ML19346A023

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Interrogatories Directed to Shoreham Opponents Coalition Re Contentions on Emergency Planning Zones,Ingestion Pathway & QA & QC Programs.Related Correspondence
ML19346A023
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 05/21/1981
From: Earley A
LONG ISLAND LIGHTING CO.
To:
SHOREHAM OPPONENTS COALITION
References
NUDOCS 8106040363
Download: ML19346A023 (57)
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1. 05 c Before the Atomic Safety and Licensing Board Agg .

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^y The Applicant serves on the Shoreham Cpponents Coali i (SCC) the interrogatories that appear below. A sworn response to them must be provided to the Applicant in accordance with the terms of 10 CFR 5 2.740b. Pu:suant to 5 2.740(e), if the answer to any question is not known when the response is filed, the answer must be provided as soon as the missing information becomes available.

II.

We request answers to each of the following questions 1/

about SCC contentions:

A. SCC CCNTENTION 1 SCC Contention 1 was admitted by the Board's Order of June 26, 1980 as follows:

95 5 Ok 1/ If SCC does not now know the answer to a particular ques-tion, please state for each instance in which an answer is not yet known, on what date soc expects the missing information to become available. .

TfilS DOCUMENT CONTAINS POOR QUAUTY PAGES 81060403N- 6

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Intervenors contend that the emergency planning zones (EPZ) set forth by the Commission in the NRC Policy Statement of October 23, 1979 (44 Fed. Reg. 61123) are inadequate for the Shoreham nuclear plant in that: -

a. The 10-mile (radius) EPZ plume expo-sure pathway fails to provide ade-quate consid^ ration of the following local conditicns: demography, meteorology, topography, lend use characteristics, access routes, local jurisdictional boundaries and release time characteristics.
b. The 50-mile (radius) EPZ ingestion pathway fails to provide adequate consideration of the following local conditions: demography, meteoro-logy, topography, land characteris-tics, and time of year of release.
1. Please explain the basis for the allegation that the 10 mile EPZ set forth by the Commission is inadequate for Shoreham because it fails to pro-vide for local demography.
2. Please explain the basis for the allegation that the 10 mile EPZ set forth by the Commission is inadequate for Shoreham because it fails to pro-vide for local meteorology.
3. Please explain the basis for the allegation that the 10 mile EPZ set forth by the Commission is inadequate for Shoreham because it fails to pro-vide for local topography.
4. Please exp..ain the basis for the allegation that the 10 mile EPZ set forth by the Commission is inadequate for Shoreham because it fails to pro-vide for local land use characteristics.
5. Please explain the basis for the allegation that the 10 mile EPZ set forth by the Commission is inadequate for Shoreham because it fails to pro-vide for local access routes.

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6. Please explain the basis for the allegation that the lO mile EPZ set forth by the Commission is inadequate because :it fails to provide for local jurisdictional boundaries.
7. Pleas 6 explain the basis:for the allegation that the 10 mile-EPZ set forth by the Commission is ,

inadequate because it fails to provide for local release-time characteristics.

8. Does SOC contend that the NRC Policy Statement cited in this contention violates any Commission regulation or regulations?
9. If the answer to question A.8 is anything but a simple negative, please state which regula .

tion (s) and explain why the Policy Statement allegedly violates each one.

10. Please answer questions A.1 through A.9 for the equivalent allegations concerning the 50 mile EPZ ingestion pathway.

. To the extent not already indicated in response to questions.A.1 to A.10, please answer the following ques-tions regarding each allegation in Contention 1:

11. What are the facts 2/ on which SOC:3/
a. now relies; and

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b. expects to rely during the Shoreham oper-ating license hearings?
12. What are the documents,4/ if any, on which SOC:

2/ " Facts," as used in these interrogatories, include the calculational or other assumptions, if any, underlying various assertions of fact. " Including" and " include," as used in these interrogatories, mean " including but not limited to."

3/- " SOC," as used in these interrogatories, means Shoreham opponents Coalition, its officers, agents, employees, and con-sultants, f

4/ " Document" or " documents," as used in these interroga-tories,-mean any handwritten, typed, printed, recorded or gra-

' phic matter however produced or reproduced, including material (footnote cont'd)

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a. now-relies;.and
b. expects to rely during the Shoreham oper-ating license hearings?
13. Either attach to the response to these inter-rogatories a-copy of each document included in the answer to question A.12 indicating the por-

. tions on which SOC relies now or expects to rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bea s;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references to the portions on which SCC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if so:

(1) the date it was destroyed; (footnote cont'd) stored for use in automatic data processing systems, whether or not in the possession, custody or control of SCC and whether or not claimed to be privileged against discovery on any ground, including: reports; records; lists; memoranda; correspondence; telegrams; schedules; photographs; sound recordings; films; hand, machine and computer calculations; computer codes; data; and written statements of witnesses or other persons having knowledge of the facts.

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(2) the reasons it was destroyed; and (3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

14. Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?

1S. Regarding each person identified in the answer to question A.14:

a. What is the person's full name?
b. What is the person's address?
c. What is che person's present or last known position and business affiliation?
d. What is the person's field of expertise'
e. On what date did SCC first contact or con-sult the person?
f. What are the dates of all subsequent con-tacts or consultations with the person?
g. Were any reports made to SCC by the person?
h. If the answer to question A.15g is anything other than a simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was submi_ted by the I person wt -

acting in an advisory ca-pacity, . 2 prospective witness, or both.

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16. For each witness SOC intends to call during the Shoreham operating license hearings, please answer question A.15 and indicate: ,
a. What is the subject matter of the witness' ,

testimony?

b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
17. Has. SOC made any studies.or observations 5/ on which it:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
18. If the answer to question A.17 is anything other than a simple negative:
a. indicate whether the study or observation has been. included in any document prepared by or for SCC; and
b. for each study, ob se rvs. tion, or document identified in the answers to questions A.17 and A.18, provide the information requested in question A.13, unless such information was supplied in the answer to question A.13
3. SCC CONTENTION 2 SCC Contention 2 was admitted by the' Board's Order of June 26, 1980 as follows:

Intervenors contend that the emergency plan-ning requirements for the 50-mile (radius) ingestion pathway for the Shoreham facility, as set forth in the NRC Policy Statement of October 23, 1979 (44 Fed. Reg. 61123), are inadequate in that they do not adequately 5/ " Studies or observations," as used in these interroga- l tories, include physical, empirical, calculational, assump- '

tional, and other types of work, whether recorded in writing or )

not.

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address the effects of releases through the liquid pathway.

