ML20091N021
| ML20091N021 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/08/1984 |
| From: | Nichols N, Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20091M972 | List: |
| References | |
| NUDOCS 8406120172 | |
| Download: ML20091N021 (57) | |
Text
y2 i
1-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 34 J01!! pp.12 Before the Atomic Safety and Licensing Board fCC,u h3 f ] *
~
BMNcy In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION RELATING TO LEA CONTENTION I-42 Philadelphia Electric
- Company, Applicant in the captioned proceeding, in accordance with 10 C.F.R. 52.754 and the Atomic Safety and Licensing Board's
" Order Scheduling Proposed Findings" (April 27, 1984),
hereby submits its Proposed Findings of Fact and Conclusions of Law in the Form of a Partial Initial Decision Relating to LEA Contention I-42.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
j Mark J. Wetterhahn Nils N. Nichols Counsel for the Applicant June 8, 1984 Ob
-W
O.
o PARTIAL INITIAL DECISION (ON LEA CONTENTION I-42)
Preliminary Statement 1.
Limerick Ecology Action
(" LEA")
filed a petition to intervene in the Limerick Generating Station
(" Limerick" or " Station") operating license proceeding on September 21, 1981.
At a prehearing conference held January 6-8,
- 1982, this Atomic Safety and Licensing Board
(" Board") found that LEA had standing to intervene and admitted, inter alia, its Contention I-42 concerning environmental qualification of safety-related equipment, subject to its further specifica-tion.M 2.
In our unpublished " Memorandum and Order Confirm-ing Rulings Made at Prehearing Conference," dated October 28, 1983, LEA Contention I-42 was admitted as respecified.
Contention I-42 states that:
The applicant (sic) has not shown compliance with the Commission's rule, Environtvental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, Jan. 21, 1983, 48 FR 2729, 10 CFR 550.49.
Particularly, it has neither established a program for qualifying all of the electrical equip-ment covered by $50.49, nor performed an analysis to ensure that the plant can be safely operated pending completion of 1/
Philadelphia Electric Company (Limerick Generating
~
Station, Units 1 and 2), LBP-82-43A, 15 NRC 1423, 1439, 1497-98 (1982).
1
o.
equipment qualification, as required by 550.49(i).
Failure to comply will threaten the health and safety of the public.
The City of Philadelphia, which was admitted to the Limerick operating-license proceeding as an interested governmental participant, also took part in the litigation of this issue.2_/
Evidentiary hearings were held on April 9-10, 1983 in Philadelphia, Pennsylvania.
Introduction 3.
The Applicant presented the testimony of a panel of witnesses relating to Contention I-42.
The panel includ-ed William J. Boyer, leader of the Environmental Qualifica-l tion Group of Philadelphia Electric Company's
("PECO")
Nuclear Generating Branch; Daniel Thompson, the electrical engineer responsible for the environmental qualification of Nuclear Steam Supply System ("NSSS") equipment at Limerick; Dennis Klein, supervisor of the Bechtel Power Corporation
("Bechtel")
licensing group assigned to Limerick; Loren Stanley, President and Principal Consultant of Zytor, Inc.,
and formerly Quadrex Corporation Group Manager in charge of the Limerick Component Classification Program; Edward Sproat, Electrical Project Engineer,.PECO; Thomas Shannon, engineer in charge of the NSSS Branch of the Limerick Power Plant Design
- Section, PECO; Wesley
- Bowers, supervising 2/
Id. at-1456.
... a; engineer in charge of the. Nuclear Control Branch of the Control-Engineering
- Section, PECO; and John
- Doering, Limerick Operations Engineer and Senior Reactor Operator, PECO. ' These witnesses are qualified in their respective disciplines and tne Board has relied heavily upon their testimony.
4..
=The same is equally true of the witnesses testify-ing on behalf of the Staff.
The Staff presented the testi-many. of Armando Masciantonio, Environmental Qualification Branch, NRC; and Robert LaGrange, Section Leader, Equipment Qualification
- Branch, NRC.
Both witnesses were highly qualified and their testimony is entitled to great weight.
Neither LEA or the City of Philadelphia presented witnesses on this contention.
Summary 5.-
As applied to the. Limerick Generating Station, the scope of equipment required to be considered for environ-mental qualification was unchanged by the adoption of 10 C.F.R. 550.49 in. January 1983.
The aquipment required to be qualified by.550.49 consists of three subsets of electrical equipment important to safety which is located in.a harsh environment.
The ' equipment-defined by
$50.49 (b) (1),
safety-related. equipment, has been traditionally. recognized as -requiring environmental' qualification and, ' indeed, the criteria requiring its qualification have been referenced in the Limerick Final Safety Analysis Report- ("FSAR"). since it was' originally submitted to the NRC in~ March 1981.
D
s,
6.
The new classes of equipment required to be environmentally qualified, which intervenor asserted were not taken into account at Limerick, consist of the subsets of equipment defined in subsections (b) (2) and (b) (3) of 550.49.
With respect to the equipment defined in subsection (b) (2), PECO employed a conservative safety classification practice in the design of its systems which resulted in no equipment within the scope of this subsection requiring qualification.
Whenever cases were identified during the design process in which the failure of nonsafety-related components could possibly prevent the attainment of safety function objectives, they were eliminated by design modi-fications or by adding them to the Limerick Q-List and qualifying them as necessary.
An equipment safety classi-fication program performed by an independent company ver-ified that Limerick has no equipment falling within sub-section (b) (2) requiring qualification.
7.
The post-accident monitoring equipment which requires environmental qualification, as set forth in sub-section (b) (3), had already been anticipated prior to the adoption of.S50.49 and PECO had previously committed to its qualification.
The equipment set forth in subsection (b) (3) was defined in December 1980 by Regulatory Guide
(" Reg.
Guide") 1.97, Rev.
2.
PECO committed to meet the require-ments set forth in this document in March 1981.
8.
Inasmuch as Limerick has no equipment falling within subsection (b) (2) and has committed to meet the
i requirements of Reg. Guide 1.97, Rev.
2, regarding sub-section (b) (3), plant operators could not be misled by the failure of unqualified equipment falling within the scope of either of these subsections.
- Moreover, plant procedures assure that only qualified equipment will be utilized if the need arises.
9.
- Finally, the PECO Environmental Qualification Report ("EQ Report") is not inadequate because no action is identified to correct the alleged deficiency where equip-ment's qualified life does not equal the plant's 40 year life.
A qualified life of less than 40 years is not a deficiency.
If the qualified life of any equipment item is less than 40 years, it is scheduled for replacement prior to the end of its qualified life.
Otherwise, equipment is routinely scheduled for maintenance on an "as required" basis.
Compliance with 10 C.F.R.
SSO.49 (b) (1) 10.
The equipment defined by 10 C. F. R. 550.49 (b) (1),
safety-related electric equipment, has been traditionally recognized as requiring environmental qualification.
This requirement was originally embodied in various General Design Criteria ("GDC") set forth in Appendix A of 10 C.F.R. Part 50.
These criteria have been referenced in the FSAR h
since it was originally submitted to the NRC in March 1981
- (;
and the structures, systems and components required to be reviewed ' for environmental qualification are set forth in the Limerick Q-List.
}
g
, 9 11.
The Limerick Q-List was established in accordance with 10 C.F.R. Part 50, Appendix B,
as the controlling document identifying the safety-related structures, systems and components required to assure the:
(1) integrity of the reactor coolant pressure boundary; (2) capability to achieve and maintain safe shutdown; and (3) capability to prevent or mitigate the consequences of an accident which could result
,g in potential offsite exposures comparable to the guidelines of 10 C.F.R. Part 100.
Bechtel Power Corporation, the Limerick architect-engineer, and the Applicant's engineering staff evaluated all structures, systems and components using the GDC set forth in 10 C.F.R. Part 50, Appendix A,
to determine those which are required to achieve the above safety functions and which must, therefore, be included on the Q-List.
Information from other boiling water reactor plants was:also used in this evaluation since many of them contain systems and components identical or similar to ones used in Limerick.
The Q-List has been updated as necessary to reflect' design changes.
These revisions have been reviewed by both Bechtel and PECO to ' ensure the correct classification of 'all structures, systems and components.
W.-Boyer, et al.,
ff. Tr. 9529, at 4-5.
.12.
Under the requirements of $50. 49, ' all equipment-must be qualified.on the basis of actual tests.
The PECO EQ group reviewed.the specifications for ' the. tests', the. test plans, follow-up reports,.and in some' cases actuallylpartic-
- ipatedLin the tests.
