SNRC-1026, Forwards Supplemental Motion for Low Power OL
| ML20087L423 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/21/1984 |
| From: | Mccaffrey B LONG ISLAND LIGHTING CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| SNRC-1026, NUDOCS 8403270197 | |
| Download: ML20087L423 (1) | |
Text
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1 LONG ISLAND LIGHTING COMPANY i
dE%EP l SHOREHAM NUCLEAR POWER STATION g
$,,mn-umxa P.O. BOX 618, NORTH COUNTRY ROAD e WADtNO MlVER, N.Y.11792 i
March 21, 1984 SNRC-1026 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 LILCO's Supplement To Motion For Low Power Operating License Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322
Dear Mr. Denton:
Enclosed herewith is one copy of Long Island Lighting Company's SUPPLEMENT l'O MOTION FOR LOW POWER OPERATING LICENSE.
This Supplement, together with its four supporting affidavits, was served upon all parties to this proceeding on March 20, 1984.
A copy was also hand delivered to Mr. Ralph Caruso, the NRC Project Manager for Shoreham.
Ten additional copies are being express delivered to your attention as of the date of this letter.
LILCO is available, at your convenience, to provide any additional information or to meet with your Staff at any time in the interest of expediting your review of this filing.
Please do not hesitate to contact the undersigned at (516) 929-6111 to discuss this matter further.
Very truly yours,
/C 2 B.
R. McCaff y
Manager, Nuclear Compliance and Safety JPM:ck Attachment cc:
C. Petrone R.
Caruso R.
Starostecki, Region I
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8403270197 840321 DR ADOCK 05000322 gg PDR FC-893 5
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-Huxrow & WILLI Aus 707 EAST MAIN STREET P.o. Box 1535 24566.3 wAa NiNoro n. D. C.
Racuwown,VamonwrA 23212 m r wo.
NEw Yonx,NEw YoRx f o'a'c' a'" "* * ** '* * - 8 3 61 Los ANGELES, CALIFORNIA TELTPHONE 804-788 8200 RALEIGH. NoRTN CARoLIN A TWX 710 9 5 6 - 0 0 61 NcaFoLx,VeRolN A KN3xVf LLE, TEN N ESS EE.,
March 20, 1984 Lawrence Brenner, Esq.
Dr. Peter A. Morris Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Fourth Floor Fourth Floor East West Towers (North Tower)
East West Towers (North Tower) 4350 East-West Highway 4350 East-West Highway Bethesda, Maryland 20814,
Bethesda, Maryland 20814 Dr. George A. Ferguson Administrative Judge Atomic Safety and Licensing Board Panel School of Engineering Howard. University 2300 6th Street, N.W.
Washington, D.C.
20059 Gentlenen:-
l LILCO'hereby files today the enclosed Supplemental Motion for Low Power Operating License.
The supporting affidavits which accompany the motion have not been executed yet.
Signed copies will be served as soon as possible.
Sincerely, 9
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.u hony F Ear ey, J l
221/765 Enclosure cc:
Service List s
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LILCO, March 20, 1984
-CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of LILCO's Supplemental Motion for Low Power Operational License were served this date upon the following by first-class mail, postage prepaid, or by hand, as indicated by an asterisk.
Lawrence Brenner, Esq.*
Chairman Nunzio J.
Palladino*
Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel 1717 H Street, N.W.
U.S. Nuclear Regulatory-Wash'ington, D.C.
20555 Commission Fourth Floor Commissioner Victor Gilinsky*
East West Towers (North Tower)
U.S. Nuclear Regulatory 4350 East-West Highway Commission Bethesda, Maryland 20814 1717 H Street, N.W.
Washington, D.C.
20555 Dr. Peter A. Morris
- Administrative Judge Commissioner Thomas M. Roberts
- Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory _
1717 H Street, N.W.
Commission Washington, D.C.
20555 Fourth Floor East West Towers (North Tower)
Commissioner James K. Asselstine*
4350 East-West Highway U.S. Nuclear Regulatory Bethesda, Maryland 20814 Commission 1717 H Street, N.W.
Dr. George A. Ferguson*
Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Commissioner Frederick M. Bernthal*
Board Panel U.S. Nuclear Regulatory School ~of Engineering Commission Howard University 1717 H Street, N.W.
2300 6th Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20059 L
g r Atomic Safety and Licensing Mr. Jay Dunkleberger Appeal Board Panel New York State Energy Office U.S. Nuclear Regulatory Agency Building 2 Commission.
Empire State Plaza Washington, D.C.
20555 Albany, New York 12223 Secretary of the Commission Bernard M. Bordenick, Esq.*
U.S. Nuclear Regulatory David A. Repka, Esq.
Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Maryland National Bank Building Atomic Safety and Licensing 7735 Old Georgetown Road Board Panel Dethesda, Maryland 20814 U.S.. Nuclear Regulatory' Commission Stephen B. Latham, Esq.
Washington, D.C.
20555 Twomey, Latham & Shea 33 West Second Street Martin'Bradley Ashare,-Esq.
P. O. Box 398 Attn:
Patricia A. Dempsey, Esq.
Riverhead, New York 11901 County Attorney Suffolk County Department of Law Ralph Shapiro, Esq.
Veterans Memorial Highway Cammer and Shapiro, P.C.
Hauppauge, New York 11797 9 East 40th Street New York, New York 10016
-Herbert H.. Brown, Esq.*
Lawrence Coe Lanpher, Esq.
James B. Dougherty, Esq.
Karla J. Letsche, Esq.
3045 Porter Street Kirkpatrick, Lockhart, Hill',
Washington, D.C.
20008 Christopher & Phillips 8th Floor Howard L. Blau, Esq.
1900 M Street, N.W.
217 Newbridge Road Washington, D.C.
20036 Hicksville, New York 11801 Mr. Marc W. Goldsmith-Jonathan D. Feinberg, Esq.
Energy Research Group New York State 4001 Totten Pond Road Department of Public Service Waltham, Massachusetts 02154 Three Empire State Plaza Albany, New York 12223 MHB Technical Associates 1723 Hamilton Avenue
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' Suite K San Jose, California 95125 Y
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- f Llatn W r '_ k Anthony Fparl'sy, Jr.
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Hunton & Williams 707 East: Main Street
. Post Office Box 1535 Richmond, Virginia -23212 DATED:
March'20, 1984
.i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (OL)
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(Shoreham Nuclear Power Station,
)
Unit 1)
)
SUPPLEMENTAL MOTION FOR LOW POWER OPERATING LICENSE Hunton & Williams 707 East Main Street Richmond, Virginia 23212 March 20, 1984 9
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$7ioib k
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
'In the Matter of
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-LONG ISLAND LIGHTING COMPANY-
)
Docket No. 50-322 (OL)
)
(Shoreham Nuclear. Power Station,
)
Unit 1)
)
SUPPLEMENTAL MOTION FOR LOW POWER OPERATING LICENSE Hunton & Williams 707 East Main Street Richmond, Virginia 23212 March.20, 1984 j
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LILCO, March 20, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
SUPPLEMENTAL MOTION FOR LOW POWER OPERATING LICENSE I.
INTRODUCTION The Shoreham Nuclear Power Station represents both a huge commitment of economic resources and Long Island's only power plant'not dependent o'n foreign oil.
Thus, there are com-pelling reasons for the station's early operation.
Instead of being free to begin necessary and beneficial low power testing and training, however, Shoreham faces six to nine months of delay rooted in litigation concerning diesel generators.
This delay is unnecessary to assure the public health and safety for the activities authorized by a low power license.
~ LILCO filed its motion for a low power license on June 8,'1983.
In ruling on that motion, the Licensing Board re-solved favorably to LILCO all issues relevant to low power op-eration except for Suffolk County's then recently admitted diesel contention.
In the words of the Licensing Board:
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Even(though'we' resolve all contentions c
which are the subject of this Partial Initial Decision favorably to LILCO, at
.leastoinsofar as operation at levels up
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-to-five percent of rated power is con-cerned,--we.do not authorize the issuance of the license for fueljloading-and:
low-power operation'which LILCO has re-quested at.this time. HNo.such licence may be authorized until~such time as that portion:of Suffolk county's re-cently : admitted ~ emergency diesel genera-
. tor contention may be resolved in LILCO's favor, at least. insofar as nec-essary to' support a' finding of reason-able~ assurance ~that Shoreham can be op-erated'at-levels up to five percent of rated power without endangering the health.and safety-of the public.
E
'Long Island L'ighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-83-57,.18 NRC 445, 634-(1983).
-1
-Without; waiving any a'spect of the pending low power mo-
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, tion, LILCO now aupplements1that motion'to show that the pend-J
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'ing diesel issues-need not be resolved to support the granting of.a: low power.= license for Shoreham.
Specifically, LILCO re-
' quests prompt NRC approval for the following activities at Shoreham:
.(a):. Phase I: ~ fuel load and precriticality
- testing, (b); Phase.II:
cold criticality testing,
'(c)--
Phase III:
heatup and low power test'ng to rated pressure / temperature conditions
=(approximately 1%' rated power); and -.. - -. -. - -
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(d)
Phase IV:
low power testing (1-5% rated power).
These phases are distinct; each consists of a separate set of operations and tecting.
Tcgether, they include the full se-quence of activities associated with fuel loading and low power testing up-to 5% of rated power.
During Phases I and II, AC power and a fortiori diesel generators are not necessary to satisfy the Commission's regu-lations.
-Performance of these activities simply poses no dan-ger-to public health and safety.
For Phases III and IV, LILCO also meets the substantive requirements.of the NRC's regula-tions pertaining to AC power sources.
First, during these operations, Shoreham will have fully tested, though not fully litigated, TDI diesels available for operation.
Second, even assuming all three of these diesels fail to operate, LILCO will also have ample alternate sources of AC power available for Shoreham such that there will exist reasonable assurance of no undue risk to the public health and safety from the operation of the plant at power levels up to 5% rated power.
Against this background, the ongoing diesel generator litigation poses no obstacle to the early issuance of a low power license.
As a' practical matter, LILCO believes that whether Shoreham is entitled to such a license is a question that only >
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the Nuclear Regulatory Commisbion itself can decide.
The in-tensely political environment that now envelops Shoreham makes virtually certain that_the NRC's highest tribunal must act be-fore the plant will be allowed to-conduct any operations, even loading-fuel.. Recognition of this reality prompts LILCO to re-quest:
1.
That this Board promptly refer the pres-ent supplemental motion to the Commis-sion for decision, pursuant to 10 CFR $
2.718; 2.
That if the Board decides against-imme-diate referral, it then consider and de-cide this supplemental motion in an ex-pedited fashion and thereafter certify its-decision to the Commission, pursuant to 10 CFR S 2.730.
'II.
A LOW POWER LICENSE SHOULD BE AUTHORIZED The facts supporting this supplemental motion are pre-sented in the following attached' affidavits:
Affidavit of Jack A. Notaro and William E.
Gunther, Jr. (Notaro Affidavit);
. Affidavit of William G.
Schiffmacher (Schiffmacher Affidavit);
Affidavit of Dr. Glenn G.
Sherwood, Dr.
Atambir S.
Rao and Mr. Eugene C.
Eckert (Sherwood. Affidavit); and Affida'.it of William J. Museler (Museler Af-fidavit). __-.
n A.
Phase I:
Fuel Load and-Precriticality Testing Phase I includes. operations producing no risk whatever to.public health and safety.
The various activities, tests and training attendant to fuel loading and precriticality testing
-are' described'in the Notaro Affidavit at 11 6, 7.
In general, during initial core loading, 560 fuel bundles are placed in specified locations within the reactor vessel and tests are
-performed concerning water chemistry surveillance, control rod
. drive. stroke time and friction, installation, calibration and use of special startup neutron instrumentation, and core veri-fication instrument operability.
In addition to the check of systems reliability provided by these-tests, valuable experi-
-ence is gained-by personnel assigned to the Reactor Engineering Section, Radiochemistry Section, Operating Section, Maintenance Section, and Instrumentation and Control Sectiota.
Once fuel is in the vessel, core verification must be conducted prior to the reactor's going critical.
Notaro Affi-davit at 1 7.
At this stage, instrumentation and control tech-nicians verify and calibrate 31 local power range monitor in-struments.
Health physics technicians survey various locations in the plant to-determine background radiation levels within
.the plant with fuel in the vessel.
Oper.stors test control rod s-y
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drive scram times.
And, operation of the recirculating pumps
'with fuel in the vessel is conducted to-determine core internal pressure drops-and to verify system performance.
Again, valu-able experience is obtained by the plant personnel.
For these precriticality activities, diesel generators fare not necessary to satisfy the Commission's regulations.
The necessity for diesel generators.deri"es from GDC 17, which states-in pertinent part:
An onsite electric power system.
shall be provided.
to provide suf-ficient capacity and capability to as-sure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure bottndary are not exceeded as a result of antici-pated operational occurrences and.(2) the core is cooled and containment in-tegrity and other vital functions are maintained in the event of postulated accidents.
During fuel loading and precriticality testing, no AC
-power is required in order.to meet these requirements.
This conclusion is confirtaed by a review of FSAR Chapter 15's man-dated safety analysis.
During Phase I activities, most of the anticipated operational occurrences and postulated accidents covered in Chapter 15 simply could not occur.
Sherwood
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4 Affidavit at 11 8-10.
Even those events that are possible would have no impact on.public health and safety, if they were in! fact to occur.
Id. at 11 11-13.
Thus, fuel design limits and design conditions of the reactor coolant pressure boundary 1
.would not be exceeded and core cooling would be maintained even assuming anticipated. operational occurrences, postulated acci-dents and the absence of diesel generators.1/
Id. at 1 13.
The license LILCO seeks with respect to fuel load and precriticality testing is identical to the low power approval recently-authorized by the Commission for the Diablo Canyon plant.
As the Commission noted:
4
' The risk to public health and safe-ty from fuel loading and pre-criticality testing is extremely low since no self-sustaining nuclear = chain reaction will take place under the terms of the li-cense.and therefore no radioactive fis-sion products will be produced.
p Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2), CLI-83-27, 18 NRC slip op. at 5 (Nov.
8,-1983).
The Commission's conclusion-that the risks are ex-tremely low for operation'of a reactor with fuel loaded, but no 1/
Containment integrity is not an applicable concept during fuel loading and precriticality testing because these activi-ties are conducted with the head removed from the vessel. _
I n
. self-sustaining chain reaction, is echoed in the attached
- Sherwood Affidavit.
No fission products or decay heat will be produced during precriticality operations at Shoreham.
Sherwood Affidavit at.11 7, 11.
Accordingly, these activities present no risk at all to the public health and safety, even assuming the absence of any AC power.
Also, the Commission recognized that there was no need -
for hearings concerning Pacific Gas and Electric's request to load fuel'and conduct precriticality testing because these ac-tivities-presented.no significant safety issues:
Since there are no significant safety issues material to fuel loading and pre-criticality testing, and there will be no prejudice to future Commis-sion decisions, a consideration of the equities f avors denial of the. Joint In-tervenors' request to defer the decision on the licensee's request for rein-statement and extension of-the license to load fuel and conduct pre-criticality testing pending the holding of a hearing-on the licensee's request.
-Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant,. Units 1 and 2), CLI-83-27, 18 NRC slip op. at 6 (Nov.
8, 1983).
L r
I The rationale for.the' Commission's grant of a license s
to Diablo Canyon applies with even greater force with respect tio Shoreham.
Quality assurance litigation calling into ques-tion many-aspects of the Diablo Canyon design was ongoing at the time of the Commission's action.
Shoreham, however, al-ready has a massive, favorable Partial Initial Decision on all safety-issues except those concerning its existing diesel gen-erators.
See generally Long' Island Lighting Co. (Shoreham Nu-clear Power Station, Unit 1), LBP-83-57, 18 NRC 445 (1983)
(opinion), and unpublished Board' Findings of Fact and Ap-pendices.
Since there is no" requirement for diesels during Phase I, the acsurance of no risk to the public health and safety from Phase I activities is even greater at Shoreham than at Diablo Canyon because all quality assurance issues at Shoreham have been favorably resolved.
B.
Phase II:
Cold Criticality Testing Phasc II also includes operations that entail virtually no risk to the public because, in the event of the limiting de -
sign basis accident, months would be available to restore cool-ing water to the core' This phase achieves reactor criticality
.at extremely low power levels (.0001% to.001%).
During this phase, the effectiveness of each of the 137 control rods in controlling reactivity is measured.
Reactor operators will be
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1 able to perform reactivity control manipulations.
And, core cleanliness verification and installation of vessel internals occurs.
Along the way, the plant staff places in service, op-erates,; tests and, maintains 41-reactor and support systems.
Overall, approximately 5,000 manhours of valuable training and experience take place during Phases I and II cf low power testing.
Notaro Affidavit at 1 11.
Significantly,
. LILCO's Phase I and II-program is designed to provide Shoreham's operating personnel with more BWR experience and training than would result from a conventional program.
Id. at 11 7-9, 11, 24.
In Phase II,~like Phase I, no emergency AC power (including _ diesels) is required to meet the NRC's regulations
.and protect the public health and-safety.
Again, this is dem-onstrated by'the analysis in the Sherwood Affidavit.
The ex-tremely low power levels achieved during cold criticality testing; result in such insignificant amounts of decay heat that essentially' unlimited time -- months -- would be available to restore cooling to the core, in.the event of even a limiting
' design basis accident.2/
Moreover, under the plant conditions 2/
Although virtually no power would be needed if a Chapter
'15~ event were to occur, LILCO will take steps to ensure that j>
.the' plant-is shut down during specified circumstances that might-have an impact on AC power availability.
See Museler Af-
'fidavit at-1 7-9,- 11.
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present in Phase II, many events analyzed in Chapter 15 simply could not occur or would be very unlikely when compared to the situation during normal operations.
As in precriticality testing, even the possible Chapter 15 events would have no im-pact on public health and safety regardless of the diesels' availability. 'Thus, the risk to the public is virtually nonexistent.
It follcws that the onsite power provisions of GDC 17, requiring sufficient capacity to assure the prescribed safety functions set out in the criterion, are met because no emergency AC power (onsite or offsite) is-needed.
Given the absence of any need for emergency AC power during Phase II, the Diablo Canyon rationale as discussed above
. applies with equal force here.
Consistent with the ruling in
- Diablo Canyon, LILCO is entitled forthwith to approval for Phase II activities at Shoreham.
C.
Phases III and IV:
Heatup and Low Power Testing to Rated Pressure / Temperature Conditions (Approximately 1% Rated Power) and Low Power Testing (1% - 5% Rated Power)
During these phases of low. power testing, reactor
-heatup and pressurization are achieved, and the power level is taken in progressive steps first to 1% of rated power and then from 1% to 5% of rated power.
During the course of these ac-tivities, the plant staff will be required to place in service, l Q.
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operate, test and maintain the 54 plant systems identified in paragraph 24 of the Notaro Affidavit.
The operation of these systems and the other activities performed during these phases of-39w power testing provide extremely valuable training and hands-on experience for Shoreham's personnel.
These activities include rod withdrawal sequences, testing and calibration of neutron monitoring instrumentation, gathering information con-t cerning initial heatup and operation of nuclear steam supply and power generation systems, initial operation of control sys-tems,-and much other work that cannot be undertaken prior to heatup of the plant to rated temperatures and pressures.
Notaro Affidavit at 11 12-24.
In light of LILCO's intention to perform expanded training throughcut low power testing, Messrs.
Notaro and Gunther estimate that approximately 6,000 manhours of. experience-will be gained during Phases III and IV.
Id. at 1 24.
Operation of the plant during Phases III and IV poses far less risk to the public health and safety than does op-eration of the plant at_100% rated power.
This reduced risk is attributable to three factors.
First, operation at low power L
results in a small inventory of fission products in the core compared to full power operation.
This low fission product in-ventory substantially reduces the amount of decay heat present l _
in tha. core following shutdown and substantially reduces the radioactivity in the core that could be released upon fuel failure.
Sherwood Affidavit at V 26.
Second, operation of the plant at low power gives the operator. increased time to take appropriate manual actions.
This minimizes the severity of transients and reduces the likelihood that there will be any need for automatic operation of the plant's safety systems.
Id. at 1 27.
And third, the capac ty requirements for miti-
~ gating syrtems (such as cooling and ventilation systems) are substantially reduced because of the low power levels.
Thi3 reduces the amount of plant equipment needed to mitigate events (i.e., fewer pumps) and, as a result, reduces AC power require-ments.3/
Id. at 1 28.
Chapter 15 af Shoreham's FSAR provides the results of analyses-for the spectrum of transient and accident events that must be accommodated by the plant to meet NRC regulations.
Sherwood J.ffidavit at 1 4.
A review of the 38 Chapter 15 events shows that three of them cannot occur during Phases III 3/
Decisions in other contexts.have recognized that these three factors substantially reduce the risk attributable to low power operation.
See Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), LBP-82-3, 15
-NRC 61, 188-89 (1982); see also Duquesne Light Co (Beaver Val-ley Power Station, Unit No. 1), LBP-76-3, 3 NRC 44, 66 (1976);
46 Fed.~ Reg. 61132-33 (1981); 46 Fed. Reg. 47764-65 (1981).
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and IV.
Id. at 1 24.
Of the remaining 35 events, 31 do not require an assumption of the loss of offsite AC power concur-rent with the event.3/
Thus, these Chapter 15 results are not affected by the status of the diesel generators since they are not required to mitigate these events.
- 11. at 25.
For the four Chapter 15 events that do assume a loss of normal offsite AC power, there is reasonable assurance that emergency AC power will be available at Shoreham to accomplish the required safety functions.
First, LILCO will have avail-able for operation fully tested TDI diesel generators through-out Phases III and IV of the low power testing program.
Museler Affidavit at 1 11.
To ensure the operability of the TDI diesels during Phases III and IV, LILCO will meet all of the applicable requirements of the Shoreham Technical Specifi-cations.
The Technical Specifications require that the op-erability of AC power sources be periodically demonstrated in the event a diesel or offsite power source is unavailable.
For example, if one diesel or one offsite power circuit is unavailable, LILCO must demonstrate that the other two diesels are operable by starting them within one hour and then once 4/
This assumption would be particularly inappropriate for Shoreham because of the ready availability of alternative AC power sources, both onsite and offsite.
See Schiffmacher Affi-davit.
o
.every eight hours thereafter.
Id.
If the inoperable diesel or
.'offsite circuit is not restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the plant must be shut down.
Id.
The Technical Specifications also include periodic surveillance testing requirements for the diesels to ensure their operability.
Id.
Thus, notwithstanding the ongoing diesel generator litigation, Shoreham will in fact have available diesels that have demonstrated their ability to oper-
-ate in the rigorous pre-operational test program.
This op-erability will be maintained as required by the Technical Spec-ifications.
Second, even in a world of conservative assumptions, it is simply not credible that all AC power to Shoreham will be lost.
This is apparent from the following six part analysis.
1.
At the outset, a LILCO system-wide blackout is not likely.
LILCO's bulk power transmission system has a generating capacity of 3,721 megawatts, achieved through a com-bination of various types of generating units.
As the
.Schiffmacher Affidavit indicates:
Subsequent to the Northeast Blackout of 1965, LILCO implemented substantial measures to increase reliability of its system.
These included installation of blackstart gas tur-bines at each of its major generating sta-tions and implementation of automatic.
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underfrequency load shedding procedures.
In the'18 years since, there has been no loss of the entire LILCO grid.
There has only been one incident in which LILCO has lost any ap-preciable portion of its bulk power transmis-sion system.
That one incident affected!
LILCO's system east of Holbrook.
Despite the lack of any procedures then in effect mandating priority emphasis on restoring power to Shoreham, power was restored ~to the entire Shoreham area within one hour and four minutes.
With the priority procedures now in
.effect to restore power to Shoreham and the availability of_several independent deadline blackstart gas turbines, all of which are de-scribed below, it has been demonstrated by exercises that today power can be restored to Shoreham in a matter of minutes.
Schiffmacher Affidavit at 1 10 (footnote omitted).
In short, both the nature of the available facilities and their history of reliability make a system-wide blackout unlikely.
- Moreover, LILCO's 138107 and 69 KV high voltage transmission network is tied to the New York Power Pool and the New England Power Grid.
Thus, in the event LILCO suffered an internal power deficiency, an additional 1,090 MW would be available to LILCO through
,three interconnections with the New York Power Pool and another 285 MW of power could flow through the tie with the New England Power Grid.
Id. at-11 7, 9.
2.
The configuration of LILCO's transmission circuits
. feeding _-Shoreham further assures the availability of power to h-l
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the site..Shoreham is: served by multiple circuits over differ-ent rights-of-way, as wellins lui undergroun'd line.
Four 138 KV transmission circuits run to Shoreham along.two separate and independent rights-of-way. ~ Additionally, three 69 KV circuits i
enter:the-. Wildwood' Substation, approximately one mile south of Shoreham'and, from.there,.a-separate 69 KV circuit enters the site.
These transmission lines, like the entire LILCO trans-
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. mission network, are designed to withstand winds of at least 100.to 130 miles per hour.
Schiffmacher Affidavit at 11 12-14.
'Moreover,:the 69 KV circuit from the 69 KV substation to the
? reserve ' station service transformer is underground and there-
-fore ~less susceptible to damage.
Id. at 1 13.
3.
- That : LILCO'~s system will provide power to Shoreham is further assured by a> number of independent gas turbines located cat <various_ places and' designed to-start during system blackout conditions. 'There ars 10 gas turbines at Holtsville~(approxi-mately-20. miles.fromlShoreham), 5'of'which.are now, or by April
-will be, equipped with blackstart capability, and'two of which lalready'have. deadline-startLcapabilities specifically to sup-port.Shoreham.5/
Schiffmecher Affidavit at 1 18.
Under 5/- '"Blackstart" means'the ability to start independently of
.anotherJpower-source.
" Deadline start" means the capability to (footnote continued)
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s procedures tested monthly at Holtsville, restoration of pcwer to Shoreham can be accomplished in less than 15 minutes upon the automatic starting of one gas turbine and the system opera-
' tor's clearing of a transmission line to Shoreham.
Actual tests.have shown that power can be restored in 6 minutes.
Id.
-LILCO's system. operators are well trained that implementation of this procedure is the paramount priority in the event of a blackout.
Id.
4.
Providing still more blackstart power capability in the event of a system blackout are two gas turbines east of Shoreham at Southhold (15 MW) and East Hampton (20 MW), either of which is capabla of sup? lying adequate power to Shoreham.
These: units operate independently of the 10 He'.tsville gas tur-bines. -Schiffmacher Affidavit at i 19.
Moreover, LILCO has blackstart gas-turbines at each of its major generating sta-tions, including Port Jefferson, which is 11 miles west of Shoreham and connected to it through a 69 KV line.
Id. at 11.10, 19.
(footnote continued) start automatically without operator intervention and without reliance on another power source.
.A "blackstart" generator 9
without " deadline start" must be started manually.
l R??
t.
5.
If.one assumes the' failure all of the sources of power Idiscussed:soffar,[despite their diversity, redundancy and.
g -
reliability, then in the interests'of stringent conservatism a e
dedicated 20 MW-gas turbine 11s being installed and will be op-erational on the site by April 1984.
This turbine is equipped
'with.a fully automatic (" deadline") blackstart capability; it will1 start automatically upon the loss of voltage to the 69 KV bus.
Schiffmacher. Affidavit at 1 20.
In only two to three minute s,' it'can restore power'to the plant's emergency buses.
Iji. at'1 21.6/ 'To further assure restoration of AC power, LILCO's' procedures call for concurrent;, rather than sequential,
~
- efforts to restore power-to.Shoreham using this 20 MW gas tur-lbine and all other available means.
Id. at 1.20.
Thus, this onsite gas turbine willistart immediately and automatically
'while! system-operators simultaneously restore power to the Shoreham transmission facilities via Holtsville, East Hampton, Southhold,_ Port Jefferson, and alliof the other available-imeans.
Id.
.6/; 'LILCO plans periodic tests of.this 20 MW gas turbine to
-ensure-its continued' operation and reliability.
Additionally, LILCO will maintain a mobile source of fuel at the site should
- anything. happen to the stationary fuel source for the turbine.
Museler Affidavit at 1 8.~
e
.j 1
,,,y
---4.
o.- :
6.
Finally, to go beyond stringent conservatism, LILCO has assumed.the near incredible -- that all of the power sources described above fail.
To service this hypothesis, LILCO will install by May 1984 a block of four 2.5 MW blackstart mobile diesel generators at Shoreham.
These mobile units will be con-nected directly into the plant's four KV bus network, thereby being capable of supplying power to the plant's emergency four KV network.
Schiffmacher Affidavit at 1 25.
Thus, these die-sels will bypass the' station's normal service transformer and reserve-transformer in the event emergency power is needed.
- Iji.
Only two of the four mobile units will be necessary to provide the power required for safe shutdown under normal-or accident conditions.
Id. at 1 27.
In' sum, there is a backup for every credible failure of AC power, and more.
'If one of LILCO's major generating _sta-tions goes out of service, blackstart gas turbines are avail-able at each.
If an extremely unlikely system-wide failure oc-curs, power.is available through the two power pools to which LILCO is connected.
If these pools fail, independent
.blackstart gas turbines at three locations away from Shoreham, and at each of LILCO's major generating stations, will provide power to-the plant in minutes, using the available transmission
system.
If the entire transmission system fails, the 20 MW gas turbine located on site is available to start automatically and provide power to Shoreham.
And if that gas turbine fails si-multaneously with a collapse of everything else, then there still remain the four mobile diesel generators also located onsite and ready to serve required plant loads.
All of these supplementary sources of AC power stand apart from -- while also complementing -- the TDI diesels.
It is also well to be clear that time is not so much of the essence after an accident at low power as it is after one at full power..The most limiting Chapter 15 event during Phases III and IV low power testing is tne loss of coolant ac-cident (LOCA).
Sherwood Affidavit at 1 29.