1. What is meant by the " liquid pathway"?
2. Please explain the basis for the allegation that the emergency planning requirements for the 50 mile ingestion pathway set forth in the NRC Policy Statement do not adequately address the effects of releases through the liquid pathway.
3. Does SCC contend that any NRC regulation or reg-ulations require consideration -f hypot' .tical Shoreham releases through the liquid patnway?
4. If the answer to question 3.3 is anything but a simple negative, please state which regulations allegedly require considerat. ion of hypothetical Shoreham releases through the liquid pathway and the basis for the allegation.

To the extent not already indicated in response to questions 3.1 to 3.4, please answer the following ques-tions regarding each allecation in Contention 2:

5. What are the facts on which SCC:
a. now relies; and
b. expects to rely d tring the Shoreham oper-ating license hearings?
6. What are the documents, if any, on which SCC:

a, now relies; and

b. expects to rely during the Shoreham oper-ating license hearings?
7. Either attach to the response to these inter-rogatories a copy of each document included in the answer to question 3.6 indicating the por-tions on which SOC relies now or expects to rely, or provide a description of each document, including the following:
a. its title, contents and length;
b. its date;
c. the-date it was completed if different from the:date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references to the portions on which SCC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if so:

(1) the date it was destroyed; (2) the reasons it was destroyed; and (3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

8. Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:
a. now relies; and 4 b. expects to rely during the Shoreham oper-ating license hearings?
9. Regarding each person identified in the answer to question 3.8:
a. What is the person's full name) l
b. What is the person's address? i
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c. What is the person's present or last known position and business affiliation?

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d. What is the person's field of expertise?
e. sn what date did SOC first contact or con-sult the person?
f. What are the dates of all subsequent con-tacts or consultations with the person?
g. Were any reports made to SOC by the person?
h. If'the answer to question 3.9g is anything other than a simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or both.

10. For each witness SCC intends to call in the Shoreham operating license hearings, please answer question 3.9 and indicate:
a. What is the subject matter of the witness' testimony?
b. What are the facts and/or opinions to which the w.tness will testify and the grounds for each fact or opinion?
11. Has SOC made any studies or observations on which it:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
12. If the answer to question 3.11 is anything other than a simple negative:

l a. indicate whether the study or observation has been included in any document prepared l by or for SCC; and l

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b. for each study, observation, or document identified in the answers to questions 3.11 and B.12a provide the information requested in question B.7, unless such information was supplied in the answer to question B.7.

C. SCC CONTENTION 3 P SOC Contention,3 was admitted by the Board's Order of March 5, 1980 as follows:

The recent revision 2 of Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" details the needed devices and qua.ifications of instruments, many of which are not presently a pr -t of Shoreham design.

1. Please list all of the devices or instruments included in Regulatory Guide 1.97 that SCC cen-tends are not presently part of the Shoreham design.
2. For each of the devices or instruments listed in response to question C.1, please state the rea-sons why SCC believes the device or instrument is required and reference the specific sec-tion (s) of NRC regulations allegedly violated by its omission.
3. By what date does SCC contend Regulatory Guide 1.97 must be implemented?
4. Please explain the basis for the date selected in response to question C.3.

To the extent not alreadv indicated in response to ,

questions C.1 to C.4 please answer the following questions regrding each allection in Contention 3:

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5. What are the facts on which SCC: -
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
6. What are the documents, if any, on which SCC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
7. Either attach to the response to these inter-rogatories a copy of each document included in the answer to question C.6 indicating the por-tions on which SCC relies now or expects to ,

rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es)' and position (s) of its author (s) and signer (3,), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references to the portions on which SCC  :

relies now or expects to rely; and

h. a statement whether it has been destroyed and, if so:  ;

(1) the date it was destroyed; (2) the reasons it was destroyed; and (3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

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8. :Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
9. Regarding each person identified in the answer to question C.8:
a. What is the person's full name?
b. What is the person's address?
c. What is the person's present'or last known position and business affiliation? ,

- d. What is the person's field of expertise?

e. On what date did SCC first contact or con-sult the person?
f. What are the dates of all subsequent con-tacts or consultations with the person?
q. Were any reports made to SCC by the person?
h. If the answer to question C.9q is anything other than a simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; and (3)_whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or both.

10. For each witness SCC intends to call in the Shorehad license hearings, please answer ques-tion C.9 and indicate:
a. What is the subject matter of the witness' testimony?

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b. What are the facts and/or opinions to which the witness will testify and the grounds for each-fact or_ opinion?
11. Has SCC made any studies or observations on which it:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
12. If the answer to question C.11 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document prepared

'uy or for SOC; and

b. for each study, observation, or document identified in the answers to questions C.ll and C.12a, provide the information requested in question C.7, unless such information was supplied in the answer to question C.7.
13. Is SCC alleging that any Shoreham systems, sub-systems, equipment, and/or components are in violation of any NRC regulation (s)?
14. If the answer to question C.13 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).
15. Is SCC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shorehan systems, subsystems, equipment, and/or components does not comply with NRC regula-tion (s)?
16. If the answer to question C.15 is anything but a simple negative, state precisely:
a. for which Shoreham systems. subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate,
b. with which NRC regulation (s) the demonstra-tion of safety. allegedly fails to comply;
c. which parts of the demonstration of safety allegedly fail to comply; and

~d. why those parts of the demonstration of safety allegedly fail to comply.

D. SCC CONTENTION 6(a)(i)

SOC Contention 6(a)(1) was admitted by the Board's

- Order of October 27, 1980 as follows:

Intervenors contend that the Applicant has not adequately developed and imple-mented a quality assurance / quality con-trol program for the design, procure-ment, construction and installation of structures, systems, and components for the Shoreham Nuclear Station as required by 10 CFR Part 50, Appendix B, Criteria I through XVIII, and 10 CFR Part 50, Appendix A, Criterion 1. Specifically, Intervenors contend that based on the review of 30 allegations of construction irregularities at the Shoreham site as described in NRC Investigation 50-322/79-24, an adequate level of safety has not been achieved at the Shoreham cite with regard to root causes of the irregularities as follows:

A. (Timeliness of Quality Assurance Program) Failure of the Applicant and Applicant's con-tractors, agents, or consultants to establish and execute a Quality Assurance Program at the earliest, practicable time in accordance with Criteria 1 and 2 of Appendix B as demonstrated by allegations 14, 20, 21.

