ML20023D088

Supplemental Paragraphs to Be Included in Proposed Opinion & Supplemental Proposed Findings on Suffolk County Contention 11 Re Valve Failures.Certificate of Svc Encl

ML20023D088
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/16/1983
From:	Flanagan D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
NUDOCS 8305190208
Download: ML20023D088 (9)

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UNITED STATES OF AMERICA  :%,h t -

NUCLEAR REGULATORY COMMISSION

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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) )

LILCO'S SUPPLEMENTAL PARAGRAPHS FOR INCLUSION IN ITS PROPOSED OPINION AND SUPPLEMENTAL PROPOSED FINDINGS ON SC CONTENTION 11 - VALVE FAILURES Pursuant to the Board's " Memorandum and Order Providing For Further Filings on Suffolk County's Motion to Reopen the Record on Contention 11" (April 28, 1983), LILCO submits the following supplemental paragraphc for inclusion in its proposed opinion and supplemental proposed findings. These supplements are to be used if the Board reopens the record on SC Contention

11. For the reasons stated in its earlier response to SC's .

Motion to Reopen the Record on Contention 11, LILCO continues to believe that reopening is inappropriate and unwarranted.

l Respectfully Submitted, O

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Daniel O. Flanagan ey One of LILCO's Counsel Hunton & Williams P. O. Box 1535 Richmond, VA 23212 DATED: May 16, 1983 8305190208 PDR 830516 ADOCK 05000322 O

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D. VALVE FAILURE

[ Note: -

To be inserted in Volume 1 of LILCO's Proposed Opinion (January 17, 1983) following first full paragraph on page 25.)

The effectiveness of LILCO's program for evaluating in-dustry experience is reflected in the fact that Shoreham's in-service testing plan included certain check valves and established certain testing requirements for them. Recently, the Staff has required operating plants to include such valves and requirements in their in-service test plans. (Board Finding D-24a).

[ Note: To be inserted in Volume 1 of LILCO's Froposed Opinion (January 17, 1983) following

the carryover paragraph on page 28.]

Thecomprehensivenessof5horeham' sin-servicetest plan is shown by the fact that certain check valves were in-cluded in the plan and both forward and reverse flow testing were specified for the valves. Until recently, some operating plants did not include such valves in their testing programs and other plants did not adequately test the valves that were included in their testing programs. (Board Finding D-30c). -

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Subsequen'tly, the NRC Staff in I&E Bulletin 83-03, as part of a generic effort to improve in-service testing has required operating plants to test such valves in a manner akin to LILCO'_s testing. (Board Findings D-30a and b).

Although the County suggested that other check valves should be, but may not be, included in Shoreham's testing plan or that they may not be properly tested,l/ the record is clear that check valves are included in Shoreham's plan (Board Finding.D-30d). LILCO's treatment of the diesel generator j check valves indicates a recognition that certain check valves may need special testing. There is nothing in the record to 1/ The County also argued that the significance of check valve failures at Dresden and Quad Cities goes beyond check valves, and that the failures are evidence of the consequences of the failure to perform adequate valve reliability assessments, of the deficiencies of standard valve position indication systems, and of inadequacies of the surveillance testing which is commonly performed. SC Proposed Opinion Vol. 2 at 14 (as supplemented). Not only p is there no detailed evidence in the record to support l such broad generalizations,.they have no relevance to Shoreham. Suffolk County has failed to establish that there are any valves which should be, but which are not 1

included in the testing program or that either the use of position indicators or the surveillance testing at Shoreham is deficient or inadequate in any regard. In fact, the inclusion of the check valves which were the subject of Bulletin 83-03, and appropriate testing re-quirements for them in Shoreham's plan is evidence that such inadequacies and deficiencies do not exist at

Shoreham.

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suggest that this recognition was not taken properly into account in developing Shoreham's plan or that the plan other-wise treats check valves inadequately.,2,/

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Revision 3 of Shoreham's In-service Testing Plan, which is expected to be in effect at fuel load, was submitted to .

the NRC in SNRC-857 (April 15, 1983). This document provides the testing requirements for check valves.

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SUPPLEMENTAL PROPOSED FINDINGS D. VALVE FAILURES D-2a. The Board reopened the record for the purpose of admitting the following documents into evidence: (1) IE Bulletin 83-03, " Check Valve Failures in Raw Water Cooling Systems of Diesel Generators" (March 10, 1983); Letter, R. W.

! Starostecki, NRC Staff, to M.S. Pollock, LILCO, " Subject IE Bulletin No. 83-03 (etc.]" (April 1, 1983); (3) Affidavit of Dale G. Bridenbaugh (March 25, 1983); and (4) Affidavit of John A. Rigert (April 21, 1983). Memorandum and Order Providing for Further Filings on Suffolk County's Motion to Reopen the Record on Contention 11.