Tr. 9546-49-(W.[Boyer)'.
,y n!)
'j ',
Compliance With 10 C.F.R. S50.49 (b) (2) 13.
Intervenor contended that the adoption of 10 C.F..R.
S50.49 (b) (2) expanded the scope of equipment required to be environmentally qualified and that the Applicant had not complied with this provision.
10 C.F.R.
S50./,(b) (2) provides, in essence, that all nonsafety-related equipment whose failure under postulated environmental conditions could prevent the accomplishment of specified safety functions shall be qualified.
Contrary to the intervenor's assertion, the evidence indicated that Limerick's conformance with various regulatory requirements and guide-lines, and conservative design practices has resulted in L
system designs involving no equipment within the scope of subsection (b) (2) requiring qualification.
W.
- Boyer, e t, M., ff. Tr. 9529, at 7; Tr. 9553, 9575, 9595 (W. Boyer).
14.
As part of this process, the interfaces between safety-related electrical components were evaluated during the plant design process and whenever cases were identified in which the failure of nonsafety-related components could prevent attainment of safety function objectives, they were eliminated by implementing design modifications or by adding i
them to the Q-List and qualifying them as necessary.
W.
Boyer, et d.,
ff. Tr. 9529, at 7; Tr. 9554-57 (W. Boyer, Klein, Shannon).
The design modifications were reviewed and approved by the' Staff.
Tr. 9561-62 (Sproat).
b=.
O.
Independant Verification Program 15.
In addition to the design process described above, PECO retained Quadrex Corporation ("Quadrex") to conduct an independent verification program to ensure that all elec-trical equipment required to perform a safety function was properly identified.
This program was initiated by Quadrex in February 1982.
W. Boyer, et al.,
ff. Tr. 9529, at 9; Tr.
9550-51 (Stanley) ;
Tr.
9562 (W.
Boyer) ;
9616-17, 9619 (Thompson).
Quadrex was fully qualified to conduct such a program, having previously conducted similar programs at a number of other nuclear plants.
Tr. 9550-51 (Stanley).
16.
Using a
recognized
- program, designated Q*5, Quadrex established a
Component Classification Program
("CCP") to evaluate electrical components at Limerick.
The CCP rules were adopted from previous classification experi-ence gained with both boiling water reactors ("BWR's") and pressurized water reactors
("PWR's").
A wide range of reference documents were also used to develop the classi-fication rules including, inter alia,: the Limerick Final Safety Analysis Report ("FSAR") ; NUREG-0737, Classification of TMI Action Plan Requirements; Reg. Guide 1.26, Quality Group Classification Standards for Water, Steam, and Radio-active-Waste-Containing Components of Nuclear Power Plants; Reg. Guide 1.29, Seismic Design Classification; Reg. Guide 1.97, Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs - Conditicns During and Following an Accident; ANSI /ANS 4.5-1980, Accident
r-Monitoring Functions in LWR's; and ANSI /IEEE Std. 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations.
W. Boyer, et al.,
f f. Tr. 9529, at 9-10.
17.
The Q*5 CCP was then initiated by defining specif-ic tasks.
Within the first task, the scope of the work and program rules were determined.
The work scope was to review Limerick plant systems and their components and to assign a five-character code to each component classifying it in accordance with its relative safety ranking.
The standard Q*5 Program Rules were modified as necessary in accordance with PECO's specifications.
These modifications included
. identifying:
(1) the equipment's specific safety function in response to a high energy line break ("HELB") or loss of coolant accident ("LOCA"); (2) the safety function for which the equipment is relied upon; (3) the equipment's location; (4) the duration for which it is required to perform its safety function objectives in response to a HELB or LOCA; and (5) the electrical state of the equipment in performing its safety
- function, i.e.,
energized,- de-energized or alternatively energized and de-energized.
W. Boyer, g al.,
ff. Tr. 9529, at 10-11.
18..
.The second task.was initiated by - Quadrex and reviewed ~ by. PECO.
Under this task, Quadrex prepared a matrix of required systems versus events as defined in Chapter 15 of the FSAR and independently proposed a number of other systems for review.
W.
Boyer, et al.,
ff. Tr.
9529,-at 11-12.
l
19.
Intervenor cited the emergency lighting system, in-plant communications system, the plant process computer system, and the computer software as examples of systems which were improperly excluded from the classification program.
The evidence indicated that these systems and the computer software were properly excluded from the CCP because they are not safety-related as defined by 10 C.F.R. 550.49; they are not relied upon to provide lighting, commu-nications or information, respectively, during a design
)
basis accident in areas which could produce a harsh environ-ment, and their individual or collective failures could not prevent achiec ment of the safety function objectives defined in subparagraphs (i) through (iii) of 10 C.F.R.
S50.49, paragraph (1).
W.
Boyer, et al.,
ff. Tr. 9529, at 11-15.
20.
The objective of the third task was tc assure understanding and familiarity with each plant system to be analyzed prior to starting the component classification coding process.
The primary source documents discussed in Proposed Finding 16 were used to describe the particular plant system; the safety functions ' required of that system were identified from the FSAR and System' Descriptions.
This information was then correlated with results obtained. from previously completed Q*5 programs - for other BWR plants to further ensure. its reliability.
W.
Boyer, et al., ff. ~ Tr.
9529, at,15.
p
21.
Once this task was accomplished, individual components were identified and classified by their safety functions.
For each component, the coding of each iden-tified function was accomplished using the component classi-fication rules.
Other components with a functional rela-tionship to the particular component under analysis were also identified on the coding form along with their classi-fication results.
An internal consistency check was then provided by comparing the final coding of particular components with the coding of functionally related components.
W.
Boyer, et al.,
ff. Tr. 9529, at 16.
22.
This check assured that each component was evalu-ated in the context of its functional relationship to other components.
It also provided a means of interrelating each component to other components within a particular system.
Furthermore, at each system boundary with other plant systems, this comparison assured that the overall system was evaluated relative to its external interfaces.
Finally, the highest overall coding for che particular component was determined for each of the Q*5 positions.
W. Boyer, g M.,
ff. Tr. 9529, at 16-17.
23.
There were also two additional levels of review and approval by different. individuals within Quadrex of the tasks described above.
W.
Boyer, et al.,
ff. Tr. 9529, at 17; Tr. 9624 ~ (Stanley).
Moreover,.once Quadrex approved and submitted its report to the Applicant, it underwent yet another level of review and approval.
Tr. 9624 '(Thompson).
a.
24.
In addition to the tasks described above, the results of the Quadrex CCP codes were compared against the Bechtel Quality Assurance Drawings
("QAD's")
to determine any difference between the codes and the Limerick Q-List.
Of the approximately 30,000 components coded, there were 16 electrical equipment classification differences such that equipment was-not classified as safety-related by Bechtel, but should have been considered for inclusion in the Limerick EQ program.
Of these items, nine were located in a mild environment and another four did not require environmental qualification.
The remaining three items were included in the Limerick EQ program.
W.
Boyer, et al.,
ff.
Tr. 9529, at 22-23.
25.
Inasmuch as the Quadrex CCP rules were prepared and implemented prior to the publication of 10 C.F.R. S50.49 in January 1983, they were compared against that rule and it was determined that the CCP. rules fully comply with S50.49.
This conclusion was also based on a comparison of the Q*5 rules against the guidance provided by draft Reg. Guide 1.89, Rev.
1.
Draft Reg. Guide
- 1. 89,. Rev.
1, Appendix A, lists each of the typical equipment items or systems
.important. to safety.
With' the exception of the Auxiliary.
Feedwater System, which is used only on PWR's, each item of equipmentcor system important to safety listed in Appendix A was included in -the Limerick Q*5 CCP.
All applicable examples-contained in Appendix B of draft Reg. Guide 1.89, Rev.-
1, were also included in the ' Limerick.Q*5 program
except. for the turbine generator control system.
Its exclusion was based on BWR plant design in that that system is isolated and is also protected by automatic operation of safety-related equipment and instrumentation, such as the main steam line isolation valve closure on low pressure and the reactor protection system trip signals from turbine control valve fast closure and turbine stop valve closure.
W. Boyer, et al., f f. Tr. 9529, at 23-25; Tr. 9566, 9594 (W.
Boyer).
Compliance with 10 C.F.R. S50. 49 (b) (3) 26.
Intervenor also contended that Station operators could be misled by the failure of equipment ' that was not qualified in accordance with S50.49 (b) (3).
The post-accident ' monitoring equipment defined by subsection
- (b) (3)' is also-set forth in Reg. Guide l.97, Rev.
2, which is referenced in -the _ regulation.