3. (Cuality Assurance Authority)

Failure of the Applicant to as-sure that persons and organiza-tions performing quality assur-ance functions have sufficient independence from cost and schedule considerations, and adequate "stop-work" authority in accordance with Criterion 1 of Appendix B, as demonstrated by allegations 14, 21 and 30.

C. (Qualification and Training)

Failure of the Applicant to ade-quately assure that the indoc-trination and training of on-site QA/QC personnel has been provided as necessary to assure that suitable proficiency is achieved and maintained, in ac-cordance with Criterion 2 of Appendix B, as demonstrated by allegations 7, 17, 19, 20, 21 and 29.

D. (Process Control) Failure of the Applicant to establish measures to assure that the special pro-cesses of welding, heat treat-ing, bracing, nondestructive testing and cleaning are con-trolled and acconplished by qualified personnel using quali-fled. procedures in accordance with applicable codes, stan-dards, specifications, criteria, and other special requirements imposed by the Applicant, or Applicant's contractors, agents or consultants, in accordance with Criterion 9 of Appendix 3, as demonstrated by allegations 2, 10, 17, 19, 20, 21, 23 and 29.

E. (Construction 7erification)

Failure of the Applicant to establish measures to control materials, parts, or components which do not conform to require-ments in order to prevent their '

f ".vertent use or installation, i accordance with Criterion 15 ou Appendix 3 as demonstrated by ,

  • O allegations 1, 4,.5, 6, 8, 12, 15, 22, 23, 26 and 30.

F. (Corrective Action) Failure of the Applicant to establish cor-rective action measures to as-sure that significant conditions adverse to quality are deter-mined and that corrective action is taken to preclude repetition,

- in accordance with Criterion 16 of Appendix B, as demonstrated by Violation A and allegations 2 and 22.

G. (Follow-up Audit) Failure of the Applicant to take timely follow-up action, including re-audit, of deficiencies iden-tified in audits, in accordance with Criterion 18 of Appendix 3 as demonstrated by allegations 1, 5, 6 and 14.

1. Please explain what is meant by the term " root causes of the irregularities."
2. Please explain what is meant in part A by " ear-liest, practicable time" in relation to the con-struction of Shoreham.
3. Part A of this contention also references

" Applicant's contractors, agents, or consul-tants." Please identify by name each person or organization to which the allegation refers. ,

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4. Taking into account SCC's definition of " ear- ,

liest, practicable time," in what ways did each ,

of the persons or organizations listed in re- ,

sponse to question D.3 fail to comply with Criteria 1 and 2 of Appendix B?

5. Part 3 of this contention alleges insufficient

" independence from cost and schedule considera-tions." Please explain in detail what is meant by " independence from cost and schedule consi-derations."

6. Please identify which persons and organizations allegedly do not have " sufficient independence from cost and schedule considerations." .

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7. Please explain why the persons and organisations listed in response to question D.6 allegedly do not have " sufficient independence from cost and schedale considerations."
8. Please explain what is meant by "stop-work" au-thority.
9. Please identify which persons and organizations allegedly do not have adequate "stop-work" au-thority.
10. Please explain why the persons and organizations identified in response to question C.9 allegedly odo not have adequate "stop-work" authority.
11. Par C of this contention alleges a failure to

" adequately assure that the indoctrination and

. training of on-site QA/QC perscanel has been provided." Please explain in detail the basis for this allegation.

12. Part C also alleges a failure to " assure-that suitable proficiency is achieved and main-tained." Please explain in detail the basis for this allegation.
13. Part D of this contention alleges a failure to control five special processes (welding, heat-tre. sting, bracing, non-destructive testing, and cleanf1g). Please explain in detail how each of these processes allegedly has not been controlled.
14. Part D also alleges a failure to conduct the

' five special processes by qualified personnel.

Please explain the basis for this allegation.

15. Please liat every instance of which SCC is aware that qualified personnel have allegedly not been used in conducting the processes listed in Part D.
16. Part D alleges as well that qualified procedures have not been used in conducting the five spe-cial processes. Please explain in detail the basis for this allegation.
17. Please list every instance of which SCC is aware 7 . that qualified procedures were allegedly not fs

.,1 used for the special processes listed in Part D.

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18. And fert D' alleges a failure to comply with

" applicable codes, standards, specifications, criteria, and other special requirements imposed by the applicant, or applicant's contractors, agents or consultants." For each of these cate-gories please list the specific requirement that has allegedly not been complied with and each instance of alleged non-compliance.

19. -Part E of this contention alleges that the ap-plicant has failed "to establish measures to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation." Please explain the basis'for this allegation.
20. Please list each instance of which Soc is aware that non-conforming materials, parts, or compo-nents were allegecly used at Shoreham.
21. Part F of this contention alleges a failure to

" establish corrective action measures to assure that significant conditions adverse to quality are determined." Please explain what this allegation means and its basis.

22. Part F also alleges a failure to take "correc-tive action . . .to preclude repetition" of con-ditions adverse to quality. Please explain the basis for this allegation.
23. For the allegations in Part F, please list each instance of which SOC is aware that the appli-cant has aliegedly failed to take corrective action.
24. Part G of thir contention alleges a failure to take " timely follow-up action, including reau-dit, of deficiencies identified in audits."

Please explain the basis for this allegation.

25. Please identify each instance of .thich SCC is aware in which inadequate action on deficiencies identified in audits has allegedly been taken.
26. In the preamble to Contention 6(a)(1) SCC refers to I&E Investigation 50-322/79-24. Does SCC allege any deficiencies or errors in I&E Investigation Report- 50-322/79-24?
27. If the answer.to question D'.26 is anything-but a simple negative,1please list each alleged defi-  !

ciency or error in I&E Investigation Report 50-322/79-24. ,

28. -For each alleged' deficiency or error, identified in response-to question D.27, please explain the basis for the allegatio'n.

To the extent not already indicated in. response to ,

questions D.1 to D.28'please answer the-following ques-tions regarding each allegation in Contention 6(e.)(1):

29. What are the facts on unich SCC:
a. now relies; and 6
b. expects to rely during the Shoreham oper-ating license hearings?

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30. 19aat are the documents, if any, on which SCC: .j
a. now relies; and
b. expects to rely during the Shoreham oper- <

ating license hearings?

31. Either ittach to the response to these inter-regatories a copy of each document included in ,

the answer to question D.30 indicating the por-tions on which SOC relies now or expects to rely, or provide a description of each document, including the following: ,

a. its title, contents and length; ,
b. its date;
c. the date it was completed if different from ,

the date it bears;

d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of r:s ad-dressee, if any; P e

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f. its present location and the name, address and position of the person or persons having present custody of it; ,
g. references.to the portion.t'on which SOC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if.so:

(1) the.date it was destroyed; (2) the reasons it was destroyed; and (3)-the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

32. Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:
a. now relies; and

'b. expects to rely during the Shoreham oper-ating 11.ense hearings?

