Text

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-322/84-46.Remaining Licensing Issues Should Be Resolved W/Nrr
	ML20126E494
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/30/1985
From:	Ebneter S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Leonard J; LONG ISLAND LIGHTING CO.
References
	NUDOCS 8506170098
	Download: ML20126E494 (4)
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MAY 3 01985

Docket No. 50-322

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Long Island Lighting Company

ATTN: Mr. John D. Leonard, Jr.

Vice President - Nuclear

P. O. Box 618

Shoreham Nuclear Power Station

Wading River, New York 11792

Gentlemen:

Subject: Inspection 50-322/84-46

This refers to your letter dated January 29, 1985, in response to our letter

dated December 21, 1984.

Thank you for informing us of the corrective and preventive actions documented

in your letter. A recent Region I inspection (50-322/85-23) followed up five

of the nineteen issues identified during the previous inspection (50-322/84-46),

including your corrective and preventive actions related to these issues. The

followup will be documented in our Inspection Report 50-322/85-23 which will be

transmitted under a separate cover letter. The remaining fourteen issues,

being licensing items, are being referred to the Office of Nuclear Reactor

Regulation (NRR) for resolution. You are urged to resolve these issues with

NRR and complete all related actions expenditiously. After your actions are

cor.plete, these items will be examined during a future inspection of your

licensed program.

Your cooperation with us is appreciated.

Sincerely,

Original Signed Byi

Jacque P.Durr

Stewart D. Ebneter, Director

Division of Reactor Safety

cc:

W. Steiger, Plant Manager

J. Smith, Manager, Nuclear Operations Support

R. Kubinak, Director, QA, Safety and Compliance

E. Youngling, Manager, Nuclear Engineering

Edward M. Barrett, Esquire

Jeffrey L. Futter, Esquire 8506170098 850530

PDR ADocM 05000322

Manager, QA Department 0 PDR

Shoreham Hearing Service List

Public Document Room (PDR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of New York

0FFICIAL RECORD COPY RL SHOREHAM 84-46 - 0001.0.0

05/07/85

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Director, DRSS

Director, DRS

J. Strosnider, Section Chief IB, DRP

B. Bordenick, ELD

R. Goddard, ELD

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SHOREHAM HEARING SERVICE LIST

ADDRESSES (just make labels the individuals are not listed in the ec's)

Gerald C. Crotty, Esquire Alan S. Rosenthal, Esquire

Ben Wiles, Esquire Chairman, Atomic Safety and Licensing

Counsel to the Governor Appeal Panel

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Executive Chamber U. S. Nuclear Regulatory Commission

State Capitol Washington, D. C. 20555

Albany, New York 12224 ,

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Mr. Jay Dunkleberger Fabian G. Palomino, Esquire

New York State Energy Office Suffolk County Attorney

Agency Building 2 Executive Chamber

Empire State Plaza State Capitol

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Albany, New York 12223 Albany, NY 12224

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Energy Research Group, Inc. Gary J. Edles, Esquire

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400-1 Totten Pond Road Atomic Safety and Licensing

Waltham, Massachusetts 02154 Appeal Panel

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U. S. Nuclear Regulatory Commission

Washington, O. C. 20555

W. Taylor Reveley, III, Esquire Howard A. Wilbur, Esquire

Hunton & Williams Atomic Safety and Licensing

Post Office Box 1535 , Appeal Panel

i Richmond, Virginia 23212 U. S. Nuclear Regulatory Commission

Washington, O. C. 20555

Honorable Peter Cohalan Robert Abrams, Esquire

Suffolk County Executive Peter Bienstock, Esquire

County Executive / Legislative Bldg. Department of Law

Veteran's Memorial Highway State of New York

Hauppauge, New York 11788 Room 46-14

Two World Trade Center

New York, New York 10047

Martin Bradley Ashare, Esquire

Suffolk County Attorney

H. Lee Dennison Building

Vetaran's Memorial Highway

Hauppauge, New York 11788

James B. Dougherty, Esquire

3045 Porter Street, N.W.

Washington, D.C. 20008

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donstructior. 4

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50-322

MHB Technical Associates Dr. Peter A. Morris

n San Jose, California95125

1723 Hamilton Avenue,

Administrative Judge

Suite

Atomic K & Licensing Board

Safety

U.S. Nuclear Regulatory Commission

Stephen Latham, Esquire Washington, D.C. 20555

John F. Shea, Esquire

Twomey, Latham & Shea

Post Office Box 398 Eleanor L. Frucci, Esquire "