As described in FSAR Section 7.5.2.5.1 l. 2., the Applicant has committed to the
- NRC to meet the' requirements set ~ forth in Reg. Guide l.97, Rev.
2, by the time fuel is loaded.
-W.
Boyer, et al.,
ff.
Tr..9529, at 6; Tr. 9622-(Bowers).
Squib Valves and Keylock Switch 27.
Intervenor also asserted that the Standby ' Liquid Control-System squib valves and the1related Keylock switch
. in-the control room were improperly excluded from the EQ.
' program.
The evidence _ indicated, however, that the Standby Liquid Control LSystem.. keylock switch is not -located 'in an
~
area': subject to - harsh: environments andi - therefore,. is not
+l
within the scope of 10 C.F.R. 550.49 and that the squib valves have been added to Appendix B,
" List of Equipment Important to Safety," of the Applicant's EQ Report.
W.
Boyer, et al.,
ff. Tr. 9529, at 3, 21.
Correlation of Systems Important to Safety 28.
As p' art of its review, the Applicant also corre-lated the list of systems important to safety contained in Appendix A of its EQ Report, with the list of such systems contained in FSAR Table 3.2-1 and justified the omission of those systems not included in its Report.
Tr. 9576-77 (W.
Boyer).
Justification for omission from Appendix A is based on the fact that a system is located in a mild environment or is not used to mitigate the effects of an accident.
The results of this review were provided to the Staff on January 16, 1984.
Tr. 9657-59 (Masciantonio).
29.
To ensure the validity of the Applicant's con-clusions regarding its omissions from Appendix A, the Staff generated its own list of systems important to safety.
Essentially, the six branches of the NRC's Division of Systems Integration developed lists of such systems which were then supplied to the Environmental Qualifications Branch.
The list of systems generated by the Staff is generic in some respects and specific.to Limerick in other respects.
Tr.
9659-60, 9693-96 (Masciantonio).
-Based on this. list, the Staff determined that all omissions from Appendix A
of the' -Applicant's EQ Report were fully l
justified.- Masciantonio, ff. Tr. 9640, at_5-6.
l
O.
Misleading of Plant Operators 30.
Taterw nor also contended that plant operators could ba
- isle. by the failure of equipment that has not been properly :: 2alified, but which falls within the subsets of equipment defined by subsection (b) (2) and (b) (3) of 10 C.F.R. 550.49.
Inasmuch as Limerick has no equipment falling within the scope of S50.49 (b) (2) and has committed to environmentally qualify the equipment identified by subsection (b) (3) prior to fuel load, there is no potential for Limerick operators to be misled by the failure of such equipment.
- Moreover, the Limerick Transient
Response
Implementation Plan
(" TRIP")
Procedures assure that plant operators will rely on Reg. Guide 1.97, Rev.
2, equipment when harsh environmental conditions exist in the plant.
W.
Boyer, et al.,
ff. Tr. 9529, at 25.
31.
The TRIP procedures,
_ hich are specific to w
Limerick, provide direction to control room personnel during design basis and degraded accident scenarios.
These procedures are entered when symptoms known as entry con-ditions are indicated and are designed to specifically remedy such. symptoms.
W.
Boyer, et al.,
ff. Tr. S529, at 25-27.
.3 2.
Whenever_an adverse symptom develops, the operator
.will immediately enter the applicable procedure and take the correctiv.e ~ action directed by that procedure.
That proce-dure ' will be followed until its exit conditions are sat-isfied.
If the particular transient continues to degrade,
the operator will enter contingency procedures to handle the I
more degraded conditions until he can return to the main procedures.
W. Boyer, et,al., ff. Tr. 9529, at 27.
-33.
All entry conditions into,the TRIP procedures are monitored by environmentally qualified instrumentation.
Once in the TRIP procedures, which are set forth in flow chart form, the operator is directed down various action paths.
At the beginning of each path, if there is a possibility that_the operator might use other than qualified instrumentation in the execution of that procedure, he is conditionally instructed, by cautions contained in the procedure, _to utilize specific instrumentation.
When an operator encounters a caution, he looks it up on a table contained in the procedure and executes it.
The impact of cautions on the actual execution of the TRIP procedures is minimal since the instrumentation that must be used is either-the instrumentation the operator would normally choose under those conditions 'or the only qualified in-strumentation available to monitor that parameter.
.W.
- Boyer, et al.,
ff.
Tr.
- 9529, at 28-29; Tr.
9601-11 (Doering).
34.
While'many TRIP procedures use only instrumenta-tion that has been environmentally qualified, they are not limited solely to the use of such' instrumentation.
In fact, there are only three paths under. which an operator is directed, under adverse conditions, to use _only ' qualified '
instrumentation.
The ' evidence ~-indicated that. to limit - an.
.E-
operator to the use of qualified instrumentation without any indication of actual adverse environmental conditions in the reactor building could unduly restrict execution of the procedure.
This is because environmentally qualified instrumentation may cover a broader rauge than non-qualified instrumentation and thus, in some circumstances, be less suitable for use because it is less precise.
By contrast, the instrumentation an operator normally relies upon is restricted generally to a narrow band around the operating range and is therefore more exact.
Tr. 9607-09 (Doering).
35.
Limerick has a great deal of environmental moni-toring instrumentation in the secondary containment that can be used to determine adverse environmental conditions.
These diverse systems include the use of thermocouples, fire protection instrumentation, ventilation monitoring, and temperature instrumentation.
Any of these systems can independently indicate the development of adverse environ-mental. conditions and thus alert.the operator to utilize the specific instrumentation qualified under Reg. Guide 1.97.
W.
- Boyer, et al.,
ff.
Tr.
- 9529, at 28; Tr..
9585-86 (Doering).
36.
A number of important-to-safety items located in the secondary containment have been exempted from the requirements ~ of Reg. Guide 1.97 because 'it has been de-
)
termined that ~ they would not be subjected to a harsh en-vironment under any circumstances.
These exemptions - are based on a
detailed.
evaluation of safety function
l
_.18 -
requirements and the time during which the equipment would need to perform its safety function.
Specifically, this analysis considered the requirements for each specific equipment item, the accidents the equipment would be used to
- mitigate, the point at which the equipment would be utilized, and the environmental conditions that would exist at that time.
The Staff has reviewed the criteria used in the exemption analysis and found them to be appropriate.
Tr. 9587-89 (W. Boyer).
Maintenance Requirements 37.
Intervenor also contended that PECO's EQ program is inadequate because in those cases in which equipment's qualified life does not equal the 40 year plant life, no action is identified to correct the deficiency.
To the
- contrary, the evidence indicated that the environmental qualification of instrumentation and other electrical equipment is contingent upon the performance of required maintenance and replacement at the end of its designated life.
The designated life of equipment is the period of normal plant operation during which the equipment is expect-ed to operate satisfactorily and still perform its safety function.
In some cases, the designated life of certain equipment is 40 years, the length of the Station's license.
In other instances, the designated life is less than 40 years.
W.
Boyer, et al.,
ff. Tr. 9529, at 32-33; Tr. 9581 (W. Boyer).
s
38.-
As part of the environmental qualification docu-mentation review process, maintenance requirements relatEd' to the environmental qualification of electrical equipment are documented on individual equipment environmental quali-fication review records
("EORR's").
The maintenance re-quirements for that item are identified on the EQRR by reference to applicable sections of the test reports and other documentation.
W. Boyer, et al.,
ff. Tr. 9529, at 33.
39.
.Each EQRR is reviewed by the Limerick Plant Staff Maintenance Group to determine if it contains information concerning _ required replacement intervals or maintenance activities that are necessary to maintain qualification of the equipment ' during its designated life.
If the EQRR indicates that the designated life of an item is greater than 40 years and-that no maintenance is required to maintain its environmental qualification, no further review is necessary.'-
When maintenance activities are required to sustain environmental qualification, the documents' listed in the Maintenance Requirements section of the EQRR. are reviewed and_the required activity, including its frequency, is-listed on a Maintenance Group-form.
This information is
- then-incorporated within plant procedures-and. into. a computer program to ensure that the desired activity is carried out on the properischedule.
When the'EQRR indicates that equipment has a. designated life of less than 40 years, its -re' placement schedule - -is listed on a Maintenance Group.
form.:
After determining.-
th'e-required maintenance or y
L.-
q __
20~-
equipment-replacement activities, a
list of procedures necessary.to implement those activities is then established.
W.
Boyer, et al.,
ff. Tr.
9529, at 34; Tr.
9581-82 (W.
Boyer).
Staff Review of Limerick EQ Program
.40.
