ML19350E309

First Set of Interrogatories & Request for Production of Documents Directed to Util Re Proposed Rule for Licensing Requirements for Pending OL Applicants.Certificate of Svc Encl

ML19350E309
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/09/1981
From:	Latham S SHOREHAM OPPONENTS COALITION, TWOMEY, LATHAM & SHEA
To:	LONG ISLAND LIGHTING CO.
Shared Package
ML19350E302	List: ML19350E301 ML19350E304 ML19350E307 ML19350E309
References
NUDOCS 8106170288
Download: ML19350E309 (6)

Text

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Mater of )

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LONG ISLAND LIGHTING COMPANY ) Docke t No. 50-322

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(Shorenam Nuclear Power Station,)

Unit 1) )

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SOC'S FIRST SET OF INTERROGATORES AND REQUEST FOR PRODUCTION OF DOCUAENTS TO LONG ISLAND LIGHTING COMPANY I.

The Shoreham Opponents Coalition (SOC) serves on the Long Island Lighting Company (LILCO) the interrogstories that appear below. A sworn response to them.must be provided to SOC in accordance with the terms of 1G c'FR Section 2.740(b) and._50 CFR Section 2.741. Pursuant to Section 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

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1. For the recommendations and requirements listed ~

in NUREG-0578 : 1/

1/ NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendarlons , U.S. NRC, July,.

1979. _

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I a) Please provide a list of all correspondence and documents 2' betwee n *_:L"O 3/and ::.e NRC , ce: ween LILCO and 3E, and between L'TLCO and Stone & Wetster related to the requirements in tne sucject document. Please provide the author, addressee, sucject, and orief description of :ne conter.:s of each. _

b) For each and every recommendation or requirement listed in NUREG-0578 :

1) Identify each requirement which Applicant believes is applicable to Shorenam and state whether Applicant will meet the requirement prior to fuel load.

2) Please state whether LILCO currently meets each and every aspect of the requirements identified in 1(b)1. above.

3) For each item where LILCO does not meet one or more detailed recommmendations or requirements, list the exceptions, waivers or modifications requested and state whether any such exceptions, waivers or modifications have been granted by NRC.

2/ " Document" or " documents," as used in these Interrogatories, mean any handwritten, typed, printed, recorded or graphic matter however produced or reproduced,. including material stored for use in ,

automatic data. processing systems, whether or not in the possession, custody or control of LILCO and whether or not claimed to be privileged against discovery on any ground, including: reports; records; lists; memoranda; correspondence; telegrams; schedules; pho tog raphs.; sound recordings; films; hand, machine and. computer l -- calculations; computer codes; data; and written statements of witnesses or other persons having knowledge of the facts.

3/ "LILCO," as used in these interrogatories, means Eong Island Lighting Company, its officers, agents, l

employees and consultants.

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4) For each recommendation or requirement where LILCO does not meet one or more parts of the requirement but has chosen an alternate approach, please describe in detail the alternate approach and state whether the NRC has approved the alternate approach.

c) Please provide a copy of any and all documents submitted to the NRC defining LILCO's positions and responses to the recommendations or requirements in the subject document.

2. For recommendations or requirements listed in NUREG-0737,4/ please provide answers to each of the questions and requests in 1 a) , 1 b) , and 1 c) above.

3. For each issue listed in NUREG-0660 5/ but not

-- listed in NUREG-0578 or NUREG-0737, please provide answers to each of the questions and requests in Interrogatory 1 a) , 1 b), and 1 c).

4. Please provide a copy of all documents and correspondence between LILCO and GE and between LILCO and Stone & Webster which is related to the LILCO position on any and all of the issues and requirements in NUREG-0 578, 07 37, and 0660.

5. Please provide a copy of each and every. item of correspondence or other documents. between LILCO and the BWR Owners Group which relates to any and all of the issues in NUREG-0578, 0737, and 0660.

6. Please provide schedules for implementation of modifications to the Shoreham plant resulting from any and all requirements in NUREG-0578, 0737, and 0660.

4/ NUREG-0737, Clarification of TMI Action Plan Requirements , NRR, U.S. NRC, Octooer, 1980.

5/ NUREG-0660, NRC Action Plan Developed as a Result of the TMI-2 Accident, U.S. N RC , Vo l . 1, May, 1980.