33 West Second Street Attorney

Riverhead, New York 11901 Atomic Safety & Licensing Board Panel

U.S. Nuclear Regulatory Ccmmission

Jonathan D. Feinberg, Esquire Washington, D.C. 20555

New York State

Department of Public Service Leon Friedman, Esquire

Three Empire State Plaza Costigan, Hyman and Hyman, P.C.

Albany, New York 12223 120 Mineola Boulevard

Mineola, New York 11501

Ezra I. Bialik, Esquire

Assistant Attorney General

Environmental Protection Bureau

New York State Department of Law

2 World Trade Center

New York, New York 10047

Herbert H. Brown, Esquire Paul Sabatino, II, Attorney at Law

Lawrence Coe Lamnpher, Esquire Counsel to Legislature

Kirkpatrick, Lockhart, H.'1, Legislative Building '

Christopher & Phillips Veteran's Memorial Highway

1900 M Street, N.W. Hauppauge, New York 11788

Washington, D.C. 20036

Karla J. Letsche, Esquire

Kirkpatrick, Lockhart, Hill,

Christopher & Phillips

1900 M Street, N.W.

Washington, D.C. 20036

Lawrence Brenner, Esq. Administrative Judge

Atomic Safety & Licensing Board

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Dr. George A. Ferguson

Administrative Judge

School of Engineering

Howard University

2300 - 6th Street N.W.

Washington, D.C. 20059

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LONG ISLAND LIGHTING COMPANY

SHOREHAM NUCLEAR POWER STATION

P.O. BOX 618. NORTH COUNTRY ROAD * WADING RIVER. N.Y.11792

JOHN D. LEONARD, JR.

VICE PRISIDENT NUCLEAR OPERAflONS

January 29, 1985 SNRC-1141

Dr. Thomas E. Murley

Regional Administrator

Office of Inspection and Enforcement

Region I

U.S. Nuclear Regulatory Commission

631 Park Avenue

King of Prussia, PA 19406

Fire Protection

Shoreham Nuclear Power Station - Unit 1

Docket No. 50-322

Reference 1: Letter NRC (Thomas T. Martin) to LILCO (J . D.

Leonard) dated 12/21/84 forwarding Inspection

Report 84-46

Dear Dr. Murley:

The purpose of this letter is to respond to the Reference (1)

letter which forwarded the report of your Fire Protection

Inspection held during the week of December 3, 1984. As you are

aware, LILCO had verbally requerted and was granted an extension

to the requested fifteen day response period. This extension was

requested to provide LILCO with an opportunity to present its

position on various items contained in the report. As a result

of our meeting with the Staff on January 15, 1985, it was agreed

that LILCO would, within two weeks after the meeting, respond to

the deviations as requested in Appendix A to Reference 1, and

would also provide its position or status, as appropriate,

regarding the other unresolved items contained in the report.

This information is contained in Attachment 1 (Response to

Deviations) and Attachment 2 (Remaining Unresolved Items). In

addition, Attachment 3 provides LILCO's position regarding the

issue of automatic suppression for areas of cable tray

concentration.

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Should you have any questions, please contact this office.