The Staff has reviewed the Applicant's EQ program
- for. completeness, accuracy and conformance to the estab-lished - requirements.
This review included determining the proper definition of the scope of the program as defined by l10 C.F.R.
550.49, proper definition of postulated environ-
.ments and demonstration of qualification in accordance with-NRC rules and regulations.. Masciantonio, ff. Tr. 9640, at 4-5; Tr. 9649-50.(Masciantonio).
41.
As noted previously, to assure that all equipment required to be qualified was included in the Applicant's EQ program,' the Staff. compared the " List of Systems Important to Safety" submitted by PECO as Appendix A of its-EQ Report with a St'af f generated list of - systems, their required safety functions-and operability times.
- Also, as noted previously, on December 19, 1983,.the Staff requested PECO to correlate the systems listed-in-Appendix A of'its Report with!-the' systems-listed in -FSAR Table-3.2-1, which constitutes a list of alliplant systems'and: subsystems,.and to' justify any, omissions; PECO responded to this request.on-a January-16, -1984.
Based = on ~ this information, the' Staff
- determined :, that the L Applicant 'had adequately justified. all.
^
a r
b
omissions from Appendix A.
Masciantonio, ff. Tr. 9640, at 5-6; Tr. 9645-46, 9668, 9673 (Masciantonio).
42.
Additionally, the Staff compared the total number of components and equipment types set forth in the Limerick EQ program with other plants of similar design and reviewed the process used to select the components that were included in the program.
Masciantonio, ff. Tr. 9640, at 6; Tr. 9646, 9674 (Masciantonio).
- Finally, the Staff reviewed the methodology used by the Applicant to arrive at its list of components to ensure that it was appropriate.
Tr.
9646 (Masciantonio).
43.
The Staff then reviewed conformance of PECO's EQ program with S50. 49 (b) (2) for nonsafety-related equipment whose' failure under postulated accident conditions could affect safety functions.
Conformance with S50.49 (b) (2) is determined by reviewing the issues set forth in IE Intorma-tion Notice 79-22 and Reg. Guide 1.75.
Masciantonio, ff.
Tr.
- 9640, at 6;
Tr.
9665-66,
- 9668, 9678, 9686 (Masciantonio) ; Tr. 9684-88, 9708-09 (LaGrange).
44.
" Qualification of Control Systems," ' deals with the perrormance of nonsafe-ty-grade equipment subjected to an adverse environment which
'could impact.the protective functions performed by safe-ty-grade equipment.
Masciantonio, ff. Tr. 9640, at 6; Tr.
9666,- 9681 (Masciantonio).
Although the Staff's review under Information Notice 79-22'is not yet complete, Section 7.7.2.1 of the Staff's Safety Evaluation Report ("SER") has
i.
identified what the Applicant's response to this request
.must include and what the Staff must be able to conclude in order to resolve this matter.
Tr.
96r0-61, 9708-11 (LaGrange, Masciantonio).
In short, the items remaining open for review have well defined criteria that can readily be applied to determine their acceptability.
Tr.
9707-09 (LaGrange, Masciantonio).
45.
" Physical Independence of Elec-tric Systems," provides another review criterion assuring that there is no adverse interaction between safety-related and nonsafety-related equipment.
Specifically, this document provides guidance for complying with the requirements for physical independence of those circuits and electric equipment associated with the Class 1E power system, the protection system and other related systems.
The Staff's review of the Limerick EQ program's conformance to Reg.
Guide 1.75 is complete and has been found acceptable, as set forth in Chapter 8
of the SER.
g Masciantonio, f f. -
Tr.
- 9640, at 7;
Tr.
9665-66 (Masciantonio); 9709 (LaGrange, Masciantonio).
46.
To verify that the necessary equipment.is indeed qualified for the conditions under which it is required to operate,. the Staff reviewed the. EQRR summary sheets that were provided as Appendix E-of the Applicant's EQ Report.
The_ Staff also audited PECO's equipment qualification files to verify the ' bases of the submitted information and to establish that-the Applicant properly understood-those J
8 o factors necessary to the proper qualification of equipment.
Masciantonio, ff.
Tr.
- 9647, at 8-9, 11; Tr.
- 9642, 9697 (Masciantonio).
Essentially, the Staff selected 12 equip-
-ment qualification files representing approximately 10% of the items in the EQ program for a detailed review.
These files were examined for completeness and to determine if qualification were actually demonstrated.
Masciontonio, ff.
Tr.
- 9460, at 11; Tr.
9642 (Masciant.onio).
The Staff primarily relied upon past experience to determine the items it selected to be audited.
For example, equipment that has surfaced in past reviews on other plants as being unqual-ified, that has historically failed under LOCA conditions and that has never been previously audited constitute items 1
that would likely be ~ examined.
Tr.
9650-51, 9695-98 (Masciantonio).
In all cases,.it was determined that adequate proof of qualification was established.
Masciontonio, ff. Tr. 9460, at 11; Tr. 9643 (Masciantonio).
On this basis, the Staff concluded that the Applicant's EQ program is acceptable.
Tr. 9695-98 (Masciantonio).
47.
Also as part of its audit, the Staff conducted a plant walkdown to inspect the equipment as it was actually installed and to verify manufacturer and model number and proper installation of the equipment in a manner consistent with the qualification documents.
No violations were discovered during this-exercise, thus further indicating the validity of PECO's EQ program.
Masciontonio, ff. Tr. 9640, at 11; Tr. 9642-43'(Masciantonio).
Human Interaction Review 48.
Contrary to the intervenor's assertions, a human interaction review is not a requirement of the Applicant's EQ program pursuant to 10 C.F.R.
S50.49.
Masciantonio, ff.
Tr.
- 9640, at 8.
10 C.F.R.
S50.49 fully defines the requirements for environmental qualification and there is no requirement in that rule that a human interaction review be conducted.
Tr. 9661 (Masciantonio).
Status of Staff's Review 49.
As of this time, the Staff has determined that a program for qualifying electrical equipment within the scope of $50.49 has been established for Limerick.
The Staff has not yet completed its review, however, and no approval of that program has been issued.
Masciantonio, ff. Tr. 9640, at 11.
Yet to be reviewed are the remaining EQRR's (approximately 20% of the total), the information requested under Information Notice 79-22 and the subsection (b) (3) post-accident monitoring equipment committed to be installed pursuant to Reg. Guide 1.97.
Before an operating license will be issued, all equipment items in the Limerick EQ program must be demonstrated to have been qualified or a justification for interim operation, as provided for by S50.49, must have been submitted and approved by the Staff for each item _ that is not fully qualified.
Masciantonio, ff. Tr. 9640, at 14.
50.
_ Contention I-42, as litigated by LEA and the City of Philadelphia, concerns the scope of the Applicant's EQ
a.
program and particularly whether the equipment classified under subsections (b) (2) and (b) (3) was properly considered.
Inasmuch as the Staff's review of the Applicant's conformance to Reg. Guide 1.75 is complete and the necessary requirements to establish conformance with Information Notice 71-22 are set forth in the SER; and inasmuch as the Applicant has committed to install any post-accident monitoring equipment required under subsection (b) (3) prior to fuel load, the Board finds that completion of the Staff's review is not a condition prerequisite to its issuance of a partial initial decision.
51.
The Staff has indicated the criteria by which the outstanding items in the Applicant's EQ program are to be evaluated, including the criteria set forth in S50.49 and NUREG's 0800 and 0588, and that the Applicant is aware of these requirements.
The Staff's SER will not be closed out until compliance with these criteria have been demonstrated.
Accordingly, the Board may properly issue its decision on LEA Contention I-42 at this time.
Conclusions of Law 52.
Based upon the foregoing. Findings of Fact, which are supported by reliable, probative and substantial evi-dence a; required by the Administrative Procedure Act and the Commission's Rules of Practice, and upon consideration i
of the entire evidentiary record in this proceeding, the Board reaches the following conclusions pursuant to 10 C.F.R. $2.760a:
(1)
The Applicant has fully complied with the require-ments set forth in 10 C.F.R.
S50.49.
Specifically, it has established a
program for qualifying all electrical equipment at Limerick encompassed within S50.49.
It was not necessary to analyze the ability of the plant to be safely operated pending completion of the equipment qualification program inasmuch as all relevant equipment will be qualified prior to fuel load.
(2)
Limerick has no equipment falling within the category designated by 10 C.F.R. 550.49 (b) (2).
Consequently, the postulated post-accident failure of nonsafety-related equipment could not degrade any safety function or mislead plant operators.
