ML20077J507

Rept Documenting Implementation of Electrical Separation Agreement.All Violations & in-process Deviations Resolved. Util Discharged Obligations

ML20077J507
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/12/1983
From:	Britt L, Mccaffrey B LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20077J497	List: ML20077J496 ML20077J507
References
ISSUANCES-OL, NUDOCS 8308160467
Download: ML20077J507 (54)

Text

r:

, e, ,

80CMETED LILCO, August 12, 1983 USNRC

'83 !.0515 P12:d5 UNITED STATES OF AMERICA rmrr-. .,

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) )

LILCO'S REPORT DOCUMENTING IMPLEMENTATION OF THE ELECTRICAL SEPARATION AGREEMENT I. Introduction and Summary of Results This report is submitted pursuant to 1 1(c) of the "Reso-lution of SC Contention 31/ SOC Contention 19(g) -- Electrical Sep-aration," dated August 26, 1982 (the " Agreement"), as amended January 10,_1983 (the " Amendment"), attached as Exhibits 1 and 2 hereto. The Agreement, as amended, was approved by the Board on January 12 and 19, 1983 (Tr. 17,818, 18,595-96).

The Agreement, as amended, required.the following:

(1) LILCO was required to utilize design criteria for physical separation of electrical cables and raceways between equipment and panels which meet or exceed the provisions of IEEE l

384-74 and Reg. Guide 1.75 (Rev. 2). (Agreement, 1 1(a)).

8308160467 830012 I

[ PDR ADOCK 05000322 -

O PDR

, . . . - - . . .. --. . . - - _. - - = - - . . .

1 a

-i . . ,. . ,

L (2)' LILCO was required to resolve any outstanding depar-tures, known as " deviations," from its basic work specification 1

for electrical separation, SH1-159, prior to the completion of fuel load, using one of the four options stated in the letter ,

i 4 dated August 31, 1981 from R. L. Tedesco (NRC) to M. S. Pollock (LILCO) (Exhibit 3 hereto).1/ Any deviations resolved by analy-l- sis, Option 4 of the Tedesco letter, were to be available for

expedited litigation. (Agreement, 1 1(b)).

(3) LILCO was required to conduct an inspection of 20% ,

4 l of Class 1E cable and raceway installation, and of 20% of non-Class 1E cable and raceways in the vicinity of Class lE cable and j .

raceways, . for consistency with the basic electrical separation work specification, SH1-159. The inspection was to be conducted 4

1/ The_four options listed in the Tedesco-letter (Exhibit 3, at 3-4) are the following:

(1) Correct the deficiency to meet the electrical

equipment separation' criteria set forth in Sec-f- tion 3.12 of the Shoreham Final Safety Analysis Report; (2) Correct the deficiency to meet Regulatory Guide 1.75, " Physical Independence of Electric Sys-tems,"' Revision 2. dated September 1978; ,

. (3) Correct the deficiency by installing an accept-

able barrier; or Justify'the deficiency by performing a^ specific (4)

analysis-for.each cable or raceway where the-

. minimum separation 11s not met to demonstrate

. that a failure will not propagate.because of the L ' insufficient' separation.

l L.

I~

E } ,

9 O .. . ,. - . _ u a. _ ... . - , _ . _ . . _~ u. __ _ . _.

l' .

according to procedures and documentation requirements in part set out in the Agreement and Attachment A thereto, and in part arranged subsequently. Under the Agreement, as amended, the in-spection sample was to consist of 1174 Class 1E raceways. Previ-ously documented departures from Specification SH1-159 detected during the inspection, referred to as "in-process deviations,"

were required to be corrected prior to the completion of fuel load using one of the four Tedesco letter options; deviations corrected by Tedesco Option 4, but cnly those, were to be available for expedited litigation. Departures from SH1-159 not previously doc-umented were to be classified as " violations." If 9 or more vio-lations were discovered in the inspection, a 100% inspection of the plant would be r2 quired. All violations were to be resolved prior to completion of fuel load; any violations proposed to be resolved pursuant to Tedesco letter Option 4, but only those, were to be available for expedited litigation. Agreement, 1 1(c) and Attachment A thereto, 11 C, D; Amendment, 11 1, 2.

(<4) LILCO was to report the results of the inspection no later than 20 days before commencement of fuel load. That report, or a separate document delivered no later than completion of fuel load, must also confirm that all in-process deviations have been resolved or document that the in-process deviations would be re-solved prior to completion of fuel load. LILCO was also required to make the detailed data underlying the report available at the

- . . _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____l

1

e. , . .

1 site, along with the persons who conducted the inspection.

Agreement, 1 1(c).

(5) LILCO was required, concurrently with the inspec-tion, to verify the proper identification of cable trays according to the provisions of SH1-159, and to correct any deficiencies.

J Agreement, Attachment A, 1 D.3.

This Report, with attached exhibits and table, documents LILCO's fulfillment of its obligations under the Agreement, as follows:

(1) LILCO affirms that it has utilized design criteria for physical separation of electrical cable and raceways between equipment and panels at Shoreham which meet or exceed the provi-sions of IEEE 384-74 and Reg. Guide 1.75 (Rev. 2).

(2) LILCO has resolved, or will resolve prior to comple-tion of fuel load, all outstanding raceway deviations from Speci-fication SH1-159. None of these deviations will be resolved using Tedesco Option 4; therefore none will be available for litigation.

(3) LILCO has completed the required inspection in ac-cordance with the Agreement. Five (5) violations were discovered; therefore there is no requirement'for a 100% inspection. One (1)

~

in-process deviation was discovered. It and the violations will be resolved prior to the completion of fuel load, using only meth-ods other than Option 4 of the Tedesco letter;2/ therefore none 2/_ See Table 1 attached hereto for an itemized listing of the l method of disposition of each violation.

l l

I

s will be available for litigation.

(4) This document, with attachments and exhibits, con-stitutes the report required by the Agreement. LILCO has provided all of the inspectors' individual raceway inspection forms to Suffolk County and the NRC Staff. LILCO has also made all of the work papers and other documentation underlying the inspection and all the inspectors, as well as others familiar with the inspec-tion, available at the Shoreham site for two full days of review and questioning by Suffolk County consultants, on June 29 and July 15, 1983, and has provided to Suffolk County copies of all docu-mentation requested at that time. See Exhibit 5 hereto.

(5) Raceway identification was verified and separately documented by the inspectors. Thirteen (13) labeling deficiencies were noted and individually documented; each has been corrected or will be corrected prior to completion of fuel load. The results of this inspection are summarized on Table 2. The documentation underlying this inspection was made available to Suffolk County consultants on July 15.

Subject to providing notification to the Board and to all parties prior to the completion of fuel load that the outstanding deviations from SH1-159, and the five violations, one in-process deviation and thirteen identification deficiencies detected by the inspection have been resolved, LILCO represents, and this Report documents, that it has discharged all of its obligations under the

" Resolution of SC Contention 31/ SOC Contention 19(g) -- Electrical Separation," as amended.

II. Background of the Inspection The Agreement, at 1 1(c), required LILCO to conduct an in-spection of Class 1E cable and ratsway installation at Shoreham for electrical separation, focusing on deviations from the basic work specification, SH1-159. The principal requirements of that inspection, and LILCO's compliance therewith, are summarized below:

1. Scope of and Procedures for Inspection: The Agree-ment required LILCO to inspect a randomly selected 20% of Class 1E cable and raceway installation, and 20% of non-class 1E cable and raceways in the vicinity of Class 1E cables and raceways at Shoreham. Agreement 1 1(c); Attachment A thereto, 1 D.1. In ad-dition, concurrently with the separation inspection LILCO was required to verify that cable trays had been properly identified according to the provisions of SH1-159. Agreement, Attachment A, 1 D.3. The 20% sample was chosen by a random sampling methodolo-gy, described in a November 15, 1982 letter from Donald P. Irwin to Lawrence Coe Lanpher, at 4, and in an attachment thereto enti-tied " Resolution of SC Contention 31/ SOC Contention 19(g) -- Elec-trical Separation: Sample Selection and Inspection Procedures,"

at.1 (collectively, Exhibit 4 hereto). Pursuant to that I

i

• s, , s ,

methodology, 1174 raceways, out of the 5869 Class lE raceways in the plant, were selected for inspection. The plant was then di-vided into 23 areas (later consolidated to 22) for inspection.

Procedures for the inspection, outlined in general terms in the Agreement and Attachment A thereto, were required to be, and were, submitted in more detail to Suffolk County for comment by August 31, 1982. Following this submission and several rounds

. of comments by Suffolk County and responses by LILCO, dealing pri-marily with the extent of documentation and its accessibility for review by Suffolk County representatives, final agreement was reached by early January 1983.3/ At that time, on January 10, 1983, agreement on the Amendment also was reached.

2. Board Questions and Approvals: In August 1982, at the time of the initial submittal of the Agreement, Tr. 9930-35, Board members raised three questions:

1. How would the statistically valid distribution of the inspection sample required by the Agreement be accomplished?

3/ The comments and responses are contained in correspondence between LILCO and Suffolk County representatives over the course of the fall of 1982, and need not be repeated in detail here.

\

'e. , e .

2. Could inspections be conducted in sequence or by other means to avoid a " traffic jam" immediately be-fore fuel load, if any matters raised by the inspec-tion were sought to be litigated?

3. Could the Staff provide one or more persons to be-come sufficiently knowledgeable about the inspection to provide an independent assessment of its conduct?