Very truly you s, ,

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\Leonard,

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Vic President-Nuhea Operations

RWG:ck

Attachments:

1. Response to Deviations

2. Unresolved Items

3. Cable Tray concentrations

4. Response to GL 81-12 Spurious Signals HighfLow Pressure

Interfaces

5. Diesel Generator Breakers

cc: R. Caruso

P. Eselgroth

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AFFIDAVIT

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STATE OF NEW YORK )

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COUNTY OF SUFFOLK )

JOHN D. LEONARD, Jr., being duly sworn, deposes and says I am the

Vice President, Nuclear Operations for the Long Island Lighting

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Company. Attachment 1 to letter SNRC-ll41 provides our response

to Appendix A, Notice of Deviation, contained in NRC letter dated

December 21, 1984. I have read this response which was prepared

under my direction and dated January 29, 1985. The facts set

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forth in this response are based upon reports and information

provided to me by the employees, agents and representatives of

Long Island Lighting Company responsible for the activities

described in this response. I believe the facts set forth in '

this response are true.

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Jo n D. Leonard, Jr.

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. Sworn to before me this

E day of Jo.-o p 1985

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SNRC-ll41

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Response to Deviations

The identification letters used correspond to those used in

Appendix A of Inspection Report 84-46.

Deviation / Departure

A. The Fire Hazard Analysis Report (FHAR), Revision 1, dated

June 1982 (an enclosure to your letter to NRC dated August

6, 1982), Section 1, Paragraph E.1.a., describes the

licensee commitment to design the fire detector systems in

the Reactor Building in accordance with NFPA 72D/E. '

Contrary to the above, your design does not conform to NFPA

72D/E, in that the number of detectors per square foot of

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floor space has not been met; the maximum distance between

! individual detectors is exceeded (120 feet instead of 30

feet); and the location of detectors relative to ceilings

does not conform to NFPA 72D/E. (Unresolved Item 84-46-05)

Corrective Steps Which Have Been Taken >

As noted during the 1/15/85 meeting, placement of fire detectors

at Shoreham had been approved by American Nuclear Insurers (ANI)

in 1981. LILCO had, however, initiated an engineering review of

fire detectors by a qualified fire protection consultant to

assess compliance with the literal requirements of NFPA 72D/E

regarding placement and spacing of fire detectors. A draft

report has been issued and a final report is scheduled to be

issued documenting this review. In addition, LILCO has taken

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interim compensatory measures in the Reactor Building consisting

of hourly fire watch patrols.

Corrective Steps Which Will Be Taken

A physical walkdown of potential locations for additional detec-

tors to achieve literal NFPA 72E compliance has been initiated

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and a preliminary schedule for their installation has been

j developed. Departures from NFPA 72E requirements will be

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justified. In adding or relocating detectors, LILCO intends to

schedule work such that modifications are accomplished first in

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those radiation areas which provide the highest potential for

personnel exposure, in keeping with ALARA principles.

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The addition of detectors is a complex and time consuming task

which includes determination of suitable locations, for effective

operation and access for required maintenance and surveillance

activities. In addition, other aspects such as the routing and

installation of cable and the design and installation of seismic

supports must be addressed. Scaffolding and other installation

details (welding, grinding) demand a prudent approach to ensure

there is no potential for adversely affecting redundant trains of

plant equipment, thus constraining the number of areas which can

be worked at any one time. ;

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Date When Full Compliance Will Be Achieved

Initial design and installation planning has taken place for the

additional detectors. As stated previously, emphasis is being

placed on areas with high radiation zones and areas where

currently no detectors exist (Control Building corridor). This

overall ef fort requires the addition or relocation of about 300

detectors. LILCO expects to commence installation and relocation

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activities approximately the first week of February, 1985.

An ANI approved fire detection system exists throughout the

, Reactor Building. This has been supplemented by compensatory

measures prescribed in the Technical Specifications for inoper-

able fire detectors as described in letter SNRC-ll22. LILCO

believes that this system and the existing compensatory measures ,

provide an equivalent degree of protection such that compliance

r with GDC 3 is achieved.

A tabulation is attached dividing this effort into 3 phases and

showing the approximate number of detectors involved in each

phase.

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Phase I detectors will be installed by approximately June 1,

1985. Installation of detectors for Phases II and III is

targeted to be completed by December, 1985.