Although a loss of offsite power is assumed in the FSAR e.nalysis for this acci-dent, such an assumption is unwarranted for the reasons just given.7/
Even if aC power were lost at the same time a LOCA occurred,.the low fission product inventory would result in substantially longer periods of time to restore core cooling to-
-prevent core damage than during a LOCA at full power.
- Thus, 7/
Moreover, because.the plant will not be connected to the grid during Phases III and IV, accident or transient events will not cause perturbations on tb= grid that could, in turn, affect the availability of offsite power.
Sherwood Affidavit at-1 30.
during Phase III approximately five hours would be available to restore make-up water for core cooling before the limits of 10 CFR $ 50.46 and Appendix K were exceeded.
Id. at 29, and Ex-hibit 4.
During Phase IV approximately one hour would be available to restore cooling water.
Id.
Given the ready availability of both onsite and offsite AC power sources, there is more'than reasonable assurance that the core would be cooled in the event of a LOCA during Phases III and IV.
Id. at 1 31.
Finally, to further assure the safety of Phases II, III and IV testing, LILCO will take steps to place the reactor in a cold shutdown condition in the event of any of the followirg:
(a) a " hurricane warning" for the Shoreham area issued by the National Weather Ser-vice; (b) a " tornado warning" for the Shoreham crea issued by the National Weather Ser-vice; (c) a " severe storm warning"-for the Shoreham area issued by the National Weather Service; (d) a prediction for the Shoreham area by the National Weather Service of abnor-mally high tides greater than 5 feet above mean high water within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (e) an indication of seismic activity of
.Olg on the on the Shoreham seismic mon-itors; (f) the unscheduled outage of two of the four LILCO interconnections to Consoli-dated Edison and the New' England Power Grid; and _ _
(g) a low electrical frequency _ condition
'that causes an alarm on the LILCO trans-l mission system.
i s
1Museler Affidavit at 1 7.
LILCO's reliance on the combined effectiveness of onsite and offsite AC power. sources is consistent with NRC precedent.
Although differing in context, the reasoning of the Appeal Board in Florida Power and Light Co. (St. Lucie Nuclear Power Piant,fUnit No.J2), ALAB-603, 12 NRC 30 (1980), indicates
'the interrelationship of ensite and'offsite AC power sources in
~
' determining compliance with GDC 17.
The Licensing and the Ap-peal Boards there observed that onsite diesel generators were Linherently unreliable, even though technically complying with GDC 17.
In considering whether GDC 17 was nonetheless met, the Appeal: Board noted that. "[t]he ability to restore some source LofLAC.poweriafter a'. station blackout provides reasonable assur-Jance that1such an event willlnot' result in' core damage or undue hazard to the.public health and safety."
12 NRC at 60-61.
It
.is inatructive that'the Appeal Board did not rely solely on the availability of diesels or solely'on.the availability of J..
offsite' power,.but combined the two in assessing the~overall
.assuance.that:AC; power.would be available to protect the public health'and. safety.
SeeLalso. Consumers Power Co. (Big Rock
~
- Point: Nuclear Power Station), CLI-76-8,.3 NRC'598 (1976) (one.
s onsite diesel acceptable in light of high availability of offsite_ power). Significantly, St. Lucie involved an applica-tion for a full power license; LILCO is requesting permission' to operate only at low power.
In conclusion,.the presence of fully tested TDI die-
_sels, a reliable transmission system, the availability of other, multiple sources of AC' power, both onsite and offsite, and the numerous, systematic measures that LILCO will take to
^
prevent the~ loss of emergency power, all provide reasonable as-surance that Shoreham can operate up to 5% of rated power with-out undue-risk to the public h'ealth and safety.
'III.
REFERRAL AND CERTIFICATION Referral pursuant to 10 CFR 5.2.L718(1) and certifica-
. tion. pursuant:to 5 2.73O(f) are governed by-the same test, as
.this Board has observed:
Whether review should be undertaken on "cer-tification"'or.by referral before the end of the case _ turns on whether a' failure to ad-dress the issue would seriously harm the pub-lic. interest, result in unusual delay or ex-pense, or affect-the basic structure of the proceeding in some pervasive or unusual man-ner.
s Long' Island Lighting Co. (Shoreham Nuclear Power Station, Unit s
i
, +
-..._,-._--.v._-._--
1), LBP-83-21, 17 NRC 593, 598 (1983); Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), ALAB-687, 16 NRC 460, 464 (1982); Consumers Power Co. (Midland Plant, Units 1 and 2),
ALAB-634, 13 NRC 96, 99 (1981).g/
Compelling circumstances exist giving rise to a need for both prompt and final determination of the issues now pre-sented.
Failure to resolve them expeditiously will seriously harm the public interest.
It will deprive LILCO of the oppor-tunity to have Shoreham's personnel gain valuable experience and to test the plant's systems during an extensive period of 4
low power operations.
See generally Notaro Affidavit.
And it l
l will impair LILCO's capacity to move quickly toward full power
)
operation once the TDI diesels have successfully completed the litigation process.
Intolerable delay and expense will, in g/
Section 2.718(i) permits the presiding officer of the Board to "[c]ertify questions to the Commission for its deter-mination,-either in his discretion or on direction of the Com-mission."
This has been interpreted to allow referral of a question to the Commission (through the Appeal Board) before Board decision.
E.g.,
Long Island Lighting Co.,
17 NRC 593
-(1983).
As to those matters upon which the Board has already ruled, 5 2.730(f) provides:
When in the judgment of the presiding offi-ce_ prompt decision is necessary to prevent detriment to the public interest or unusual delay or expense, the presiding officer may refer the ruling promptly to the Commis-1,
.sion, and notify the parties either by an-I nouncement on the record or by written no-
[
tice.if the hearing is net in session.
- p..
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fact, result should this supplemental motion become mired in a procedural. morass.
The acute demands of the' situation stem
-from the: physical completion of the. plant, the enormous finan-Jcial' investment in it, an investment that now generate nothing
-but carrying charges,-and Shoreham's' unique capacity -- once it begins'to generate' electricity -- to lessen Long Island's now
. utter dependence.on foreign oil to fuel its power plants.
'IV.
CONCLUSION For the1 reasons discussed, LILCO is entitled now to a license to conduct the activities in Phases I through IV of Shoreham's~1ow power testing program.
The activities in Phases Ifand II pose no risk to the public health and safety, even in
- the absence.of AC power.
In Phases.III and IV, fully-tested TDI: diesels coupled with. alternative, multiple sources of AC power, both offsite;and ons'ite,. provide-reasonable assurance that AC power will be available in any_ emergency that may
~
occur.
Thus, Phases III and IV also pose no undue risk to the public health and safety.
Accordingly, LILCO urges the Board to refer this supplemental. motion to the Commission for prompt
,and final disposition,Jor~failing that, to rule as.quickly as
.is feasible on the issues presented and then certify the Board's decision directlyfto the Commission.
. 1
Respectfully submitted, LONG' ISLAND LIGHTING COMPANY i
$$1 Y bll&Lbkvl f
~
W. Tf91 Reveley, III T.
W.
lis, III Robert M. Rolfe Anthony F. Earley, Jr.
Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212
~ DATED:
March 20, 1984 d
h i..
(..
o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF JACK A. NOTARO AND WILLIAM.E. GUNTHER, JR.
Jack A. Notaro and William E. Gunther, Jr.,
being duly sworn, depose and state as follows:
(1)
My name is Jack A. Notaro and I have been the
. Chief Operating Engineer for the Shoreham Nuclear Power Station (SNPS) since April 1983.
Prior to that time, from July 1978 through April 1983, I was assigned as Operating Engineer for Shoreham.
During March-April 1981, I was assigned to the Op-erations Section of the Millstone Nuclear Power Station for the completion of a refueling outage and power operation training.
at greater than 20% power.
My duties and responsibilities as Chief Operating Engineer of Shoreham include the formulation and implementation of the training programs for all station personnel, direction of the day-to-day operation of the unit, including startup operation and shutdown of all station equip-ment and development and review of the Operation Section of the Station Operation Manual and the overall management of the Operations, Training and Security sections of the station.
c.
l I
-(2)
I have_a Bachelor of Mechanical Engineering degree (1970) and a Master of Business Administration degree (1974).
I completed the General-Electric BWR-simulator program in July 1976 and'obtained certification at-the RO and SRO levels.
In
. November 1982, I obtained a Senior Reactor Operator license on
.Shoreham.
(3)
My name is William E. Gunther, Jr. and I have been the Operating. Engineer for_Shoreham since April 1983.
My du-ties and responsibilities include the direction of the day-to-day operation and shutdown-of all station equipment, final ver-ification of all operating procedures, participation in initial requalification and replacement training programs for licensed and unlicensed operators.and the establishment and maintenance of. system operability to support fuel load.
t (4).'.I have a Bachelor of Science degree in Electrical Engineering (1970) and a Master of Science degree in Electrical Engineering (1971).
I earned a Senior Operator Certification from the General Electric Company on the Brunswick Unit 2 BWR
- in 1975 and I completed the General Physics Company BWR si-mulator program in1 December 1981 and'obtained certification at
.the.RO and-SkO' levels.
In November 1982, ! obtained a Senior Reactorz Operator license on Shoreham.
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a~
. (5)
The purpose of this affidavit is to describe the steps involved in the following phases:
Phase I:
Fuel Loading and Precriticality Testing Phase II:
Cold Criticality Testing Phase III:
Heatup and. Low Power Testing to Rated Pressure / Temperature Conditions (approximately 1% rated power)
Phase IV:
Low Power Testing (1-5% rated power)
These various phases will re described below, with a brief ex-planation of the testing and operations to be conducted during each phase.
Phase I:
Fuel Loading and Precriticality Testing (6)
Fuel loading and precriticality testing involve placing fuel in the vessel and conducting various tests of re-actor systems and support systems.
Initial core loading in-volves the placement of 560 fuel bundles in specified locations within the reactor vessel.
This major step requires signifi-
. cant testing as fuel loading progresses, and it takes at least 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br />.
The following testing is associated with initial core loading:
w w
+
c 4 (A)
Water chemistry surveillance testing.
This testing must be performed prior to, during and after the fuel loading operation.
.The purpose of water chemistry surveillance testing is to ensure clarity of the water no that the fuel loading process can proceed and to minimize the amount of the corrosion products in the primary system.
(B)
Control rod drive stroke time and friction tests.
These tests are performed during the fuel loading step to ensure that the reactor shutdown capability is maintained at all times and to ensure the control rod drive mechanisms are performing as designed.
(C)
Installation, calibration and utilization of special startup neutron in-strumentation.
This instrumentation is re-quired for core loading activities to ensure proper monitoring of core conditions by the Operating, Reactor Engineering and Instrumen-tation and Control personnel.
Source rance monitor testing and alignment tests calibrate the neutron monitoring instrumentation and verify proper final alignment of this vital equipment.
(D)
Core verification instrument op-erability check.
These checks are performed to verify that the equipment utilized to de-termine that the core has been loaded cor-rectly is operabic.
Final core verification checks are completed at this time.
The tests listed in (A) through (D) above involve valu-able supplemental training and experience for personnel as-signed to the Reactor Engineering Section, Radiochemistry Sec-tion, Operating Section, Maintenance Section and Instrumentation and Contro) Section.
The training described in
a
-S-steps ~(B), (C) and (D) can be fully accomplished only during the fuel load operation.
(7)
Following placement of the fuel in the vessel, a number of tests must be performed to verify the operability of systems prior to going critical in the reactor.
This phase of startup testing takes approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> and includes the following:
(A)
Local Power Range Monitor (LPRM) sensitivity data.
During this test, the 31 local power range monitor strings are cali-brated and verified to be operable.
Instru-mentation and control technicians will per-form this testing, and obtain training in the use of calibration procedures and special test equipment.
(B)
Zero power radiation survey for background readings.
Various locations in the plant are surveyed by health physics
-technicians to determine background radiation levels with fuel in the vessel.
(C)
Recirculation system instrument calibration chacks.
Operation of the recirculating pumps with fuel in the vessel is conducted to determine core internal pres-sure drops and to verify system performance.
Operation of the system above minimum speeds with the vessel internals installed can be accomplished only with fuel in the' reactor.
(D)
Control rod drive scram time testing.
Following fuel load, each control rod drive mechanism is scrammed from its full withdrawn position following control rod cou-pling surveillance testing to verify that rod insertion can be accomplished within the pre-scribed time.
t-l_ -
1
. (E)
Cold MSIV timing.
This functional test of the main steam isolation valves verifies that their opening and closing times are within technical specification acceptanca criteria.
Again, the testing and activities described in (A) throughf(D) above can be accomplished only after fuel has been placed in the vessel.
The experience and training gained from those activities will be an invaluable Choreham-specific aug-mentation to the years of extensive preoperational training that the reactor operators have previously undergone.
Phase II:
Cold Criticality Testing (8)
This phase involves a specified control rod with-drawal sequence that results in achieving reactor criticality at extremely low. power levels (.0001% to.001% of rated thermal power).
In addition, this step involves shutdown of the reac-tor by inserting all control rods in reverse order.
While withdrawing each. rod, reactor operators monitor the effect of its withdrawal in terms of neutron flux.
By analysis and cal-culation, Reactor Engineering personnel are able to assign a
" worth" to each control rod, i.e.,
the effectiveness of each rod in controlling reactivity.
Important cperator hands-on ex-perience is gained during.this step.
Reactor operators must annually perform a minimum of ten reactivity control
. manipulations.
This experience provides additional training
.for reactor operators in the use of appropriate instrumentation and' equipment to determine when criticality is achieved during the withdrawal of control rods.
This important experience on the Shoreham reactor can be gained only after fuel has been
.placed in the vessel.
Similarly, Reactor Engineering personnel obtain valuable training and experience during this closely monitored activity.
LILCO plans to repeat the operations dur-ing this phase of low power testing to offer each operating shift crew this valuable BWR experience.
(9)
Cold criticality testing requires plant mainte-nance personnel to install vessel internals in accordance with station procedures and with all refuel floor constraints in place.. Maintenance personnel gain experience with the op-eration of the refuel bridge and reactor building crane.
(10)
Also performed at this time is the installation of the expansion and vibration instrumentation.
Cold baseline
. data are obtained at this point to determine pipe movement as heatup occurs later in the low power test program.
The data provide a benchmark against which subsequent test results can be assessed.
E y.
(11)
During the course of fuel leading, precriticality testing, and cold criticality testing, the plant staff must place in service, operate, test, and maintain 41 systems.
These reactor. systems and support systems include the follow-ing:
Control Rod Drive System (CRD)
Core Spray System Diesel Generator 4160 V System 480 V System 120 V AC Instrument Bus 120 V AC Reactor Protection System (RPS) 120 V AC Ininterrupted Power Supply 125 V DC System 24 V DC System Low Pressure Coolant Injection.(LPCI)
HVAC-Drywell Cooling Reactor Building Closed Loop Cooling Water System (RBCLCW)
Reactor Building Normal Ventilation System (RBNVS)
Residual Heat Removal System (RHR)
Reactor Recirculation System Service Water Reactor Building Standby Ventilation System (RBSVS)
Standby Liquid Control System Condensate System Feedwater System HVAC - Control Room HVAC - Turbine Building Reactor Water Cleanup System Station Air System Turbine Building Closed Loop Cooling System Containment Area Leakage Detection System RBSVS & CRAC Chilled Water Systems Neutron Monitoring Instrumentation Reactor Manual Control Radwaste Liquid Collection and Processing Circulating Water Demineralized Water Well Water and Domestic Water System Normal Station Service Transformer and 138 KV System Reserve Station Service Transformer and 69 KV System
_g.