These questions were addressed in the letter attached as Exhibit 4 hereto, as follows: As to the first question, the random-sampling methodology resulting in selection of 1174 raceways for inspection was explained in the letter attached as Exhibit 4 and Attachment A thereto. That process has been adhered to in the conduct of the inspection. As to avoidance of a " traffic jam" immediately prior to fuel load, the letter indicated that LILCO intended to conduct the inspections in sequence, area by area, with preliminary area-by-area results being forwarded to Suffolk County representatives as the inspection proceeded. As is explained in more detail below, this procedure was followed, with Suffolk County represen-tatives receiving documentation of the inspection's progress in a half-dozen installments between June 9 and July 15, 1983.

On January 10, 1983 the parties submitted to the Board the Amendment to the original Agreement, which clarified-the defini-tion of the sample being inspected and inc~orporated a L

. .. . o ,

_g.

corresponding change in the number of violations which would trigger a 100% inspection. The parties also indicated that they did not foresee the need for any further modifications to the Agreement. At that time, with its own independent questions having been answered by the letter attached as Exhibit 4, the Board approved the Agreement and Amendment on January 12 and 19, 1983. Tr. 17,818, 18,595-96.

3. Conduct of the Inspection: The Agreement required that the inspection be conducted by inspectors from Stone &

Webster Field Quality Control, of whom none had previously partic-ipated in either the design or installation of cables and raceways at Shoreham, nor in previous quality assurance inspections for separation of cables or raceways being inspected by him pursuant to the Agreement. Agreement, 1 1(c); Attachment A, 1 C. The physical inspection was conducted between May 24, 1983 and July 14, 1983 by five qualified Stone & Webster Field Quality Control inspectors: George A. Carter, Joseph R. Flocco, Jr., Scott Fos-ter, Robert L. Friscia, and Alex Onishenko. Each raceway selected for inspection was inspected by one of these five inspectors.

Some of the 22 inspection areas were inspected entirely by one in-spector; others involved collaboration by two or more inspectors.

After physical inspection of each area and research with respect to available documentation,4/ the inspector wrote up a separate 4/ The research tools available to the inspectors involved l

principally documentary investigation, supplemented by personal (Footnote continued) l

.. , e .

preliminary sheet for each raceway documenting its compliance, or apparent lack thereof, with the provisions of Specification SH1-159 and referenced guidance. These sheets, entitled Quality Control Inspection Reports (QCIR's), were then aggregated for each area with a summary cover report and distributed to Suffolk Coun-ty, and simultaneously were routed to the Shoreham Site Engineer-inc Office (Engineering) for further review and disposition as ap-propriate.

The inspectors wrote up any departure from Specification SH1-159 which they had not found to have been properly documented at that time, i.e., prior to completion of engineering review, on an N&D (Nonconformance and Disposition) form, thus establishing it as an apparent violation for purposes of the inspection. In addi-tion, they wrote up separately, as an in-process deviation, any deviation from Specification SH1-159 which was properly documented but whose disposition had not been implemented. Each N&D, re-porting an apparent violation, and each in-process deviation, was noted on the area-by-area reports.5/

(Footnote continued) i communications as needed. On five occasions, one or another of the inspectors requested an interpretation of design require-ments from Engineering. In each case, Engineering provided its answers in a written Inter-Office Communication (IOC).

5/ As Table 1 indicates, seven N&Ds in total were written up.

Of these, five became violations. The other two were voided after Engineering reviewed them and located pre-existing docu-mentation of the deviation, which was then shown to the perti-(Footnote continued)

Concurrently with the separation inspection, a verifica- l tion was conducted of the identification of those raceways being inspected for electrical separation characteristics. Attachment A to Agreement, 1 D.3. The results of that verification were sepa-rately written up on individual QCIR forms for each raceway.

4. Observation of the Inspection: As had been re-quested by the Board, the Staff made Mr. James Higgins, the resi-dent NRC inspector at Shoreham, available to monitor the progress of the inspection. While LILCO cannot present Mr. Higgins' views of the consistency of the inspection as conducted with the terms of the Agreement, LILCO is aware that Mr. Higgins has kept in ac-tive touch with the inspection process and with those conducting it from the outset, and believes that he has an adequate basis on which to present judgments about the inspection, if required.

The Agreement guaranteed Suffolk County access, at the Shoreham site, to the detailed data underlying the inspectors' re-ports or any separate document covering resolution of in-process deviations, and to the inspectors and other persons responsible for resolution of in-process deviations. Agreement, 1 1(c). Pur-suant to these provisions, LILCO has afforded Suffolk County (Footnote continued) nent inspector, who concurred that the deviation had been docu-mented.

• • . ,

• a

_3,_

consultants two full-day visits to the Shoreham site, on June 29 (Messrs. Hubbard and Minor) and July 15 (Mr. Minor). During those visits, Messrs. Minor and Hubbard were given access to each of the five inspectors and in fact talked with each of them individually; they also talked with Mr. Higgins on June 2.9, without the presence of LILCO personnel. In addition, all documentation relating to the inspection was made available to them for their review; and all documentation requested by them to be copied was copied. See 1

Exhibit 5 hereto, itemizing documentation sent to Suffolk County.

During their visits they also interviewed, or were given access to, the following LILCO personnel knowledgeable about the inspec-tion: Lawrence F. Britt (UNICO Systems Superintendent); D. Earl Hall (FQC Inspector Supervisor -- Electrical); Brian R. McCaffrey (Manager, Nuclear Compliance and Safety); W. James Riess (UNICO Electrical Special Projects Superintendent); and Robert L. Bernard (Assistant Manager, FQC Division).

III. Results of the Inspection A. Cable / Raceway Separation l

i The basic results of the inspection may be summarized as follows:

.. Violations: 5 g/

.. Violations being resolved by Tedesco Option 4: O d

.. Number of in-process deviations: 1

.. ' Deviations being resolved by Tedesco Option 4: O These results are displayed in more detail, area-by-area, in Table 1 attached hereto.

The Agreement requires LILCO to perform a 100% inspection of the Shoreham plant if one or more violations were found'in each of 9 or more of the 1174 raceways inspected. Agreement, Attach-ment A, 1 D.2.; Amendment, 1 2. Since fewer than nine violations were found, a-100% inspection need not, and will not, be conducted.

p/ One of the five violations involves a raceway (1TC445B in the Relay Room) which has no cable in it, and is uncovered, for approximately 11' of its 19' length. Because of the plant's configuration, cable will never be laid in any part of that 11' empty run. A conduit crosses raceway 1TC445B during that empty run at a distance less'than the l' x 3' separation provided for in. Specification SH1-159 for open trays. This crossing of an empty tray is the sole basis for a violation on raceway ITC445B. LILCO.has included it in the totallaf 5 violations, but considers it to be a violation only in the most technical sense.

• 1 E wtv n -rw 5 er ' p- p- --

'+ve e .z--,P * -.-

• a. .

• a r

The Agreement also obligates LILCO to resolve all devia- i tions from Specification SH1-159, and violations detected by the ,

, f

. inspection, prior to the end of fral load. Agreement, 11 1(b),(c). Each of the areas inspected had already been completed in terms of electrical work. Thus, the only deviations remaining ,

to be corrected were violations and in-process deviations.7/ They b

will all be corrected before the end of fuel load, in the manners  :

indicated on Table 1.8/

The Agreement permits LILCO to use any of the four methods t

described in the Tedesco letter (Exhibit 3 hereto) to resolve sep-aration deficiencies. The Agreement also provides Suffolk County  ;

7/ The logic of the. electrical separation inspection runs as [

follows: Specification SH1-159 is the basic specification for

, electrical installation. A departure from it is, at the time 1

it occurs, a " deviation." A deviation which has been properly l documented but not yet dispositioned in-accordance with the four options of the Tedesco letter is an "in-process devia-tion." A deviation not properly documented is a " violation."

, A deviation'which has been properly documented and disposi-tioned becomes a part of the plant's design and no-longer re- r i mains a deviation. All departures from Specification SH1-159 7 :should be documented by QA/QC programs as work proceeds in an

j. area. The inspection performed pursuant to.the Agreement was i not performed, except as indicated in footnote 8, until planned 4

work was complete in any given area. As a result, normal QA/QC programs should have already detected all departures from.

1 SH1-159; and thus any such departures found during the inspec-

tion pursuant to the Agreement would not be merely "devia-tions," but either "in-process deviations" or " violations."

L 8/' Two raceways on Elevation 78' were physically unavailable

, .for inspection at~the time it was conducted because of rework 4 'in progress in the immediate area. One of these, Raceway

j. ICC901SA6, has been subsequently inspected satisfactorily. The

. . other,- Raceway 1CX901TA2, will be inspected prior to fuel load, as. contemplated'by the Agreement.

?

T ,, .. ,. .a...,-. ~, . , - . , -

2 the opportunity to challenge by expedited litigation the resolution by LILCO of any deviation corrected by analysis (Tedesco Option 4), by filing contentions within ten days of re-ceipt of notice of the Staff's acceptance of the analysis, but not to challenge any other method of resolution of deviations. Agree-ment, 1 2. LILCO has not used Tedesco Option 4 to resolve any de-viations from Specification SH1-159. Therefore, there are no res-olutions of deviations eligible to be litigated. The manner in which each of the violations and in-process deviations uncovered by the inspection is to be resolved is displayed on Table 1 hereto, which presents, area by area, a summary of the results of the inspection.

B. Raceway Identification Inspection Raceways are required by Specification SH1-159 to be marked with an identifying number and color coding to indicate their electrical division. Concurrently with the electrical sepa-ration inspection, the inspectors conducted an inspection of all 1174 raceways for proper identification and color coding.