33. Regarding each person identified in the answer to question D.32:
a. What is the person't full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliation?

-d. What is the person's field of expertise?

! e. On what date did SCC first contact or con-sult the person?

! f. What are the dates of all subsequent con-

acts or consultations with the person?
g. Were any reports made to SCC by the person?
h. If the answer to question D.33g is anything

. other than a simple negative, indicate for each such report:

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(1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or both.

34. For each witness SOC intends to call in the Shoreham operating license hearings, please answer question D.33 and indicate:
a. What is the subject matter of the witness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
35. Has SCC made any studies or observations on which it:
a. now relies; and a b. expacts to rely during the Shoreham oper-4 ating license hearings?
36. If the answer to question D.35 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document prepared by or for SOC; and
b. for each study, observation, or document identified in the answers to questions D.35 and D.36a, provide the information requested in question D.31, unless such information .

was supplied in the answer to question D.31.

37. Is SCC alleging that any Shoreham systems, sub-systems, equip ~aent , and/or components are in  ;

violation of any NRC regulation (s)?

38. If the answer to question D.37 is anything but a simple regative, state pr'cisely:

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which Shoreham systems, subsystems, equip-a.

ment, and/or components allegedly violate the regulation (s); and

b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).
39. Is SOC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or
  • components does not comply with NRC regula-tion (s)?
40. If the answer to question D.39 is anything but a simple negative, state precisely:
a. for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;
b. with which NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;
c. which parts of the demonstration of safety allegedly fail to comply; and
d. why those parts of the demenstration of safety allegedly fail to comply.

E. SOC CONTENTION 7(a)(ii' Contention 7(a)(ii), as originally drafted, involved generic issues arising out of the accident at Three Mile Island, Unic 2. A Justiciable version of the contention has yet to be offered by SCC. On May 13, 1981, the NRC's response to the accident at TMI became the subject of rulemaking (46 Fed. Reg. 26491-98). Accordingly, many of the issues SCC has previously indicated a desire to raise can no longer be considered in an individual licensing case such as tbis. The Applicant will await the admission

e ,

1 of a_ justiciable contention, if any, before filing interrogatories on this subject.

F. SCC CONTENTION 8 SCC Contention S was admitted by the Board's Order of June 26, 1980 as follows':

TMI-2 demonstrated the need to measure fuel cladding temperatures during acci-dent conditions. GDC 13 requires that:

" Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for a normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to ensure adequate safety, including those variables and systems that can affect the fission process, the in-tegrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to main-tain these variables and systems within prescribed operating ranges."

Intervenors contend that the Shoreham plant design does not have instrumenta-tion to permit measurement of fuel clad temperature in the range experienced at TMI-2 as required by GDC 13.

1. Please explain the basis for the allegation that the existing instrumentation at Shoreham inade-quately measures fuel cladding temperatures.
2. What types of instruments and what ranges does SCC allege to be required by GCC 13?
3. What is the basis for assuming that the fuel temperatures experienced at TMI, a PWR, would be similar to those experienced during an accident at Shoreham, a BWR?

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To.the extent not already indicated in response to .

questions F.1 to F.3, please answer the following ques-tions regarding each allegation in Contention 8:

4. What.are the facts on which SOC:
a. now relies; and b, expects to rely during the Shoreham oper-ating license hearings?
5. What are the documents, if any, on which SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-

. ating license hearings?

6. Either attach to the response to these inter-rogatories a copy of each document included in the answer to question F.5 indicating the por-tions on which SCC relies now or expects to '

rely, or provide a description of each document, including the following:  ;

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es) and position (s) of '

its author (s) and signer (s), if different;

e. the name, address and position of its ad-dressee, if any;
f. its present location and the nace, address and position of the person or persons having present custody of it; l
g. references to the portions on wh.'ch SCC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if so:

P a

(1) the date it was destroyed; (2) the reasons it was destroyed; and (3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

7. Who are the persons, if any, on whose opinions and/or knowledge of facts SCC:
a. now relies; and
b. ' expects to rely during the Shoreham oper-ating license hearings?
8. Regarding each person identified in the answer to question F.7:
a. What is the person's full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliation?
d. What is the person's field of expertise?
e. On what date did SCC first cor. tact or con-sult the persen?
f. What are the dates of all subsequent con-tacts or consultations with the person?
g. Were any reports made to SCC by the person?
h. If the answer to question F.Sq is anything other than a simple negative, indicate for each such report:

(1) the date of the report; j (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or ,

both.  !

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_9. For each witness SOC intends to' call during the Shoreham operating licent3 hearing, please answer question F.8 and indicate:

a. What is the subject matter of the witness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for each. fact or opinion?
10. Has SOC made any studies or observations on which it:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
11. If the answer to question F.10 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document prepared by or for SCC; and
b. for each study, observation, or document identified in the answers to questions F.10 and F.11a, provide the information requested in question F.6, unless st.ch information was supplied in the answer te question F.6.
12. Is SCC alleging that any Shoreham systems, sub-systems, equipment, and/or components are in violation of any NRC regulation (s)?
13. If the answer to question F.12 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly. violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).
14. Is SCC alleging that the Applicant's and/or NRC Staff's demo:ctration of the safety of certain Shoreham systems, subsystems, equipment, and/or ccmponents does not comply with NRC regulation (s)?
15. If the answer to question F.14 is anything but a simple negative, state precisely:
a. for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;
b. with which NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;
c. which parts of the demonstration of safety allegedly fail to comply; and
d. why those parts of the demonstration of safety allegedly fail to comply.

G. SCC CONTDITION 9 SCC Contention 9 was admitted by the Board's Order of March 5, 1980 as follows:

As evidenced by the accident at Three Mile Accident [ sic] Unit 2, accident conditions can be aggravated by the op-eration of the plant while one or more safety systems are inoperable. At Three Mile Island, two auxiliary feedwater

' system valves were closed when they should have been open. Intervenors con-tend that the Shoreham plant does not contain an adequate system to inform the reactor operator when a safety system has been deliberately disabled.

Applicant must provide a system which meets the specifications of regulatory guide 1.47 or its equivalent in order to adequately protect the public health and safety and which complies with 10 CFR Part 50, Appendix A, Criteria 20, 21 and 22.

