ML20009H083

Third Set of Interrogatories & Request for Production of Documents Directed to Util Re Statement of Position for Each Paragraph of NRC Position & Description of Alternative Positions.Certificate of Svc Encl

ML20009H083
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/29/1981
From:	SHOREHAM OPPONENTS COALITION, TWOMEY, LATHAM & SHEA
To:	LONG ISLAND LIGHTING CO.
References
NUDOCS 8108050423
Download: ML20009H083 (5)

Text

7/29/81

['

JtELATED CORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

)

(Shoreham tcuclear Power Station, )

Unit 1) )

SOC'S THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION // t 3 OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY -

4:: , AUG 31981 > ';

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\O Pur uant to 10 CFA Sections 2.740(b) and 2. 741 (d ) , the Shoreham Opponents Coalition, (SOC) serves on the Long Island Lighting Company (LILCO) the interrogatories and requests for production of documents that appear below. 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.

In view of the resumption of informal discovery and discussions among SOC, Staff and LILCO, a sworn response to these interrogatories and documents requests need not be provided within the time frames stated in the regulations. It is SOC's understanding that these interrogatories will be discussed prior to and at the next informal meeting among the parties and that LILCO will begin to assemble its answers prior to the date of that next meeting. i)bD3 5

8108050423 G10729 /[

PDR ADOCK 05000322 PDR C

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As used in the interrogatories and request for production of documents, the following definitions apply as indicated:

1 "LILCO," means Lang Island Lighting Company, its officers, agents, employees and consultants.

2 " Document" or " documents," 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; 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.

Please provide. answers to the following questions which pertain to specific SOC contentions in Docket No. 50-322.

Each of the three interrogatories and documents requests that appear below are to be answered for each of the Regulatory Guides admitted as part of SOC Contention 19 by the Board s Memorandum ,

and Order dated July 7, 1981, subparts A-L.

1 For each paragraph of the Regulatory position set forth in the Regulatory Guide, state whether or not the Applicant is in full compliance with each paragraph of the Regulatory position.

pr L___ .__________.__.___._.__.__.__m___...___ _ _ _ _ _ . _ . _ _ _ _ _ _ . . . - _ _ _ - _ _ _ . _ - _ _ _ _ _ _ _ _ , _ _ _ . _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ - _ . _ _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ . . .

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2. For each paragraph of the Regulatory position identified in question 1 to which the answer is affirmative, cite the relevant portion (s) of the FSAR cad /or any other documents which set forth the method of compliance and provide copies of any such documents (other than the FSAR).

3. For each paragraph of the Regulatory position identified in question 1 to which the answer is negative:

a. Describe the alternative (s) to the Regulatory position implemented by the Applicant;

b. Is it the Applicant's position that the alternative (s) identified in 3(a) provide an equivalent level of safety to that specified in the Regulatory position?

c. Explain in detail the basis for the answer to 3(b) and provide copies of all documents upon which the Applicant

) relies to support that position.

J j Respectfuly submitted, TWOMEY, LATHAM & SCHMITT

Attorneys.for Shoreham i Opponents Coalition

( 33 West Second Street '

P.O. Box 398 Riverhead, N.Y. 11901 1

i

Dated

, July,29, 19.81 .

4

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hr.t AlhD COklmspomnwy UNITED STATES OF AMERICA /

~g y . NUCLEAR REGULATORY. COMMISSION .

7 .de 51981 > 4

_BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i U E;Y2f A, t

$ "- g cx ,_Z1 In the Matter of ) ';5 d40 LONG ISLAND LIGHTING COMPANY

)

) Docket No. 50-32

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)

(Shoreham Nuclear Power Station,)

Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " SOC's Third Set of Interrogatories and Request for Production of Documents to Long Island Lighting Company" dated July 29, 1981, and " Motion of the Shoreham Opponents Coalition (SOC) For Reconsideration of Board's Dismissal of Certain Regulatory Guides Contained in SOC's Contention 19" dated July 30, 1981, and submitted by the Shoreham Opponents Coalition, in the above captioned proceeding, have been served on the following, by deposit in the United States mail, first class, this 30th day of July, 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, E.sq .

Atomic Sa.fety & Licensing Board Hunton & Williams U.S. Nuclear Regulatory Comm. P.O. Box 1535 Washington, D.C. 20555 Richmond, 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 Washington, 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.

Washington, D.C. 20555 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm. Samxl J. Chilk, Secretary Washington, D.C. 20555 Dock? ting and Service Station U.S. Nuclear Regulatory Comm.

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

David J. Gilmartin, Esq. J.P. Novarro Suffolk County Attorney Project Manager, LILCO Suffolk Co. Dept. of Law P.O. Box 618 Veterans Memorial Highway Wading River, N.Y. 11792 Hauppauge, N.Y. 11787 Energy Research Group, Inc.

Patricia Dempsey, Esq. 400-1 Totten Pond Road Asst. County Attorney Walthan., Mass. 02154 Suffolk Co. Dept. of Law Veterans Memorial Highway Bernard M. Bordenick Hauppauge, N.Y. 11787 Counsel for NRC Staff U.S. Nuclear Regulatory Comm.

MHB Technical Associates Washington, D.C. 20555 1723 Hamilton Avenue ,

Suite K. Nora Bredes San Jose, Ca. 95125 SOC Coordinator 195 E. Main Street Jeffrey L. Putter Smithtown, N.Y. 11787 Long Island Lighting Co.

l 250 Old Country Road Mineola, N.Y. 11501 Q

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St(~;-<,;

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Stephen B. Latham

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