Thirteen marking deficiencies were found. The nature of each de-ficiency and the raceway on which it was located are displayed on Table 2. All marking deficiencies will be corrected prior to fuel load.

l l ..

I

a' '

s v, - . , s v '

. . , , . . , y

• ~ -

~

g ~*

,\ ,

IV. Other Matters

\

The Agreement also obligated LILCO to resolve outstanding .

Staff concerns with respect to two other matters: cable separa-tion in NSSS cabinets, and potential missile hazards from RPS motor generator sets. (Agreement, 1 1(d)). The Agreement also provided Suffolk County with the opportunity to challenge the ,

Staff's acceptance of these issues by filing a contention with re- ,

spect to them within ten days of receipt of notice of the Staff's proposed method of resolution of the matter. The Staff notified all parties of its acceptance of LILCO's proposed RPS motor gener '

ator set missile analysis by letter dated January 4,,1983 (Exhilait 6 hereto), and of LILCO's NSSS cabinet cable separation analysis by letter dated February 17, 1983 (Exhibit 7 hereto). ~No conten-i tions were timely filed regarding either of these two matters, andi they are therefore closed. ,

V. Conclusion s N

ii Subject to confirmation to the Board and to all parties prior to the completion of fuel load that all violations and

' t in-process deviations have been resolved, LILCO has discharged 5-all of its obligations under the '.' Resolution of SC Contention

/

9

l e

i r . .

3g** .

_17

g. 1, 31/ SOC Contention 19(g) -- Electrical Separation," and the Amenddent thereto in the manners stated above.

, s 's.

Respectful {Ay submitted,

\.,

(

gC Brian R. 'aff' , ,

3 ., , Manager, Nu a mpliance &

. Sh ty (LILCO Qs _

Lawrence F. Britt, UNICO Syatems Superintendent (LILCO)-

\

b i

i t.

- _ . _ _ _ _ _ _ . _ _ _ . . . _ _ _ ._. - . . . . . _m . . - -

TABLE 1 ELECTRICAL' SEPARATION INSPECTION: SUpW4ARY OF RESULTS

• Violations Inspection Ares . Raceways .Caceways ' 96&Ds Basis of In-Process Deviations

.(No., Name, .

Inspected Accepted Raceway N4:0 . Raceway Nature of' Disposition Quantity Raceway

• Insmector i Inits.1 (Oty.1 (Oty.1 ID No. ID No. Quantity ID No. Disposltion fTedesco Ootion) ID No.

1 _ Reactor Building -39 39 0 --

>0 --

0 E--

Primary (GAC) 2.- Reactor Building . 152 15 'O --

0 --

0 --

El. 175' (AO)

3. Reactor Building : 107. . 107 0 --

0 '--- 0 --

.El.'8' (JRF,RLF)

4. . Reacto r Bui t d i ng '

37' '37 0 --

0 --

O --

• El. 150'-(JRF)- .

5. Reactor Building: 121 119 1CL941BL 6023 0 --

0 --

El. 112' (SF) 1CX783BA 6024 1 1CX783BA Accept as is 3

6. Reactor Building 6 '6 .0 --

0 --

0 --

El. 95' (RLF) '

,7. Reactor Building 152 - 149 1/ 1CX902CB2 5971 1 1CX902CB2 Cover tray 3 1 1CC901TA8 1/.

.El. 78' (GAC)' 1CK671AH1 5977 0 --

t8. . Reactor Building 50 49 1CX633RX1 5958 1 1CX633RX1 Accept as is 1,2 0 --

El. 63' (JRF,RLF,SF)

9. . Reactor Building 50 50 . .0 -- 0 --

0 --

E l . 40'. (JRF, RLF )

10. Screenwell (RLF) 20 19 1/ 0 --

0 --

0 --

.11. Manhole No.1, Tur- 7 7 - 0 --

0 --

0 --

bine Bldg.,~ Normal Switchgear Room Area El. S'8" (AO)

12. Control Building 17 17 0 --

0 --

0 --

Battery Rooms A,B, C, Haliway No.;8, El. 25'(AO) 13.2HVAC Room El. 44' 8 8 0 --

0 --

0 --

(RLF)

- 14.. Chi l ler and HVAC 0 0 52 52 -- --

0 --

Rooms, El. 63'(JRF)

15. - Chi l l e r Room 13 13 0 --

0 --

0 --

El. 44'(RLF)

16 '[ Combined with Area 14)

17. Emergency Switch- 126 126 0 --

0 --

0 --

, gea r Rooms El. 25' (JRF,RLF)

18. . Cont ro l Room (SF) 96 -96 0 --

0 --

0 --

19 . Relay Room El 44' 149 147 ITC445B 5966 1 ITC445B Accept as is 1,2 0 --

(JRF,RLF,AO) 1TC423R 5975 1 1TC423R Cover trav 3

- 20. - Turb i ne Bldg. ( SF) 42 42 0- --

0 --

0 --

. 21. Diese l Gene ra to r 58 - 58 0 --

0 --

0 --

Room (RLF)

22. Ya rd (JRF) 9 9 g/ 0 --

0 --

0 --

GRAND TOTALS 1174 1165 1/. 7 5 1-1/ . The category or " Raceways Accepted" does not include two raceways which do not contain any known electrical separation defects but.were not available for inspection at the time it was conducted. Raceway 1TC353B, located in Manhole No. 2, had been permanently sealed per engineering guidelines and with NRC Staff approval prior to the inspection, and will not become available

' for inspection. Raceway 1CX901TA2, loceted on Elevation 78', was unavailable for- inspection because of unrelated rework in the a rea . It will be inspected prior to completion of fuel load.

4 2/ Ends of ducts 'In Manhole No. 2 on Raceways 1DL914R29, IDH914011, 1DC914B07, were inaccessible for inspection because of sealed

~

manhole. The balance of each raceway was inspected and found satisfactory, and accepted on that basis.

/ This in-process deviation had already been properly documented and dispositioned at the time of the inspection. The E } disposition (Installation of a tray cover) had not yet been implemented at the time of the inspection, but will be prior to fuel '

load.

TABLE 2 <

RACEWAY IDENTIFICATION INSPECTION

SUMMARY

A. Summary of Results Raceways Inspected For Identification Markings: 1174 Raceways With No Identification Marking Discrepancies: 1161 Raceways With Identification Marking Discrepancies: 13 B.' Itemization of Identification Discrepancies

}

Raceway Area Discrepancy ICC667kQ1 1 No identification ICX960TB1 2 No identification markers between El. 175' and 51. 8' .

ICL941BL 5 Redundancy markers not installed every 15' ICC901TA7 7 DCO-19503 Open ICX902CA1 17 DCO-19530 Open 1TL770B 7 Redundancy. marker missing on El. 78' i 1WK761BD1 7 No identification 4

IWK761B06 7 No identification

! ICC971BJ 12 Lacks ID or redundancy marker at wall penetration (Batt.-Rm.)

ICX9710A1 12 Missing ID and redundancy markers

'1FL56037 14 Name plate and redundancy marker missing */.

4 1FH560R21 14 Name plate and redundancy marker missing */

1FC560B061 14 'Name' plate:and redundancy marker missing */

• / Closed as of 7/25/83.

t A

'f x

~ . , . .;:-... - ,, .. . - , , ., - ,. . --

. , - *J, EXHIBIT 1 l

~

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) )

)

RESOLUTION OF SC CONTENTION 31/

SOC CONTENTION 19(g) -- ELECTRICAL SEPARATION 2

THIS AGREEMENT by and among Long Island Lighting Company ("LILCO"), the Nuclear Regulatory Commission Staff

(" Staff"), Suffolk County ("SC") and the Shoreham Opponents' Coalition (" SOC") (hereinafter collectively, the " Parties"),

resolves SC Contention 31 and SOC Contention 19(g) in ac-cordance with the terms stated below, subject to the approval i

of the Atomic Safety and Licensing Board ("ASLB" or " Board").

RECITALS A. SC and SOC have each filed substantia.lly identical contentions, denominated SC 31 and SOC 19(g), which allege two Principal types of defects regarding the physical independence of electrical cables for the Shoreham Nuclear Power Station

("Shoreham"). The first allegation asserts that LILCC's design criteria for electrica' eparation of electrical cables and raceways fail to comp'_y with NRC's General Design Criteria 3, 17, and 21. Reg. Guide.l.75 (Rev. 2), which incorporates the guidance of IEEE 384-74, sets forth a method acceptable to the I

4 m.-.. ._ - , - - .- . , , . . , , , , r. , . . , , - , , -

-t y,,e

1 NRC Staff to meet electrical separation requirements for assuring electrical independence pursuant to General Design i

Criteria 3, 17, and 21. The second allegation concerns the l I

adequacy of LILCO's implementation of its stated separation i criteria (i.e., S&W Specification SH1-159 and FSAR Section 3.12).

B. The Staff questioned, in its direct testimony, whether the cable separation criteria used in various NSSS cabinets at Shoreham were fully consistent with the regulatory requirements stated in Reg. Guide 1.75 (Rev. 1) (Testimony of John D. Knox, et al. filed May 25, 1982, at para. d, pp. 8-9).

While recognizing other exceptions to the guidelines of IEEE 2 384-74 and Reg. Guide 1.75 (Rev. 1), the Staff's direct testi-mony in all other respects took the position that the cable separation criteria used at Shoreham are consistent with all pertinent regulatory requirements.

