ML20155H074

Discusses 860410 Meeting W/Util Re Open Items Concerning Fire Protection Program.Demonstration of Ability to Maintain Positive Control Over Automatic Depressurization Sys Valves in Compliance W/Ie Info Notice 85-009 Required

ML20155H074
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/29/1986
From:	Butler W Office of Nuclear Reactor Regulation
To:	Leonard J LONG ISLAND LIGHTING CO.
References
IEIN-85-009, IEIN-85-9, NUDOCS 8605120220
Download: ML20155H074 (6)

Text

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o oq'o. UNITED STATES l ' ' 3 ,, #\g NUCLEAR REGULATORY COMMISSION 5 WASHINGTON, D. C. 20555

%, ...../ APR 2 91986 Docket No. 50-322 Mr. John D. Leonard Vice President - Nuclear Operations Long Island Lighting Company Shoreham Nuclear Power Station P.O. Box 618 Wading River, NY 11792

Dear Mr. Leonard:

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SUBJECT:

FIRE PROTECTION - SHOREHAM NUCLEAR POWER STATION On April 10, 1986, representatives from your office met with members of the NRC staff to discuss certain open items related to the fire protection program at Shoreham. These items arose from the NRC fire protection inspection performed at Shoreham during the week of December 3, 1985, as reported in Inspection Report 50-322/84-86. You initially responded to the Inspection Report on January 29, 1985 (SNRC-1141), and further supplemented your response in letters dated June 3, 1985 (SNRC-1168), November 16, 1985 (SNRC-1211), December 9, 1985 (SNRC-1220),

and January 16, 1986 (SNRC-1222). At the time of the April 10, 1986 meeting, the Office of Nuclear Reactor Regulation had closed all open items in the Inspection Report for which it was responsible except Item 84-46-17. This closure was documented in Supplement 9 to NUREG-0420, dated December, 1985.

The only remaining open item concerns the alternative shutdown capability of the facility in the event of a fire in the control room. Specifically, it deals with the effects of fire-induced spurious signals on high/ low pressure system interfaces. The first system of concern to the staff is the Automatic Depressurization System (ADS) and the 8 safety / relief valves (S/RVs) associated with it. These S/RVs are controlled solely from the control room ind cannot be overridden from the remote shutdown panel, as the three remaining S/RVs can. The spurious opening of these valves would constitute an uncontrolled loss of coolant, which the staff finds unacceptable.

In SNRC-1222 and at the April 10, 1986 meeting, you stated your preference to allow the ADS system to remain in automatic operation in the event of a fire in the control room. You stated that the spurious operation of any S/RVs could be controlled automatically by the ADS or responded to manually by disabling the errant valve. This would involve dispatching an operator to the relay room below the control room to observe the valve indicating lights and the valve tailpipe temperatures. As justification for this plan of operation, you cited the GE Emergency Procedure Guidelines (EPG), which advise operators not to defeat the automatic operation of any ECCS system without having at least two positive indications that such operation is unwarranted.

8605120220 860429 PDR ADOCK 05000322 F PDR s

.o We have carefully considered your arguments and have determined that we cannot

accept your proposal to deal with this possible scenario on an ad hoc basis.

First, we have noted that Step RC/L-2 on page RC-3 of Revision 3 of the EPG specifically states an example of a case where an ECCS system (in fact, the i

ADS system) should be prevented from automatically operating. In the case where an operator can maintain a sufficient water level in the reactor, he should I

reset the AD5" timer (and thus effectively prevent it from operating automatically)

if the timer has started. This shows that the EPG recognizes that the maintenance of a safe, stable reactor condition sometimes take precedence over the auto-matic initiation of ECCS equipment. The staff believes that your application of certain of the EPGs to the case of a severe fire in the control room is inap-propriate, because such an event is outside the boundary of events which were considered in developing the EPGs. The staff believes that the overriding concern in the event of such a fire, besides extinguishing it and regaining control from the control room, should be to maintain the reactor in a safe,  !

stable condition. Without positive control of the ADS valves, this level of stability cannot be assured.

We, therefore, require that you demonstrate the ability to maintain positive control over the ADS valves in the event of a fire in the control room. If you believe that use of the ADS valves is essential to your safe shutdown ,

capability, you should install transfer switches (to isolate the control of the valves from the control room) and ADS instrumentation and controls in the remote shutdown panel. The new instrumentation and controls must comply with the guidelines identified in IE Information Notice 85-09. In addition, you must verify that the first action to be taken by an operator upon leaving the control room is to transfer control of the ADS from the control room to the remote location. This open item requires resolution prior to issuance of a full power license.

In a similar vein, the staff has noted that several check valves in the RHR and

! core spray systems have small bypass valves (1E11*M0V081A, B and IE21*M0V081A, B) whose spurious operation could result in the over-pressurization of low pressure systems outside containment, thus causing an unisolatable intersystem LOCA. We require that you take action to prevent a LOCA by this path. This item also ,

requires resolution prior to issuance of the full power license.