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'SNRC-ll41 - Attachm:nt 1

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Fire Detector Installation

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New Relocated Existing

Area Detectors Detector Detectors

Phase I

Reactor Building 62 2 17

(Elevation S', Elevation 175',

RWCU Area, Main Steam Line

Tunnel Area)

Control Building Corridors 8

and 9, Computer Room ,

Phase II

Remainder of Control Building 48 12 116

and Screenwell

Phase III

Remainder of Reactor Building 178 0 33

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SNRC-1141 - Attachment 1

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Deviation / Departure ,

B.- The FHAR, Revision 1, Section 1, Paragraph D.l.j., describes

the licensee commitment to provide fire doors having a fire

resistance rating at least equal to the required rating of

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the barriers in which the doors are located.

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Contra'ry to the above, the resistance rating of a signifi-

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cant number of fire doors in the plant is less than the

o' rating of fire barriers in which they are located in that

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the fire doors have been degraded due to their modifications ;

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9 for security reasons. (Unresolved item 84-46-07)

Corrective Steps Which Have Been Taken

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Prior to the NRC Inspection in December, LILCO had initiated an

Underwriter's Laboratory (U/L) fire door inspection'which

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identifiedH59 FHAR fire doors requiring repair. This work is ;

presently underway, and 13 doors are now repaired. In the *

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t interim, compensatory measures have been taken in accordance with .

the: provisions of the Technical Specifications, Section 3.7.8. !

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I Corrective Steps Which Will Be Taken !

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LILCO.will continue its effort _to repair the subject fire doors.

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It-is' anticipated that U/L reinspection and approval will be l

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sought.upon completion of the entire effort. It should be :

recognized 'that in order' to meet NRC regulatory requirements,

) - certain modifications were required to be made to the doors. An '

example of this is the addition of magnetic switches which

provide an indication of door closure. U/L is not expected to i

I. approve.this application. For these doors, LILCO will justify ;

! their acceptability for fire protection utilizing the following

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1) It is LILCO's position that a simply mounted magnetic ,

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switch of the type and size used at Shoreham will not

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2) Where welded' angle brackets have been utilized for l

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mounting of the switches, suitable. resistance of the

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-door is achieved if an automatic spray suppression l

system exists in close proximity to the door or an j

automatic gas suppression system exists in an adjoining ;

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Date When-Full Compliance Will Be Achieved

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The remainder of the FHAR fire doors are scheduled to be repaired

in April, 1985.

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Deviation / Departure

C. The FEAR, Revision 1, Section 1, Paragraph E.2.c., describes

the licensee co=nitment to separate the diesel and electric

fire pumps and their associated co=ponents by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire l

barrier.

Contrary to the above, the cables fro = the diesel fire pump

controller and day tank pumps are routed through the sa=e

fire areas as the electric fire pump, thereby not teeting

the required 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barrier separation. (Unresolved

item 84-46-08)

Corrective Steps Which Have Eeen Taken

LILCO has imple=ented an hourly fire watch patrol for the

electric fire pump room. In addition, engineering has been ,

initiated to relocate the subject cables to ensure cc=pliance

with the FRAR.

Corrective Steps Which Will Be Taken

As'noted above, the subject cables will be relocated to ensure

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compliance with the THAR.

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Date When Full Compliance Will Be Achieved

This codification will be corplete in April, 1985.

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SNRC-Il41 - Attechment 1

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Deviation / Departure

D. The FHAR, Revision 1, Section 1, Paragraph D.I.j., describes

the licensee's commitment to provide an adequately rated

fire damper where a ventilation duct penetrates a fire wall.

Contrary to the above, no fire damper is provided in the

ventilation duct penetrating the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months fire wall between

the HVAC and chiller rooms at elevation 44 feet.

(Unresolved item 84-46-09)

Corrective Steps Which Have Been Taken

LILCO has implemented the provisions of the Shoreham Technical

Specifications, Section 3.7.8 as an interim compensatory measure.

In addition, engineering has been completed to install a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

rated fire door in the opening between the HVAC Equipment Room

and the plenum located west of the Chiller Equipment Room.