(3)
The feedwater control system, emergency lighting system, the communications system, the plant process comput-er system, and the computer software were. reviewed for inclusion in the Applicant's Environmental Qualification program and it was determined that they do not fall within the purview of 10 C.F.R. S50.49.
(4)
Those systems required to mitigate the conse-quences of a loss of coolant accident or a high energy line
-break were fully considered and included within the list of systems and equipment to be qualified Where necessary.
(5)
A human interaction review is not required by 10 C.F.R. 550.49.
(6). The Applicant has an effective program-to maintain and replace equipment as necessary in those cases in which
i (..
the. qualified life of equipment is not equal to the 40 year licensed life of the plant.
(7)
The Keylock switch and the Standby Liquid Control System do not fall within the scope of 10 C.F.R. S50.49 and were therefore properly excluded from the Applicant's Environmental Qualification program.
The squib valves have been added to the Environmental Qualification Report " List of Equipment Important to Safety".
I 2
'T DOCKETED USNPC 1
APPENDIX A 84 JUN 11 P2:12 WITNESS LIST
<g e
Witness Following Transcript Page Ashley, Gordon K.
" Professional Qualifications 8205 Gordon K. Ashley II"
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation Resulting From the Assumed Ruptures of the ARCO and Columbia Gas Transmission Pipelines."
Benkert, John W.
" Professional Qualifications 8205 John W. Benkert."
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation Resulting From the Assumed Ruptures of the ARCO and Columbia-Gas Transmission Pipelines."
Bowers, Wesley W.
" Professional Qualifications."
9526
" Testimony Relating to Contention 9529 I-42, Environmental Qualification of Electric Equipment."
Boyer,-Vincent S.
" Testimony.of Vincent S.~Boyer, 5412 Senior Vice President, Nuclear Power, Philadelphia Electric b
e Witness Following Transcript Page Company, Regarding Contentions V-3a and V-3b."
" Testimony of Vincent S. Boyer, 6237 Senior Vice President, Nuclear Power, Philadelphia Electric Company Regarding Contention V-4."
Statement of Professional 8205 Qualifications.
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety.Related' Structures to Withstand the Effects of Postulated
. Detonation Resulting From the Assumed Ruptures of the ARCO and Columbia Gas Transmission Pipelines."
" Testimony Relating to Onsite Emergency 9772 Planning Contentions."
Statement of Professional 9772 Qualifications.
Boyer, William J.
" Professional Qualifications."
9526
" Testimony Relating to Contention I-42, 9529 Environmental Qualification of Electric Equipment."
Brown, Jack G.
"Tastimony'of Jack G. Brown, Columbia 5261 Gas Transmission Corporation Director of Transmission Engineering, Related to Contention V-3b."
" Jack G. Brown Professional 5261 Qualifications."
Buchert, Kenneth
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of.
Safety Related Structures to Withstand the Effects of Postulated Detonations;Resulting From the
e '~
Witness Following Transcript Page Assumed Ruptures of the ARCO and Columbia Gas Transmission Pipelines."
" Professional Qualifications 8802 Kenneth P. Buchert."
Campe, Kazimieras M.
"NRC Staff Testimony Kazimieras M. Campe 6131 on Pipeline Hazards With Respect to the Limerick Generating Station (FOE Contention V-3b). "
"Kazimieras M. Campe Professional 6131 Qualifications."
" Testimony of Charles M..Ferrell and 6136 Earl H. Markee, Jr. and Kazimieras M.
Campe Concerning ARCO and Columbia Gas Pipelines."
" Supplemental Testimony of Charles 7136 M. Ferrell, Earl H. Markee, Jr. and Kazimieras M. Campe Concerning FOE
-Contentions V-3a and V-3b."
"Kazimieras M. Campe Professional 6136 Qualifications."
Christman, LeRoy A.
" Testimony of LeRoy A. Christman, 5093 Montello District Manager, ARCO Pipe Line Company, Related to Contention V-3b."
Daebeler, George F.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
" Professional! Qualifications."
9772
~Doering,-John
. " Professional-Qualifications."
'9526
" Testimony Relating to Contention I-42, 9529'
r
- Witness' Following Transcript Page Environmental Qualification of Electric Equipment."
,Dubiel, Richard W.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
" Professional Qualifications."
9772 Farrell, Charles M.
" Testimony of Charles M.
Ferrell and 6136 Earl H. Markee, Jr. and Kazimieras M.
Campe Concerning ARCO and Columbia Gas Pipelines."
" Charles M. Ferrell Professional 6136 Qualifications."
" Supplemental Testimony of Charles M.
7136 Farrell, Earl H. Markee, Jr. and Kazimieras M. Campe Concerning FOE Contentions V-3a and V-3b."
" Testimony of Charles M. Ferrell on 9041 Blast Overpressures at the Limerick Generating Station."
" Charles M. Ferrell Professional 9041 Qualifications."
Geier, Bernard A.
" Testimony of Bernard Geier 6883 Concerning the Impact of Cooling Tower Plumes on Induction (Carburetor) Icing'of Aircraft."
" Professional-Qualifications of 6883 Bernard Geier."
Hasbrouck, Bevier
" Calculation of Overpressure on 5750 Reactor Building From Rupture in ARCO Pipeline: Spraying Gasolene Into the Hillside of Possum Hollow
~
Run."
y-.
Witness' Following Transcript Page
" Scenario.for #1010 Pipeline 5750 Rupture and Gas ~ Release for Anthony and FOE.(V-3a,.b) Prepared by Bevier Hasbrouck."
" Testimony of Bevier Hasbrouck on 5750 Contentions V3a and V3b for Anthony /
FOE' Deflagration and Detonation from Rupture of-Columbia Gas Transmission's Pipeline for Natural Gas."
"Bevier Hasbrouck Professional 5750 Qualifications for Nuclear Accident Scenarios."
i Kankus, Roberta A.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
" Professional Qualifications."
9772 Klein, Dennis A.
" Professional Qualifications."
9526
^
" Testimony Relating to Contention I-42, 9529 Environmental Qualification'of Electric Equipment."
Krug, Harry E.P.
" Testimony.oflHarryLE.P. Krug-6883 Concerning the' Impact of-Cooling ToweriPlumes on Induction (Carburetor) : Icing of Aircraf t."
" Professional Qualifications of.
6883
[
Harry E.P. Krug."~
Kuo, Pao-Tsin
" Testimony of:P;T. Kuo and. Norman D.
9043
-Romney.Concerning' Margins of-Structural' Capability of Category-1 Structures to Resist Blast Over-
- pressures and ModeLof Structural Failure.of the' Cooling Towers."
,s '
Witness Following Transcript Page
" Professional Qualifications Pao-Tsin 9043 Kuo" Lefave, William T.
" Testimony of William T.
Lefave 9047 Concerning the Flooding Effects of Safety Related Equipment From a
. Cooling Tower Collapse at the Limerick Generating Station."
" William T. Lefave Professional 9047 Qualifications."
Linnemann, Dr. Roger E.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
" Professional Qualifications."
9772 Markee, Earl H.
" Testimony of Charles M. Ferrell 6136 and Earl H. Markee, Jr. and Kazimieras M. Campe Concerning ARCO and Columbia Gas Pipelines."
" Earl H. Markee, Jr. Professional 6136 Qualifications."
" Testimony of Earl H. Markee 6883 Concerning the. Cooling-Tower Plumes."
" Earl H. Markee, Jr. Professional 6883 Qualifications."
" Supplemental Testimony of 7136 Charles M. Ferrell, Earl H.
Markee, Jr. and Kazimieras M.
Campe Concerning FOE Contentions V-3a and V-3b."
Murphy, Gary W.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
l
k n Witness Following Transcript Page
" Professional: Qualifications."
9772 s
'i Palaniswamy, Ranga k
" Professional Qualifications 8203 Ranga Palniswamy."
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation Resulting From the Assumed Ruptures of the ARCO and Columbia Gas Transmission Pipelines."
Payne,, Walter C.
" Testimony of Walter C. Payne with 5357 Regard to Contention V-3a and V-3b."
Reid, Gary-J.
.f.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
" Professional Qualifications."
9772 Romano, Frank R.
" Written Testimony by AWPP Relating 6725 to Carburetor Ice Contention, V-4."
" Qualifications of~ Frank Romano."
6725 Romney, Norman D.
" Testimony of P.T. Kuo and Norman 9043 D.2Romney Concerning Margins of Structural Capability of Category 1 Structures to Resist Blast
't Overpressure =and' Mode of Structural Failure of the. Cooling Towers."