1. Please define what is meant by the term "delib-erately disabled."
2. List each safety system for which SCC contends a Shoreham operator would have inadequate indica-tion that the system has been " deliberately dis-tbled."
3. For each system listed in response to question .

G.2, please explain the basis for the allegation '

that the specifications of Regulatory Guide 1.47 or its equivalent are not met.

To the extent not already indicated in response to questions G.1 to G.3, please answer the following ques-tions regarding each allegation in Contention 9:

4. What are the facts on which SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
5. What are the documents, if any, en which SCC:
a. now relies; and
b. expects to rely during the Shoreham cper-ating license hearings?
6. Either attach to the response to these inter-regatories a copy of each document included in ,

the answer to question G.5 indicating the por-tions on which SOC relies now or expects to rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references to the portions on which SCC relies now or expects to rely; and
h. a_ statement whether it has been destroyed and, if so:

(1) the date it was destroyed;

.(2) the reasons it was. destroyed; and (3) the name, address and present or last.

known position and business affiliation of the person or persons who destroyed it.

7. Who are the persons, if any, on whose opinions and/or knowledge of facts SCC:

- a. now relies; and

.b. expects to rely during the Shoreham oper-ating license hearings?

8. Regarding each person identified in the answer to question G.7:
a. What is the person's full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliation?
d. What is the person's field of expertise?
e. On what date did SCC first contact or con-sult.the person?
f. What are the dates of all subsequent con-tacts or consultations with the person?
g. Were any reports made to SCC by the person?
h. If the answer to question G.8g is anything other than a simple negative, indicate for each such report:

(1) the date of the report;

.c (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a' prospective witness, or both.

9. For each witness SCC intends to call during the Shoreham operating license hearing, please answer question G.8 and. indicate:
a. What is the subject matter of the witness' testimony? i
b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
10. Has SCC mada any studies or observations on which it:
a. ~ now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
11. If the answer to question G.10 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document prepared by or for SCC; and
b. for each study, observation, or document identified in the answers to questions G.10 and G.lla, provide the information requested in question G.6, unless such information was supplied in the answer to question G.6.
12. Is SCC alleging that any Shoreham systems, sub-systems, equipment, and/or components are in violation of any MRC regulation (s)?
13. If the answer to question G.12 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. hcw those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).
14. Is SOC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or components does not comply with NRC regula-tion (s)?
15. If the answer to question G.14 is anything but a simple negative, state precisely:
a. -for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;
b. with which NRC regulation (s) the demonstra-

. tion of safety allegedly fails to comply; ,

c. which parts of the demonstration of safety allegedly fail to comply; and
d. why those parts of the demonstration of safety allegedly fail to comply.

H. SOC CONTENTION 12 (? ART TWO) 50C Contention 12 (part two) was admitted by the Board's Order of June 26, 1980 as follows:

The ongoing Mark II test program has recently determined a need to install additional downecmer bracing at least (sic] two GE-SWR plants, LaSalle and Zimmer. Additionally, further Mark II tests are underway and still to be analyted by the Staff. Secause of the potential inadequacy of this design fea-ture. Intervenors contend that the Shoreham primary containment system has not been demonstrated Oc fulfill the requirements of 10 CFR, Par 50, Appendix A, Criteria 4, 16 and 50.

1. Please explain what " additional downcomer brac-ing" needed to be installed at Zimmer and l LaSalle as a result of the Mark II test program.
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2. Does SCC claim that this " additional downcomer bracing" is not installed at Shoreham?
3. Please explain how the failure to have "addi-tional downcomer bracing," as defined in ques-tions H.1 and H.2, violates 10 CFR, Part 50, Appendix A, Criteria 4, 16 and 50.

To the extent not already. indicated in response to questions H.1 to H.3, please answer the following ques-tions regarding each allegation in Contention 12 (part two):

4. What are the facts on which SOC:

. a. now relies; and

b. expects to rely during the Shoreham oper-ating license hearings?
5. What are the documents, if any, on which SOC:
a. nov relies; and
b. expects to rely during the Shoreham oper-ating license hearings?

6 Either attach to the response to these inter-rogatories a copy of each document included in the answer to question H.S indicating the por-tions on which SCC relies now or expects to rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any; e
f. its-present location and the name, address and position of the person or persons having present custody of it; g.- references to the portions on which SCC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if so:

(1) the date it_was destroyed; (2) the reasons it was destroyed; and

.(3) the name, address and present or last known position and business affiliation of the person'or persons who destroyed it.

7. Who-are the persons, if any, on whose opinions and/or knowledge of facts SCC:
a. now relies; and
b. exp.tcts to rely during the Shoreham oper-ating license hearings?
8. Regarding each person identified in the answer to question H.7:
a. What is the person's full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliation?

c' . What is the person's field of expertise?

a. On what date did SCC first contact or con-sult the person?
f. What are the darcs of all subsequent con-taccs or censultations with the person?
g. 'Jors any reports made to SCC by nha person?
h. If the answer to question H.8g is anything I other than a simple negative, indicate for each.such report:

t (1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or '

both.

9. For each witness SCC intends to call in the Shoreham operating license hearing, please  ;

answer question H.8 and indicate: ,

a. What is.the-subject matter of the witness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?

t

10. Has SCC made any studica or observations on which it:
a. now relies; and i
b. expects to rely during the Shoreham oper-ating license hearings?
11. If the answer to question H.10 is anything other .

than a sinple negative:

a. indicate whether the study or observation has been included in any document prepared by or for SCC; and
b. for each study, observation, or document  !

identified in the answers to questions H.10 and H.11a, provide the information requested in question H.6, unless such information was supplied in the answer to question H.6.

12. Is SCC alleging that any Shoreham systems, sub-systems, equipment, and/or components are in violation of any NRC regulation (s)? ,
13. If the answer to question H.12 is anything but a simple negative, state precisely:

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-Q - - - - - , - _ -

a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allogedly violate the reg-ulation(s).
14. Is SOC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or components does not' comply with NRC regula-tion (s)?
15. If the answer to question H.14 is anything but a simple negative, state precisely:
a. for which Shoreham systems, subsystems,

, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;

b. with which NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;
c. which parts of the demonstration of safety

' allegedly fail to comply; and

d. why those parts of the demonstration of safety allegedly fail to comply.