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7. Please provide a copy of all correspondence and documents between LILCO and the NRC related to tne requirements in Regulatory Guide 1.97, Revision 2. 6/

8. Does Shoceham comp'i 3' with all details included in the Proposed Rule for Lic9nsing Requirements for Pending Operating License . Applicants as published in the May 13, 1981 Federal Reg ister ,' Vol . 45, No. 92, pages 26491 through 2o498?

a) List all parts of the proposed rule which Shoreham does not currently meet.

b) Provide copies of any correspondence or comments provided by LILCO to the NRC regarding the proposed rule. If these are not yet submitted, please provide the date LILCO plans to provide comments to the NRC and provide. SOC with a copy at that time.

c) Please provide a copy of any correspondence or comments by the BWR Owners Group to the NRC in response to the proposed rule.

Respectful-ly submitted, SHOREHAK OPPONENTS COALITION f / Q Yl

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i W. &

Stephen B. Latham Twomey, Latham & Schm'tt .

P.O. Box !8 Riverhead, N.Y. 11901

__ _ Dated: June 9, 198?

6/ Regulatory Guide 1.97, Instrumentation for Light- '

Water-Cooled Nucl. ear Power Plants to Assess Plant, Conditions during and Following an Accident, Rev is ion 2, -

Decemoer, 1979.

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• s e vI e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARO In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docnet No. 50-322

)

(Shoreham Nuclear Power Station,)

Unit ') )

CERTIFICATE OF SERVICE I hereby certify that copies of Shoreham Ooponents Coalition's Status Report, Answers of Shoreham Opponents Coalition to First Set of Applicant's Interrogatories, dated May 21, 1981, and Shorenam Opponents Coalition's First Set of InterrogaIories and Request for Production of Documents to Long Island Lighting Company dated June 9, 1981, were served upon the following by

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first-class mail, postage prepaid, on June 9, 1981:

Louis J. Carter, Chairman Ralph Shapiro, Esq.

Administrative Judge Cammer and Shapiro 23 Wiltshire Road No. 9 East 40th Street Philadelphia, Pa. 19151 New York, N.Y. 10016 Mr. Frederick J. Shon, Member W. Taylor Reveley, III, Esq.

Atomic Safety & Licensing Board Hunton & Williams U.S. Nuclear Regulatory Comm. P.O. Box 1535 Washington, D.C. 20555 Richm'dnd, Va. 23212 Dr. Oscar H. Paris, Member Jeffrey Cohen, Esq.

Atomic Safety & Licensing Board Deputy Commissioner & Counsel U.S. Nuclear Regulatory Comm. New York State Energy Office Washingtor., D.C. 20555 Agency Bldg. 2 Empire State Plaza Edward M. Barrett, Esq. Albany, N.Y. 12223 General Counsel Long Island Lighting Co. Atomic Safety & Licensing 250 Old Country Road Appeal Board Mineola, N.Y. 11501 U.S. Nuclear Regulatory Comm.

dashington, D.C. 20555 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm. Samuel J. Chilk, Secretary Washington, D.C. 20555 Docketing and Service Station U.S. Nuclear Regulatory Comm.

Howard L. Blau, Esq. Washington, D.C. 20555 217 Newbridge Road Hicksville. N.Y. 11801

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David J. Gilmartin, Esq. J.P. Novarro Suffolk County Attorney Project '4anager, LILCO Suffolk Co. Dept. of Law P.O. Box 61d veterans Me.norial Hignway Wading River, N.Y. 11792 Hauppa ug e , N.Y. 11787 Energy Research Group, Inc.

Patricia Dempsey, Esq. 400-1 13tten Pond Road

-Asst. County Attorney - Waltnam, Mass. 02154 Suffolk Co. Dept. of Law Veterans Memorial Highway Bernard M. Bordenick Hauppaug e, N.Y. 11787 Counsel for NRC Staff U.S. Nuclear Regulatory Comm.

MH3 Technical Associates Washington, D.C. 20555 1723 Hamilton Avenue Suite K Nora Bredes San Jose, Ca. 95125 SOC Coordinator 195 E. Main Street Smithtown, N.Y. 11787

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Stepnen B. Latham 9

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