss' ion Suite K -
The Governor Nelson A. Rocke feller - San Jose, California 95125 Building Empire State' Plaza Hon. Peter Cohalan Albany, New York 12223 -
Suffolk County Executive .
County Executive / Legislative" David J. Gilmartin, -Esq. Building Suffolk County Attorney Veterans Memorial Highway .
County Executive / Legislative Bldg. Hauppauge, New York 11788
. Veterans Memorial Highway ,
Hauppauge, New York .11788 * -
. Ezra I. Bialik, E,sq.
Atomic Safety'and Licensing Assistant Attorney General .
Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Law Washington, D.C. 20555 2 World Trade Center New York, New Yorl! 10047 Docketing and Service Section '
Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Washington, D.C. 20555 -
U.S. Nuclear Regulatory Bernard.M..B,ordenick, Esq.
- Commission Washington, D.C. 20555 David A. Repka , Esq. '
i U.S. Nuclear Regulatory Commission - Matthew J. Kelly, Esq. -
t Washington, D.C. 20555 Staff Counsel, New York State Public Service Comm.e l
Stuart Diamond ' 3 Rockefeller Plaza l
Environment / Energy .friter .-
Albany, New York 122'23 NEWSDAY Long Island, New York 11747 I
L .
Daniel F. Brown, Esq. * ~
l
{ -
At.omic Safe ~ty and ,
Licensing Board Panel
- U.S. Nuclear Regulatory Commission
.,- Washington, D.C. 20555 , , 3 .
' /[,/ i / :h &
I Karla'J. Letsche KI RKPATRIC K , LOCKHART, HILL,
- CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Flocr Dh7E- January 21, 1983 ,
Washington, D.C. 20036 -
l */ Hand delivery l, **/ By telecopier and Federal Express I .
_