Fire Protection System Fire Suppression System Reactor Vessel Water Level Radiation Monitoring System Heat Tracing System The operation of these systems provides valuable
-training and experience to operating plant personnel, including licensed operators.
LILCO plans to repeat certain of the ac-tivities in this phase of low power testing to provide addi-tional, valuable BWR operating experience. It is estimated that there will be 5000 total manhours of training accomplished and
-achieved during fuel loading, precriticality testing, and cold criticality testing described above.
Phase III:
Heatup and Low Power Testing to Rated Pressure / Temperature Conditions (Approximately 1% Rated Power)
(12)
During this phase of low power testing, reactor heatup and pressurization commences and the power level is taken in progressive steps to 1% of rated power.
Along the way, the heatup and pressurization of the reactor vessel and associated piping systems enables the plant staff to perform importent tests relating to thermal expansion of piping and in-
- tegrated system operation under actual operating conditions.
The principal steps associated with this phase of low power testing are described below.
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. (13)
Rod withdrawal sequences are followed to achieve criticality and syetem heatup from ambient conditions to 150 psig.
During this step, the following tests and training are accomplished:
(A)
Conduct Source Range Monitor (SRM) response testing to verify source range moni-toring calibration and response; (B)
Establish condenser vacuum follow-ing establishment of steam seals and other main turbine auxiliary systems; (C)
Obtain initial baseline readings for Nuclear Steam Supply (NSS) system thermal expansion; (D)
Place steam jet air ejectors in service on main steam; j
(E)
Achieve warmup of the High Pressure Coolant Injection (HPCI) and Reat: tor Core Isolation Cooling (RCIC) systems, (F)
Achieve controlled warmup of reac-tor feed pump turbines and integrated op-erations of the condensate and feedsater sys-tems; (G)
Obtain Intermediate Range Moni-tar / Source Range Monitor (IRM/SRM) overlap data; (H)
Obtain Intermediate Range Monitor (IRM) range 6-7 overlap data; and (I)
Perform an Average Power Range Mon-itor (APRM) calibration while heating up.
I Operating personnel and instrumentation and cont-ol
. technicians receive valuable training and experience in the course of these steps.
l (14)
With the reactor at 150 psig and during the con-tinued heatup frem 150 to 250 psig, the following system tests are performed:
(A)
Drywell inspection; (B)
Data gathering for Nuclear Steam Supply (NSS) system thermal expansion; (C)
Data gathering for Balance of Plant (BOP) system thermal expansion; (D)
Operation of Main Turbine Electro-Hydraulic Control (EHC) System; I
(E)
Data gathering for Reactor Building Closed Loop Cooling Water gRBCLCW) steady state performance; (F)
RCIC initial operability demonstra-tion with manual start and hot quickstart, condensate storage tank (CST) to CST recirculation; (G)
Motor Operated Valve (MOV) dynamic testing on Residual Heat Removal (RHR) sys-tem; (H)
HPCI initial operability demonstra-tion with manual starts and hot quickstarts, CST to CST recirculation; (I)
Maintenance of suppression pool within technical specifications using RHR suppression pool cooling; (J)
Operation of steam seal evaporator, radwaste evaporator and main condenser deaerating cystem;
^
.) ',
h (K) -Verification of capability to shut down the reactor from.outside the control room utilizing the Remote Shutdown Panel.
- (15).With the reactor.at 250.psig and during the con-tinued heatupLfrom 250 psig to 350.psig, the following testing is' performed:
.(A)
Maintain EHC pressure setpoint at' 250 psig and withdraw control rods to open turbine. bypass valves.(BPV) for Safety Relief
.. Valve,(SRV) testing; (B)
Functionally test the Safety Relief Valves ~(SRV) manually opening one SRV at a
-time; l(C)- Obtain drywell piping vibraticn-idata'.while performing the SRV tests; (D)
Gather data for system thermal ex-pansion tests.
(16).With the reactor coolant system pressure between-350 psig andL550'psig, the following testing is performed:
(A)I-Place one reactor'feedwater pump and the'lowJflow fetdwater controller in ser-
- vice ar.d monitor their operation to er.sure that.they_ perform their function of. supplying 1~
. water to the reactor. vessel at the appropri-
.atefflow rate;-
~
(B)
Gather data for' system thermal.ex-pansion tests; ITS Vi
-(C)
Perform' Average-Power ~ Range Monitor
. (APRM):heatup rate calibration;
.(D)
Verify loose parts monitoring system. operability.
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(17)
With the reactor coolant system pressure between 350-psig and 800 psig, the following testing is performad:
(A)
Conduct _a drywell temperature in-spection and gather data for system thermal expansion tests;
.(B)
Obtain Reactor Building Closed Loop Cooling Water System (RBCLCW) performance data; (C)
Scram selected control rods to ob-tain' scram time data.
(13)
With the reactor coolant system pressure at E00 psig and heatup to 920 psig, the following occurs:
(A)
Scram selected control rods for scram time data; (B)
Obtain system thermal expansion data for nuclear steam supply systems and balance of plant systems.
Phase IV:
Low Power Testing (1-5%)
(19)
During this pnase of low powe~ testing, the power level iu taken-in progressive steps from 1% to 5% of rated thermal power.
With'the reactor coolant-system at rated tem-perature and pressure, the operator will withdraw rods and open one--Main Turbine bypass valve to establish a steam flow such that core therraal power is less than 5% rated thermal power.
-Once this condition is established, the following tests are performed:
1 1
(A)
Demonstrate RCIC operability; (B)
Demonstrate HPCI operability; (C)
Perform dynamic motor operated valve ter*.s, inservice leak. tests and-hot hanger sets on plant systems;
-(D)
Align Traversing Incore Probt (TIP);
.(E)'
Calibrate the bottom reactor pres-sure vessel' head drain line flow indicator and perform main steam-isolation valve func-tional tests;
-(F)
Perform RCIC and HPCi controller tests (CST to CST recirculation); and (G)
Perform IRM/APRM overlap calibration, f
(20) JAfter the completion of the tests just listed, the first choldown'to ambient conditions will commence.
During this'cooldown, the following activities take place:
1 (A).
Perform source range moni-tor / intermediate range monitor overlap
. calibration; (B)
Position one turbine bypass valve so that core thermal power.is less then 5%
and maximum steam flow is available for HPCI; 7
(C)
Perform ~a HPCI/RCIC stability test to demonstrate 1the stability of the control-1er setting from the 1000 psig test;
'(D)
Perform a drywell and reactor.
building 1.nsp2ction of system thermal expan-sion instruments.
, ~., -.. - - --,
4.(21)
Then comes a'second heatup to rated conditions.
During this.heatup, the key activities include:
(A)
Demonstration of the source range and intermediate range monitor response to control rod withdrawal; (B)
Gathering of system thermal expan-sion data; (C) ' Calibration of the average power range. monitors.
(22)- When the plant is at rated temperature and pres-sure, the plant staff ver'fies that core thermal power is less than 5% rated thermal power by performing a heat balance.
4
- After the verification.of core thermal power is complete, a RCIC cold quickstart.and endurance run are performed.
4 (23)
Subsequent to the completion of the second test period at 920 psig, the plant will be cooled down to ambient conditions.
During this cooldown, the plant will obtain nuclear 4 team supply system thermal expansion data for the sec-I ca.d time.
When ambient conditions are reached, the low power tests are con 71uded.
Repeated startups and heatups to rated
- conditions will be performed at'Shoreham, however, so that each operating crew can be' riven the' opportunity to experience plant response to the tests and' activities presented above.
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. (24)
In order to support and perform all of the func-tions and tests performed during Phases III and IV described above, the plant staff will be required to place in service, operate, test and maintain 54 plant systems.
In addition to the reacter systems and support systems listed in paragraph 12 above, these are as follows:
1 Automatic Depressurization System (ADS)
HPCI Offgas_ System l
_RCIC Generator Seal Oil System Main Steam System
- Turbine Generator Turbine EHC Turbine Lube Oil System Steam Seal System Area Leakage Detection Reactor Vessel Pressure and Temperature Systems Remote Shutdown System
.It is important to emphasize once more-that the operation of these systems and the various functions and tests performed during Phases III and IV of low power _ testing, as with the ac-tivities during Phases I_and II, will provide valuhble training and experience to cperating plant personnel, including licensed operators.
As noted in this affidavit LILCO intends to expand the' fuel load and precriticality testing, cold criticality l
testing and low power testing activities to provide Shoreham's fl F
operating personnel with additional operating experience above
=
'that which would result from a conventional fuel load and low C:
power. testing. program.
It is estimated that 6000 manhours of training will occur during Phaser: III and IV, in addition to theJ5000 manhours during Phases I and II.
Jack A. Notaro William E.
Gunther, Jr.
STATE OF NEW YORK
)
)
To-wit:
COUNTY OF SUFFOLK
)
Sube ribed and sworn to before me this day of March,.1984.
My commission expires:
Notary Public
'~
E rg V
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
,0, In theLMatter of,
)
)
LONG ESLAND LIGHTING COMPANY-
)
Docket No. 50-322 (OL)
~
)
.(Shoreham Nuclear Power Station,
)
Unit 1)~
)
. AFFIDAVIT OF WILLIAM G.
SCHIFFMACHER William G.
Schiffmacher, being duly sworn, deposes and etates as follows:
.(1)
My.name is' William G.
Schiffmacher and I have been Manager of the Electrical Engineering Department at LILCO since Augu'3t 1981.
I-have been employed by LILCO since June 1965 in a variety.of technical, management and supervisory po-sitions, the principal ones of which are as follows:
m July _1972-Supervisor, Substation Opere.tions November 1972 Responsible for coordinating efforts of 15-20 field personnel i'u'olved in operation of the electric system.
-November 1972+
-Supervisor, Transmission and September'1975 LIntersystem Planning Responsible for planning and recom-mending system transmission projects including substations; complement of 5 engineers.
p,
n ' September 1975-Manager, Electric-System Planning December 1977 Responsible'for conduct of all studies and investigations for planning LILCO's electric facilities.
Division is. organized into four specialties - generation, economics, transmission and inter-system studies.
Work include 3
. preparation of reports and testi-mony for economic and technical aspects of, among others, Shoreham and Jamesport nuclear units and associated transmission and inter-connection facilities.
Personnel complement of 15 includes 12 engineers, 1 economist and 2 technicians.
' December 1977-Manager, Substation Design and May.1979 System Control and Protection Responsible for the physical-electrical design of.all substa-tions and complete engineering and design of all protective relaying, supervisor _ control and telemetering systema for LILCO; complement of 12 engineers.
L, May 1979-Manager, Electric Systam Planning April-1981 Same as above.
April 1981-Manager of-Overhead and August 1981 Underground Distribution Materials (2)
As Manager, Electrical Engineering Department, my duties _and responaibilities include responsibility for all L
1 electrical engineering, including overhead and underground
. transmission, substation engineering, distribution engineering,
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% and-electrical engineering associated with nuclear and fossil.
plants _and buildings.
-(3)
I have a' Bachelor of Electrical Engineering degree-
~from' Manhattan College- (1965) and a Master of Science degree in ManagementLEngineering (1969). from'Long Island University.
(4)
The purpose of this affidavit is to' describe all
..m
-of the normal and. additional sources of AC power available to support the Shoreham Nuclear Power Station without reliance on Lthe Transamer'ica Delaval emergency diesel generators.
This ex-L-
planation will; describe the high' reliability provided.by the
. numerous and diverse ~meansjof providing adequate AC power to-s.-
Shoreham.
(5). There are_ numerous sources of AC power available to and designed'for Shoreham.
Each has substantial' backup in 1
'the.unlikely eventLof-failure.
They include the following, all
'of-which are depicted in. Exhibit A:1/
n=-
(a)
LILCO has. a 138 KV and a 69 137 high voltage
' network system with;significant interconnection if' For convenience, the facilities described below e.re refer-
~
enced.to Exhibit'A by letters noted in parentheses here and in
-triangles.on the exhibit.
Additional detail and perspective fare provided in Exhibit A-1.
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6-capacity (i) with the New York Power Pool through Coa-solidated Edisonf(three ties totaling 1090 MW) and (ii) with.the New England Power Grid through lines beneath1 Long Island Sound through Connecticut Light & Power Company-(285 MW).
See (A) Exhibit A: Exhibit B (LILCO Interconnections). 'This ensures the availability of sufficient power throughout the system to serve Shoreham's needs.
Moreover, each of LILCO's major generating facilities is equipped with a backup blackstart2/ gas. turbine to provide starting power under blackout. conditions.
As an example, Port Jefferson is a major generating station with two 185 MW steam generating-units and a blackstart gas turbine only eleven miles from Shoreham.
See.(L) Exhibit A.
(b)
Within the LILCO system, there are four 138 KV circuits into'the Shoreham 138 KV switchyard (see
- (D) Exhibit A) along two separate and distinct rights-
-of-way.
.See (B, C) Exhibit A.
Also, Shoreham is supplied by three separate 69 KV circuits entering a
' separate switchyard at Wildwood which connects to the 2/D "Blackstart" indicates the' ability to be started indepen-ydently of any other power source.
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-S-Shoreham 69 KV switchyard.
See-(E) Exhibit A.
In con-trast, GDC 17 requires.only "two physically independent circuits (not necessarily on separate rights-of-way)"
and permits a single switchyard.
(c)
Even in the event the entire grid is unavailable, the LILCO system-includes 10 gas turbines at-Holtsville (Holtsville is approximately 20 miles from the Shoreham site), 50 MW per turbine, two of which are presently equipped with deadline blackstart
. capability designed and installed to support Shoreham.
See (F) Exhibit A.
Three more will be equipped with blackstart capability by April, 1984.3/
(d)- As further-backup, there are three blackstart gas turbines located at Southhold (see (G) Exhibit A),
East _Hampton (see (H) Exhibit A), and Port Jefferson (see'(L) Exhibit A), each of which can supply 69 KV power to Shoreham.
j3 4
.Two of the five have deadline blackstart and the other
.three'will be-started by the system operator.
Deadline op-eration implies automatic start without operator intervention if system' power is lost.
+
7,_
19
'.fu s-(e) -At the site, LILCO is completing the instal-
~
lation of.a 20 MW-gas turbine with deadline blackstart capability. 'See (I). Exhibit A.
This will provide ade-quate AC power to Shoreham even in the unlikely' event all transmission supplied are lost.
M
~
L (f)
To allow further independence from the LI'CO grid and independence from the normal station service transformer and reserve station service transformer,.
LILCO is in the process of obtaining and installing a block of four 2.5 MW blackstart mobile diesel genera-
' tors to_be located on site and routed into the plant's emergency 4 KV-buses.
See (J) Exhibit A; Exhibit C (Plant 4 KV system).