I. SCC CONTENTION 12 (PART THREE)

SCC Contention 12 (part three) was admitted by the Board's Order of July 2, 1980 within the guidelines for litigating hydrogen control issues provided by the Commission in CLI-80-16. SOC has not yet proposed a ver-sien of this contention that conforms to the Commission's guidance. The following interrogatories are submitted to speed the particularization process:

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1. D9es SCC intend to submit ~to-the Board a partic-ularited version of Contention 12 (part three)?
2. If the answer to question I.1 is anything but a simple negative, state when 50C anticipates sub-mitting such a particularized contention.
3. Will the particularited contention contain allegations concerning Shoreham's compliance with any part of 10 CER, Part 50?
4. If the answer to question I.3 is anything but a simple negative, please explain why each of these allegations can be admitted under the Board's July 2, 1980 Order.
5.  ? lease list any other allegations SCC intends to make concerning the issue of hydrogen generation and control.

To the extent not already indicated in response to questions !.1 to I.5, please answer the following ques-tions regarding each allegation that SOC intends to in-clude in Contention 12 (part three):

6. What are the facts on which SCC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
7. What are the documents, if any, en which SOC:
a. now relies; and
b. expects to rely during the Shorsham oper-ating license hearings?
8. Either attach to the response to these inter-rogatories a copy of each document included in the answer to question I.7 indicating the por-tions on which SCC relies now or expects to rely, or provide a description of each document, including the following:
r. -
e. . \

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a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
q. references to the portions on which SCC

. relies now or expects to rely; and .

h. a statement whether it has been destroyed and, if so:

(1) the date it was destroyed; (2) the reasons it was destroyed; and (3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

9. Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
10. Regarding each person identified in the answer to question I.9:
a. What is the person's full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliation?
d. What is the person's field of expertise?
e. On what'date did SCC first contact or con-sult the person?
f. What are the dates of all subsequent con-tacts or consultations with the person? ,
q. Were any reporcs made to SCC by the person?
h. If the answer to question I.10g is anything other than a simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; i and (3) whether the report was submitted by the person whi.le acting in an advisory ca-pacity, as a prospective witness, or both.

1 11. For each witness SCC intends to call in the Shortham operating license hearing, please i

answer question I.10 and indicate:

a. What is the subject matter of the witness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
12. Has SCC made any studies or observations on ,

I which it:

4

a. now relies; and i:
b. expects to rely during the Shoreham oper- .

ating license hearings?

13. If the answer to question I.12 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document prepared by or for 50C; and r I

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

o. .o
b. for each study, observation, or document identified in the answers to questions I.12 and'I.13a provide the information requested

-1.. question'I.8, unless such information was supplied in the answer to question I.8.

14. Is SCC alleging that any Shoreham systems, . sub-systems, equipment, and/or components are in violation of any NRC regulation (s)?
15. If the answer to question I.14 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s). ,
16. Is SCC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or components does not comply with NRC regula-

. tion (s)?

17. If the answer to question I.16 is anything but.a simple negative, state precisely:
a. for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;
b. with which NRC regulatiog(s) the demonstra-tion of safety allegedly fails to comply;
c. which parts of the demonstration of safety allegedly fail to comply; and
d. why those parts of the demonstration of safety allegedly fail to comply.

J. SCC CONTEN* ION 15 SCC Contention 15 was admitted by the Board's Order of March 5, 1980 as follows, with the cavett that it was limited to I&E Bulletin 79-26:

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L Intervenors contend that the reactor control rod design proposed for use at the Shoreham Plant does not meet the requirements of 10 CFR, Part 50, '

Appendix A, Criteria 4,~;21 and 22. This contention is suppo ted by the issuance of the NRC's I&E Bulletin 79-26 which-advises the operators of SWR's of a  ;

recently observed control rod failure mode that can go undetected, jeopardis-ing the shutdown capability of the reac- .

tivity control system and endangering' the public health and safety.

1. I&E Sulletin 79-26 was addressed to a generic problem found in General Electric SWR's. Does >

SCC claim that this problem is specifically ap- ,

plicable to Shoreham's design?

2. If the answer to questions J.1 is anything but a i simple negative, please explain the basis for claiming that I&E Sulletin 79-26 supports the allegation that Shoreham violates 10 CFR, Part ,

50, Appendix A, Criteria 4, 21, 22. a

3. I&E Sulletin 79-26 contains interim and long .

term actions to ensure that degradation of con-trol rod function does not occur. Does SCC con-tend that:

, a. the interim action is inadequate; and

b. the long term action is inadequate?
4. If the answer to question J.3a or b is a..ything but a simple negative, please explain in detail the basis-for the alleged inadequacies.

To the extent net already indicated in response to {

questions J.1 to J.4, please answer the following ques-tions regarding each allegation in Contention 15:

5. What are the fac*.s on which SCC:
a. now relies; and
b. expects to rely during the Shoreham cper-ating license hearings?

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-6. What'are the documents, if any, on which SOC:

a. now relies; and b, expects to rely during the Shorcham oper-ating license hearings?
7. Either-attach to the response to these inter-rogatories a copy of each document included in the answer to question J.6 indicating the por-

.tions on which SCC relies now or expects to rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;

. c. the date it was completed if different from the date it bears;

d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if'any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references to the portions on which SOC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if so:

(1) the date it was destroyed; (2) the reasons it was destroyed; and ,

(3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

8. Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:

f

a. now relies; and
b. expects to' rely during the Shoreham oper-ating license _ hearings?
9. Regarding each person identified in the answer to question J.8:

i

a. What is the person's full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliation?
d. What is the person's field of expertise?
e. On what date did SCC first contact or con-

. sult the person?

f. What are the dates of all subsequent con-tacts or consultations with the person?
g. Were any reports made to SOC by the person?
h. If the answer to question J.9g is anything other than a simple negative, indicate for each such report:

(1) the date of -he report; (2) whether the report was written or oral;

. and (3) whether the report was submitted by the person while acting in an e.dvisory ca-pacity, as a prospective witness, or both.

10. For each witness SOC intends to call in the Shoreham operating license hearing, please answer question J.9 and indicate:
a. What is the subject matter of the witness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for f each fact or opinion?

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11. lHas SCC made any studies or observations on.

'which it: -

a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
12. If the answer to~ question J.11 is anything other than a simple negative:

-a. ' indicate whether the study or observation has been included in any document prepared by or for SCC; and

b. for each study, observation, or document identified in the answers to questions J.11 and J.12a, provide the information requested in Question J.7, unless such information was supplied in the answer to question J.7.

4

13. Is SCC alleging that any Shoreham systems, sub-systems, equipment, and/or components are in violation of any NRC regulation (s)?

1

14. If the' answer to question J.13 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).

! IS. Is SCC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or components does not comply with NRC regula-tion (s)?

