ML20094G563
| ML20094G563 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/03/1984 |
| From: | Rigert J, Stergakos E LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20094G527 | List: |
| References | |
| OL-3, NUDOCS 8408130359 | |
| Download: ML20094G563 (8) | |
Text
d RELATED C0;(WESPONDENGQ ST LILCO, August 3, 1984
.o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- Q' 'ED Before the Atomic Safety and Licensing Board In the Matter of
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) Docket No. 50-322-OL-3
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LONG ISLA*4D LIGHTING COMPANY f,TQu
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(Shoreham Nuclear Power Station, )
Unit 1)
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' AFFIDAVIT OF ELIAS P.
STERGAKOS AND JOHN A. RIGERT ELIAS P. STERGAKOS and JOHN A. RIGERT, being duly sworn, depose and say as follows:
1.
[Stergakos only]
My name is Elias P.
Stergakos.
I am employed by the Long Island Lighting Company as Manager of the Radiation Protection Division; I report directly to the Manager of Nuclear Engineering Department.
I have the overall responsibility for the Corporate overview and technical direction of all aspects of radiological protection and the design of radwaste systems.
My business address is Long Island Lighting Company, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, 11792.
2.
[Rigert only]
My name is John A. Rigert.
I am employed by Long Island Lighting Company as Manager, Nuclear Systems Engineering Division of the Nuclear Engineering Department.
My business address is Long Island Lighting Company, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, 11792.
[Both affiants declare Paragraphs 3 through 9, as follows:]
8408130359 840803 gDRADOCK 05000322 PDR e
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.: 3.
We make this affidavit in response to the July 24, 1984
" Memorandum and Order Determining that a Serious Safety Matter Exists" of the NRC Licensing Board in the Shoreham emergency planning hearings.
The purpose of this Affidavit is to provide support for the proposition that 24 or more hours after initiation of the descent to cold shutdown from full power following normal operating procedures -- a process which takes less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -- there is no postulated abnormal event that could result in radiological consequences in excess of EPA's Protective Action Guidelines of 1 rem to the whole body and 5 rem to the thyroid.
This conclusion is based upon a review of the events described in Chapter 15 of the Shoreham FSAR.
The EPA PAGs have been utilized in NRC licensing proceedings to help determine the need for off-site radiological. emergency response capability.
4.
Chapter 15 of the Shoreham FSAR provides the results of analyses for the spectrum of accident and transient events that must be accommodated by the Shoreham plant to demonstrate compli-ance with the NRC's regulations.
This portion of the safety analysis is performed to evaluate the ability of the plant to operate without undue risk to the health and safety of the public.
The Shoreham FSAR was submitted to the NRC Staff for its review and was approved in the Staff's Safety Evaluation Report for Shoreham (NUREG-0420).
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5.
A number'of the Chapter 15 events need no longer be E
postulated because of the different plant config tration and system lineup under. cold shutdown versus operating conditions.
In particular,fthe MSIVs would be closed; the reactor would be fully depressurized; and only low level decay. heat would be produced.
As'a result of these plant conditions, even events which are theoretically possible are of little concern since they are unlikely to occur.
Should they nonetheless occur, the available time for automatic or manual mitigation of the event would be greatly increased; the capacity requirements of the mitigation systems would be greatly reduced; and the radioactive inventory of the core and plant systems would be reduced thus reducing the I
potential radiological consequences.
6.
The review of the Chapter 15 analysis revealed that of the 38 accident or transient events addressed in Chapter 15, 21 of the events could not occur physically during cold shutdown because of the operating conditions of the plant.
An additional 14 events could physically occur, but the offsite. radiological consequences would be inconsequential or non-existent.
The remaining 3 events are possible at cold shutdown but have offsite radiological consequences below the PAG limits.
One of the 21 events which could not occur during cold shutdown could, however, occur during f-
~ the refueling mode.
This event is the fuel handling accident that l
is discussed separately in Paragraph 9 below.
l identifies the category into which each Chapter 15 event falls.
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7.
Of the four events which may produce an offsite radiolog-ical effect three produce doses which are at least an order of magnitude below the PAG limits even at full power operations.
Event 29 represents occasional miscellaneous spills and leaks which may occur outside the primary containment.
The offsite consequences are described in FSAR $$ 11.2 and 11.3 and are trivial (approximately 0.001 rem / year).