Delivery of the door, which is the controlling factor for

completion of this fix, is being expedited.

Corrective Steps Which Will Be Taken

As noted above, LILCO will install a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated fire door.

This represents a suitable barrier between the HVAC Equipment

Room and the plenum to the west of the Chiller Room, thus

suitably inhibiting the propagation of fire from one of these

areas to the other. In addition, the FHAR will be revised to

depict this change.

Date When Full Compliance Will Be Achieved

This modification will be completed prior to exceeding 5% power.

An FHAR Revision will be submitted to the NRC by April 5, 1985.

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Deviation / Departure

E. The FHAR, Revision 1, Section 1, Paragraph E.5., describes

the licensee commitment to design the Carbon Dioxide

Suppression Systems in accordance with NFPA 12.

Contrary to the above, the Acceptance Test results for such

systems in the Battery Rooms and Cable Tunnel indicate that

the design objective was not achieved in that the carbon

dioxide design density was not achieved at the highest test

point. (Unresolved item 84-46-10)

Corrective Steps Which Have Been Taken

As an interim compensatory measure, LILCO has implemented the

provisions of the Shoreham Technical Specifications, Section 3.7.7.3 for the Battery Rooms A and B.

The inability to meet the CO, design objective in these rooms at

the high elevation was suitably documented as a test exception,

and resolved satisfactorily by engineering with the approval of

ANI. The concentration of CO 3 achieved during the test was

determined to be acceptable f$r the following reasons:

1) The locations where the combustibles are located

experienced a CO, concentration meeting NFPA 12

requirements (greater than 50% density).

2) The fire loading at the high elevation test points in

the room is minimal as combustibles are concentrated at

the lower room heights (batteries and cable trays) .

Thus, the actual CO 2 level at these points, though

below the level required by NFPA 12, will provide

adequate fire protection.

For the Cable Tunnel, this has been judged to be acceptable on

the basis that no safety related equipment is located in this

area.

Corrective Steps Which Will Be Taken

The FHAR will be revised to reflect this exception.

Date When Full Compliance Will Be Achieved

An FHAR revision will be submitted by April 5, 1985.

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Deviation / Departure

F. The FHAR, Revision 1, Section 1, Paragraph E.5., describes

the licensee commitment to design the Carbon Dioxide

Suppression systems in accordance with NFPA 12. ;

Contrary to the above, the design criteria for such system

in the Computer Room is not met in that the fire detectors

which actuate the system are located above the suspended

ceiling and such location would prevent timely successful

actuation of the system if a fire occurred. (Unresolved

item 84-46-11)

Corrective Steps Which Have Been Taken

Engineering has been initiated to install two additional fire

detectors in the Computer Room below the false ceiling, in order

to achieve compliance with NFPA 12.

Corrective Steps Which Will Be Taken

As noted above, two additional detectors will be installed in the

Computer Room.

Date When Full Compliance Will Be Achieved

The addition of these detectors will involve the installation of

supports and other operations which will create an environment

unsuitable for computer use. Experience has shown that shutdown

of the computer and protective covering is necessary to prevent

impact on this equipment. In view of the need for availability

of the computer during low power testing and the fact that the

computer room does not have a safe shutdown function, it would be

most beneficial to schedule this modification during a " window"

so as to impart a minimum constraint on the low power test

schedule. In any event, this modification will be completed by

June 1, 1985.

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SNRC-1141 - Attachm:nt 1

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Deviation / Departure

G. The FHAR, Revision 1, Section 1, Paragraph D.1.j., describes

the licensee commitment to provide a minimum of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire

rating for ceiling / floor assemblies.

Contrary to the above, such protection was not maintained

for the structural steel which forms a part of the ceiling /

floor assemblies in the charcoal filter room and chiller

room in that their fireproofing protection ("pyrocrete"

coating) was found damaged at elevation 63 feet.