Finally, we noted during the April 10 meeting that Attachment 1 to SNRC-1222 was confusing in setting forth the location of the permissives for high/ low pressure interlocks. We, therefore, request that you provide us with a complete list of all such interlocks, describing their locations and describing whether a fire in any single fire area could disable all of the interlocks for any pressure isolation valve.

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3-If you have any questions regarding this letter, please contact Mr. Ralph Caruso *

(301-492-9475).

Sincerely, t I Walter R. Butler, Director-BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page  !

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O Mr. John D. Leonard, Jr. Shoreham Nuclear Power Station 1

Long Island Lighting Company (list 1)'

i cc:

Stephen 5. Latham, Esq. Gerald C. Crotty, Esq.

John F. Shea, III, Esq. Ben Wiles, Esq.

I Twomey, Latham & Shea Counsel to the Governor l Attorneys at Law Executive Chamber i Post Office Box 398 State Capitol

! 33 West Second Street Albany, New York 12224 Riverhead, New York 11901 i Herbert H.-Brown, Esq.

Alan S. Rosenthal, Esq., Chairman Lawrence Coe Lanpher, Esq.

Atomic Safety & Licensing Appeal Board Karla J. Letsche, Esq.

. U.S. Nuclear Regulatory Commission Kirkpatrick & Lockhart Washington, D.C. 20555 1900 M Street, NW - 8th Floor

Washington, D.C. 20036 W. Taylor Reveley, III, Esq.

i Hunton & Williams Dr. Monroe Schneider j 707 East Main Street North Shore Committee i Post Office Box 1535 Post Office Box 231 i Richmond, Virginia 23212 Wading River, New York 11792 j Howard A. Wilber Fabian G. Palomino, Esq.

! Atomic Safety & Licensing Appeal Board Special Counsel to the Governor i U.S. Nuclear Regulatory Commission Executive Chamber - State Capitol Washington, D.C. 20555 Albany, New York 12224

) Atomic Safety & Licensing Board Panel Anthony F. Earley, Jr. , Esq..

! U.S. Nuclear Regulatory Commission General Counsel

.I Washington, D.C. 20555 Long Island Lighting Company 175 East Old County Road Atomic Safety & Licensing Appeal Board Hicksville, New York 11801

. Panel U.S. Nuclear Regulatory Commission Mr. Lawrence Britt Washington, D.C. 20555 Shoreham Nuclear Power Station Post Office Box 618

! Gary J. Edles, Esq. Wading River, New York 11792 Atomic Safety & Licensing Appeal Board i U.S. Nuclear Regulatory Commission Martin Bradley Ashare, Esq.

j Washington, D.C. 20555 Suffolk County Attorney

! H. Lee Dennison-Building Richard M. Kessel Veteran's Memorial Highway  !

! Chairman & Executive Director Hauppauge, New York 11788 l l New York State Consumer Protection Board )

j Room 1725 Resident Inspector i

250 Broadway Shoreham NPS i I New York, New York 10007 U.S. Nuclear Regulatory Commission

, Post Office Box B -

1 Jonathan D. Feinberg, Esq. Rocky Point, New York 11778 l New York State Department of Public Service Regional Administrator, Region I

Three Empire State Plaza U.S. Nuclear Regulatory Commission i Albany, New York 12223 631 Ptrk Avenue i

Kino of Prussia, Pennsylvania 19406 I

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4 Shoreham (1) cc:

Robert Abrams, Esq. Mr. Francis J. Gluchowski Attorney General of the State Assistant Town Attorney of New York Town of Brookhaven ATTN: Peter Bienstock, Esq. Department of Law Department of Law 475 East Main Street State of New York Patchogue, New York 11772 Two World Trade Center Room 46-14 New York, New York 10047 Mr. William Steiger Plant Manager Shoreham Nuclear Power Station Post Office Box 628 Wading River, New York 11792 MHB Technical Associates 1723 Hamilton Aenue - Suite K San Jose, California 95125 Honorable Peter Cohalan Suffolk County Executive County Executive / Legislative Building Veteran's Memorial Highway Hauppauge, New York 11788 Mr. Jay Dunkleberger New York State Energy Office l Agency Building 2 Empire State Plaza Albany, New York 12223 Ms. Nora Bredes Shoreham Opponents Coalition 195 East Main Street Smithtown, New York 11787 Chris Nolin New York State Assembly Energy Committee 626 Legislative Office Building Albany, New York 12248 Peter S. Everett, Esq.

Hunton & Williams 2000 Pennsylvania Avenue, NW J

Washington, D.C. 20036 l

_,. * +w.r e-1, .- ,

4 If you have an (301-492-9475)y questions regarding this letter, please contact Mr. Ralph Caruso Sincerely, original signed by Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page DISTRIBUTION 4

Docket file: - " '

NRC PDR Local PDR

! PD#4 Reading RBernero Bordenick, OELD i

JPartlow EJordan BGrimes M0'Brien ACRS(10)

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PD M PD#4/D BWR BWPS RCa so:lb WButler Dnan WHodges JRid ely 04/g/86 04/$86 04/zg/86 04/p}/86 04/d/86 1

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