ML19263B022

Motion of Summary Disposition of Suffolk County Contention 14a.Allegations Re Turbine Generator Raise No Matl Issues of Fact.Contention Is Ripe for Summary Disposition in Favor of Applicant

ML19263B022
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/18/1978
From:	Whittemore F HUNTON & WILLIAMS
To:
Shared Package
ML19263A941	List: ML19263A958 ML19263A964 ML19263A985 ML19263B002 ML19263B005 ML19263B022 ML19267A293 ML19267A306 ML19267A308
References
NUDOCS 7901040041
Download: ML19263B022 (8)

Text

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UNITED STATES OF AMERICA p NUCLEAR REGULATORY COMMISSION y y? 1

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• LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

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(Shoreham Nuclear Power Station, ) Unit 1) ) Motion for Summary Disposition of SC Contention 14a

1. Suffolk County (SC or County) contention 14a was accepted by the Board only for purposes of discovery because it was insufficiently particularized. Tr. 75, 121. This conten-tion reads as follows:

14a. Intervenors contend that the Applicant has not adequately demonstrated that the Shoreham nuclear plant meets the require-ments of 10 CFR Part 50, Appendix A, Criteria [ sic] 4, Environmental and Missile Design Bases, with regard to turbine orientation and/or missile shields. - SC's Amended Petition to Intervene at 18 (Sept. 16, 1977).

2. This contention has been clarified in SC's Response to Applicant's Second Set of Interrogatories at 32-33 (Jan. 31, 1978) and SC's Particularized Contentions at 14-1 to 14-4 (Nov. 30, 1978). In these filings the County alleged:

a. That Regulatory Guide (Reg. Guide) 1.115 requires that the turbine generator be oriented in a certain way with respect to the reactor; 79010400Y( C

b. That the orientation of Shoreham's turbine generator violates this alleged regulatory guide requirement; and

c. That a thorough probability analysis should be performed for Shoreham's turbine missiles.

3. These allegations raise no genuine issues of fact for the following reasons:

a. Contrary to SC's first allegation, set out above, Reg. Guide 1.115 does not require that the turbine generator be oriented in a particular manner with respect to the reactor.

Turbine orientation is but one of three acceptable methods set out in Reg. Guide 1.1151/ for ensuring that the risk to an essen-tial system from turbine missiles is acceptably low. The other two are (1) protecting essential systems that are in the missile strike zones with barriers and (2) demonstrating that any unpro-tected essential systems are so small or far away from the tur-bine that the sum of the probabilities of those systems being damaged, assuming the release of a low-trajectory missile, is less than 10-3 (one in 1000 per year). Although the Staff stated that turbine orientation was the preferred method of pro-tecting essential systems, it acknowledged that " plants with less than favorable turbine orientation have been found accept-able." Reg. Guide 1.115 at 1.115-3. 1/Reg. Guide 1.115 provides guidelines for protecting the plant against low-trajectory turbine missiles, which travel in essen-tially a straight line from the turbine to the point of impact. These missiles are distinct from high-trajectory missiles, which travel over an arcing course.

h. Shoreham's essential systems are adequately protected under both the missile barrier and low probability methods. See Affidavit of Robert M. Kascsak at 11 3-4.

Thus Shoreham complies with Reg. Guide 1.115 and Criterion 4.

c. A thorough turbine missile probability analysis has been performed for 5horeham. That analysis is set out in FSAR S 10.2.3 and shows that the risk from turbine missiles at Shoreham is acceptably low. See Affidavit of Robert M.

Kascsak at 11 2-4. Therefore, no further analysis is war-ranted.

d. Furthermore, great care was taken in the design of the turbine generator to minimize the potential for turbine missiles. This was accomplished by selecting _the best materials and by providing redundant controls to minirize the possibility of dangerous overspeeds. See Affidavit of Robert M. Kascsak at 1 5.

4 For the above reasons, SC's contention 14a raises no genuine issue of fact. Accordingly, under 10 CFR S 2.749, it is ripe for summary disposition in favor of the Applicant. We request that disposition. Respectfully submitted, LONG ISLAND LIGHTING COMPANY

                                        /         b/ & &

F. Case Whittemore W. Taylor Reveley, III Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 nATED: December 18, 1978

SC 14a UNITED STATES OF AMFRICA 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

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(Shoreham Nuclear Power Station ) Unit 1) ) AFFIDAVIT OF ROBERT M. KASCSAK Robert M. Kascsak, being duly sworn, states as follows:

1. I am Project Engineer of the Shoreham Nuclear Power Station. A statement of my professional qualifica-tions is attached.