C. In a letter to LILCO dated May 27, 1982 and describing'the-results of Safety Inspection No. 50-322/82-08, conducted between March 30 and May 10, 1982, the Staff also

- raised a question concerning potential missile hazards associ-ated with failure'of the Reactor Protection System ("RPS") l

< Motor Generator Sets on nearby Clas's lE cables. The letter indicated that LILCO would need'to conduct a review to deter-mine the effects.of any potential missiles and provide the 4 results of that review to the' Staff (pp. 7-8).

1

. ~_ _ _ _ . _ _ _ ._. _ . __ . . _ _ _ _ _ , _ _ _ _ , , _ . ,

I-I L ,.

_3_

I t

D. -The Parties have met to discuss resolution of these Contentions. As a result of this process, LILCO, as set forth below, has agreed to implement actions requested by SC and the j

Staff which, in the view of SC and SOC, will enhance the safety l of Shoreham. Accordingly, the Parties agree to resolution of SC Contention 31 and SOC Contention 19(g) on the terms and con-

. ditions outlined below.

AGREEMENT I 1. LILCO agrees to the following:

1

.(a) LILCO's design criteria for physical separa-

' tion of electrical cables and raceways between equipment and panels will meet or exceed the provisions of IEEE 384-74 and

[

Reg. Guide 1.75 (Rev. 2). For purposes of this Agreement, the following guidelines will be used to judge particular aspects I of LILCO's physical separation criteria (in all other respects, LILCO's physical separation criteria for electrical cables and l

i i raceways between equipment and panels will be judged with e

i reference to the provisions of IEEE 384-74 and Reg. Guide 1.75 (Rev. 2)):

- -(1) For purposes of determining compliance with 3-foot or 5-foot vertical separation require-ments of IEEE 384-74, distance may be measured from bottom of tray to bottom of tray.

i l

.; . . . _ . . _ - -- .,, . . = _ - - - - , - , , m. -._m. ,mm. ....m. _ . , . ,,

, l

-g-(2) Where a nbn-Class lE tray is above a l l

Class lE tray and otherwise applicable vertical j separation criteria are not met, only the Class lE i

tray need be covered. If the vertical separation is less than the 3-foot or 5-foot requirement, the non-Class lE tray in this instance shall be assumed to be of open ladder design and shall be no closer than 12 inches from the Class lE tray, measured from bottom of lower tray to bottom of upper tray.

(3) In crossing situations between redundant

(i.e., different colored) Class lE trays where otherwise applicable vertical separation criteria are not met, the lower t' ray will be covered where it crosses the upper tray and extending one foot beyond the upper tray on each side.

(b) Any deviations, as defined in paragraph B.1 of Attachment A hereto, will be resolved prior to the completion of fuel load, utilizing one of the four options stated in the letter dated-August 31, 1981 from R. L. Tedesco (NRC) to M. S.

Pollock (LILCO) ("Tedesco letter"). Any deviations to be resolved by option 4 of the Tedesco letter shall be identified i

not later than 20 days prior to start of fuel load, and docu-mentation identifying such deviations to be resolved by Option 4 and describing or analyzing their resolution shall be  !

l 1

l

. l

submitted to the Staff, SC, and SOC at that time. Any deviation corrected by analysis (Option 4) and accepted by the Staff may be challenged by SC or SOC pursuant to paragraph 2 below. The Staff shall use its best efforts to evaluate and resolve any such submittal within 14 days from receipt, and shall promptly notify the Board and the other Parties when it resolves any deviation corrected by analysis.

(c) LILCO has inspected, or will inspect prior to the start of fuel loading, 20% of Class 1E cable and raceway installation, and 20% of non-Class lE cable and raceways in the vicinity of Class lE cable and raceways. The basic inspection procedure is set forth in Attachment A hereto. Detailed inspection procedures will be provided to the Parties on or before August 31, 1982. Questions by the Parties relating to the adequacy of such procedures to accomplish the inspection called for by this paragraph shall be presented to LILCO within 15 days of their receipt. LILCO shall promptly consider them in good faith. Any Party dissatisfied with LILCO's resolution of such questions may present them to the Board within 10 days of receiving such resolution by LILCO, for expedited decision.

The inspection will be conducted by inspectors of whom none e shall have previously participated-in the design or installa-tion of cables or raceway at Shoreham, nor in previous quality assurance inspections for separation of cable or raceway being I -

s_____m____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _

. - - . . . - - = . _ . ___________ _ _ _

l l

1 l

inspected by him pursuant to this Agreement. Any violations, as defined in paragraph B.2 of Attachment A hereto, found by the inspectors will be resolved prior to the completion of fuel load, utilizing-one of the four options stated in the Tedesco letter. Any violations to be resolved by Option 4 of the Tedesco letter shall be identified not later than 20 days prior to sta';t of fuel load, and documentation identifying such vio-lations and describing or analyzing their resolution shall be submitted to the Staff, SC, and SOC at that time. Any viola-tion corrected by analysis (Option 4) and accepted by the Staff may be challenged by SC or SOC pursuant to paragraph 2 below.

The Staff shall use its best efforts to evaluate and resolve any such submittal within 14 days from receipt, and shall

'l l promptly notify the Board and the other Parties when it resolves any violation corrected by analysis.,

The results of the inspection shall be documented by the inspectors in a report which shall be provided to the Board and the Parties at the earliest possible time, but in no i case less than 20 days prior to the commencement of fuel load.

I

/

The report (or a separate document delivered no later than com-pletion of fuel load) shall als.o confirm that all in process l i

deviations (as defined in Attachment A) have been resolved, or shall document that the in process deviations will-be resolved I

prior to completion of fuel load. If requested by the Board or l

• ~ * ' " ' -. . . , , . , _ _ . . , , _ . , , . _ _

i

. . l

.' l any of the Parties, LILCO shall make available at the site the detailed data underlying the report (or any separate document covering resolution of in process deviations) and shall make available for discussions the persons who conducted the inspec-2

- tion or resolution of in process deviations.

(d) LILCO agrees to resolve the concerns expressed in the direct testimony of the Staff concerning cable separa-  ;

tion in NSSS cabinets, and those.noted in IEE Report 82-08 con-cerning missile hazards from the RPS motor generator sets.

Such resolution shall take the form of a submittal by LILCO to the Staff on each matter, with copies simultaneously provided to SC, SOC and the Board, on or before August 31, 1982. The Staff shall use its best efforts to. evaluate and resolve any such submittal within 14 days from receipt, and shall promptly notify the Parties and the Board upon' acceptance of such sub- ,

mittal. Each submittal, as accepted by the Staff, and subject

! to the provisions of paragraph 2 below, shall be implemented by LILCO prior to the completion of fuel loading. If the Staff does not find a LILCO submittal to be acceptable, the Staff shall-give its reasons for such finding to LILCO and the Parties and LILCO shall make new submittals until the Staff finds them acceptable.

w & -e . -> , w -.%.e-i.. - , . ,,_r -,+r, ,,,--~r -w yw -,,n -y , , e . . - -v- - , , , -- ,--

2. In the event that (a) any deviation described in paragraph 1(b) above or any violation described in paragraph 1(c) above shall be resolved by an analysis (Option 4 of the Tedesco letter) which is satisf actory to the Staf f but not to SC or SOC, or (b) either or both of LILCO's submittals propos-ing to resolve the NSSS panel and RPS motor generator set mat-ters described in paragraph 1(d) above shall be satisfactory.to the Staff but not to SC or SOC; then such matters shall be available for litigation among the Parties on an expedited basis on the following terms and conditions. If SC or SOC desires to litigate any matter described in item (a) or (b) of this paragraph, they shall submit a revised contention (s) related to such item. If both SC and SOC desire to litigate any such matter, they shall file a joint contention. Any con-tention must be submitted within 10 days of receipt of notice _

of the Staff's acceptance of LILCO's proposed method of resolu-tion of the matter, shall be limited to the scope of the matter under consideration in LILCO's proposal, and shall specify why

, in the view of SC and/or SOC the manner of resolution accepted by the Staff is not sufficient to meet the separation require-ments of Reg. Guide 1.75 (Rev. 2) and IEEE 384-74 and why any analysis supporting the Staff and LILCO positions is inadequate to meet the intent of Reg. Guide 1.75 (Rev. 2) and IEEE 384-74.

SC agrees that in any expedited litigation it shall offer

[

l

L

, 9-testimony to support each of its contentions submitted pursuant to this Agreement. As noted above, any litigation shall pro-ceed on an expedited basis, with the intention being that any such expedited litigation will be completed and the Board will have issued findings thereon (either oral or in writing) prior to completion of fuel load. In the event the Board has not issued findings prior to completion of fuel load, or in the event the Board does issue findings sustaining SC's or SOC's position, then the parties shall have the right to advise the Board, on an expedited basis, of their respective views, under I

applicable law, as to whether the situation requires a delay in initial criticality. The Board, upon consideration of these views and the applicable law, shall -make whatever findings are necessary concerning the date of initial criticality.

3. SC agrees to withdraw Contention 31, and SOC agrees to withdraw Contention 19(g), subject to the right to resubmit contentions under paragraph.2 of this Agreement.