D-24a. The efficacy of LILCO's industry evaluation program is reflected in the fact that Shoreham's test plan required check valves in the diesel generator cooling water supply system to be included in the test program and required them to be tested for both forward and reverse flow, even though the plan was developed prior to the issuance of Bulletin

' 83-03. Rigert Affidavit at 2. Subsequently, the NRC Staff required these valves to be included in test plans and specified that forward and reverse flow testing, or an acceptable alternative, be performed. Bulletin 83-03 at 4.

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D-30a. The NRC Staff has recently underta' ken a' generic effort to improve valve in-service test programs.

Testing re-quirements so developed will be predicated upon operating expe-rience and will lead't'o more effective in-7.yrvice testing pro-grams. Bulletin 83-03 at 2. The NRC Staff has indicated that LILCOwillberequiredtocomplywithrequirementsthatahe developed as a result of this effort. Letter, Starostecki to ,

Pollock (April 1, 1983).

,a D-30b. Bulletin 83-03 imposes certain requirements on t

' g < t operating plants 'for testing of check valves in the diesel gen-erator raw cooling water supply systems. Bulletin 83-03 at 1, 4-5. The Bulletin itself imposes no similar requirements on h'olders of construction permits such as LILCO, but provides guidance for the development of their in-service testing pro-

. grams. Id..ct 5. Nevertheless, because LILCO's in-service testing prcgram had already been ' reviewed by the NRC Staff, LILCO is required to comply with the Bulletin. Letter, Starostecki to Pollock (April 1, 1983). LILCO already complies or will comply with all requirements of the Bulletin. Rigert s Affidavit at 2-3. -

/w D-30c. The events referred to in Bulletin 83-03 (thor.e at Dresden and Quad Cities) concerned check valves not included * .

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the in-service testing, programs at those respective plants.

^7 .n addition, some operating plants which Bulletin 83-03 at 3.Y ,

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,. did ine'1'ude such? valves in the testing program only test ,

for forward flow. Bulletin 83-03  %

at 1. Bulletin 83-03

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prequi' ras that such. valves be tested for forward and reverse J

flow (or that an ceceptable alEernative to such testing be im-

. Prior to the issuance of the bulletin, LILCO's 1

plemnted) . ,

h valves be in-service testifie plan already required t hat suc Rigert Affidavit at

' tested for both 5$rward and)teve,rse flow.

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% *3 D-30d.

The ASME Code 'requ' ires that check valves be Bulletin considered for {nclusion in in-serv' ice testing plans.

83-03 at 2. LILCONinclud9sicheck valves in its testing pro-

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k Tr. 3783 (Fortier,); se,e, Ri'gert Affidavit at 2.

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t D-35a. Following the litigation of SC Contention 11,

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' the Staff reviewed Shoreha p, s valve test plan in November and December, 1982. Letter, Starostecki to Pollock (April 1, Nevertheless, Suffolk County 1983); see_ Rigert Affidavit at 2.

. has not identified any specific deficiencies with the tenting plan.

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LILCO, May 16, 1983 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 Paragraphs for Inclusion in its Proposed Opinion and Supplemental Proposed Findings on SC Contention 11 - Valve Failures, were served this date upon the following by hand as indicated by an asterisk, or otherwise by first-class mail, postage prepaid.

-Lawrence Brenner, Esq.* Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris

• Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission -

U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. James H. Carpenter * .

Administrative Judge Daniel F. Brown, Esq.*

Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 9

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Bernard M. Bordenick, Esq.* David J. Gilmartin, Esq.

David A. Re ka, Esq. Attn: Patricia A. Dempsey, Esq.

U.S. Nuclear Regulatory County Attorney

, Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highwsy Hauppauge, New York 11787 Herbert.H. Brown, Esq.* Stephen B. Latham, Esq.

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Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Karla J. Letsche, Esq. 33 West Second Street Kirkpatrick, Lockhart, Hill, P. O. Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor 1900 M Street, N.W. Ralph Shapiro, Esq.

Washington, D.C. 20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Marc W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, Esq, Waltham, Massachusetts 02154 3045 Porter Street Washington, D.C. 20008 MHB Technical Associates 1723 Hamilton Avenue Howard L. Blau

. Suite K 217 Newbridge Road San Jose, California 95125 Hicksville, New York 11801 Mr. Jay Dunkleberger Matthew J. Kelli. Esq.

New York State Energy Office State of New York Agency Building 2 Department of'Public Service Empire State Plaza Three Empire State Plaza Albany, New York 12223 Albany, New York 12223 It - _= -i

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Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 16, 1983 l