Event 31 is postulated to occur due to the failure of one of the off-gas system charcoal absorber tanks during system operation.
The offsite consequences are described in FSAR $ 15.1.31 and the whole-body dose is approximately 0.02 rem.
The consequences during cold shutdown would be significantly reduced since the off-gas system would be out of service.
Event 32 entails the simultaneous failure of all liquid radwaste tanks as described in FSAR $ 11.2.3.4.2 and results in a whole-body dose of less than 0.0004 rem and a thyroid dose of less than 0.5 rem.
8.
Our review of Chapter 15, described above, confirms that no accident could occur during a cold shutdown condition which would result in any undue risk to the public health and safety.
9.
If fuel handling operations or other operations requiring access to the core are conducted following cold shutdown, a fuel handling accident (Event 36), not possible during cold shutdown, may occur.
The offsite consequences of this type of accident vary
-depending on fuel burnup and on the time that has passed since the attainment of cold shutdown.
As time passes following cold
,c n
r shutdown, all such consequences would diminish to levels below EPA PAG limits.
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' Elias P. S gakos John A. Riget
~
COUNTY OF SUFFOLK)
STATE OF NEW YORK)
Subscribed and sworn to before me this 7
day of UncVio t 1984.
0 f0kirl b
NOTARY PUBLIC
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My Commission Expires on OA d 50, /k8D~
CONNIE MARIA PARDU A0TARY PUBLIC, State of New Yort No. 524615810 Qualified in Suffolk Comt Commission Ezeiros Mfo4c) y30, /9@
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ATTACHMENT 1 FSAR CHAPTER 15 ACCIDENT CONSEQUENCES REACTOR AT COLD SHUTDOWN, 24 HOURS OR MORE AFTER INITIATION OF DESCENT FROM OPERATION AT 100% POWER Chapter 15 Event Event Category
'1.
Generator Load Rejection 2.
Turbine Trip 3.
Turbine Trip with Failure of Generator Breakers to Open 4.
MSIV Closure 5.
Pressure Regulator Failure - Open 6.
Pressure Regulator Failure - Closed 7.
Feedwater Controller Failure -
Maximum Demand 8.
Loss of Feedwater Heating 9.
Shutdown Cooling (RHR) Malfunction -
Decreasing Temperature 10.
Inadvertent HPCI Pump Start 11.
Continuous control Rod Withdrawal During Power Range Operation 12.
Continuous Rod Withdrawal During Reactor Startup 13.
Control Rod Removal Error During Refueling 14.
Fuel Assembly Insertion Error During Refueling
~ Event not possible.
Event possible but offsite radiological consequences are inconsequentiaqi or non-existent.
Event possible but consequence below PAG limits.
r E.p 15.
Off-Design Operational Transients Due to Inadvertent Loading of a Fuel Assembly into an Improper Location 16. - Inadvertent Loading and Operation of a Fuel Assembly in Improper Location 17.
Inadvertent Opening of a Safety / Relief Valve 18.
Loss of Feedwater Flow 19.
Loss of AC Power
- 20. _ Recirculation Pump Trip
- 21. ' Loss of Condenser Vacuum 22.
Recirculation Pump Seizure 23.
Recirculation Flow Control Failure -
With Decreasing Flow 24.
Recirculation Flow Control Failure -
With Increasing Flow -
25.
Abnormal Startup of Idle Recirculation Pump 26.
Core Coolant Temperature Increase 27.
Anticipated Transients Without SCRAM (ATWS) 28.
Cask Drop Accident 29.
Miscellaneous Small Releases Outside Primary Containment 30.
Off-Design Operational Transient as a Consequence of Instrument Line Failure 31.
Main Condenser Gas Treatment System Failure 32.
Liquid Radwaste Tank Rupture
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>,7 33.
Control Rod Drop Accident 34.
Pipe Breaks Inside the Primary Containment (Loss of Coolant Accident) 35.
Pipe Breaks Outside Primary Containment (Steam Line Break Accident) 36.
Fuel Handling Accident 1/
37.
Feedwater System Piping Break 38.
Failure of Air Ejector Lines 1/
Event not possible during cold shutdown.
If fuel handling operations were conducted following cold shutdown and an accident were to occur, the consequences at the Shoreham site boundary would be below PAG limits if sufficient time had passed following the attainment of cold shutdown.
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