- n h, .

l COUNSEL FOR LONG ISLAND COUNSEL FOR SUFFOLK COUNTY LIGHTING COMPANY.

taf kl s E* - - -, Ib UDUNSEL.FOR NUCLEAR REGULATORY COUNSEL FOR SHOREHAM OPPONENTS COMMISSION COALITION DATED: August 7M, 1982 i-1

ATTACHMENT A ELECTRICAL INSPECTION PROGRAM SEPARATION OF ELECTRICAL CABLES AND RACEWAYS A. Purpose This attachment implements an inspection program described in paragraph 1(b) of a " Resolution of SC Contention 31/ SOC Contention 19(g) -- Electrical Separation"

(" Agreement"),'and describes a program to inspect installed cable and raceways routed between equipment and panels at Shoreham prior to the commencement of fuel loading in order to assure final "as-built" conformance of such cable and raceways with the pertinent separation criteria of FSAR Section 3.12, as further defined in detail on work specification SH1-159.

B. Definition

1. Deviation - A failure to meet the cable separation requirements of work specification SH1-159.

2. Violation - A deviation that has not previously been identified on an E&DCR. An E&DCR shown incorrectly as having been implemented on an as-built drawing used for the inspection shall be considered to be a violation. All viola-tions will be written up on a Nonconformance and Disposition l

report.

3. In Process Deviation - A deviation that has been identified on an E&DCR but the resolution (meeting one of four f

l options in Tedesco. letter) has not been implemented.

l l

r-_ n .,-w + . - - -

1 I

C. Inspection The inspection shall be performed by inspectors from Stone & Webster Field Quality Control (FCC), of whom none shall have previously participated in either the design or installa-tion of cable or raceway at Shoreham, nor in previous quality l i

assurance inspections for separation of cable or raceway being inspected by him pursuant to this Agreement.

D. Scope

1. The inspection shall include 204, on a statisti-cally valid distribution, of IE cable and raceway routed between equipment and panels at Shoreham, and of non-lE cable and raceway in the vicinity of such IE cable and raceway. The inspection will document all deviations from work specification SH1-159 with respect to cable separation. The inspection shall be made according to approved procedures and shall be docu-i mented. It is understood that inspections are typically per-formed only after all outstanding E6DCR's have been disposi-tioned and implemented. It is also understood that there may be cases -where an outstanding EEDCR is noted on an as-built

! drawing at the time of the independent inspection. Any such E&DCR (or in process deviation) will be followed by FQC through disposition and implementation of any required corrective action and will be documented as required'in paragraph 1(b) of the Agreement.

l

4

2. MIL STD-105D methodology shall be used to determine the number of acceptable violations found during the inspec-tion. If the number of violations disclosed by the inspection exceeds 15 (from the sample of approximately 2400 cables and raceways inspected), then 100% of Class IE cable and raceway l

running between equipment and panels, and all non-Class lE j cable in the vicinity of such IE cable, will be inspected.

3. All violations disclosed by this inspection shall be resolved using one of the four methods set forth in the Tedesco letter. Concurrently with the separation inspection, verification of proper identification of cable, tray and con-duit, per the provisions of SH1-159, will be performed. Any deficiencies will be corrected. Upon completion of the 20%

inspection, and of the 100% inspection if held, a report cover-ing the entire inspection will be promptly prepared and made available to the Parties and the Board in accordance with the provisions of paragraph 1(c) of the Agreement. Documentation of cable and raceway inspections may be attached to the report or may be made available for inspection at the Shoreham site.

' E. Tolerances l l A tolerance of + 1 inchlis permitted for determining compliance with SH1-159 or IEEE~384-74, but in no case shall the separation be less than 1 inch (unless an analysis is per-I formed pursuant to Option 4 of the Tedesco letter).

1

r b - - - EXHIBIT 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board h -

In the Matter of -

)

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

I .

AMENDMENT TO " RESOLUTION OF '

SC CONTENTION 31/ SOC CONTENTION 19 (g) -- '

ELECTRICAL SEPARATION"

,On August 26, 1982, LILCO, Suffolk County ("SC") , the Shoreham Opponents Coalition (" SOC"), and the NRC Staff (collectively, the " Parties") entered into an agreement ,

entitled " Resolution of SC Contention 31/ SOC Contention 19 (g) --

Electrical Separation." In subsequent discussions, the Parties have determined that the August 26 Resolution needs to be amended. Accordingly, the August 26 Resolution is amended as follows: 1

1) The 20 percent inspection of Class lE cable and raceway will involve 1174 Class lE raceways and all non-Class lE l raceway in the vicinity of such Class 1E raceway (The 1174 Class lE raceways average slightly more than 5 cables per raceway).

l 2) A.s provided in the August 26 Resolution, all i

! deviations, violations and in-process deviations will be docu-mented in the inspection. Thus, there may be multiple deviations or violations documented for a single raceway. However, for l .

o . .- _ _ _ _ . . _ _ . - . . . _ _ . _ . _._. _ __._. _ _ _ _ _ ._.-. _ . _ , __ , .

. purposes of determining whether a 100 percent inspection is required, the following criterion applies: if one or more violations are identified on each of 9 or more raceways, then a 100 percent inspection is required.

3) In all other respects, the August 26 Resolution remains unchanged.

. h_e. fat -)

COUNSEL FOR LONG ISLAND COUNSEL FOR SUFFOLY COuwxY LIGHTING COMPANY ,

DOM [ '

COUNSEL FOR SHO:EHAM OPPi hk / [4 NENTS

' COUNSEL FOR NUCLEAR REGULATORY COMMISSION COALITION fj DATED: January /D, 1983 ,

t i

I

\

EXHIBIT 2 UNITED STATES OF AMERICA  ;

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board i -

l In the Matter of -

)

) .

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

I .

AMENDMENT TO " RESOLUTION OF SC CONTENTION 31/ SOC CONTENTION 19 (g) --

ELECTRICAL SEPARATION" On August 26, 1982, LILCO, Suffolk County ("SC") , the Shoreham Opponents Coalition (" SOC"), and the NRC Staff (collectively, the " Parties") entered into an agreement .

entitled " Resolution of SC Contention 31/ SOC contention 19(g) --

Electrical Separation." In subsequent discussions, the Parties have determined that the August 26 Resolution needs to be amended. Acccrdingly, the August 26 Resolution is amended as follows:

i

1) The 20 percent inspection of Class lE cable and raceway will involve 1174 Class lE raceways and all non-Class lE raceway in the vicinity of such Class lE raceway (The 1174 Class lE raceways average slightly more than 5 cables per raceway).

2) A.s provided in the August 26 Resolution, etl deviations, violations and in-process deviations will be docu-mented in the inspection. Thus, there may be multiple deviations or. violations documented for a single raceway. However, for

^ . . _ , . . . _ . _ - . _ . . _ . _

/

purposes of determining whether a 100 percent inspection is required, the following criterion applies: if one or more violations are identified on each of 9 or more raceways, then a 100 percent inspection is required.

3) In all other respects, the August 26 Resolution remains unchanged.

& k_e, fAJ =)

COUNSEL FOR LONG ISLAND COUNSEL FOR SUFFOLY COUirlY LIGHTING COMPANY ,

uuninQsklad u,,L B. L%

COUNSEL FOR NUCLEAR REGULATORY COUNSEL FOR SHOEHAM OPP'NENTS COMMISSION COALITION j DATED: January /@ , 1983 ,

i l

4 EXHIBIT 3 h o UNITED STATES

[ ,g} ( NUCLEAR REGULATORY COMMISSION 5 E WASHINGTON. D. C. 20555 t a

"%...../

AUG 311981 i Docket No. 50-322 Mr. M. S. Pollock Vice President - Nuclear .

Long Island Lighting Capany 175 East Old Country Road Hicksville, New York 11801

SUBJECT:

STAFF. POSITIONS - SHOREHAM NUCLEAR POWER STATION During our review of LILCO's application for an operating license for the Shoreharn Nuclear Powr Station, we developed staff positions on several issues.

These issues must be resolved prior to issuance of an operating license. A discussion of our positions are presented below.

The first issue is iten II.B.3 from NUREG-0737, " Clarification of TMI Action Plan Recuirements." We reviewed LILCO's letters of May 15, July 23, and July 31, 1981, which describe your proposal to meet the requirements of II.B.3. We found that these submittals did not provide sufficient'infonnation to demonstrate that the reactor coolant and suppression chamber samples are representative, to provide a procedure for relating radionuclide concentrations to fuel damage, and to provide operational capability of the post-accident sampling system with loss of off-site powr. Our specific concerns in these areas are as follows:

1. That the reactor coolant liquid sample which is taken from the jet pop diffuser will be diluted to an uncertain degree by the reactor coolant system makeup water source. This condition occurs when low volunes of steam are being generated which significatly reduces the amount of moisture which leaves the core and is subsequently returned to the downcomer via the moisture separators. This condition can result in the samples being analyzed at lower .

concentrations of soluble species (chloride, boron, iodine, etc.) than are actually present in the core area, and thus provide an imprecise estimate of the core damage.

2. T'ut the suppression chamber samples, .due to the location of the sample points relative to reactor coolant system safety valve discharge points, will either l be excessively diluted or virtually undiluted resulting in erroneous estimates of core damage. We require the applicant to provide infonnation to demonstrate to our satisfaction that these sample points are located such that adequate mixing will occur and the samples are representative of the mixture rather than J only the discharged fluid. j

• e.

r

~ en, w y y , -w,-- ,w , , , , , ,- W +- -

M. S. Pollock -

2-

3. That an acceptable procedure be provided to relate specific radionuclide concentrations to the estimated extent of core damage.