2. A thorough analysis of the probability of a turbine missile damaging an essential system at Shoreham has been per-formed. This analysis, which is set out La FSAR S 10.2.3, demonstrates that the probability of a turbine missile damaging an essential system is negligible.

3. Reg. Guide 1.115 states that an essential reactor plant system in the missile strike zone, as defined in Reg. Guide 1.115 at 1.115-2, is adequately protected against low-traj ectory turbine missiles "if no missile can compromise the final barrier protecting an essential system." Reg. Guide 1.115 at 1.115-4.

Shoreham's only essential systems in the missile strike zone are those systems in the reactor building and the screen well.

FSAR Fig. 10.2.3-1. There is a total of nine feet of concrete between the turbine and the systema,in the reactor building, and six feet of concrete protect the systems in the screen well. Id. at 10.2-7. These concrete barriers were analyzed in accordance with the criteria recommended by Bush,1I which include the angle of impact on the affected structure and the thickness of concrete between the turbine and the essential system. Id. at 10.2-6. In both cases the concrete barriers are so thick that they would not be compromised. Id. at 10.2-7. Therefore, the Shoreham design meets the criteria in Reg. Guide 1.115 for protecting essential systems with missile barriers. 4 Reg. Guide 1.115 also states that all essential sys-tems that are not shielded by a missile barrier will be consid-ered adequately protected if they are so small and far away from the turbine that the sum of the probabilities of a low-traj ectory missile damaging such systems , assuming the release of such a missile, is less than 1 x 10

                                                  -3 . Reg. Guide 1.115 at 1.115-4. Shoreham meets this criterion becaus'e there are no essential systems located in the missile strike zone that are not protected by a missile barrier.       See paragraph 2 above.

5. Great care has been taken in the design of the tur-bine generator to minimize the possibility of material failures.

Also, the turbine generator unit is protected against dangerous 1/ 3ush, S.H., " Probability of Damage to Nuclear Ccmpenents due to Turbine Failures," Nuclear Safetv, Vol. 14, No. 3, May-June 1973. This authority was cited by the Applicant on page 10.2-t1 of the FSAR and by the Staff La Reg. Guide 1.115 note 1.

e overspeed by redundant speed control ~ systems. The electrohy-draulic control (EHC) system controls the speed during normal and transient conditions. If the EHC system speed control fails, either a mechanical overspeed or a backup overspeed sys-tem shuts down the turbine generator unit. FSAR 55 10.2.2, 10.2.7. Robert M. Kascsax Subscribed and sworn to before me this 4 6 Y day of December 1978. d a A MotaryPublicM My Commission Expires: /))7 m [M '[[[ I p .. . .

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QUALIFICATIONS OF ROBERT M. KASCSAK My name is Robert M. Kascsak. My business address is Long Island Lighting Company, Shoreham Nuclear Power Station, P. O. Box 618, Wading River, New York. I am currently Proj ect Engineer of the Shoreham Nuclear Power Station, which position I have held since January 1976. As such, I am responsible for the review and approval of de-sign activities prepared by our Architect / Engineer, Nuclear Steam Supply System Vendor, and LILCO in-house engineering de-partments. I graduated frc anhattan College in 1969 with a Bachelor of Mechanical Engineering degree. In 1977 I received a Masters of Science degree in Nuclear Engineering from Poly-technic Institute of New York. I have completed training courses in BWR and PWR technology. In 1969 I joined Long Island Lighting Company as an Assistant Engineer in the Mcchanical and Civil Engineering Department. I worked in various fossil fuel power station proj ects in the capacity of Associate and Senior Engineer. In particular I was involved in the late stages of the North-port Power Station Unit 3 and the early stages of the North-port Power Station Unit 4 mechanical engineering design. From July 1974 to March 1975 I served as LILCO Lead Mechanical Engineer for the Shoreham Nuclear Power Station and the Jamesport Nuclear Power Station. In March 1975 I

joined the Shoreham Project Group as an Assistant Project Engineer, after which I assumed my present position. I am a registered Professional Engineer in New York State and a member of the American Society of Mechanical En-g ine e r.5 . P e}}