" Professional Qualifications 9045 Norman.D. Romney" tr ha
Witness Following Transcript Page Sears, John R.
" Testimony of John R. Sears on Behalf 9776 of the NRC Staff Regarding Limerick Ecology Action's (LEA) Onsite Emergency Planning Contentions."
" Professional Qualifications."
9776 Shannon, Thomas E.-
" Professional Qualifications."
9526 4
" Testimony Relating to Contention I-42, 9529 Environmental Qualification of Electric Equipment."
Sproat, Edward F.
" Professional Qualifications."
9526
" Testimony Relating to Contention I-42, 9529 Environmental Qualification of Electric Equipment."
Stanley, Loren
" Professional Qualifications."
9526
" Testimony Relating to Contention I-42, 9529 Environmental Qualification of Electric
. Equipment."
Seymour, Maynard E.
" Affidavit of Maynard E. Smith and 6234
' David Seymour in Support of a' Motion for Summary _ Disposition Regarding Contention V-4."
Statement'of' Professional Qualifications 6234 Smith, Maynard E.
" Affidavit of: Maynard E.' Smith and 6234 David'Seymour'in Support of a Motion for1 Summary Disposition Regarding
' Contention V-4."'
LStatement ofl Professional Qualifications 6234 2
f Witness Following Transcript Page Thompson, Daniel J.
" Professional Qualifications."
9526
" Testimony Relating to Contention I-42, 9529 Environmental Qualification of Electric Equipment."
Vollmer, H. William
" Professional Qualifications H. William 8203 Vollmer."
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation Resulting from the Assumed Rupture of the ARCO and Columbia Gas Transmission Pipelines."
Ullrich, Werner T.
" Testimony Relating to Onsite 9772 Emergency Plan Contentions."
" Professional Qualifications."
9772 Walsh, John D.
" Testimony of John D. Walsh Relating 5411 to Contentions V-3a and V-3b."
" Professional Qualif-ications John D. Walsh" 5411 C
" Professional-Qualifications John D. Walsh" 8205
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation
'Resulting1from'the Assumed Ruptures of the ARCO and Columbia Gas Transmission Pipelines."
Wescott, Rex G..
- Testimony of Rex G. Wescott.Concerning 9045 the Hydrologic' Effects of a Cooling
I~
Following
' Witness Transcript Page Tower Collapse at the Limerick Generating Station."
" Professional Qualifications 9045
- Rex G. Wescott."
Wong, Albert K.-
' " Professional Qualifications 8203 Albert K. Wong."
" Testimony of Philadelphia Electric 8213 Company Regarding the Ability of Safety Related Structures to Withstand the Effects of Postulated Detonation Resulting From the Assumed Ruptures of the. ARCO and Columbia Gas Transmission Pipelines."
t 2
J Ek' N
ME
1 T
DOCKETED USHRC APPENDIX B 84 JJN 11 P2:i3 Exhibit List
,r-Applicant Exhibit Identified at Admitted at Description _ Transcript Page Transcript Page Transcript Page PECO Ex. 7 Limerick Gener-5357 5357 ating Station Site Plan, AB-207392-5, August 31, 1970.
PECO Ex. 8 Color Photograph 6236 6236 of Cooling Tower Plumes Coming from the John Amos Plant.
PECO Ex. 9 Cooling Towers 6413 6413 and the Environ-ment, Major Contributors:
Maynard Smith, Mark Kramer and David Seymour, October 1974.
PECO Ex. 10 Amos Cooling 6649 6649 Tower Flight Program, Test No.
48A, March 11, 1975.
PECO'Ex. 11 Douglas Point 6650
-Power Plant Site Evaluation Final Report, Vol. 1, Part 2, L.C.
Kohlenstein, Project Engineer, Published by the Johns Hopkins University
' Applied Physics Laboratory, January 1976.<
~
Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page PECO Ex. 12 John E. Amos 6765 Cooling Tower Flight Program Data,_ Conducted for the American Electric Power Service Corpora-tion by Smith-Singer.
Meteorologists, Inc., December 1975-March 1976.
PECO Ex. 13 Environmental-6868 Measurements of Power Plant Cool-ing Tower and s
Stack Plumes, Final Report for AEC, ERDA and DOE, Conducted' by the Department of Meteorology, Pennsylvania State University, Edited by D.W.
Thomson, R.G.-de Pena, J.A. Pena, Updated.
PECO Ex. 14 Table 2.2-3 of 6972 the Limerick Generating Sta-tion 1 Final Safety Analysis Report,
" Airports Within Ten Miles of the Site," Rev. 4, 05/82.
- PECO Ex. 15 Figure 1, One page.
8214 8214 document,. Free Air-
-Burst Blast Environment-PECO Ex._16 Figure 1, One page 8214 8214
-document entitled
" Air-Burst Blast.
Environment" PECO Ex.-17 l Figure 2, One page-8214 8214
. document entitled
~" Surface-Burst Blast-s I
b
-..e
.e-
. i Exhibit Identified at Admitted at
. Number Description Transcript Page Transcript Page Environment."
PECO Ex. 18 Figure 3, One pag 8214 8214 document entitled
" Site Plan"
.AB-207392-5 indicating.the postulated line of centroids of detonation (paral-
'lel to Columbia Pipe Line)
PECO Ex. 19 Figure 4, one page 8214 8214 document entitled-
" Cooling Tower General Arrange-ment" PECO.Ex. 20 Figure 5, One page 8214 8214 document entitled
" Cooling Tower Section Looking North" i
PECO Ex. 21. Figure 6, One page 8214 8214 document entitled
" Cooling Tower Looking West" l
PECO Ex. 22 Figure 7,-Single 8214 8214 page, large scale drawing entitled " Seismic-Category I Underground Facil-
-ities"-
PECO Ex._23. Figure 8, single
-8214 18214.
.page,'large scale sheet entitled
-" Profiles.of'RHR
'&'ESQ. Pipes Showing Ground Cover"
!PECO Ex. 24 Figure 9,. single 8214:
8214 page, large
. scale sheet en-titled " Profiles-of Cat.:1-
= Electrical Duct'
. Banks' Showing-t.
. L*'
Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page Ground Cover"
.PECO Ex. 25 Figure 10, one 8214 8214 page document en-titled " Intense Storm Site Runoff Pattern:
General Plan,"
PECO Ex. 26 Figure.ll, one 8214 8214 page document entitled "In-tense Storm Site Runoff Pattern:
Spary. Pond and Cooling Tower Areas," Figure 2.4-5, LGS FSAR.
PECO Ex. 27 Figure 12, one 8214 8214 page document en-titled " Duct Bank Sections" PECO Ex. 28 Figure 13, one 8214 8214 page document en-titled " Buried Pipe Bedding" PECO Ex. 29 Environmental 9531 9532 Qualification Report for Limerick Generating Station, Units 1 and 2.
October 1983.
PECO Ex. 30 Letter dated 9534 9534 January 16, 1984 transmitting document entitled
" Additional Infor-mation Required for Limerick Envi-
'ronmental Qualifi-cation Program."
PECO Ex. 31 ' Letter dated 9537 9537 February 16, 1984 from J.S..
s t
- ~
j Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page Kemper to A.S.
Schwencer con-veying Figure 4,
" Calculated Reactor Enclosure LOCA Temperature Profile" and Enclosures 1 and 2 PECO Ex. 32 Emergency Plan, 9772
- 9773, Limerick Generat-9996 ing Station, Unita 1 and 2 (through Rev. 8), Section 3, Section 4, Section 5.2.2, Section 5.3.2, Section 5.3.3 (Table 5-5), Section 6, Sec-tion 7.1, Section 7.3, Section 7.4, Section 7.5 (Table 7-3, Table 7-4, Table 7-5, Figure 7-2), Section 8.1.1, Section 8.3 (Table 8-1), Appendices A, B, E, I, Answers to NRC Questions 810.5b, 810.13,-
810.18, 810.24, 810.30, 810.32, 810.33, 810.35, 810.37, 810.40, 810.41, 810.45, 810.46, 810.47, 8 1 0.'4 8, 810.49, 810.53, 810.54, 810.55, 810.57 and 810.59 PECO Ex. 33 Emergency Plan Im-9772
- 9773, plementing Proce-9996 dures, Limerick Generating Station, EP-101 (Classifi-cation of Emergen-cies), EP-102 (Un-usual Event Re-
-sponse), EP-103
-(Alert Response),
EP-104-(Site Emergency Response),
i
e Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page EP-105 (General Emergency Response),
EP-110' (Personnel Assembly and Ac-countability),
EP-201 (Technical T pport Center (TSC) Activation),
EP-202 (Operations Support Center (OSC) Activation),
EP-203 (Emergency Operations Facili-ty (EOF) Activa-tion), EP-208 (Security Team Acti-vation), EP-210 (Dose Assessment Team), EP-220 (Radiation Protec-tion Team Activa-tion), EP-221 (Personnel Dosimetry, Bioassay, and Respiratory Protection Group),
EP-222 (Field Survey Group),
EP-230 (Chemistry Sampling and Analysis Team Activation),
EP-250 (Personnel Safety Team Activa-tion), EP-251 (Plant Survey Group), EP-252 (Search and Rescue /First Aid),
EP-254 (Vehicle and Evacuee Control Group), EP-255 (Vehicle Decontami-nation), EP-260 (Activation of 'the Firefighting Group), EP-291 (Staffing Augmenta-tion.60 Minute Call Procedure), EP-305 (Site Evacuation),
EP-307 (Reception and Orientation of' Support' Personnel),:
. Exhibit Identified at Admitted at Number Description.