(Unresolved item 84-46-12)

Corrective Steps Which Have Been Taken

LILCO had implemented an hourly fire watch patrol in the above

areas of the Control Building. As stated at the January 15, 1985

meeting, LILCO has replaced or repaired damaged fire proofing

material. A reinspection of damaged areas was performed by LILCO

and subsequent inspection was performed by the Resident Inspector

on January 9, 1985.

Corrective Steps Which Will Be Taken

No further action is required on this specific item and the

hourly fire watch that had been initiated as a compensatory

measure has been terminated.

Performance of technical specification surveillance requirement 4.7.8.1 provides adequate assurance that fire proofed sections of

fire rated walls are suitably maintained or appropriate measures

taken.

Date When Full Compliance Will Be Achieved

Full compliance has been achieved.

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SNRC-1141 - Attach =cnt 1

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Deviation / Departure

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H. Supple =ent 1 to the Shoreha Safety Evaluation Report,

Section 9.5.4, docu=ents the licensee ec==it=ent to install

self-contained 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery pack e=ergency lighting in all -

areas of the plant which could be canned to bring the plant

to a safe cold shutdcwn. !

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Contrary to the above, such lighting in several such areas

in the Reactor Building was not installed. (see Inspection

Report 50-322/84-46, Paragraph 8.b. for exact locations). <

(Unresolved ite: 84-46-19)

Corrective Actions Which Have Been Taken

In letter SNRC-572, dated May 21, 1981, LILCO cc==itted to i

install 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery powered e=ergency lights in areas needed

for operation of safe shutdown equip =ent and in access and egress

routes thereto.

The equip =ent needed for safe shutdown in the event of loss of

habitability of the Control Roo= is described in the Shoreha:

, FSAR Section 7.5.1.4. This equip =ent is operable fro = the Re=ote

Shutdown Panel (RSP). Eight hour battery power lights have been

installed within the RSP roc = and in access and egress routes to

this roc =. Thus, LILCO =eets the cc==itment =ade in letter "

SNRC-572. <

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In the course of following plant procedures for re=cte shutdcwn, ;

certain precedural steps are taken which, while good practice in

te==s of minimizing potential plant perturbatic cr enhancing

future plant availability, are not needed and could be re=cred

from the procedure without affecting safe-shutdcwn. For exa=ple,

procedure SP 29.022.01, " Shutdown frc= Outside the Control Roc =

E=ergency Procedure", includes a step calling for verification of '

auto start of the Reacter Feed Pu=p Turbine (RFFT) turning gear.

This step requires an cperator to physically go to the RFFT; this

verification, however, is not required for safe shutdev- ci-4-

larly, the specific locations in the Reactor Building that were

noted as requiring operator action (unresolved ite= S4-46-19) are

for performance of actions such as verification of equipment

operation,syste= venting, or redundant instru=ent readcut. These

actions are not required for safe shutdown.

LILCO recognizes the importance of being able to deal with an

event such as loss of the Control Roc = and the desirability of

flexible operator capability and response. LILCO's design phil-

osephy relative to this issue has been defense in depth. The

following additional Shoreham plant features are pertinent.

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1) Eight hour battery packs are installed in the diesel

generator roc =s, energency switchgear rocns, Centrol

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Building and the Screenwell Building. (The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ;

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battery powered energency lights located in Diesel !

Generator Room 101 are being relocated to inprove '

illumination at the diesel control panel.)

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2) A 125 volt AC/DC energency lighting systen is located

j throughout the Reactor Building (this is not in lieu of

'the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery packs, but supplemental). ,

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l' 3) In addition to the lighting noted above, LILCO has ;

l installed two (2) rechargeable handlights in the l

Control Roc = and two (2) rechargeable handlights in the

remote shutdown panel area.

Actions Which Will Be Taken

As stated above, LILCO will relocate the battery powered e=er-

gency lights in Diesel Generator Roon 101. i

Date When Ccepliance Will Be Achieved

Full ec=pliance will be achieved prior to exceeding 51 power.

