ML20073B700

Motion to Reopen Record on Suffolk County Contention 11 Re Passive Mechanical Valve Failure.Recent NRC Data Indicates Likelihood of Undetected Valve Failure Greater than Previously Anticipated

ML20073B700
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/07/1983
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20073B703	List: ML20073B700 ML20073B715
References
IEB-83-03, IEB-83-3, ISSUANCES-OL, NUDOCS 8304120515
Download: ML20073B700 (3)

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. , > A, . 04/07/83 00CKETED USHRc UNITED: STATES OF AMERICA 'g3 pp i NUCLEAR REGULATORY COMMISSION I /J0.12

.Before the Atomic Safety and' Licensing Board?7 '

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

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(Shoreham Nuclear Power Station, ) i Unit 1) )

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MOTION TO REOPEN RECORD ON SUFFOLK COUNTY CONTENTION 11 Suffolk County Contention 11, Passive Mechanical Valve Failure, concerns mechanical valves at Shoreham failing in an undetectable mode, thus rendering a safety-related system inoperable or potentially inoperable without that status'being j known to plant operators. (Suffolk County Finding 11:3). The record on SC Contention 11 includes data regarding the likelihood of valve failures (e.g., Suffolk County Findings 11:9-15) and whether the inservice testing and inspection program.being prepared for Shoreham will be adequate to alert operators to otherwise undetectable valve failures (e.g., Suffolk County Findings 11:30-38).

Recent data compiled by the NRC indicate-that the' likelihood.

of undetected valve failure.may be greater than previously.

anticipated and that the inservice. testing programs used by -*

licensees have not been adequate to identify such failures. -These A

4, y 830412051505000322 830407

- Paa 5DRADOCK v s. _t., -

, s, data are set forth in I&E Bulletin 83-03, " Check Valve Failures in-RAW Water Cooling Systems of Diesel Generators," dated March 10, 1983. -

Mr. Bridenbaugh, one of the County's witnesses on SC Contention 11, has reviewed I&E Bulletin 83-03. His Affidavit, a copy of which is attached hereto, documents that I&E Bulletin 83-03 constitutes significant new information in support of the County position on SC Contention 11. (A copy of I&E Bulletin 83-03 is attached to Mr. Bridenbaugh's Affidavit.)

The data in I&E Bulletin 83-03 document instances where valve failures had existed for a period of time -- at least a month ---

but that regular testing had not detected the failures. The l

L failures were discovered only by direct inspection of valve internals. The valve failures reported at Dresden rendered two l diesels inoperable at the same time.

Suffolk County submits that these data are important new information that need to be considered as part of the resolution of SC Contention 11. These data are being brought'to the Board's t

! attention promptly after issuance of the I&E Bulletin.

Accordingly, the County requests:

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1. That the record be reopened to take I&E Bulletin 83-03 l into evidence; and

2. The parties be authorized to supplement their-findings ,

in light of this new evidence.

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The County would not oppose a further hearing on these data -

if requested.by other parties, but does not itself request'such a hearing.

Respectfully submitted, David J. Gilmartin Patricia-A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New YorkL 11788 Herbert H.-Brown' Lawrence'Coe'Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER-&'PHILLIPS' 1900 M Street, N.W.

Washington, D.C. 20036 Attorneys for Suffolk County April 7, 1983 f

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