Transcript Page Transcript Page EP-313 (Distribu-tion of Thyroid Blocking Tablets),
EP-316 (Cumulative Population Dose Calculations for Airborne Releases -
Manual Method),
EP-317 (Determina-tion of Protective Action Recommenda-tions), EP-325 (Use of Con-tainment Radiation Monitors to Estimate Release Source Term),
EP-401 (Entry for Emergency Repair-and Operations),
EP-500 (Review.and Revision'of Emergency-Plan)
PECO Ex. 34 Revised Table 4-2 9772 9773 Emergency Plan PECO Ex. 35 Emergency Procedure 9772 9773 Corporate, EP-C-326 PECO Ex. 36 Emergency Procedure 9772 9773 Corporate, EP-C-315 PECO Ex. 37 Surveillance Test 9772 9773 Procedure ST-7-EPP-351-0, Limerick Generat-ing Station PECO Ex. 38 Final Safety Analy-9772 9773 sis Report, Limerick Generating Station, Sections 1.3 (page 1.13-18b), 2.1.2.3,
.2.3.3, 2.3.3.2, 3.7.4, 7.5.1.4.2.1.5, 7.5.2.5.1.1.2, 7.6.1.1.6, 11.5, 11.5.2.2.1, 11.5.2.2.11, 11.5.2.3.1, 1 1.~ 5. 4,
11.5.5,11 3.4, 2
Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page 12.5.2.2.4, 12.5.2.2.6, a
i 12.5.3, 12.5.3.2, 12.5.3.4.2, 12.5.3.5, 12.5.3.5.1 Section 2.2.3.1.3 10284 10285 and Tables 2.2-1, 2.2-5, 2.2-6 PECO Ex. 39 Environmental 9772 9773 Report - Operating License Stage, Limerick Generating Station, Section 6.1.5 PECO Ex. 40 Letter of Agreement 9772 9773 dated August 16, 1983 between Hospital of the University of Pennsylvania and Radiation Management Corporation (in-cluding attached Radiation Plan entitled "Decontami-m nation and Treatment i
of Radioactively Contaminated Patient at Hospital of the University of Pennsylvania")
PECO Ex. 41 Letter of Agreement 9772 9773 dated June 25, 1982 between Keystone Helicopter Corporation and Radiation Manage-ment Corporation PECO Ex. 42 Letter of Agreement 9772 9773 g
j[
dated January 1, 1984 between Radia-tion Management Corporation anc Applicant PECO Ex. 43 Letter of Agreement 9772 9773 dated April 5, 1984 I
Exhibit Identified at Admitted at i
Number.
Description Transcript Page Transcript Page between Pottstown Memorial Medical Center and Applicant PECO Ex. 44 Letter of Agreement 9772 9773 dated April 2, 1984 between Linfield Fire Company and Applicant PECO Ex. 45 Letter of Agreement 9772 9773 dated April 2, 1984 between Limerick Fire Company and Applicant PECO Ex. 46 Applicant's Analy-10173 10220 sis of Minimum Staffing Require-ments for NRC Licensees for Nuclear Power-Plant Emergencies as re-quired under NUREG-0654, Table B-1 Limerick Ecology Action LEA Ex. 1 Compilation of 10283 Attachment P's from Draft #5 of Municipal RERP's regarding service by Goodwill Ambulance f
Staff Staff Ex. 6 NUREG-0911 6137 6138 i
" Safety Evalu-(Bound in ation Report ff.'6138) l Related to the Operation of Limerick Generating Station," Sec-tion 2.2.2, August 1983.
Staff Ex. 7 Regulatory Guide 6150 6153 1.91-(Revision-
, - Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page
- 1), " Evaluations of Explosions Postulated to Occur on Trans-portation Routes Near Nuclear Power Plants,."
February 1978.
Staff Ex. 8 VFR Terminal Area 7104 Chart for the Philadelphia Area, 18th Edition, Sep-tember 2, 1983.
Staff Ex. 9 National Trans-7145 portation Safety Board Pipelines Accident Report.
No. NTSB-PAR-76-8, Los Angeles, California, cover pg. and fig. 3, June 16, 1976.
Staff Ex. 10 NUREG-0570, " Toxic 7145 Vapor Concentra-tions Control Room Following a Postulated Acciden-tal Release,"
June 1979.
Staff Ex. 11 Army Technical 7146 Manual, TM 5-1300,
" Structures to Resist the Effects of Accidental Explosions," TM 5-1300, cover pg.,
fig.4-4 and 4-12, June 1969.
Staff Ex. 12 National Trans-7147 portation Safety Board Pipeline Accident Report No.
NTSB-DAR-80-6.
Bayamon, Puerto.
-Rico, cover pg.,
summary pg. and pgs.~5,12, January 30, 1980.
wy-Exhibit-Identified at Admitted at Number Description Transcript Page Transcript Page Staff Ex. 13.U.S. Atomic-Energy 7147 Commission, "Meteoro-logy and Atomic Energy 1968,"
July 1968.
Staff Ex. 14 NUREG/CR-1748, 7148
" Hazards to Nuclear Power Plants from Nearby Accidents Including Hazardous Materials - Pre-liminary Assess-
. ment," Chemical Engineering,. cover page and pgs. F-2, F-4, F-8 and F-11, Undated.
Staff Ex. 15 " Unconfined-Vapor 7148 Cloud Explosions,"
V.C. Marshall, June 14, 1982.
Staff Ex. 16 " Conditions of 7149 External Loading of Nuclear Power Plant Structures by Vapor Cloud Explosions and Design Require-ments," W. Geiger, Undated.
Staff Ex. 17 " Transactions of 7151 the 4th Interna-tional Conference on Structural Mechanics in Reactor Tech-nology," August 19, 1977.
Staff Ex. 18 Department of 7151 Transportation,
" Explosions Hazards Associated tri th Spills of Large Quantities of Hazardous Materials Phase II," Report No.
CG-D-85-77,'C.D. Lind and J.C. Whitson, November 1977.
b-
. o. '
Exhibit' Identified at Admitted at Number.
Description Transcript Page Transcript Page Staff Ex. 19 NRC Testimony 7152 of Jacques B.J.
Read Relating to Safety Implica-tions of the 4
Natural Gas Pipelines which Passes by the Hartsville Site, In the Matter of Tennessee Valley Authority (Harts-ville Nuclear Plants Units lA, 2A, 1B, and 2B),
Undated.
Staff Ex. 20 Army Technical 9050 Manual, TM 5-1300, (Bound in ff. 9055)
" Structures to Re-sist the Effects of Accidental Explosions,"
dover page and figures 4-3, 4-4, 4-5, 4-6, 4-7 and 4-12, June 1969.
Staff Ex. 21 One page graph, 9051 9054
" Limerick Peak (Bound in Positive Reflected ff. 9055)
Overpressure and Positive Phase Pulse Time Due to 56 Tons of TNT,"
Undated.'
Staff Ex. 22 U.S. Atomic Energy 9051 Commission, "The (Bound in Nuclear Weapons,".
ff. 9055)
Effects of Samuel Gladstone, Editor, cover
_page and pgs. 147 and 151, April 1962.
Staff'Ex. 23 Table I,
" Summary 9051 9055 of Accidental (Bound in Explosion ff. 9055)
Pressures," Undated.
Sfaff Ex. 24 Figure 1 " Selection 9052 of Critical Element (Bound in for Purpose of.
ff.'9055)'
f
6: '
' Exhibit Identified at Admitted at Number
-Description Transcript Page Transcript Page Analysis and Design,"
February 8, 1984.