With.this general description of.the variety of AC power sources for.Shorehan as background, I will turn next to a more. detailed description of each source and a consideration of its role.in providing additional assurance that adequate AC power will be provided to Shcreham under normal and emergency conditions.
LILCO'S SYSTEM GRID AND INTERCONNECTION CAPACITY
-(6) :LILCO has a generating capacity of 3721 MW
a
.. consisting of 2240 MW of baseload steam turbine units, 432 MW of mid-range and peaking steam turbine units and 1049 MW of in-ternal combustion peaking units consisting of gas turbines and diesel generators.
(7)
In addition to LILCO's bulk power transmission system, LILCO is interconnected with the New York Power Pool through Consolidated Edison.
This interconnection is made
.through three ties providing an additional 1090 MW of power if needed as follows:4/
Summer Ratings (MW)
Voltage Normal LTE STE Lake Success-Jamaica 138KV 238 341 427 Valley Stream-Jamaica 138KV 271 318 441 Shore Road-Dunwoodie 345KV 581 839 1479 (8)
Since all members of the New York Power Pool (NYPP) are required to maintain reserve capacity of 18% over their peal: demand, and since the Pool members do not experience peak demands at the same times, a Pool-wide 22% reserve margin 4/
. Exhibit B (LILCO Interconnections) depicts the various interconnections with their nominal ratings.
The slight dif-ferences in power ratings between Exhibit B and the above rat-ings resulted from rounding off.
Exhibit B also reflecta only normal power ratings and not the long-term emergency (LTE) and short term emergency (STE) ratings included above.
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.-is ~ achieved. :Furthermore,-the NYPP operates with~enough spinning; reserve to cover.the-loss of-the largest generation source in'the state.
(9)
LILCOcis also connected with the New England Power. Grid beneath Long Island. Sound through the Northport-
Norwalk tieline which'is_a 138 KV line rated at 285 MW.
- ( 10 )'
Subsequent to the Northeast Blackout of 1965, LILCO implemented substantial measures to increase reliability of_its system.
These included installation of blackstart gas
- turbines at each of11ts major generating stations and imple-mentation of automatic'underfrequency load shedding proce-
' dures.5/ _In theE18. years since, there has been no loss of the
. entire LILCO' grid.
There.has only been one incident in which LILCO has lost any_ appreciable. portion;of its bulk power trans-mission: system.
That one incident affected LILCO's system east of Holbrook.
Despite ' tie lack of any procedures then in effect
' mandating priority emphasis on-restoring power to Shoreham, 1 power was restored-to the entire Shoreham area within one hour andLfour' minutes.
With the: priority procedures now in effect L5/
Underfrequency load shedding-schemes allow restoration of sa balance between load to be served and generation available by automatically disconnecting load from the' system.
This pre-vents cascading; outages of multiple facilities on the system.
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[1 Lto: restore, power-to Shoreham and the. availability of several 2
1 independent deadline blackstart' gas turbines, all of.which are
- described below, it has-been demonstrated by exercises that
((
jtoday powerJean be: restored to.Shoreham in a matter.of minutes, i.
'(11). The reliability of LILCO's bulk transmission sys-Ltem was-further evidenced when' Consolidated Edison's system ex-periencedfa' blackout in:1977.
LILCO's entire bulk transmission system' remained on'line'and'there was no1 interruption in ser-Lvic'e'toothe'LILCO system.
!g THE DESIGNED' SYSTEM FOR'SHOREHAM-r.
A.
. Transmission Network
[
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((12). The Shoreham1 Nuclear Power Station'is inter-p
{ connected to the LILCO system through.138 KV and 69.KV cir-
-cuits.
Four 138'KV. transmission circuits-serve 2the 138 KV.
L h
Shoreham? switchyard.
.Two' circuits emanate from the Holbrook 138 KV.subctation,-(B-1) Exhibit A;.one from the Wildwood-Riverhead-138 KV substation, (C-1) Exhibit A; and one
- from the-Brookhaven~138 KV. substation,.(C-2) Exhibit A.
See
_also Exhibit Df(LILCO system diagram)~.
Two separate and inde-
? pendent rtghts-of-way are provided, each containing two of the
~
'four'138.'KV circuits..The 138 KV switchyard is arranged in.a 1
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3.- 'two' bus configuration with-circuit breakers and switches ar-ranged to permit 11 solation and/or repair of either bus section.
- This. permits continuation of 138 KV power supplied.from sepa-
. rate rights-of-way even if-an entire bus section is out of ser-vice.
(13)
Additionally, three 69 KV circuits feed the Wild-
- wood' substation which is approximately one mile scuch of
'Shoreham and from there, one 69 KV circuit enters the site.
'These three circuits emanate from Riverhead (see (E-1) Exhibit
.A)',
Holtsville (see (E-2) Exhibit A), and Port Jefferson (see (E-3) Exhibit A).
See also Exhibit D.
The 69 KV line from Wildwood to the :Shoreham 69 KV switchyard has been placed un-derground in the vicinity of the 138 KV facilities to maintain complete independence of supply between the normal! station ser-vice (NSS) and. reserve station service (RSS) transformers.
See
-(K-1) Exhibit A.
The circuit continues underground from the substation to the RSS. transformer-
!Furthermore, in the unlike-ly event tJuat either of these underground sections should fail, a-bypass 69 KV circuit (bypassing the 69 KV switchyard) to the RSS transformer has.been provided.
See (K-2) Exhibit A.
By utilizing this bypass circuit, power can be restored without
.having to repair the underground cable or route power through the Shoreham 69 KV' switchyard.
This bypass allows
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reestablishment of -the 69 KV RSS supply: substantially more huickly'than'the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required in Technical Specifica-tion " Electrical Power Systems 3/4.8.1.1" without'the necessity of removing the nuclear plant.from service.
(14)
Both.the 138 KV and 69 KV lines form part of the
~
-LILCO network transmission system.
This system is designed to withstand' winds of' minimum speeds of-100-130 mph.
Other natu-ral phenomena such as tornadoes, hurricanes and earthquakes
- have not' adversely impacted LILCO's bulk transmission system.
Nevertheless, when such phenomena are expected, specific pre-cautionary procedures will be invoked as described in the affi-l davit-of Will'iam J. Museler.
(15).Even in the unlikely event that any of the trans-mission facilities are damaged, LILCO has the ability to recon-
-struct such facilities rapidly.
LILCO routinely constructs _its
'own transmission facilities.
Therefore, LILCO has a large force of trained personnel to construct-and restore transmis-Esion facilities.
These trained ~ crews are available'24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a dayito' respond to emergency conditions.
In order to assure
. prompt responsiveness for the' lines-serving Shoreham, LILCO is
' undertaking extraordinary measures to preplan such an op-
'eration. -This includes measures such as pre-assigning poles i
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. and hardware and storing this equipment at optimized locations, I
sus well as conducting additional training of overhead lines
. personnel. LUsing these measures, LILCO can restore a mile of-69 KV' transmission facil'ities within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
While it is not anticipated-that.such extensive damage would occur on any one transmission line, this capability provides a benchmark indicating the expeditious manner in which LILCO could restore facilities.
(16)_: Additionally, the necessity for reconstructing transmission facilities at.any. instant in order to serve Shoreham'is minimized by the nature of the transmission system.
.It-is a network system'of interconnected lines which provide
.the:abilityito route orLreroute power over' multiple paths.
J B.'
Independent'Blackstart Generators (17)
The reliability of.LILCO's' system providing power.
to Shoreham is further enhanced by a number of independent gas turbines at various11ocations specifically designed to start
'during. blackout conditions.
Exhibit A shows the location of
.these gas' turbines discussed below.
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~ - ( $ 8'). The LILCO system includes 10 gas turbines-at~
lH$ltsville', 2 of'which are. equipped with deadline blackstart lcapabilityiand_3 of(which will have blackstart: capability de-a
-signed.and; installed to support Shoreham.
See (F) Exhibit A.
- ~Allifive blackstart turbines are under the control of and-can
- be-started by..the system operator.6/
Power from-these gas tur-
- bines is capable ofLbeingl supplied to' Shore 2.am through various transmission paths ultimately leading to any of the 138 KV lines'or~the1 three 69 KV111nes to Shoreham as depicted in Ex-hibit A.
Underisimulated conditions,- tests have shown that' power can be restored:to Shoreham from Holtsville in 6 minutes.
~
(The systemcoperator,(in~close< coordination by telephone and/or
~
radioLwith the Shoreham control room) deliberately isolates theseigas turbines;so that the system-appears to be in a.
blackout--mode.. A unit;Jautomatically starts and the operator then~ clears a'transmicsion line-express to Shoreham.
Imple.-
mentation'of this procedure has been directed in LILCO'a Emer-
~
" ~
gencyj and Unusu al1 Procedures - Manual' as ' the paramount priorit'j ifor the LILCOJsystem: operator ~in the event of'a blackout.
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1
.Testsfof th'e.Holtsville gas-turbines ~and~ practice restoration s
~
J 7 6/ f.Theasystem operator controls-the entire LILCO grid from a
- ce.ntral point.-
There..are 3.such operators.on~ duty at all times g
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nf pcuar to Shoreham are conducted twice a month.
See Museler Affidavit at 1 18.
( 1. ).There are additional deadline blackscart gas tur-bines _at 2 locations east of Shoreham, Southhold (15 MW) (see (G)LExhibit A) and East Hampton (20 MW) (see (H) Exhibit.A),
either of.which-is capable of supplying adequate power to Shoreham in the event the Holtsville units are unavailable.
Power from-each'of'these units is supplied to Shoreham by 69 KV circuits to_Riverhead_where routing to Shoreham can continue via 69 KV or 138 KV lines.
See Exhibit D.
A description of testing to assure the reliability of these units is included in the-Museler affidavit.
Finally, there is a blackstart gas turbine at the_ Port Jefferson 370 MW steam plant [ eleven miles Lto the west of Shoreham which'is also capable'of supplying power to Shoreham.
See (L) Exhibit A.
C.
Onsite 20 MW Gas Turbine (20)
The redundant methods of restoring power to Shoreham described above complement and provide yet another backup for the most~ rapid method of restoring AC power to Shoreham which'is a dedicated 20 MW gas turbine being installed at_the-site. -See~(I) Exhibit.A.
This gas turbine 1.as deadline
_ blackstart capablity and is scheduled to be operational in L1
g
. s April'1984.
Thus, even with the loss of all alternative AC power; sources and their backups, including the Holtsville, e
Southhold.and East Hampton gas turbines, more than adequate AC
- powericould be provided by the
',0 MW gas turbine on the site.
-It has the ability.to carry all plant emergency load together withLsome selected plant nonemergency load.
LILCO's procedures call for concurrent, rather than sequential, efforts to restore power to Shoreham using any and all of the available power
-sources. --That is,_the 20 MW gas turbine will start automat-ically, while the system operator will simultaneously institute-action to restore power to Shoreham through the transmission system.
(21)
The 20 MW gas. turbine is connected to the 69 KV bus'at Shoreham.
It is also equipped with fully automatic
-(deadline) blackstart capability which gives it the ability to start automatically upon loss of voltage to the 69 KV bus and
' pick up load as required.
The 69.KV bus supplies power to the ress;rve-station' service transformer via an underground 69 KV cable.
Power.can be restored to the reserve station service transformer ~in approximately 2-3 minutes.
-(22) __With its newly installed low pressure air start
- system 1and fuel-control system, the 20 MW gas turbine at
. Shorehcm le virtually identical to the gas turbine at East
-Hampton-which has had an operational availability of 97.9%.
LILCO's procedures 'for~ testing this 20 MW gas turbine to assure
'its reliability are described in the Museler Affidavit.
(23)
The 20 MW gas turbine should be able to fulfill
-its function even after'a seismic event.
It is a Turbo Power and MarineL(Pratt and Whitney) gas turbine.
There are no sub-stantive differences between Pratt and Whitney gas turbines specifically designed in accordance with.the seismic building code and the.20 MW unit at Shoreham.
The code requires that machines withstand a.3g horizontal acceleration.
Accordingly, Turbo Power and Marine has assured LILCO that the 20 MW gas turbine would be structurally sound-during a design basis seismic event at Shoreham which would exert only a.2g horizon-tal acceleration and.113g vertical acceleration.
See letter-of John T. O'Brant attached as Exhibit E.7/
7/-
There is no seismic information available.as to the elec-trical panels associated with the unit.
If the unit were op-
-erating, there:is a possibility that it would trip during a de-sign basis earthquake because of relay contact bounce.
It would restart automatically in a deadline mode after conclusion of the seismic' event if-necessary to prevfde AC power.
Howev-er, usually the gas turbine w311 be in a sttrlby mode, ready to run and provide power after such a seismic event has occurred and resulted in some disruption of the normal system power sup-ply.
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> : (24).
In'an effort to minimizc the risk of damage to the fuel tank and associated piping in a seismic event, LILCO will-constantly have available a standby mobile supply of fuel for the 20 MW-gas turbine (and for the 4 mobile diesels dis-cussed below) by having a loaded tanker truck on site at all.
times during low power operation.
MOBILE AC POWER SOURCES (25)
Though not necessary or' required, LILCO will pro-
. vide a sixth.AC_ power source to operate upon the unlikely loss i
of Shoreham's normal-d; signed sources of AC power (i.e.,
in ad-dition to the-blackstart gas turbines at haltsville, the blackstart gas: turbines at-Southhold, East Hampton and Port Jefferson and the 20 MW ilackstart gas turbine at Shoreham),
LILCO is installing at Shoreham a block of four 2.5 MW General Motors'EMD blackstart mobile diesel generators, model 20-645 E-4, to be directly connected into the plant's 4 KV bus network which, _in turn, will provide power to.the emergency 4 KV buses (see (J)-Exhibit A).
This provides the additional benefit of being able to supply power to the emergency 4 KV buses in the
.unlikely event of the simultaneous loss of the NSS and RSS transformers and all three of the TDI diesel generators.
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-(:26) :Th'ese.mobilefdiesel' generators will be able to I
! supply l power'ti the-plant'siemergancy systems within 30 minutes ofz starting the diesels.
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CONCLUSION (27)
Even under system blackout conditions,.there are numerous ways l toe eed' power to Shoreham. 'For example, upon f
' loss of the!LILCO-grid,Lthe multiple units at Holtsville, or
~
the:Southhold,' East Hampton or Port Jefferson gas turbines can
- generate = adequate power.
Upon the inability to start.any ofi (theseisystem blackstartJgas turbines or upon the loss of:the-
. transmission routes.into the. site, the onsite 20 MW gas turbine remains lavailable--and will; start automatically and provide Jpower to'the-RSS transformer. (If that were to fail, there are.
stillofour mobile dieseltgenerators'available to serve. required' cplant loads.8/. A maximum of two.of.the four mobile units 9/
Lwould be. req' ired'for safe shutdown under normal or accident-u conditions. ;Accordingly based'on the historical reliability 4
Jof-the LILCO grid,:-the multiple redundant sourcec of. power available to Shoreham under blackout' conditions and the J8_/c. The three TDI. diesels would also be-available.
See Museler Affidavit at 1--11.
F 9j( nTesting may show1that only one mobile unit will suffice.