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SNRC-Il41

ATTACHHENT 2

Unresolved Items

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. The following provides the LILCO position or status on other

unresolved items in Inspection Report 84-46 that were not

discussed.in Attachment 1 to this letter,

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Unresolved Item 84-46-01 - Cable Separation Analysis Report

Per the agreement at the January 15, 1985 meeting, NRC Region I

' will be in communication with LILCO regarding the selection of

1

one or two zones of the Cable Separation Analysis Report and

subsequent (approximately 3 weeks later) inspection of

implementation of this analysis at the offices of Stone & Webster

Engineering Corporation, Boston.

! Unresolved Item 84-46-02 - Specific Locations of Components

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Procedures required for shutdown outside the control room have

i been revised to reflect the specific locations of various valves

! and components where local operation may be performed in the

course of. implementing this procedure.

-Unresolved Items 84-46-17, 84-46-03 and 84-46-04 - Generic Letter

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81-12, Spurious Signals, High/ Low Pressure Interface

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Although not strictly applicable to Shoreham a response to

Generic Letter 81-12 was presented to the NRC at the January 15,

1985 meeting, and LILCO's position was provided via handout for

staff review. This included information on high/ low pressure

interfaces and spurious signals. A copy of this handout is

included as Attachment 4.

Unresolved Item 84-46-04 - Diesel Generator Breakers

In addition to-spurious signals, unresolved-item 84-46-04

. involved the cooling requirements for the TDI diesel generators.

Information on this item was also presented at the January.15,

i 1985 meeting and a handout was provided for staff review. A. copy

of this handout is included as Attachment- 5.

Unresolved Item' 84-46-06 - ' Controls for RCIC/HPCI Fire

,! . Suppression

1

As noted during the. meeting held on January 15, 1985,. control

panelsfand associated control cables for deluge valves associated

with the RCIC/HPCI PumpEareas-are offset from the deluge

protected. areas. ' Power cables have been located such that while

not necessarily offset, they are not within the deluge protected

area. The syster, however, is. designed such that the deluge

} valve, once.open, will remain open until manually closed. The

Shoreham design and' installation, therefore, meets the

requirements of NFPA 15.

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SNRC-1141 - Attachment 2

Page 2

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Unresolved Item 84-46-13 - Fire Hazards Analysis for Corridors

and Manhole

A fire hazard analysis for Control Building corridors and

Electric Manhole #1 had not been included in the FHAR. A revised

FHAR will be submitted by April 5, 1985.

As stated at the January 15, 1985 meeting, an analysis has been

conducted for these areas. The Control Building corridors

contain no redundant safety-related cables required for safe

shutdown and no loss of redundant systems is possible upon a fire

in these areas. Similarly, a fire in Manhole #1 could not affect

redundant trains for which credit is taken in the shutdown

scenario associated with such a fire.

Although the results of the fire hazards analysis were favorable,

LILCO will nonetheless install fire detectors in Control Building

corridors 8 and 9. This will be accomplished by June 1, 1985.

Manhole #1 has existing fire detectors and a CO2 suppression

system.

Unresolved Item 84-46-14 - Single Header in the Reactor Building

Branch Technical Position 9.5-1 Appendix A requires that a single

failure not impair the fire suppression system. LILCO complies

with the BTP. With respect to the single header in the Reactor

Building, LILCO has utilized the guidance of MEB-1 in determining

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that the postulated pipe failure for this moderate energy system

would result in a crack producing a leakage of 165 gpm. Such a

failure would not impair the fire suppression system in the

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Reactor Building since each fire pump has a rated capacity of

2500 gpm.

The single header configuration utilized at Sho~reham was

inspected and reviewed by the NRC during the FSAR review process

(1979-1980). As a result of a staff question (FHAR Question 1),

a redundant feed to the Reactor Building was installed. With

this modification, the Staff accepted the design of Shoreham's

fire header for the Reactor Building.