Staff Ex. 25 Figure 2, " Typical 9052 Load Deformation Curve Idealized Elastic-Plastic Sy-stem," February
-13, 1984.
J-Staff Ex. 26 1979 Supplement 9053
" Code Require-(Bound in ments for Nuclear ff. 9055)
~
Safety Related Concrete Structures (ACI 349-76) and Commentary on Code Requirements for Nuclear Safety Concrete Structures (ACI 349-76), Appendix C,
Undated.
Staff Ex. 27 Memorandum from 9071 9073 Norman D. Romney, (Bound in Structural ff. 9073)
Engineer, NRC, to George Lear, Chief, Structural and Geotechnical..
Engineer Branch, NRC, " Limerick Conference Call Between NRC Staff, Bechtel Corpora-tion and Phila-delphia Electric company," March 13, 1984.
Staff Ex. 28' Regulatory Guide 9211 1.142 (Revision
- 1) " Safety-Related Concrete Structures for Nuclear-Power Plants (Other Than Reactor Vessels and Containments), "
October 1981.
-L
6
- 14 Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page FOE FOE Ex. 1 Nuclear 5542 Power, Armory (Rejected)
Lovins, pg. 161, Undated.
FOE Ex. 2 National Trans-5257 5258 portation Safety Board Pipeline Accident Report No. NTSB-PAR-73-2, Hearne, Texas.
August 1, 1973.
4 FOE Ex. 3 National Trans-5758 5759 portation Safety Board Pipeline Accident Report No. NTSB-PAR-75-3, Farmington, New Mexico, March 4
15, 1974.
FOE Ex. 4 Transactions of the 5768 ASME'" Decompression (Rejected) of Gas Pipelines During Longitudinal Ductile Fractures,"
G.G. King, March 1979.
4 FOE Ex. 10 Journal of the Soil 8881 Mechanics and Founda-tion Division,
" Depth Prediction for Earth-Pene-j trating Projectiles" C. Wayne Young, May i
1969.
l-FOE Ex. 5 Figure 6-2,
'8979
" Structures i
to Resist-the
' Effects of Acciden-tal Explosions,"
Undated.
FOE Ex. 11
" Nuclear ~ Safety-9007 Related Concrete Structures, ACI-349-80," pg 349-83, Undated.
v
I
-1; Es-
- Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page FOE Ex. 9 LGS FSAR Table 9009 3.5-5,
" Railroad-
-Accident-Generated Missile Parameters,"
Undated.
FOE Ex. 6 Post Card Depicting 9253 Limerick Generating Station.
AWPP AWPP Ex. 1 The New Private 6949 Pilot, Published by Pan American Navigation Ser-vice, 8th Edition,
. Cover Page and Pages 53-54.
AWPP Ex. 2 Those Icy Fingers 7046 in Your Carburetor, Aviation Con-sumer Magazine, January 1, 1982.
4
R, 3
00thETED USNRC 34 JUN 11 p233 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
i
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I.
hereby certify that copies of
" Applicant's Proposed Findings of Fact and Conclusions of Law in the Form of a Partial Initial Decision Relating to LEA's Onsite Emergency Planning Contentions," dated June 8,
1984 in the captioned matter have been served upon the following by deposit in the United States mail this 8th day of June, 1984:
Lawrence Brenner, Esq. (2)
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing and Service Section Dr. Richard F. Cole Office of the Secretary Atomic Safety and U.S. Nuclear Regu-latory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Ann P. Hodgdon, Esq.
Counsel for NRC Staff Office
- Dr. Peter A. Morris of.the Executive Atomic Safety and Legal Director Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Hand Delivery
l 3 Atomic Safety and Licensing Angus Love, Esq.
Board. Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C.
7.0555 Robert J. Sugarman, Esq.
Sugarman, Denworth &
Philadelphia Electric Company Hellegers ATTN:
Edward G. Bauer, Jr.
16th Floor, Center Plaza Vice President &
101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Director, Pennsylvania Emergency Management Agency Mr. Frank R. Romano Basement, Transportation 61 Forest Avenue and Safety Building Ambler, Pennsylvania 19002 Harrisburg, PA 17120 Mr. Robert L. Anthony Martha W.
Bush, Esq.
Friends of the Earth of Kathryn S. Lewis, Esq.
the Delaware Valley City of Philadelphia 106 Vernon Lane, Box 186 Municipal Services Bldg.
Moylan, Pennsylvania 19065 15th and JFK Blvd.
Philadelphia, PA 19107 Limerick Ecology Action P.O. Box 761 762 Queen Street Spence W.
Perry, Esq.
Pottstown, PA 19464 Associate General Counsel Federal Emergency
- Charles W. Elliott, Esq.
Management Agency Brose and Postwistilo 500 C Street, S.W.,
Rm. 840 1101 Building Washington, DC 20472 lith & Northampton Streets Easton, PA 18042 Thomas Gerusky, Director Bureau of Radiation Zori G. Ferkin, Esq.
Protection Assistant Counsel Department of Environmental Commonwealth of Pennsylvania Resources Governor's Energy Council 5th Floor, Fulton Bank Bldg.
1625 N. Front Street Third and= Locust Streets Harrisburg, PA 17102 Harrisburg, PA 17120 Jay M. Gutierrez, Esq.
U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Federal Express E
D,
' James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Director Department of Emergency Services.
14 East Biddle Street West Chester, PA 19380 z
Robert M. Rader
l$ l tw T,-
00LMETEg U3hRC UNITED STATES OF AMERICA 14 J@( j i P2 43 NUCLEAR REGULATORY COMMISSION GFF G 07 S w[,COCKLIN 4 3 "
E In the Matter of
)
ERAncy
)
' Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
. CERTIFICATE OF SERVICE I
hereby.
certify that copies of
" Applicant's Proposed Findings of Fact and Conclusions of Law in the Form of a Partial Initial Decision Relating to LEA Contention I-42," dated June 8, 1984 in the captioned matter have been served upon the _ following by deposit in the United States mail this 8th day of June,- 1984:
- Lawrence Brenner, Esq. (2)
Atomic Safety and Licensing Atomic Safety and-Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission' Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing and Service Section
-
- Dr._ Richard F. Cole Office of the Secretary Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S.-Nuclear Regulatory-Washington, D.C.
20555 Commission Washington, D.C.
20555
- Ann P. Hodgdon, Esq.
Counsel for NRC Staff Office-
- Dr.-Peter A. Morris of the Executive Atomic Safety and
. Legal Director-Licensing Board
_U.S. Nuclear _ Regulatory
- U.S. Nuclear Regulatory Commission-Washington, D.C..
20555
. Washington, D.C.
20555 Commission
~
'
- LHand Delivery 4
4
.\\
f
5 Atomic Safety and Licensing Angus Love, Esq.
Board Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C.
20555 Robert J. Sugarman, Esq.
Sugarman, Denworth &
Philadelphia Electric Company Hellegers ATTN:
Edward G. Bauer, Jr.
16th Floor, Center Plaza Vice President &
101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Director, Pennsylvania Emergency Management Agency Mr. Frank R. Romano Basement, Transportation 61 Forest Avenue and Safety Building Ambler, Pennsylvania-19002 Harrisburg, PA 17120 Mr. Robert L. Anthony
- Martha W. Bush, Esq.
Friends of the Earth of Kathryn S. Lewis, Esq.
the Delaware Valley City of Philadelphia 106 Vernon Lane, Box 186 Municipal Services Bldg.
Moylan, Pennsylvania 19065 15th and JFK Blvd.
Philadelphia, PA 19107 Limerick Ecology Action P.O. Box 761 762 Queen Street Spence W. Perry, Esq.
Pottstown, PA 19464 Associate General Counsel Federal Emergency
- Charles W. Elliott, Esq.
Management Agency Brose and Postwistilo 500 C Street, S.W.,
Rm. 840 1101 Building Washington, DC 20472 lith & Northampton Streets Easton, PA 18042 Thomas Gerusky, Director Bureau of Radiation Zori G. Ferkin, Esq.
Protection Assistant Counsel Department of Environmental Commonwealth of Pennsylvania Resources Governor's Energy' Council 5th Floor, Fulton Bank Bldg.
1625 N. Front Street Third and Locust Streets l
Harrisburg, PA 17102 Harrisburg, PA 17120 Jay M. Gutierrez, Esq.
l U.S. Nuclear Regulatory l
Commission i
631 Park Avenue l
King of Prussia, PA 19406
- Federal Express
--m_
A
- V.3-James.Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Director Department of' Emergency
' Services 14 East Biddle Street West Chester, PA 19380 Nils N. Nichols
_