16. If the answer to question J.ls is anything but a j simple negative, stace precisely:
a. for.which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate; e

^* a

b. with whiah NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;
c. -which parts _of the demonstration of safety allegedly. fail to comply; and
d. why those parts of the demonstration of safety allegedly-fail to comply.

K. SOC Contention 16 SOC Contention 16 was admitted by the' Board's Order of March 5, 1980 as follows:

The ECCS at Shoreham may not meet the requirements of 10 CFR, Part 50 because of clad swelling and flow blockage. New test results obtained by the NRC Staff and reported in NUREG-0630 show that modeling of clad swelling and flow blockage is inadequate.

1. What medels does SCC allege were used in analy:-

ing clad swelling'and flow blockage for Shoreham?

2. Does SCC contend that the clad swelling modeling for Shoreham was inadequate?
3. Does SCC contend that the flow blockage modeling for Shoreham was inadequate?
4. If the answer to either question K.2 or K.3 is anything but a simple negative, please explain in detail the basis for SOC's allegation that the modeling was inadequate.
5. Does SCC have any information other than that contained in NUREG-0630 which would indicate that the flow blockage or clad swelling model for Sh:reham were inadequate?
6. If the answer to question K.5 is anything but a simple negative, please identify the informa-

- tion.

e

7. -For any information listed in response to ques-tion K.6 explain why it allegedly shows the flow

-blockage or clad swelling models for Shoreham were. inadequate ~.

To the extent not already_ indicated in response to questions K.llto K.7, please answer the following ques-tions'regarding-each allegation in Contention 16:

8. What are the facts on which SOC:
a. now relies; and
b. . expects to rely durinJ the Shoreham oper-ating license hearings?
9. What are the documents, if any, on which SCC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
10. Either attach to the response to these inter-rogatories a cury-of each document included in the answer to question ~K.9 indicating the por-tions on which SCC relies now or expects to rely, or provide a description of each dccument, including the following:
a. its title, contents and leng-h;
b. its date;
c. the date it was completed if different from
  • he date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it; b o

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g. references to the portions on which SCC -

relies now or expects to rely; and

h. a statement whether it has been destroyed and, if so:

(1)'the date it was destroyed; i

(2) the reasons it was destroyed; and (3) the name, address and present or Iast known position and business affiliation of the person or persons who destroyed it.

11. Who are the persons, if any, on whose opinions and/or knowledge of facts SCC:

. a. now relies; and

b. expects to rely during the Shorehan. oper-ating license hearings?
12. Regarding each person identified in the answer to question K.ll:

, a. What is the person's full r..tme?

b. What is the person's address?
c. What is the person's present or last known position and business affiliation?
d. What is the person's field of expertise?
e. On what date did SCC first contact or con-sult the person?
f. What are the dates of all subsequent con-tacts or consultations with the person?
g. Were any reports made to SCC by the person?
h. If the answer to question K.12g is anything other than a simple negative, indicate for each such report:

(1) the date of th<a report;

- - - - , , , ,-, , - , ~

(2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting-in an advisory ca-pacity, as a. prospective witness, or both.

13. For each witness SCC intends to call in the Shoreham operating license hearing, please answer question K.12 and indicate:
a. What is the subject matter'of-the witness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
14. Has SCC made any studies or observations on which it:

4

a. now relies; and
b. expects to rely during the Shoreham oper-ating' license hearings?
15. If the answer to question K.14 is anything other i

than a simple negative:

a. indicate whether the study or observation has been included in any document prepared by or for SOC; and
b. for each study, observation, or document identified in the answers to questions K.14 and K.15a, provide the information requested 4

in Question K.10, unless such information was supplied in the answer to question K.10.

16. Is 50C alleging that any Shoreham systems, sub-systems, equipment, and/or components are in
violation of any NRC regulation (s)?
17. If the answer to question K.16 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and 4 % e - w - wn'

j

b. how those systams, subsystems, equipment, and/or components allegedly violate the reg--

ulation(s).

18. Is SOC alleging that the Applicant's and/or NRC Staff's demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or components does not comply with NRC regula-tion (s)?
19. If the answer to question K.18 is anything but a simple negative, state precisely:
a. for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;
b. with which NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;
c. which parts of the demonstration of safety allegedly fail to comply; and
d. why those parts of the demonstration of safety allegedly fail-to comply.

L. SOC CONTENTION 17 SOC Contention 17 was admitted by the Board's Order of March 5, 1980 as follows:

Intervenors contend that the design of the Shoreham Nuclear Unit i violates 10 CFR 50.55a(h) (section 4.16 of IEEE 279) which states:

the protection system shall be so designed that, once initiated, a protective system action shall go to completion.

As evidenced by the. accident at Three Mile Island Unit 2, a reactor operator can shut off the emergency core cooling system prior to the completion of its stated finction. Such an action by a reactor operator can aggravate a reactor accident and the failure of the Shoreham

.*. : =

design to prevent such operator actions endangers the public health and safety. ,

The Shoreham. design must b' modified so that operator action cannot disable a safety system once it has been initiated prior to that system's completion of its safety function.

-1. Please list sach safety system or component that SOC alleges can be disabled by operator action prior to completion of its safety function.

2. For each system or component listed in response

'to question L.1, please explain t'e basis for alleging that it can be disabled by operator

. action.

. 3. For each system or component listed in response to question L.1, please explain what SCC consid-ers to be the " completion of its safety func-tion."

4. SOC claims that the "Shoreham design must be modified." What specific modifications does SCC allege to be required?
5. For each of the modifications listed in response i .to question L.4, please provide SCC's evaluation of the consequences of precluding the operator from manually overriding the operation of the system or component.

To the extent not already indicated in response to

questions L.1 to L.5, please answer the following ques- ,

tions regarding each allegation in Contention 17:

J

6. What are the facts on which SCC:
a. now relies; and i
b. expects to rely during the Shoreham oper-ating license hearings?
7. What are the documents, if any, on which SCC:

l l

1 l

s m ab a '. now relies: snd

b. expects to rely during the Shoreham oper-ating license hearings?
8. Either attach.to the respon.e to these-inter-rogatories a copy of each document included in the answer to question L.'7 indicating the por--

tions on which SOC relieu now or expects to  ;

rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if- different;
e. the name, address and position of its ad-dressee. if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references to the portions on which SCC relies now or expects to rely; and
h. a statement whether it has been destroyed

- and, if so:

(1) the date it was destroyed; (2) the reasons it was destroyed; and (3) the name, address and present or last known position and business affiliation of the person or persons who destroyed it.

