ML19325D617

Forwards Handwritten Changes Made to Pages 83-86 of 890928 Upper Mgt Conference Between NRC & Long Island Lighting Co

ML19325D617
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/04/1989
From:	Mcgranery J DOW, LOHNES & ALBERTSON
To:	Brown S Office of Nuclear Reactor Regulation
Shared Package
ML19325D614	List: ML19325D617
References
NUDOCS 8910250147
Download: ML19325D617 (5)

Text

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ENCLOSURE , j 1

Dow; LOHNES & AIEERTSON  !

ATTORNEYS AT LAW

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l october 4, lose  :

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Mr. Stewart W. Brown l l Project Manager  ;

Division of Reactor Projects-I/II Office of Nt' clear Reactor Regulation Mail stop 14-E21 i U.S. Nuclear Regulatory Commission Washington. D.C. 20b55 l Dear Mr. Browns t

I have reviewed pages #3-86 of the transcript of the  ;

Upper Management Conference between Nuclear Regulatory Commission  ;

Staff and Long Island Lighting Company datsd September 28, 1989 [

from the beginning of my comments until the and of the meeting. i t

our tape of that meeting indichtes that the changes j made in Mndwriting on the attached pages 83-86 are nseded in i order te correct that transcript. l t

With tany thanks for your consideration, I am, I

sincerely, q h M! f Jahes P. McGraroerk , Jr,  !

JPM: jab  !

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Enclosure  ;

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- 83  !

1 intentions to review the way you notwally review operations,  !

2 and we'll keep you informed through the region as to where l i

3 we stand and make the packages available. [

4 MR. 4ROWH: Okay. If tha're are any members of l t

5 the public that would like to make a statement at this ties, 6 please come forward and identify yourself and please speak

't into the microphone here, j 8 Yes. l

, 9 W ,. McGRANWRAY: James F. McGran[nery,Jr. My -

10 affiliation was given earlier.

11 2'd like to address my comments to the staff.  ;

12 I was.very encodraped at the beginni*iy of the l i

13 meeting when Dr. Murley said that the staff was not going to  ;

14 de allowing piecemeal deconstissioning. Very positive. l 15 However, we then had a presentation in which the [

16 licensee outlined three categories of equipment that it is

& A 6 l '1 going to be mak systems. It is going to be putting 18 away in storage a third of the plant's operating systems. j 19 It then detailed a procedure that it had for deciding how to 20 mothball or store these systems. ,

21 Gentlemen, that's piecemeal decosnissioning, j 22 Yhat's what you said you weren't going to allow.

23 And Dr. Murley also said that not until this day j

- 24 had he seen those categories of equipment or systems. You  !

25 asked some questions about some of them to what this t Heritage Reporting corporation (202) 628-4888 l

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1. difference is between operational and functional. You were l

2 given some information about some of them. j 3 There's no reason why you can't ask, order, the 4 licensee to deliver the particular evaluations of all of

$ those systems to you so that at this very sensitive stage 6 you can make your own independent judgment of whether they

'l are being properly categorised and maintained.

8 Finally, I would like to men, tion a werd that I did 9 not hear. It's called NEF ational Environmental Policy 10 Act. l

)

11 I knew that last year you ament!,ed your rules to l 12 not require an Environmental Impact Review of every reactor ett  ;

13 decomunissioning. Your basis for that was a @.s, which 14 considered as its basis that the reactor had either reached i i

15 the end of its operatir.g life through age, or the end of its  !

16 operating life through accident. It did not consider this

, 17 case.

f 18 This is a case where we have a brand new reactor  ;

.19 and therefore one of the alternatives to be considered is [

00 operation. Whether LILeo operates it or not is a separate ,

21 question. And whether LILCC's characterisation of its W

.asT 4.- l 22 agreement as being stone is correct nor not sa  ;

23 separate question. -

24 I think that you need to do an envirennental ,

25 review before you allow this decomunissioning to go forward. .

Heritage Reporting Corporation (202) 628-4888 I

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. i 85 1

1 Thank you very much.

2 DR. MURI.EY: Okay. 1,et me respond very briefly.-

l 3 3 don't want to get inte eatended dialoyue. But I think the '

4 com ents a,e ,ood and 1 thi = they .eser e an ans.or.  ;

5 The first comment was the three categories of  !

6 systems. One sategory of which,is the preservation group of  !

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7 systems where the utility'45 is developint lay-up procedures.

8 We do not regard that as piesemeal l l

9 decommissioning. In fact, the whole purpose of the lay up i f

to is to make sure that they are maintained operational and  ;

11 that they can be restored to service if that's planned.

12 Your second point was that we had not soon the 13 categories of the systems today and there is no reason that 14 we could not--I guess your point is no reason that we have 15 to accept that category or that we could not change it. i I  :

16 That's quite true. We do intand to review all the .

I 17 categorization of the three types of systems, operational,  !

i 18 functional and protected. And we'll satisfy ourselves that '

- 19 those are the appropriato list of systems in those I

20 categorien. .

21 With regard to NEPA, I should say that, of course,  :

!. 22 any request for a licensing action or a change in the .

C-23 licences' will trigger certain NEPA functions. '

24 I'll ask my counsel if there are any other ,

l 25 comments on that matter. i f

Meritage Reporting Corporation l (202) 628-4888 l

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fWe will carry out. u. n NK p Pn I

1 NR. sc1NTo:

2 obligations and do an environmental review required for the l 3 action that is asked of us.

i 4 And I'll touch on the other word that you didn' t l 5 mention and that one,, we will not engage in improper l M A e i

, 6 segmentation. We allow,to engage in improper p

, .egment.u.a.

6 DR. NtJPLEY: It's always good to hear our counselle(

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p say that we will it;.. Pm 21 p .

10 NR. BROWN: Are there any more comments or l

11 statements?

12 7h[hismeeting10 adjourned. Thank you.

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, (Whereupon, at 3: 40 p.m., the meeting was )

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i 14 adjourned. )  :

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Heritage Reporting cerporation (202) 628-4888 1

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