4. That all electrically powered components associated with. post-accident sampling are capable of being supplied with powr and operated within thirty minutes of an accident in which there is core degradation, or supplied with powr at some time greater than thirty minutes after an accident so that a sanple can be taken and analyzed within three hours of an accident, '

l assuming loss of offsite powr. l The next issue involves cur review of the Remote Shutdown System at Shoreham. In the eveat of loss of habitability of the control room for reasons other than fire, I we are concerned that random single failures in the instruments and controls of ,

systems controlled from the remote panel or in the systems thesselves may prevent attaining cold or hot shutdown from the remote shtdown panel.

It is our position that you demonstrate a capability to attain and maintain hot  !

shutdom and subsequently cold shutdown from outside the control room, assuming a single failure in the systens required for affecting safe shutdown. Offsite power should be assumed to be unavailable.

Your response to this issue should address the following specific requirenents.

These requirements must be met in order to demonstrate compliance with 10 CFR Part 50, Appendix A (GDC-19), Appendix K, and Appendix R.

1) The design should provide redundant safety grade capability to achieve and maintain hot shutdown from a location (s) remote from the control room, assuming no fire damage to any required systems and equipment and assuming -

no accident has occurred. Credit may be taken for manual actuation (exclusive

, of continuous control) of systems from locations that are reasonably accessible from the Remote Shutdown Panel. Credit may not be taken for manual actions involving jumpering, rewiring or disconnecting circuits.

2) The design should provide redundant safety grade capability for attaining subsequent cold shutdom through the use of suitable procedures.

3) The design should be su:h that the manual transfer of control to the remote location (s) should not disable any automat.ic actuation of ESF functions while the plant is attaining or maintained in hot shutdown, other than where ESF features are-manually placed in service to achieve or maintain hot shutdown.

It is parmissible to disable automatic LPCI acutation in this manner only

! when necessary in order to enable control'of the.RHR system from the remote location.and while operating this system to effect cold shutdown from hot shutdo m . ,

.- , - - , e n , , , , -w,- , , - , , en . , - , ~ - ~ , . , ,

M. S. Pollock .

4) The design should provide, as a minimum, non-redundant safety grade systens

necessary to achieve and maintain hot shutdown from either the control room or from a remote location (s) assuming a postulated fire in any fire area,

including the control room or the Remote Shutdown Panel. Credit may be taken for manual actuation (exclusive of continuous control) of systems from locations that are reasonably accessible from the control room or the Remote Shutdown Panel, as applicable. Credit may not be taken for manual actions involving jumpering, rewiring or disconnecting circuits.

5) The design should provide, as a minimum, non-redundant safety grade systems necessary to achieve and maintain cold shutdown from either the control room or from a remote location (s). The design should be such that in the event of fire damage in any fire area, systems could be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if required for cold shutdown.

The last issue involves the minimum separation criteria for electrical cables and raceways at Shoreham. LILCo was originally notified of this problem in Inspection Report 50-322/79-07 dated August 21, 1979. You commited to separation criteria for electrical equipment in Section 3.12 of the Shoreham Final Safety Analysis Report. These criteria were found acceptable by the NRC Staff during our current review of Shoreham. The Office of Inspection and Enforcement identified several instances where the electrical cables and raceways did not meet the separation criteria. This failure to meet your minimum separation criteria at Shoreham has been a continuing violation as stated in 79-07 and subsequent reports from the Office of Inspection and Enforcement.

In LILCO's letter to Report T. Carlson of the Region 1 Office of Inspection and Enforcement dated April 16,1980.(SNRC-471), you stated that a separation. analysis was being developed to justify your policy of not correcting the separation deficiencies at Shorehan. In a meeting held on February 10, 1981, your represen-tatives presented the Shoreham separation analysis to members of the NRC staff.

Shortly after this meeting, our Shoreham project manager notified your represen-tatives that the separation analysis was an unacceptable justification for not meeting your own minimum separation criteria at Shoreham.

It is our position that each deficiency in separation for electrical cables and raceways meet one of the following options:

1. Correct the deficiency to meet the electrfcal equipe.ent separation criteria setforth in Section 3.12 of the Shoreham Final Safety Analysis Report.

L 4

, - y e p- --r -- -

.w , , m,s , , ,~-,e - ----

a

~

M. S. Pollock  %

2. Correct the deficiency to meet Regulatory Guide 1.75, " Physical Independence of Electric Systems," Revision 2 dated September,1978.

3., Correct the deficiency by installing an acceptable barrier.

4. Justify the deficiency by performing a specific analysis for each cable or i raceway where the minimum separation is not met to demonstrate that a failure will not propagate because of the insufficient separation. .

I encourage you to give your personal attention to each of these matters so I that they may be resolved expeditously.

Sincerely, h* S0 kr u Robert L. Tedesco, Assistant Director for Licensing

Division of Licensing cc

See next page S

w 5

I

(

l l

l

Mr. M. S. Pollock -

Vice President - Nuclear Lono Island Linhtino company David Gilmartin, Esq.

175 East Old Country Road Suffolk County Attorney Hicksville, New York 11801 County Executive / Legislative Bldg.

Veteran's Memorial Highway  !

cc: Hauppauge, New York 11788

> Howard L. Blau, Eso.

Blau and Cohn, P. C. mB Technical Associates 217.Hewbridae Road 1723 Hamilton Avenue - Suite K Hicksville, New York 11801 San Jose, California 95125 Jeffrey Cohen. Eso.

' Stephen Latham, Esq.

Geouty Comissioner and Counsel Twomey, Latham 4 Schmitt New York State Energy Office P. O. Box 398 Acency Building 2 33 West Second Street Empire State Plaza Riverhead, New York 11901 Albany, New York 12223 Joel Blau, Esauire Eneroy Research Group, Inc.

New York Public Service Comission The Governor Nelson A. Rockefeller Bldg.

4no-1 Totten Pond Road Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 B. R. McCaffrey Ezra I. Bialik Shoreham Nuclear Power Station Assistant Att' orney General P. G. Box 618 Environmental Protection Bureau Hadina River, New York 11742' New York State Department of Law 2 World Trade Center

4. Taylor Reveley, III, Eso. - New York, New York 10047 Hunton A Williams P. G. ' Box 15'l5 Richmond, Viroinia 23212 -

Raloh Shaniro, Esc.

Camer 4 Shaoiro o East 40th Street New-York, New York 10016 . -

Jeffrey Futter

, Long Island Lichting Company 250 Old Country Road '

Mineola, New York 11501 Desident Insnector/Shoreham NPS c/o 11.S. Nuclear Regulatory Comission D. O. Box B -

8.ocky Doint, New York 11778 Honorable Deter Cohalan.

Suffolk County Executive County Executive /Leoislative Buildino

. Veteran's Memorial Hiohway 3 Haunnauce, New York 1178M l O

EXHIBIT 4 H u wr ow & WII.x.IAM S vor ra.1 Mai. sv.s , p. o. son isas O O 6

• ev. Rscuasoara,vamonarxA aaesa . ..,u . . s. ..

e o. as n .. ae.a3.

" " ' . ' * . " . ' . * . * . * . . ' " " ' " * " "Ta" Ls

. . " p.o = t e04-7ea.eaoo

~ * " "* '"" ""

a o ' "m.". . 24566.000003

• • • a* = ' November 15, 1982 =ev 6 ' =. 8357 i

Lawrence Coe Lanpher, Esq.

Kirkpatrick, Lockhart, kill, Christopner & Pnillips BY EAND Eighth Floor 1900 M Strcet, N.W.

Washington, DC 20036 -

Electrical Separation: SC 31/ SOC 19(e)

Dear Larry:

This letter responds to the Atomic Safety and Licensing Board's questions of August 27, 1962 (Tr. 9930-35) concerning various provisions of the Resolution of SC Contention 31/bOC Contention 19(g) -- Electrical Separation, dated August 26, 1982 (the " Agreement *). It also responds to the comments ten-dered on behalf of Suffolk County (the " County *) under cover of your letter of October 11, 1982, concerning inspection proce-dures sent to the County by L1LCO on August 31, 1982.

1. BT+CKGROUND On August 27, 1982, the Board requested claritication of three aspects of the Agreement:

1. Whether, in view of the closeness to fuel loao of l

various actions contemplated by the Agreement, the NRC Regulatory Staff should be enabled to become sufficiently knowledgeable about the pertornance of the inspection called for under 1 1(c) of the Agreement to be able to render a timely, independent judgment on it (Tr. 9930-31, 9934-35):

2. Why the time frame for resolution ot disputes l relating to-the electric inspection needed to be so close# l (potentially beginning as little as 20 days) before fuel loao (Tr. 9932); and e

1 .

l

.. - . _ . - - - . . . . - - - -l

f .

Howrow & WILLIAMS

3. The basis for selection of the 204 sample of cable and raceway contemplated in 1 1(c) of the Agreement (Tr. 9932).

Your October 11 letter forwards an attachment which suggests that the inspection procedures sent by LILCO to Suffolk County on August 31, 1982 pursuant to 1 1(c) of the

. Agreement (Stone and Webster (SWEC) Quality Control Instructions FS 1-F 12.1-07D (April 4, 1980) and FS 1-F 12.1-081 (March 19, 1982)) appeared inconsistent in six stated respects with various provisions of the Agreement and Attachment A thereto.17 I have appended the attachsont to your October 11 letter to this letter.

In anticipation of our report to the Board tomorrow, November 16, I will address both sets of questions -- the

Board's and yours -- in this letter.