A copy of drawing M-10661, Rev. 12, " Water Fire Protection

System" is enclosed, showing the water suppression system in the

Reactor Building. Shoreham Technical Specifications require that

if the fire suppression water system becomes inoperable, a backup

fire suppression water system must be established within 24

hours. From the enclosed figure it can be seen that certain

non-postulated circumferential breaks in the Reactor Building

could be isolated and backup suppression established via hose

reels or extinguishers. Depending on the location, certain other

non-postulated breaks could render the fire suppression system

temporarily inoperable. If backup suppression could not be

established, LILCO would bring the plant to the shutdown

condition.

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.SNRC-ll41 - Attachmsnt 2

.Pege 3

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The FSAR has always contained the single header configuration.

The NRC accepted this configuration and LILCO believes that a

backfit is not justified.

Unresolved item 84-46-15 - Structural Integrity of Cable Tray .

Penetrations Seals

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This item involves the concern that a cable tray penetration seal

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may be damaged by imposition of dynamic loads imposed on the seal

l Hby failure of " unprotected" cable tray support in the case of a '

fire.

There are a total of 35 cable tray supports adjacent to

penetrations'in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months areas. These supports are identified on

l Table 1. As indicated on Table 1, automatic fire suppression is

provided in the affected areas except for the screenwell and the

turbine building where a total of 8 supports are located. For

those areas where automatic fire suppression is provided, the

potential effect of fire loading on the supports is not ,

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considered for this analysis because the suppression system will

i minimize the severity of any fire that occurs, making damage to

supports.unlikely.

Where automatic fire suppression is not provided, the combustible

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materials which could contribute to a fire are primarily cables

and the fire loading is low, except for El. 37-6 in the turbine

}- building which has moderate fire loading. The actual fire

loading for these areas is quantified on Table 1. Considering

that cables are the only significant combustibles in the area, it

is extremely unlikely that a fire could develop which would

affect the cable tray supports. The cable jackets are made of

flame retardant and self ' extinguishing material and even the

worst-case cable fault can not establish a deep-seated fire in

the cable tray. Even an exposure fire in the area resulting from

one gallon (see FHAR question 1) of gasoline will not establish a

fire in the cable trays. If the fire takes place with the

gasoline container intact, the fire will last approximately 40-

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g minutes and the temperature in the region of the cable trays will

{ be only about 250*F. If the container spills, the fire will last

less than one minute and the temperature at the cable trays will

j be less than 750'F. Conceivably, the gasoline could be poured

j- into the cable-tray in the vicinity of the support and ignited.

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The resulting fire could establish a deep-seated fire in the

! cables themselves when the fire retardant materials are driven

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out after an extended burning period. Should this unlikely event

occur, it.has been determined that the temperature at which the-

! installed cables would burn is approximately ll50*F.-

This temperature is based on gesting performed by Factory Mutual l'

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Research Corporation for EPRI and-the United States Department

of Transportation. Cables installed at SNPS are of similar l

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SNRC-1141 - Attachment 2

Pcgn 4

materials as the majority of cable samples tested by Factory

Mutual. The temperatures recorded by Factory Mutual were the

surface temperatures at the cable during propagation of fire.

Actual temperature at the cable tray supports would likely be

less than the approximate ll50'F measured during testing.

Without regard for thermal lag and assuming the cable tray

support is exposed to that temperature for the duration of the

fire, the support will not fail. At 1150'F, the strength of

structural steel is approximagely 50 percent of the yield

strength at room temperature

Analysis of the cable tray supports show that the stresses due to

deadweight of the tray are within allowable limits at 1150*F.

Therefore, no additional protection of the cable tray supports in

the subject areas is required.

1. EPRI NP-1200, Categorization of Cable Flammability Table

5.1, Page 5-2

t 2n Steel _ Design Manual, U.S. Steel, January 1981.

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TABLE 1

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AUTOMATIC

PENETRATION FIRE

NUMBER SUPPORT LOCATION SUPPRESSION FIRE LOAD

1 Scrr:enwell No 30,538 BTU /ft

SW 104 ( 4 0.5 hrs)

Screenwell No Same

SW 105

2 Emergency Switchgear Yes Not Applicable

Room 101