9. Who ar rhe persons, if any, on whose opinions and/ot .<newledge of facts SCC:
a. 'now relies; and

~'o- ~i 1

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b.  : expects to rely during the Shoreham oper-ating license hearings?
10. Regarding each person identified in the answer to: Question L.9:
a. What is'the person's full name?
b. What is the person's address?
c. What is the person's present or last known position and business affiliatten!
d. What is the person's field of expertise?
e. On what date did SOC first contact or con-sult the person?

. f. What are the dates of all-subsequent con-tacts or consultations with the person?

g. Were any reports made to SCC by the person?
h. If the answer to question L. log is anything other.than a simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or both,

11. For each witness SCC intends to call in the Shoreham operating license hearing, please answer question L.10 and indicate:
a. What is the subject matter of the aitness' testimony?
b. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
12. Has SCC'made any studies or observations on which it:
a. now relies; and-
b. . expects to rely during the Shoreham oper-ating license hearings?
13. If the answer to questien L.12 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document prepared by or for SCC; and
b. for each study, observation, or document identified in the answers to questions L.12 and L.13a, provide the information requested in question L.8, unless such information was supplied in the answer to question L.8.

. 14. Is SCC alleging that any.Shoreham systems, sub-systems, equipment, and/or components are in

.-iolation of any NRC regulation (s)?

15. If the answer to question L.14 is anything but a simple negative,-state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).
16. Is SCC alleging that the Applicant's and/or NRC Staff's' demonstration of the safety of certain Shoreham systems, subsystems, equipment, and/or components does'not comply with NRC regula-tion (s)?
17. If the answer to question L.16 is anything but a simple negative, state precisely:
a. for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly inadequate;
b. with which NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;

.i

  • .a;. _.

2

c. which parts of the demonstration of safety allegedly fail to comply; and i
d. why those parts of the' demonstration of safety allegedly fail to comply.

M. SOC CONTENTION 19 On March 18, 1981, SOC submitted a particularized version of Contention 19. The Applicant and the NRC-Staff .,

have objected to the bulk of SOC's proposed contention.

Pending the Board's decision, the Applicant requests that-the following interrogatories be answered for the four Regulatory Guides.(1.9, 1.140, 1.443, and 1.144) that the Applicant agreed were properly included in the contention.

If the Board admits more than these four regulatory guides, further. questions will be forthcoming.

1. For each Regulatory Guide allegedly not met by Shoreham, please list the precise regula ory position or positions SCC contends have been violated.
2. For each regulatory position identified in response to question M.1, please explain the basis for the allegation that Shoreham fails to meet it.
3. For each regulatory position identified in response to question M.1, please indicate whether failure to meet the position allegedly results in the violation of any NRC regulation or regulations.
4. For each alleged failure to meet NRC regulations idanti-fled in response to question-M.3, please list the regula- '

tion and explain the basis for contending that it has been violated.

To the extent not already indicated in response to questions M.1 to M.4, please answer the following ques-i tions regarding each allegation in Contention 19:  !

1 l

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

a vo. _

.. +

4 '

4. What'are the facts on which SOC:
a. n(,w relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
5. 'What-are the documents, if any, on which SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
6. Either attach to the response to these inter-rogatories a copy of each document included in the answer to question M.5 indicating the por-tions on which SCC relies now or expects to

. rely, or provide a description of each document, including the following:

a. its title, contents and length;
b. its date;
c. the date it was completed if different from the date it bears;
d. the name(s), address (es) and position (s) of its author (s) and signer (s), if different;
e. the name, address and position of its ad-dressee, if any;
f. its present location and the name, address and position of the person or persons having present custody of it;
g. references-to the portions on which SOC relies now or expects to rely; and
h. a statement whether it has been destroyed and, if so:

(1) the date it was destroyed; (2) the reasons it was destroyed; and (3) the name, address and prestnt or last known position and business affiliation of the person or persons who destroyed it.

r- y - - -

-oz,. e 1

7. Who are the persons, if any, on whose opinions and/or knowledge of facts SOC:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
8. Regarding each person identified in the answer to question M.7:
a. What is the person's full name?
b. What it the person's address?
c. What is the person's present or last known position and business affiliation?

. d. What is the person's field of expertise?

e. On what date did SCC first contact or con-sult the person?
f. What are the dates of all subsequent con-tacts or, consultations with the person?
g. Were any reports made to SCC by the person?
h. If the answer to question M.8g is anything other than a simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was submitted by the person while acting in an advisory ca-pacity, as a prospective witness, or both.

9. For each witness SCC intends : call in the Shoreham operating license pr:ceed_ng, please answer question M.8 and indicate:
a. What is the subject matter of the witness' testimony?

e x = o-

b. What are the facts and/or opinions to which

. the witness will testify and the grounds for each fact or opinion?

10. Has SCC made any studies or observations on which it:
a. now relies; and
b. expects to rely during the Shoreham oper-ating license hearings?
11. If the answer to question M.10 is anything other than a simple negative:
a. indicate whether the study or observation has been included in any document drepared by or for SOC; and
b. for each study, observation, or document identified in the answers to questions M.10 and M.11a, provide the information requested in question M.6, unless such information was supplied in the answer to question M.6.
12. Is SCC alleging that any Shoreham systems, sub-systems, equipment, and/or components are in violation of any MRC regulation (s)?
13. If the answer to question M.12 is anything but a simple negative, state precisely:
a. which Shoreham systems, subsystems, equip-ment, and/or components allegedly violate the regulation (s); and
b. how those systems, subsystems, equipment, and/or components allegedly violate the reg-ulation(s).
14. Is SCC alleging that the Applicant's and/or NRC Staff's demonstration of ths safety of certain Shoreham systems, subsystems, equipment, and/or components does not comply with NRC regula-tion (s)?
15. If the answer to question M.14 is anything but a simple negative, state precisely:
  1. b is o c .

l

a. for which Shoreham systems, subsystems, equipment, and/or components the demonstra-tion of safety is allegedly' inadequate;
b. with which NRC regulation (s) the demonstra-tion of safety allegedly fails to comply;
c. which parts of the demonstration of safety allegedly fail to comply; and
d. why those parts of the demonstration of safety allegedly fail to comply.

Respectfully submitted, L *G ISLAND LI HT COMPANY-

/ A 7

4 Fr- taylor vele , I I .

Anthony . Earley, Jr.

Hunton & Williams P. O. Box 1535 Richmond, VA 23212 Dated: May 21, 1981-f

.f .

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