II. LILCO'S INSPECTION Let me start, however, by identifying what LILCO is doing to fulfill its commitments under the 4greement. First, although the Agreement does not require it,F LILCO is in fact 1/ The attachmen'c to your October 11 letter also asserts that

' SC wishes to reserve a later opportu'nity to compare the inspec-tion procedures for consistency with FSAR 5 3.12 and the basic S&W work specification, SH1-159. The scope of the inspection called for under 1 1(c) of the Agreement, and thus of SC's right of comment on the adequacy of procedures to accomplish

' that inspection, do not, of course, extend to the full breadth of either FSAR 1 3.12 or SH1-159, and LILCO does not accept the attempted reservation of nonexistent rights. LILCO's position would be no different if the October 11 letter had been timely submitted, i.e. , by September 15, as required by 1 1(c) of the Agreement.

2 The Agreement states that "LILCO has inspected or will In/spect . . . " the stipulated kinds and number of cable and raceway according to the criteria in the Agreement. LILCO believes that the inspections already accomplished using the QCI's forwarded to you on September 15 substantially satisfied the requirements of 1 1(c) of the Agreement and of Appendix A thereto, and that the reference to a " reinspection program" in the first paragraph of the attachment to your October 11 letter misconceives the requirements of the Agreement. Nevertheless, as stated above, LILCO is in f act performing a special 204 l

inspection. ,

l y , ,,-e e w . - - , . , - , . - , ,-.,---g,-.,, ,_.-.w-----,,,w, , - . - - -. _ , ,.w,,ww,- . -- ,--

Howrow Se WILLIAMS i

I independently reinspecting 20% of the Class IE cable and raceway installations and the non-Class IE cables and raceways in the vicinity of such Class IE cables and raceways. The inspection is being conducted using a randomly selected 20%

sample of cable and raceway distributed among each of 23 areas covering the entire plant. The results of the inspection, including violations, will be written up on inspection reports

, ("QCIR's") specifically designed for the inspection. The basic procedure for this inspection (the " Procedure"), including the method of selection of the 204 sample, actual inspection proce-dures, sample QCIR inspection report form, and listing of the 23 sectors into which the plant has been divided for purposes of the inspection, is set forth in the attached document entitled " Resolution of SC Contention 31/ SOC Contention 19(g):

Electrical Separation: Sample Selection and Inspection Procedure," dated November 2, 1982.

Under the inspection process, which is to commence in the immediate future, individual areas will be inspected in sequence as work on them is completed and they are turned over i to the plant staff. Individual areas will be inspected per the Procedure and the results, including any violations which LILCO proposesf (Tedesco Option 4), will promptly be made available to the Staf f, Suf folk County and SOC, in accordance with the Agreement.3/ Cne purpose of this sequential process will be to move as many of the inspection results as possible as far forward in time as possible, so as to minimize the likelihood of last-minute litigation immediately before planned fuel load.

The final inspection report will be submitted, as called for by 1 1(c) of the Agreement, at least 20 days before fuel load.

Although it will probably not be possible before that time to determine definitively whether the number of violations is such as to require a 100% inspection, it should be possible to get a sense of its likelihood as the inspection proceeds.

Finally, Brian McCaffrey has talked with Mr. James Biggins, the chief NRC resident inspector at Shoreham, con-cerning NRC participation in the, inspection process. Under this Agreement, Mr. Higgins, or one of his staff, will become knowledgeable about the Procedure and will accompany Stone &

Webster Field Quality Control inspectors at ra'ndom on inspec-tions of various (though not necessarily all) areas, verify 3/ As you know, under 11 1(c) and 2 of the Agreement, the Staff has committed to use its best efforts to evaluate within 14 days any violation proposed by LILCO to be resolved by analysis, and SC and SDC have 10 days thereafter to submit any

. contentions relative to any violations corrected by analysis.

l l

.- -4 Howrow 6: WILLIAus l

that the inspection was being conducted in accordance with the Procedure, and provide the " element of witnessing" with which the Board was concerned.

III. BOARD QUESTIONS i Let me now turn to specific response to the questions posed by the Board: l 1

1. NRC Staff Participation: As stated above, one or I more of the NRC I&E resident inspectors on the Shoreham site will (a) be f amiliar with the Procedure and (b) accompany Stone

& Webster FQC personnel on random inspections to witness such inspections and verify their conduct in accordance with the Procedure.

2. Timing of Inspections: As noted above, the plant ,

has been divided into 23 sectors which will be inspected i sequentially. Reports on individual sector inspections will be filed (thus triggering, in the event of violations, the Staff's and the County's response periods) promptly upon completion of each sector. In this way, we hope to minimize the possibility of last-minute litigation resulting from the inspection under 1

1 2 of the Agreement.

i 3. Selection of the 20% Sample: The sample of Class lE cables is to be selected at random from all Class lE cables and raceways throughout the plant, with attention to the inclusion of cables and raceways from each of the 23 areas.

The methodology is more fully described in the " Sample Selection Method" portion of the attached Procedure. The pop-ulation of non-Class IE cables in the vicinity of the Class 1E cables is a function of the location of Class lE cables thus, wherever a Class 1E cable or raceway is inspected, non-Class 1E

! cables within separation criteria range (vicinity) of it will also be inspected for the adequacy of the appropriate safety-related/non-safety-related separation criteria.

I propose to recite the gist of the above to the Board next Tuesday, in resolution of its three questions. I do not see any of these matters as requiring modification of the l Agreement.

IV. OCTOBER 11, 1982 LETTER The attachment to your October 11 letter raises six questions about the inspection, based on the procedures sent to the County on August 31. Let me address them in the context of the preceding discussions l

l i ,

l

Horrow & WILLhMS (a) A separate, special inspection, following the

! attached Procedure, is to be conducted beginning in the immedi-ate future.. The County's apparent fears about whether such an inspection would be conducted are needless.

(b) The attached Procedure details the basis for random selection of the 206 sample of Class lE cables and raceways. The basis for selection of non-Class IE cable and raceway in the vicinity of Class lE cable and raceway, as noted above, is simply that non-Class IE cable and raceway within

separation distance of Class lE cable and raceway is to be 1 inspected. The random number series by which the Class lE 20%

sample is being generated will be kept on site and available for inspection.

(c) The special inspection Procedure requires that the inspection be conducted on the basis of all outstanding docu-ments, including E&DCR's. Incorrect implementation of B&DCR's is a violation under the Procedure. Following up on EEDCR implementation and in-process deviations, while a requirement of the Agreement, is not a function of the inspection ger se and hence is not included in the Procedure.

(d) The Procedure and attached QCIR form set forth the basis for determination of violations. The basis for crossing the threshold from a 20% to a 100% inspection is specified in 1 D.2 of the Attachment A to the Agreement, and does not need to be repeated in the Procedure itself.

(e) The QCIR form attached to the Procedure requires identification of raceway and location and makes use of 881-159 as a reference, thus assuring proper identification of raceways and conduits. The reporting requirements for each inspected area are set forth in the Procedures the requirements for the overall inspection report are set forth in the Agreement at 1 1(c) and in Appendix A thereto at 1 D.3, and need not be repeated in the Procedure.

(f) The Procedure defines violations, which are the only items giving rise to either the need for a further inspec-tion or the possibility of further litigation. Thus, the terms

" deviation" and "in-process deviation", when not associated with violations, do not need to be set forth in the Procedure.

As to the choice of methods of resolution of violations, that lies within the province of LILCO project management, not FQC inspectors, and hence is not properly a part of the Procedure.

As to violations corrected (or proposed to be corrected) by ~

analysis, the Agreement specifies, at 1 2, the process for their resolution. Further, that material is not relevant to

,-,.w. .w,a--,-,- -,- - _ _,m,,,,~,-.--,,,_,,,,-_--,w__-- ve---,-.,,-,,ne,_,-w _-.,,w.n,,e-__. .w.--..,_

,5 HUNTON Sc WILLIAMS the preparation for or conduct of the inspection and hence not appropriate for inclusion in the special inspection Procedure.

I apologize for the length of time it has taken me to get back to you on all this. I trust that the County's dif-ficulties expressed in your October 11 letter will be resolved by this letter and its attachment. If you or Dick Hubbara have any further questions, please call me or have Dick call Brian directly.

Sincerely yours, Donald P. Irwin 91/728 Attachment cc: Bernard M. Bordenick, Esq.

Stephen B. Latham, Esq.

9 i

l l

l l

5 i

RESOLUTION OF SC CONTENTION 31/ SOC CONTENTION 19 (q)

)

i ELECTRICAL SEPARATION

\

4 Sample Selection and Inspection Procedure This document describes the detailed inspection procedures as called for on page five (5) paragraph C of the subject agreement and its attachment A.

Samplo Selection Method The sample of raceways to be inspected to resolve Suffolk County Contention thirty-one (31) was selected in a manner that insured that all Safety Related raceways had an equal chance of being included in the sample and insured that all areas of the

• plant were included in the sample.  ;

First an alphanumeric listing of all Safety Related raceways, The Stone & Webster EC-6 report with all Category II raceways suppressed, was generated. It was determined from this report that there were five thousand eight hundred' sixty-nine (5,869)

Safety Related raceways. A list of one thousand one hundred seventy-four (1,174) random numbers, twenty (20) percent of

five thousand eight hundred sixty-nine (5,869), was then-developed by the LILCO " Quality Assurance Random Number Gene-rator" computer program. As each raceway contains at a minimum one cable, the inspection will encompass one thousand one hundred seventy-four (1,174) raceways and at least one thousand one hundred seventy-four (1,174) cables.