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~ multiple transmission paths into the area,-the availability of-
'AC power to Shoreham is reasonably assured and'is considerably
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. greater than contemplated by--applicable NRC. regulations, e-William G.
Schiffmacher STATE OF NEW YORK
)
) To-wit:
COUNTY OF
)
Subseribed and sworn to before me this day of
- March, 1984.
Notary Public My commission expires:
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EXHIBIT C Plant 4 KV System s -
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UNITED Turbo P:w;r cnd Marina Iv.- TECHNOLOGIES systems, Inc.
TURBO POWER 400 Main street East Hartford. Connecticut 06106 203/565-4321 March 1, 1,984 Long Island Lighting Company 175 East Old' Country Road Hicksville, NY 10801 Attention: Mr. Richard Zambratto 1
Gentlemen:
In response to your request for information relative to the seismic resistance capability of TPM FT4 units, the following is offered.
Prior to 1975-76, the structural design of FT4 units incorporated a variety of NEMA, ANSI, ASCE, and AWB specifications, but did not incorporate specific scismic load requirements. Beginning in about 1975, we initiated design incor-poration of the " Universal Building Code" which includes a 0.3g horizontal load requirement, but no vertical load requirement.
The " Universal Building Code" requirement is that the structures and equipment be able to withstand a 0.3g horizontal load, but does not require that the unit operate through that load. We do not know whether installed protective relays and the Rowan relays installed in the FT4 sequencer units could withstand such a load without tripping.
8 Even though the structural design of pre 1975-76 units, which includes the West Babylon and the Holbrook units, did not incorporate the 0.3g horizontal load requirement specifically, it is our opinion that all those units would with-stand the 0.2g horizontal and 0.1139 vertical load requirement you mentioned and still be operable. The concern about operating through such an event with-out tripping relays would still apply.
There is one other minor point worth mentioning: in a Power Pac (one engine, one generator), the engine / generator coupling is rigid and provides a fixed re-straint for the generator rotor which would absorb any axial "g") load withoutIn a Tw significant movement.
generator couplings are the flexible Bendix type which could allow some genera-tor rotor axial movement due to imposition of horizontal load. This axial movement might compress one flexible coupling in the direction of movement and impart a momentary impact load on the power turbine thrust bearing. This remote possibility could result in a peening of the bearing ball / races leading to an eventual failure of the bearing. The restraining stretching action of the opposite end coupling makes this a minor concern.
The gas turbine itself is designed to withstand much higher "g" loads, due to severe flight and military shipboard blast load requirements in the 5-10g range.
i EXHIBIT E
Long Island Lighting Company Page 2 March 1, 1984 I hope this satisfies your immediate need.
If we turn up any additional information, we will pass it along.
Very tr ly yours.
John T. O'Briant Manager, Product Support dfp e
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Lefore the Atomic Safety and Licensing Board In the Matter of
)
1
).
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (OL)
)
-(Shoreham. Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF DR. GLENN G.
- SHERWOOD, DR. ATAMBIR S.
RAO, AND MR. EUGENE C.
ECKERT Glenn G.
Sherwood, Atambir S.
Rao, and Eugene C. Eckert L
being duly sworn, depose and state as follows:
l _
(1)'
My name is Glenn G. Sherwood.
I am employed by the General Electric Company as Manager, Safety and Licensing Operation.
My business address is General Electric Company,
-175 Curtner Avenue, San Jose, California 95125.
I have been employed in this position since 1976.
My responsibilities in-clude supervision of the preparation of licensing submittals for General Electric BWRs, including analyses' performed in
-Chapter 15 of safety analysis reports.
In particular, I have
-been. involved in the supervision of licensing matters for the Shoreham Nuclear Power Station since the initial submittal of
.the Shoreham Final Safety Analysis Report (FSAR).
In this re-gard, I am familiar with the analyses performed in Chapter 15 of that document.
From 1974, when I joined General Electric, w
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, -~to11976, I was-the Manager, Program Control Section.
My respons'ibilities included managing engineering and manufacturing work flow for General Electric's nuclear group.
I have a Bachelor of Science degree in Engineering from the U.S. Naval Academy and a Ph.D. in Engineering from the Univer-sity of Michigan.
(2)
My name is Atambir S.
Rao.
I am employed by the General' Electric Company as Manager, Plant Safety Systems Engi-neering.
My business address is General Electric Company, 175 Curtner Avenue, San Jose, California 95125.
I was appointed to my present position in 1984.
My responsibilities include ECCS performance analysis, containment performance response analy-sis, and plant safety performance evaluations, including FSAR E
' safety analyses.
I have previously held a number of positions relating to accident and transient analyses since I first joined General Electric in 1973.
Earlier responsibilities have included modeling and analyzing the thermal hydraulic behavior of BWR fuel following loss of coolant ~ accidents, assessing the implication of advances in heat transfer, fluid mechanics, thermodynamics and two-phase flow on overall BWR system re-sponse during cransients and loss of coolant accidents, devel-oping emergency operator guidelines, and assessing containment-thermal hydraulic and radiological response for various
c-accidents and transients.
I have been assigned as Manager, Emergency Core Cooling Systems (ECCS) Engineering (1979-80),
and Manager, Containment and Radiological Engineering (1982-84).
I received a Ph.D~and a Masters degree in Mechani-cal Engineering from the University of California, Berkeley, and a Bachelor of Technology in Mechanical Engineering from the
. Indian Institute of Technology, Kanpur, India.
(3)
My name is Eugene C.
Eckert.
I am employed by the General Electric Company as Manager, Power Transient Per-forming Engineering, a position I have held since 1971.
My business' address _is General Electric Company, 175 Curtner Ave-nue, San Jose, California 95125.
I am responsible for estab-lishing the simulation requirements of the computer models needed to perform transient analyses, development of design procedures evaluation of BWR stability, and evaluation and specification of the functional protection systems required for reactor abnormal transient protection.
Immediately upon joining General Electric-Company in September 1959, I partici-pated in assignments which included large jet engine control design, aircraft nuclear propulsion control analysis, nuclear submarine kinetics and control analysis, and industrial control simulation analysis at GE's Research and Development Center.
In 1962, I joined General Electric's Nuclear Energy Division to
v work <ni Boiling Water Reactor simulation and dynamic analysis.
I have been~ responsible'for design and licensing documentation
~
Dof the dynamic analysis for several GE BWRs and have.partici-pated.in initial startup testing of many of the units.
I re-ceived a Bachelor of Science Degree in Electrical Engineering from Valparaiso University in Indiana in 1958.
I attended Stanford University under an Oak' Ridge Fellowship and received a Master of Science Degree in Engineering Science in August 1959.
(4)
Chapter 15 of the Shoreham FSAR provides the re-sults of analyses for the spectrum of accident and transient events that must be acccmmodated by the=Shoreham plant to dem-onstrate compliance 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 safe-ty of the public.
The Shoreham FSAR'was submitted to-the NRC Staff for review and has'been approved'by the Staff in its
-Safety Evaluation Report.for Shoreham (NUREG-0420).
(5)
At the request of the Long Island Lighting Compa-ny, General-Electric, in-conjunction with' cognizant LILCO and Stone & Webster personnel, has reviewed all of the events con-sidered in Chapter 15 of the FSAR to determine the effect on public health and safety of the operation of the Shoreham plant 1
9 YF VP
n I -during-fuel load, criticality testing and low power operations.
Although the FSAR considers all phases of-the operation of the 1 plant from fuel load'to operation at 100% power, this review was performed _specifically to confirm that operation.of the Shoreham plant.during low power operation will pose no undue risk to public health and safety.
The review of Chapter 15 was
-divided into three parts: (1) fuel load and precriticality testing'(Phase I), (2)' cold criticality testing (PhaseLII), and (3)~ low power-testing up to 5% of rated power (Phases III and IV).1/.The review was based upon the same criteria and bases asothe original Chapter 15 analyses.
Where~ assumption of'a loss or unavailability of offsite power was required in the original analyses, pot'ential unavailability of the TDI diesel generators was considered in this review.
(6)
The General Electric review of Chapter 15 con-firms that' operation during_the phases identified above will not result-in any undue risk to the public health and safety.
In= fact,=the risk from any Chapter 15 event during both the t
fuel load and precriticality phase and the cold criticality testing phase is essentially non-existent.
The risk to the 1/
' Parts (1)-and'(2)-correspond to Phases I and II,.respec-tively, as described in the~ Affidavit of Messrs.~Notaro and Gunther.
Part-(3)-corresponds to Phases III~and IV, combined,
-as described in that affidavit.
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- public health and safety from-the Chapter 15 events postulated for low power testing up to 5% of rated power is small in com-parison to the risks already found acceptable for 100% power
'peration.
As already indicated, this review considered the o
impact of. potential diesel unavailability.
Phase I:
Fuel Loading and Precriticality Testing t
(7)
This phase of operation-of the Shoreham plant in-cludes only initial fuel loading and precriticality testing.
The reactor will remain at essentially ambient temperature and atmospheric pressure. -The reactor will not be taken critical.
Any increase in temperature beyond~ ambient conditions will be due only to external heat sources such as recirculation pump heat.
There will be no heat generation in the core.
Details of the steps to be performed during these operations are de-scribed in the Phase I di,scussion in the affidavit submitted by Messrs. Notaro and Gunther.
(8)
The review of the Chapter 15 analysis revealed that of the 38 accident or transi~ent events addressed in Chap-ter 15, 18 of the events could not occur during Phase I because of the operating conditions of the plant.
An additional 5 events could physically occur, but given the plant conditions, could not constitute events-in the context of the Chapter 15
- , safety.. analysis.
The remaining'15 events could possibly occur,
~although_ occurrence is_ highly unlikely given the plant condi-
' tions.:
In any event, it is readily apparent that the potential consequences of these 15 events would be trivial.
Exhibit 1 below lists the category-into which each Chapter 15 event falls.-
(9)
The 18 Chapter 15 events which could not occur during Phase 1 are precluded by the operating conditions of the I'
reactor.
These events all' involve operating modes or component
-operation which are not possible during this phase.
For exam-ple, during fuel loading and precriticality testing, the reac-tor is'. at essentially ambient temperature and atmospheric pres-sure. -Accordingly, no steam'is available.
Thus, all events i
which would require pressurized conditions are precluded.
Events such as turbine trip (FSAR 5-15A.1.2), loss of feedwater heating (FSAR 5 15A.1.8) and inadvertent opening of a safety relief valve require the generation of steam for the event to occur.
Similarly, there is no steam flow to interrupt, thus precluding an MSIV closure event.(FSAR S 15A.1.4).
Other events are precluded.by definition.
Thus, events such as con-
+:
tinuous' control rod withdrawal during power range operation (FSAR 5 15A.1.11) and operation of a fuel assembly in an im-
-proper location (FSAR $ 15A.1.16) cannot be postulated.
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-In addition to the 18 events which simply cannot occur, there are 5-events for which the component operation
-evaluated in Chapter 15 could occur, but the phenomena of in-terest in Chapter 15 could not exist.
All recirculation pump events, such as re irculation pump trip (FSAR $ 15A.1.20) and abnormal startup of an idle recirculation pump (FSAR
$ 15A.1.25), would be of interest only if they could affect core physics or thermal-hydraulic conditions.
With no heat
-generation or boiling in the core, there are no pertinent phe-nomena-(such as temperature differences or void collapses) to evaluate.
Another example, the. core coolant temperature.in-crease event (FSAR S 15.A.1.26), postulates a loss of RHR cool-ing..Even if the RHR system was operated in Phase I, there.
would-be no temperature increase from decay heat to evaluate should.the RHR syster be lost.
(11)
The remaining 15 events addressed in Chapter 15 could possibly occur.
However, our revieu established that all are-trivisl events which have no potential to impact public health and' safety.
Prior to initial criticality, there are_no
-fission products in the core and no decay heat exists.
It fol-lows that core cooling is not required.
In addition, with no fission product inventory, there'are no fission product re-Lleases possible.
Thus, for reactor events such as a control
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_9 rod removal error (FSAR 9 15A.1.13) and a control rod drop
~(FSAR 5.15.1.33) and for.non-reactor events such as a fuel han-dling accident (FSAR $ 15.1.36) or a liquid radwaste tank rup-ture (FSAR $ :U5.1.32), there could be no radiological conse-quences.
Therefore, there is no risk to public health and safety. -
(12)
Even a loss of coolant accident (FSAR S 15.1.34) could have no radiological consequences during Phase I.
No core cooling is required.
No fission product release is possi-ble.
The fuel simply could.not be challenged by a complete draindown.of the reactor vessel for an unlimited period of time.
(13)
In summary,-the review of Chapter 15 events for
. fuel loading and precriticality testing indicates that many Chapter 15 events simply cannot occur, and-for those that can, there can be no radiological consequences.
Therefore, there is no possible risk to the public health and safety.
This conclu-sion is not affected by any postulated diesel generator unavailability because it is in no way dependent on the avail-ability.or unavailability of any AC power.
Phase II:
Cold Criticality Testing (14)
This phase of low power testing of the Shoreham
.: plant will include cold criticality testing of the plant at es-sentially' ambient temperature and atmospheric pressure.
The power level during this phase of testing will be in the range of.0001% to.001% of rated power.
Details of the testing to be performed _during this phase are described in the Notaro Af-fidavit.
-(15)
The review of Chapter 15 revealed-that of the 38 accident or transient events included there', 15 of the events could not occur becat se of the operating conditions of the plant during Phase I.
See-Exhibit 2.
A number of these events are not possible because the reactor will be at essentially
. ambient temperature and pressure and no steam will be gener-
- ated.
For example, the generator load rejection event (FSAR
$ 15A.1.1) could not occur during this testing phase'because steam is~needed to drive the main turbine generator to permit connecting it to the LILCO transmission system.
Another exam-ple, the loss of. condenser vacuum event (FSAR $ 15A.1.21),
.could not occur because it assumes that steam is available to draw a vacuum-in the main condenser.
A third example, the in-advertent HPCI pump start event (FSAR 5 15A.1.10), could not occur because there will.be no steam available to power the HPCI pump,'a' steam driven ECCS pump.
Other Chapter 15 events could not occur because they are precluded by the configuration
11-ofLthe' plant-during this phase of low power testing.
.An. exam-
'ple~of'this type of event is the MSIV. closure (FSAR 5 15A.1.4).
The MSIVs will normally be closed throughout all of the op-erations conducted during this phase of low power testing.
In any event, there is no steam generated by the reactor to flow through:the steam lines.
(16)
In addition to the 15 events that could not occur during Phase I, many of the 23 events remaining in the Chapter 15-analysis are far less likely to occur during low power testingLthan during normal operations.
For example, the recirculation pump trip (FSAR S 15A.1.?O), the recirculation pump seizure (FSAR 5 15A.1.22), the recirculation flow control
-failures-(FSAR 5 15A.1.23 and 24) and the abnormal startup of idl'e recirculation pump (FSAR 5 15A.1.25) events, although physically possible, are not as likely to_ occur because the recirculation pumps are used for only limited periods of time during this phase of the testing program.
Similarly, the loss of feedwater event (FSAR'S 15A.1.18) is very unlikely because little, iftany, make-up water will have to be supplied to the reactor.