The raceway sample was then selected by utilizing the two lists in the following manner. The alphanumeric Safety Related list was numbered from one (1) to five thousand eight hundred sixty-nine (5,869) and the raceways whose numbers correspond to I

numbers from the random list were designated to be the sample l of raceways to be inspected.

Sample Inspection Process ,

j The ., twenty (20) percent separation criteria inspection of cables and raceway shall be conducted on an area basis as follows:

After specific plant areas are completed by construction and inspected by FQC, an independent inspection of the raceways shall be performed on an area basis from the sample list provided by LILCO FQA. This willThe ensure that inspection the separation requirements have been. met.

l

shall be performed by inspectors from Stone & Webster Field J Quality Control (FQC), of whom none shall have previously I

- participated in either the design or installation of cable )

or raceway at Shoreham, nor in previous Quality Assurance J inspections for separation of cable orThey raceway being shall be inspected qualified to by him pursuant to this agreement.

l the latest inspection guidelines in accordance with site proce-dures. The inspections shall be performed to the latest revision to the electrical installation specification and all applicable design drawings, E & DCR's etc. The results of inspections l

shall be documented on a Quality Control Inspection Report (QCIR)

(see attached sample) .

Violations

• shall be reported on an N & D and processed in accordance with existing site FQC procedures. The N & D num):>ers shall be recorded on the QCIR.

A summary shall be written for each specific plant area listing the overall findings. Attached to the report will be all of the individual raceway QCIR's as well as a raceway number inspection list as extracted from the twenty (20) percent sample list.

• Electrical Separation Agreement'- Attachment A, Para. B.2 Violation - A deviatio6 that'has not previously been identified on an E&DCR. An E&DCR shown incorrectly as having been implemented on an as-built drawing used, for the inspection shall be considered to be a violation.

^ All violations will be written up on a Nonconformance and Disposition Report.

4

,, , - , - - , , . , , --,.,-..--e---m v-,, ,m,,.---n-. ,_.,,w.-- ,-,e. ,,---o., , ,----,,e ow, e, -

,e~,- +-me-ww

,,l '. . .

GTCNE O, CGTER ENGINEECIND C^2Rr 4 il5N AliTY CONTROL ~

IP8CTION REPORT

• Tyfo','50 SYSTEM (5)OR REFERENCE LOCATION (S) DOCUMENT (S)

PARTIS) NAME

.' . ; h g

cway No. Bldg. Sill-159 Rev.

Elev. Section 3.9 1

FQC 6.1 Rev.

lNonConformance & Dispositi FQC 12.1 Rev. Repor l Electrical Installations)

O oEscRiPTiONis) AND INSPECTION REMARK (5)

'p"o { ITEMOTY.

' SAT UNSAT N/A I

1. Hortizontal Separation Criteria

2. Vertical Separation Criteria

~

3. Color to Noncolor Separation Criteria i.4 Separation Between Differently Color Coded Con-i duit Within The Same Group I

Remarks:

. I I .

' l 1

o

~

l

• UNSAT is equivalent to violation as defined in Agreement--Electrical Separation, Attachment A, l

Para. B.2 QU ALITY CONTROL INSPEC./ENG. DATE PASC 09

CTONE WC3TER EN"2INEERING CORP ( $71* N UALITY CONTROL i ,, ,,,,,,, o,,e 18PECTION REPOF4T 11600.50

• Is;p,ys),on LocsTioN(s) c"o'cu'"E"fE) setwsy No. 4 Bldg. 5H1-159 .Rev.

Elev. Section 2.1 & 3.2

PQC 6.1 Rev.

I NonConformance & Dispositi

POC 6.4 Rev. Repor I Deficiency Correct. Orders

PQC 12.1 Rev.

(Electrical Installations)

Ik p ITEM QTY. DESCRIPTION (5) AND INSPECTION REMARK (S) i i SAT UNSAT N/A l  ! 1. Identification i

I Remarks:

O QUALITY CONTROL INSPEC./ ENS, DA1 E PAGE 09 ._

- - - - - - - - _ _ - . _ - - - - . _ . - . , - _ - - - . - _ . - - _ - _ . . . - - - - . - - ~ - , . .- - . _ . - - _ . _ . - . -

ELaermICAI. SEPARATICH AMBE8ENT

- 580LUTION OF SC CONTENTICW 31/50C'COMTENTION 19 (0)

RespacTIONs av AaBn

1. Senator Be11 ding Primary

3. memotor smiteing 175' 3.'.Remotor Building 8' .

. 4. Reactor Building 150'

5. 'neactor se11 ding'113'

5. Reactor au11 ding 31. 95'

7. Reactor Building E1. 788

8. Samater Building 31. 63'

9. asaster Building 31. de'

18. Screenwell , .

11. Isanhole No. A "13. Be11way No. 8.and Battery Rooms _

- 13. EVAC 51. 44'

14. . EVAC 51. 63' ,

l

'~

is. Chiller Room 31. '44' ,

Chiller Room 31. 63' 15.

17. ~ Emergency switohgear Rooms .

15. , control Room 31. 63

.:. 19. Control Room 31. 63' -

30. . Relay Room 31. 44' .

21. Turbine Building '

~33. Diesel Generator Rooms '

n.'

- u r,ar .

- . . , _ - . . . - . - - -.,_,,,----__.,,.___--....--,--_-__,_.,__.,-...m..._. .~.---_,m,.,-_,- _ . , - _.--mw,-.-,-,,,

., 1 < s EXHIBIT 5 DOCUMENTS PROVIDED TO SUFFOLK COUNTY A. Documents Provided Pursuant to Electrical Separation Settlement Agreement

1. Electrical Separation Inspection Sheets For All Class IE Raceways Inspected (1174 Sheets)

2. Area-Inspection Summaries (22 Sheets)

B. Documents Provided Pursuant To Requests Made On June 29, 1983

1. SH1-159 Rev. 6: Cover Sheet, Index, Electrical Sep-aration Section.

2. Raceway Identification Inspection Sheets by Area.

3. (a) Copy of G. Carter's Work Sheet For In-Process Deviation For Conduit 1CC901TA8.

(b) Copy of G. Carter's Field Notebook Listing Raceways Within 3 x 5 Foot Envelope of ICC901TA8.

4. All Inspection Sheets For "In-Process Deviations" By Area.

5. E&DCR F-43728B Sheets 1, 2, 3, 4, 27, and 28. Sheet 28, originally requested, did not exist; however, sheets 15 and 19 were provided on 7-15-83 to resolve the question.

6. E&DCR F-43914 i

7. E&DCR F-43698 Resolution Pages, Sheets 1, 30, and 69-80 For R.B. Vertical Trays.

8. I.O.C. for Vertical Tray Documentation Requirements From R. Morris on 6-22-83.

9. E&DCR F-43757

10. (a) E&DCR F-42098 For Description Of APRM Channels Separation.

(b) I.O.C. by J. Wright on 6-27-83 Clarifying E&DCR For APRM Separation Criteria.

11. I.O.C. by K. Mullen on 6-24-83 For Inspection Criteria Of Manhole No. 1 Per SH1-159

12. I.O.C. by J. Wright on 6-28-83 For Inspection Criteria For Floor Openings.

C. Documents Provided Pursuant To Requests On July 15, 1983.

1. Saraple of DCO's For Identification Tag Inspections

2. Copies of N&D's 5966, 5975, 6023 and 6024 (RR &

112').

3. Copy of E&DCR F-41238A For Siltemp Wrapping Proce-dure.

4. Copy of N&D 5977 (78 S.T.).

5. I.O.C. by John Wright on 7-13-83 For Tray Cover In-spections.

6. Copy of E&DCR F-39624X, associated with N&D 6023.

7. Copy of E&DCR F-43701, associated with N&D 5977.

8. Copy of N&D 5958 (63').

9. Copy of N&D 5971 (78').

10. Copy of E&DCR F-9418B For RR Tray Cover Inspections.

11. Copy Alex Onishenko Notes of Five Tray to Conduit Relationships.

12. Copy of Cable Tray Cover Installation Drawings For Relay Room.

D. Raceway Identification Inspection Documents All Raceway Identification Documents For Emergency Switchgear Rooms (126 Sheets).*/

• / All other raceway identification documents made available on site during 7-15-83 site visit.

I

l 1 wn LILCO, Auguat 12, 1983 l 000KETED USNRC

'83 AUG 15 R2:34 CERTIFICATE OF SERVICE OFFid CF SEL6L M 00CKETING & SERVU >

In the Matter of BRANCH LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I hereby certify that copies of LILCO's Report Documenting Implementation Of The Electrical Separation Agreement were served this date upon the following by first-class mail, postage prepaid, or by hand indicated by one asterisk (*) or by Federal Express e.s indicated by two asterisks (**).

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 Regulacory 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. George A. Ferguson (*)

Administrative Judge Daniel F. Brown, Esq.(*)

Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing School of Engineering Board Panel Howard University U.S. Nuclear Regulatory 2300 6th Street, N.W. Commission Washington, D.C. 20059 Washington, D.C. 20555 1

i i

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

David A. Repka, Esq. Attn: Patricia A. Dempsey, Esq.

U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 Herbert H. Brown, Esq.(*) Stephen B. Latham, Esq.

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.

i 9 East 40th Street Mr. Marc W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, Esq.(*)

i 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 i

j Mr. Jay Dunkleberger Jonathan D. Feinberg, Esq.

New York State Energy Office New York State Agency Building 2 Department of Public Service Empire State Plaza Three Empire State Plaza j Albany, New York 12223 Albany, New York 12223 t

'~bONALD P. IRW1N l

l l Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: August 12, 1983

~ __ ..