Moreover, make-up water would not normally be supplied by'the feedwater system under'these conditions.
Other very unlikely events include miscellaneous small releases out-side primary containment (FSAR 5 15.1.29), off design
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- .- operational transient'as a consequence of instrument line fail-
.ure (FSAR $ 15.1.30), and feedwater system piping break (FSAR 5 15.1.37).
Thus,1many of the Chapter 15 events that are phys-
-ically possible during Phase II remain very unlikely in light of '1e plant conditions that will then exist.
(17) -Nonetheless, all 23 possible events contained in Chapter 15Lwere reviewed to-reaffirm that the consequences of these events,'should one occur during Phase I of low power
-testing, would be bounded by the consequences analyzed for the event considered in the ESAR.
A discussion of some of the 23 possible events contained-in Chapter 15 illustrates the basis for this conclusion.
The continuous control rod withdrawal during startup event (FSAR $ 15A.1.12) is applicable' to op-eration in.the power, source and/or intermediate range of op-eration.
During cold functional criticality testing, the reac-tor will' operate in the source and intermediate ranges and therefore the conclusions contained in Chapter 15 are applica-ble to this event should it occur during this phase of low power testing.
As the FSAR indicates, this event would not re-sult in any release of radioactive material from the fuel at any power level.
Another example is the fuel handling accident (FSAR $ 15.1.36).
As stated in the FSAR, the most severe fuel handling accident from a radiological viewpoint is a dropping
.. of the fuel assembly onto the top of the core.
The FSAR analy-sis-assumes that the fuel contains a fission product inventory equivalent to. operation of 1000 days at full rated power.
This assumption results in an equilibriam fission product concentra-tion at the time the reactor is shut down.
But as already noted, the fission product inventories in the core will be sig-nificantly less during Phase II low power testing than the in-ventories_ analyzed in the FSAR because of the extremely low power levels (.0001% to.001% of rated power) achieved during thia-testing.
Thus, even if a. handling accident took place and fuel damage did. occur, there would be significantly less fis-sion products to be released from the core than those that have already been analyzed and found acceptable in the FSAR.
A third-example is the liquid radwaste tank rupture event (FSAR $
'15.1.32).
.This' event assumes the rupture of a radwaste tank that contains a substantial amount of contaminated liquids gen-erated during the operation of the reactor.
But again, since Phase II low power testing _results in insignificant power lev-els in the reactor,.there will be'little, if any, radioactive liquids in the radwaste tank should such a rupture occur.
Thus, even the minimal consequences already described in the FSAR-for the design basis event would be further reduced under these low power testing conditions.
For each of these events, the review concluded that the consequences are significantly
y>=
less severe for any event occurring during the cold functional criticality: testing than-for the event analyzed in Chapter 15.
To summarize, because of.the extremely low power levels reached during.this testing phase, fission product inventory in the
~
core:wi11 be only a small: fraction of that assumed for the Chapter 15Lanalyses.- As indicated above, the FSAR assumes op-eration at 100%. power for 1000 days in calculating fission product inventory; the. inventory during Phase II low power testing will be less than one one-hundred-thousandth (.00001)
.~of-the fission product inventory assumed in the FSAR.
Conse-quently, none of the events analyzed in Chapter 15 could result in a release'of radioactivity during' cold criticality testing
-that would harm the public health and safety.
(18)
The review of Chapter 15 events for Phase II testing.and the conclusions reached are unaffected by any-unavailability of the TDI diesels.
Of the'23 possible Chapter 15 events reviewed,_20 of the events _in-the FSAR do not require the assumption of loss or unavailability of offsite AC power.
-See Exhibit 2.
Thus,.our conclusions for these 20 of the 23 possible. events are independent of the status of the diesels.
(19)
The three events that do assume loss or unavailability of offsite AC power are (1) pipe breaks inside the primary containment (LOCA) (FSAR 5 15.1.34), (2) feedwater 1
L system piping break (FSAR $ 15.1.37), and (3).the loss of AC powerfevent!(FSAR $ 15A.1.19).
With' respect to these events, i
_ the LOCA would be the most limiting event.
The review has-shown that if a LOCA did occur during the cold criticality testing phase, however remote that possibility, there would be-time on.the orderfof months available to res' tore make-up water for core cooling.
At the power levels achieved during Phase I I ', fission prod 4ct' inventory _is very low.
At most, decay heat will, on the average, be a fraction of a watt per rod, with no single rod exceeding approximately 2 watts.
This is less, roughly, than the heat output of a Christmas tree bulb.
It
- follows that the fuel cladding temperature would not exceed the
. limits of 10 CFR $ 50.46 and Appendix K even after months with-out cooling and without any source'of AC power.
(20)
The loss of AC power event (FSAR 5 15A.1.19) and the-feedwater system piping break (FSAR $ _15.1.37) under cold -
- criticality testing conditions do not rely on the diesel gener-ators fo' mitigation of the event.
For these events, since no r
-loss of coolant occurs and the. decay heat is minimal, core cooling is achieved, without AC power, using the existing core water inventory and heat losses'to ambient, for essentially un-limited periods of time.
In any event, as demonstrated in the Schiffmacher Affidavit, AC power sources can and will be
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a readily supplied to the Shoreham plant even if one assumes the simultaneous loss of all three emergency diesel generators.
(21)
In addition to our conclusions that the limiting LOCA event could not approach the limits of 10 CFR S 50.46 and
' Appendix K during Phase II low power testing, there are other reasons why.our findings with respect to the three events that
.aasume loss of AC power are independent of the availability of the.TDI diesels.
The LOCA (pipe break inside containment) and the feedwater system piping break postulate the double ended rupture.of a piping system.
Because the reactor will be at es-sentially ambient temperature and atmospheric pressure during Phase II, it is extremely unlikely that such a pipe break would ever occur.
In fact, the NRC Staff does not require double ended ruptures to be postulated for low temperature and low pressure systems in safety analyses.
Thus, these events are much less likely during cold criticality testing than during normal operation.
(22)
The review of Chapter 15 events for cold criti-cality testing indicates that performance of these activities at Shoreham involves essentially no risk to the public health and safety.
This conclusion is not affected by any postulated diesel unavailability.
In fact, even if AC power were not available for extended periods of time, fuel design limits and
i s
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f designiconditions of the reactor coolant pressure boundary-
- would'not be approached or. exceeded as a result of anticipated operational occurrences, and the core would be adequately cooled Anlthe unlikely event of a postulated accident.
Phases III and IV:
' Low Power Testing Up To 5% of Rated Power 4
(23)
-These-aspects of low power testing.will include operation of the plant at power levels up to 5% of rated power.
I Details of the testing-to be' performed during this phase of'op-
- eration are described as Phases III and IV in the Notaro Affi-
- davit)
'(24).The review of the 38 Chapter 15 events for these phases of. low-power testing operations revealed that two of~the i events in Chapter 15, generator load rejection (FSAR $ 15A.1.1) j and turbine trip'with' generator breaker failure-(ESAR $ 15.1.2)
~
cannot occur because the generator will not be' connected to the-g-
grid during these phases of testing.
A third event, the cask drop; is precluded by' design as stated in FSAR 5 15.1.28.
See I
Exhibit-3.
(25)
Of the-remaining 35 events-that can occur during this phase of operation, 31 of the events do not assume loss or unavailability,of AC power..-For each of these 31 events, 1 s_
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- -operationt of the plant up'to 5% of rated power will be bounded
.by the Chapter.15 analysis.
Since the Chapter 15 analysis con-siders:all possible phases of plant operation, it follows that
~ operation at 5% can result in consequences less severe than those analyzed in Chapter 15..For example, the turbine trip event'(FSAR 5 15A.1.2) assumes that the limiting event occurs with the reactor operating at 105% of rated steam flow coupled with failure of the turbine bypass valves to open.
Even this climiting event does not result in any fuel failures.
FSAR $
- 15A.1.2'specifically-notes that turbine trips at power levels less than 30% of rated power are bounded by the limiting analy-sis.
Another example is the loss of feedwater heating event
'(FSAR $ 15A.1.8).
This event assumes continuous operation of the.feedwater system and the most severe possible loss od
!feedwater heating, resulting in the injection of colder
For operation at power levels less than 5%, the im-pact'of lost feedwater heating is minimal because of the low feedwater flow.
Since these analyses are not required to as-sume the absence of AC power, potential unavailability of the TDI: diesels has no effect on the assessment of these events.
(26)
Not only are the results of these 31 events bounded by the Chapter 15 analysis, the consequences of these events are also less than the consequences stated in the FSAR.
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First,fthe power limitations during low power testing up'to-5%
-power,.the fission product inventory!in the. core will not ex-
-ceed 5% of the values assumed in the-FSAR.
In fact, because of the intermittant type of operations conducted during low power
. testing,- equilibrium fission product inventory for even 5%
power is.unlikely.to be achieved.
This low fission product in-
.ventory reduces risk-in two ways:
(a) the amount of decay heat present in the core.following shutdown is substantially re-duced,-and-(b) the amount of radioactivity that could be re-leased:upon fuel failure is substantially reduced.
(27)
The second factor contributing to the signifi-cantlyflower risk during low power operation is the increased time available for preventive or mitigating action should such action be deemed deeirable by the operator.
Longer time is available-because the limited power levels mean that~it_ takes longer for the plant to reach setpoints and-limits.
For exam-ple, (nt ; loss of. feedwater (FSAR S 15A.1.18), the water level in'
.the reactor will decrease at a slower rate than if the event occured at 100% power.
This.gives the operator more time to act' manually to restore feedwater before an automatic action
~ takes place.
Similarly, in the loss of condenser vacuum event
_(FSAR i l5.A.1.21), the operator will have more time to identi-fy the decreasing vacuum and to take steps.to remedy the
. ~. -.-... -.
's g ~
situation.before automatic actions such as turbine trip, feedpumpftrip or main steam' isolation occur.
Another example
.is-the. main steam isolation valve closure event (FSAR
'll15A.1~.~4).
At-five percent power, the amount of heat produced
^
upon isolation of the reactor. vessel.(which is followed by a reactoriscram)sresults in a much slower pressure and. tempera-
'ture. increase than would be experienced at 100% power.
This
.gives.the operator more time to manually initiate reactor cool-z ingirather.than relying on automatic action.
In effect, the operator may end.the transient before there is any substantial impactfon the. plant.
=(28)
The third: factor contributing to the signifi-cantly lower risk duringnlow power testing is the reduction in the required capacity for mitig'ating systems.
Because of the lower. levels'of decay-heat present following operation at 5%.
l power,-the demand for core cooling and auxiliary systems is substantially~ reduced, permitting.the operation of fewer sys-
'tems.and components to mitigate any event.
It follows that the AC power; requirements-for event mitigation are substantially reduced for'5% power. operation as compared to 100% power op-eration.
(29)
Jus already:-noted, only four of the events ana-i.lyzed.:in Chapter 15 require,the assumption of the
~
5,-
- ~
' unavailability of;offsite AC power for operation during Phases
- III and=IV. 'Of these fourJevents, the-loss of coolant accident is the most limiting event. ~The Chapter 15 LOCA analysis as-
.sumes the; unavailability of offsite AC power.
This is c con-servative licensing' assumption.
In fact, as described in de-
- tailnin the Schiffmacher Affidavit, there are multiple sources
- of AC power-available to the Shoreham site (e.g.,
emergency diesel: generators, two normal sources of offsite power,
'blackstart gas turbines at Holtsville, Southhold, and East 1Hampton, a blackstart gas-turbine on the Shoreham site, and mo-bile diesel generators).
Thus, AC power will be available at
~
Shoreham;to-mitigate a-loss _of coolant accident during low powercoperations'up'to 5% rated power.
In the unlikely event offsite AC power is lost, it can be restored within sufficient time to prevent exceeding the limits of 10 CFR $ 50.46 and Ap-pendix.K.
GE has determined that for 5% power so long as
.reflooding of the core has occurred within_approximately one
-hour,16 50.46 criteria.will be met.2/
As the Schiffmacher Af-fidavit demonstrates, power can be restored to Shoreham within minutes.' An' evaluation has been performed to assure the ade-quacy of cont'ainment-isolation in the event AC power sources
- 2/
.As shown in the Exhibit 4 below, lower power levels will
. result in more time to restore power and core cooling for a
. postulated =LOCA.
Thus, for 1% power approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> are available.
s,-
, cannot provide _immediate isolation in a LOCA.
Based upon the 7results'of this evaluation, we have concluded that through the
.use of-. appropriate manual action, containment isolation can be
-accomplished in a timely manner.
-(30)
For the other three events, (1) loss of AC power.
(FSAR:5'15A.1'.19), (2) pipe break outside containment (PBOC)
-(steam line break' accident) (ESAR 5 15.1.35) and (3) feedwater system piping break (FSAR 5 15.1.37), the reactor would auto-matically isolate.
This isolation is not dependent upon the availability of AC power.
For-all three events, both HPCI and RCIC would be~available to provide reactor coolant makeup.
Given the heat' capacity of passive heat sinks such as structur-al steel, suppression pool cooling would not be required for about-30. days.
Therefore, there is ample time for AC power to
~be restored..Furthermore, assuming loss of offsite power in o
the context of pipe breaks outside. containment (main steam line break accident and feedwater system break accident) is a con-servatism which stems from the PBOC analysis methodology.
That methodology requires the assumption of a loss of offsite power
.for pipe breaks which result directly in a plant trip of the turbine generator system or: reactor protection system.
Not-withstanding grid stability analyses, it is assumed that plant
-trips could cause perturbations of the grid, resulting in the
For operation at 5% power or less, how-
.ever, the turbine generator is not. connected to the grid, and therefore any assumption of induced perturbation to the offsite grid ~is not valid.
(31)
Based on our review of Chapter 15, operation of the plant during low-power testing up to levels of 5% of rated power posesino undue risk to the public health and safety.
In fact, any risk is substantially less than that already found to be acceptable by the NRC Staff in its review of Chapter 15.
Even if the Shoreham TDI diesels are assumed to be unavailable, there is ample assurance that fuel design limits and design conditions of the reactor coolant pressure boundary will not.be exceeded.as a result of anticipated operational occurrences, and that the core will be cooled and containment integrity and other vital _ functions will be maintained in the event of any postulated accident.
Glenn G.
Sherwood Atambir S.
Rao Eugene C.
Eckert
.:r,
~ - STATE OF
-)
)
To-wit:
COUNTY'OF
.)
Subscribed to before me this _ day of March, 1984.
. Notary Public
= My commission' expires:
s f
s b
4 Exhibit 1 FUEL LOAD AND PRECRITICALITY TESTING 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 Event-not possible.
Component operation possible but Chapter 15 phenomena
.cannot occur.
Event possible but no consequences.
. 112.
Continuous Rod _ Withdrawal During Reactor Startup-13.-
Control Rod Removal Error During Refueling
- 14. -
Fuel Assembly Insertion Error During Refueling 15.
Off-Design Operational Transients DueEto 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.
Los:s of AC Power
- 20. '
. Recirculation Pump Trip 21.
Recirculation Pump' Seizure 23.
Recirculation Flow Control Failure -
Decreasing Flow
.24.
Recirculation-Flow Control Failure With Increasing Flow 25.
Abnormal Startup of Idle J,
. Recirculation Pump 26.
Core Coolant Temperature Increase
~ 2 '7.
Anticipated-Transients Without SCRAM (ATWS) 28.
, Cask Drop Accident 29' Miscellaneous Small Releases outside Primary: Containment n
30.
Off-Design Operational Transient as a Consequence of Instrument Line Failure 31.
' Main Condenser Gas Treatment System Failure 32.
Liquid Radwaste Tank Rupture 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 37.
Feedwater System Piping Break 38.
Failure of Air Ejector Lines
/
I
=
Exhibit 2 t
COLD CRITICALITY TESTING Assumes Un-Event availability Chapter 15 Event Category of Offsite AC 1.
Generator Load Rejection N/A 2.
Turbine Trip N/A 3.
Turbine Trip with Failure of Generator Breakers to Open N/A 4.
MSIV Closures N/A 5.
Pressure Regulator Failure - Open N/A 6.
. Pressure Regulator Failure - Closed N/A 7.
Feedwater Controller Failure -
Maximum Demand No 8.
Loss of Feedwater Heating N/A 9.
Shutdown Cooling (RHR) Malfunction -
Decreasing Temperature No 10.
Inadvertent HPCI Pump Start N/A 11.
Continuous Control Rod Withdrawal During Power Range Operation N/A
~*
Event not possible.
Event possible but essentially no consequences.
=. -
12.
Continuous Rod Withdrawal During Reactor.Startup No 13.
Control' Rod Removal Error.During Refueling' No 14.
Fuel Assembly Insertion Error
'During Refueling No 15..
Off-Design Operational Transients I
Due to Inadvertent Loading of a
- Fuel. Assembly into an Improper Location No
- 16..
Inadvertent Loading and operation of a Fuel Assembly in' Improper
-Location No 17.
'Ina'dvertent opening of a Safety / Relief Valve N/A 18.
Loss of Feedwater Flow No 19.
Loss of AC Power Yes 20.
Recirculation Pump Trip No 21.
Loss of Co'ndenser Vacuum.
N/A L22.
Recirculation Pump Seizure No 0.
.23.
-Recirculation Flow Control Failure -
~
Decreasing Flow No 24.
Recirculation. Flow Control' Failure With Increasing Flow No
- 25.
Abnormal-Startup of Idle-Recirculation Pump No 26.
Core Coolant Temperature Increase No 27.;
Anticipated Transients Without SCRAM (ATWS)
No 28.
- Cask Drop Accident N/A 29.
Miscellaneous Small Releases-
'Outside Primary Containment No F -
L
.. 30.
Off Design Operational Transient as a Consequence of' Instrument Line Failure No 31.
Main Condenser Gas Treatment System. Failure N/A 32.
Liquid _Radwate Tank Rupture No 33.
Control Rod Drop Accident No 34.
Pipe Breaks Inside the Primary Containment'(Loss of Coolant Accident)
Yes 35.
1 Pipe Breaks Outside Primary Containment (steam line break accident)
N/A 36.
Fuel Handling Accident No 37.
Feedwater System Piping Break Yes 38.
Failure of Air Ejector Lines N/A
Exhibit 3 5% POWER Assumes Un-Event availability Chapter 15 Event Category of Offsite AC 1.
Generator Load Rejection N/A 2.
Turbine Trip No 3.
Turbine Trip with Failure of Generator Breakers to Open N/A 74.
MSIV Closures No 5.-
Pressure Regulator Failure - Open No 6.
Pressure Regulator Failure - Closed No 7.
Feedwater Controller Failure -
Maximum Demand No 8.
Loss of Feedwater Heating No 9.
Shutdown. Cooling.(RHR) Malfunction -
. Decreasing Temperature No 10.
Inadvertent HPCI Pump Start No 11.
Continuous Control Rod Withdrawal During Power Range Operation No Event cannot occur.
Bounded by_same event at higher power level per FSAR Chapter 15.
0 y
e 12.
Continuous Rod Withdrawal During
-Reactor Startup No 13.
Control Rod Removal Error During i
Refueling No 14.
Fuel Assembly Insertion Error
~During, Refueling No.
.15.
'Off-Design Operational Transients Due.to Inadvertent Loading of a Fuel Assembly Into an Improper Location No 16.
Inadvertent Loading and Operation of a Fuel Assembly in Improper Location No 17.
Inadvertent Opening of a Safety / Relief Valve No 18.
Loss of Feedwater Flow No 19. -
Loss of AC Power Yes 20.
Recirculation Pump Trip No 21.
. Loss of Condenser Vacuum No 22.
' Recirculation Pump Seizure No a
23.
Recirculation Flow Control Failure -
Decreasing Flow No 24.
Recirculation Flow Control Failure -
With Increasing Flow No 25.
Abnormal Startup'of Idle 1 Recirculation Pump No 26.
Core Coolant Temperature-Increase No 27.
Anticipated Transients Without SCRAM (ATWS)_
No 28.
Cask' Drop Accident.
N/A 29.
Miscellaneous SmaliLReleases Outside Primary' Containment No
. 30.
Off Design Operational' Transient as a Consequence.of Instrument Line Failure ~
No l
.31.
. Main Condenser Gas Treatment System Failure No 32.
-Liquid Radwaste Tank Rupture No 33.
' Control Rod Drop Accident!
No 34.
' Pipe Breaks Inside the Primary Containment (Loss of Coolant Accident)
Yes 35.
Pipe Breaks Outside Primary Containment (Steam Line Break Accident)
Yes 36.
Fuel Handling Accident No 37.
Feedwater System Piping Break Yes 38.
Failure of Air Ejector Lines No
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF WILLIAM J. MUSELER William J. Museler, being duly sworn, deposes and states as follows:
(1)
My name is William J. Museler and my business address is Long Island Lighting Company, Shoreham Nuclear Power Sta-
- tion, P. O. Box.618, Wading River, New York 11792.
I am Direc-tor, Office of. Nuclear, for LILCO, reporting directly to the Vice President, Nuclear.
My duties and responsibilities as Di-rector of the Office of Nuclear include the technical direction of tlia Shoreham diesel generator recovery effort, tha coordination of the Company's licensing activities relating to Shoreham, and acting directly for the Vice President, Nuclear, aus directed and in his absence.
(2)
I have been employed by LILCO since 1973, holding the following positions:
's
-t r
< 1981-83 Manager of Construction and Engineering responsible for supervision of the UNICO Construction, Engineering and Licensing activities for Shoreham.
-1980-81 Assistant Project Manager of Construction responsible for all Shoreham construction activities.
1977-80~
Assistant, Project Manager for Engineering, Licensing and Cost at Shoreham responsible for supervision of all LILCO and. contractor activities in these areas and for estab-lishing Company positions relating to NRC licensing review of the FSAR.
1975-77' Mechanical Construction Engineer at Shore-ham responsible for monitoring onsite mechanical effort (e.g.,
piping, welding, mechanical equipment).
1973-75 Assistant Project Engineer on Shoreham and Jamesport responsible for reviewing base plant design, ensuring the procurement docu-ments reflected appropriate design require-ments, and preparing various licensing docu-ments for the FSAR.
(3)
Prior to joining LILCO, I served as Deputy Director
.of the-Hydrogen Track Chamber (80") at the Brookhaven National
' Laboratory, and-as an Associate Staff Engineer at Comb:Istion Engineering with development and test reponsibilities associ-ated with HWOCR and'PWR systems.
I have also worked for EBASCO
, Services as Project Engineer responsible for all engineering T'
~
(;
~ activities associated with the Allens Creek Nuclear Power Sta-il
./ tion (BWR).
'I have a Bachelor's Degree in Engineering Science, j:{
~
t p
~
a: Master of Science Degree in Mechanical Engineering, and I y
4:
, have completed one year of post-graduate work in nuclear engi-
~
neering at the University of Florida with additional courses in lindustrialLmanagement from the Polytechnic Institute of Brook-lyn.
I-have held'AEC-Reactor Operator licenses on research re-actors.at'th'e. University of Florida and at Worcester Polytech-nicEInstitute.
I am a member of the American Nuclear Society and have served as. Chairman of the Long Island Section of the
- Society.
(( 4 ) - The purpose of this Affidavit is to set forth the commitments and procedures LILCO has made and will adhere to
.during specified portions of LILCO's low power testing program
-(Phases II-IV) = in orde.r to provide additional' assurance that reliable AC power will always be available to'Shoreham during
- these activities and that challenges to tJun reactor safety sys-
~
tems will be minimized.
As Director, Office'of Nuclear, I am
- authorizedLto speak on-behalf of LILCO with respect to these
~
commitments and procedures for the fuel-load and low power testing, phases.
(5)
The major challenges to Shoreham's offsite power sup-ply fall generally into two categories.
The first relates'to
. transients induced by the loss of. major generating units on
.LILCO's system or by outside events transmitted to the LILCO
5 e grid via its interconnections.
With respect to these events, the FSAR demonstrates that the LILCO grid will remain stable assuming the loss of the largest LILCO generating unit.
FSAR $
8.2.2.2.
This analysis uses the Northport Station, which con-sists of fo r separate units (Units 1-4) at 340 MW each.
It is extrd;nely unlikely that all four units would be lost in a sin-gle event, as is assumed in the FSAR analysis.
Therefore the severity of the analyzed transient is unlikely ever to be expe-rienced.
Moreover, procedural and physical modifications to LILCO's system have greatly reduced the already unlikely possi-bility of losing offsite power to Shoreham as a result of tran-sients initiated through LILCO's interconne-tions.
See Schiffmacher Affidavit generally and especially paragraph 10.
(6)
The second general category of challenges to Shoreham's offsite power' supply consists of weather and seismic related events.
The frequency and severity of these events for the Shoreham area are discussed in FSAR 55 2.3, 2.4 and 2.5.
As stated in FSAR 52.3.1.3, the probability of a tornado strik-ing the site is one in 23,200 years.
FSAR $2.5.2.5.7 notes that the' site is located in an area of low seismicity.
In ad-dition, as stated in the the FSAR, it is estimated that the maximum earthquake intensity experienced at the site has been IV-V (Modified Mercali scale).
Id.
An intensity V (MM)
4 l
u earthquake can be correlated.to a maximum horizontal ground ac-celerationJof 0.03g'which is significantly less-than the design basis earthquake acceleration'of 0.2g.
(7)
In' order :to provide added assurance of safety during
~
the in'itial criticality and low power testing Phases II, III
~and IV,,LILCO has committed to initiate procedures immediately to place the reactor in a cold shutdown condition in the event of any of the following:
t
.(a) a " hurricane' warning" for the Shoreham area, issued by the National Weather Service; (b) a " tornado warning" for the Shoreham area issued.by the National Weather Service; (c). a " severe storm warning" for the Shoreham area issued by.the National Weather Service; (d) a prediction for the Shoreham area by the National Weather Service of abnor-mally high tides greater than-5 feet above mean'high water within 24zhours; o
(e)
'an-indicationJof-seismic activity of
.Olg on the Shoreham seismic moni-
. tors;1/
.(f) 1the outage of two of the four LILCO
- interconnections to Consolidated 1/
LThe Shoreham seismic monitor alarms at this level (.Olg),
.which is only 10% of.the level currently requiring the initiation'of shutdown procedures.
.This level of seismic ac-
- tivity is also only 5% of the SSE seismic activity.
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- Edison and the New England Power Grid; and (g) a low electrical frequency condition which causes an alarm on the LILCO transmission system.
These commitments provide added assurance that cold criticality and low power testing-up to and including 5% (Phases II, III and IV) will be accomplished under conditions optimum for ensuring the highest' reliability of the AC power supply to Shoreham and the minimum risk of having a loss of AC power-while the reactor is critical.
(8)
In addition, with regard to alternative sources of AC power for Shoreham, LILCO has committed to, and will ensure that, the following operational steps are taken to provide yet additional assurance of AC power reliability for Shoreham dur-ing Phases III and IV of low power testing.
LILCO will:
(a) demonstrate on a biweekly basis through an actual test'that the Holtsville blackstart gas turbines can supply power to Shoreham in less than 15 minutes; (b) demonstrate on a biweekly basis through an actual test that the 20 MW gas turbine at Shoreham can be manu-ally started, synchronized and loaded to at least 13 MW on the grid; 4
(c) demonstrate on a monthly basis that the 20 MW gas turbine at Shoreham will start automatically on a loss of grid voltage signal;
6 o (d) demonstrate on a biweekly basis that the East Hampton and Southhold gas turbines can be manually started, syn-chronized and loaded to at least 50%
capacity on the grid; and (e) demonstrate on a biweekly basis that at least 3 of the 4 mobile diesel gen-erators on site can.be manually started and operated at rated speed.
(9)
If:any one of the surveillance tests described in paragraph 8 are unsuccessful, corrective action will be taken within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant will immediately initiate proce-dures to place the reactor in a cold shutdown condition.
(10)
As described in Mr. Schiffmacher's affidavit, LILCO has provided more than the number of offsite power sources re-quired by regulation.
Importantly, some of the supplemental offsite power sources provided by LILCO are, in fact, located onsite at Shoreham.
(11)
During Phases III and IV, of the low power testing, LILCO further commits that Shoreham plant will not be operated until the three TDI di'esel generators at Shoreham have-complet-ed-their preoperational test program as well as subsequent in-spection and refurbishment in accordance with LILCO's enhanced maintenance program.
During these phases, LILCO will comply with all applicable _onsite power technical specifications.
The
4
.o!
_g_
technical specifications contain_ requirements for demonstrating operability of the AC power sources (including the TDI diesels) or shutting down the plant when portions of the offsite power supply or-the diesels are inoperable.
For example, if one die-
.sel or-one offsite power circuit is unavailable, LILCO must demonstrate that one diesel is operable by starting it within
.one hour and then once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
If the Inop-erable diesel or offsite circuit is not restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />,1the. plant must be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Other requirements exist for the unavailability of various com-
'binations of power sources.
The technical specifications also
.contain surveillance testing requirements for the diesels, the frequency of which is related to the performance of the diesels in previous. tests.
Thus, compliance with technical specifica-tions will ensure that the TDI diesels are tested on a schedule consistent with their demonstrated in-service reliability.
~.
(12)
-In summary, during appropriate' phases of the low power test program, LILCO.will establish additional administra-tive procedures relative to reactor shutdown in the event of a potential challenge to the offsite power system; will estab-lish, through periodic testing, that the supplemental offsite power supplies to Shoreham are-reliable during this low power
P
~L o
-9 testing peri 6d; and will adhere to the appropriate technical specifications for'the TDI diesels as indicated above.
These additional measures will further ensure that the operation of the.Shoreham-Nuclear Power Station for fuel loading and op-feration'~up to 5% thermal power (Phases II-IV) will pose a neg-ligible risk to the health and safety of the public.
William J. Museler STATE OF NEW YORK
)
)
To-wit:
COUNTY OF SUFFOLK
)
Subscribed and sworn to before me this day of March,
-1984.
Notary Public My commission expires:
l