ML20027E498

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Response to ASLB 821102 & 03 Info Requests.Certificate of Svc Encl
ML20027E498
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/10/1982
From: Earley A
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
ISSUANCES-OL, NUDOCS 8211150433
Download: ML20027E498 (21)


Text

LILCO, November 10, 1982 s

- 00CKETED uvmc

'82 NT/12 01:i6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

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(Shoreham Nuclear Power Station, )

Unit 1) )

LILCO'S RESPONSE TO ASLB INFORMATION REQUESTS LILCO's response to the Board requests of November 2 and 3, 1982, is organized as follows:

Initial Transcript Item No. Issue Reference 1 Advisors to LILCO Management 12,551 2 Review of Operations Committee and Nuclear Review Board 12,551 3 Professional Oualifications of R.A. Kubinak 12,761 4 Professional Qualifications of B.R. f:cCa f f rey 12,761 All of the above items are attached. This information has been prepared either by or under t'ae supervision and direction of Mr. Brian R. McCaffrey, LILCO's 8211150433 821110 PDR ADOCK 05000322 G PDR L__

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. s Manager, Nuclear Compliance and Safety, Nuclear Operations Support Department.

Respectively submitted, LONG ISLAND LIGHTING COMPANY

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Anthony F. Earley, Jr.

Hunton & Williams P. O. Box 1535 707 East Main Street Richmond, Virginia 23212 DATED: November 10, 1982 l

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Item 1 ADVISORS TO LILCO MANAGEMENT Advisor to Vice President - Nuclear LILCO has contracted the service of Mr. John Riley, General Electric Operations Manager at Shoreham, as Advisor to LILCO's Vice President - Nuclear. Mr. Riley has been working with General Electric performing increasingly responsible assign-monts at Shoreham since August, 1977. He has been fulfilling his role as Advisor since April, 1982, meeting with LILCO's Vice President ossentially monthly in that capacity. A resume of Mr. Riley's nrofessional qualifications is attached.

Advisor to Plant Manager and Chief Operations Engineer Mr. Kent Nicholas, General Electric )12 rations Superintendent at Shoreham, has been contracted as Advisor to the Shoreham i

Plant Manager and Chief Operations Engineer. He has been operating in that role since August, 1982, meeting with the Plant Manager and/or the Chief Operations Engineer in the advisory capacity at least semi-monthly. A resume of the professional l qualifications of Mr. Nicholas is attached.

t f Operating Shift Advisors l

LILCO has committed to provide "at least one individual on site on each operating shift with substantive previous BWR operating l

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experience, including startup and shutdown of a BFR." Requests for proposals were sent out to various vendors capable of pro-viding such consultant / advisory services in sentember, 1982.

Their proposals were received on October 27, 1982, and are currently undergoing evaluation at Shorehan. The successful vendor will provide the exnerienced personnel in a timely manner sufficient for Shoreham-specific familiarization prior to fuel load. A description of the qualifications of these individuals will be submitted as soon as they are available.

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. s RESUME RILEY, John Prince Date of Birth: 9/10/44 21 Water Road Rocky Point, New York 11778 Telephone: 516-821-1628 Married - Two Children EDUCATION

--High School, Buffalo, New York

--U.S. Navy Electronics Technician School Great Lakes, Illinois

--U.S. Navy Nuclear Power School Bai.nbridge, Maryland

--U.S. Navy Nuclear Power Training Unit West Milton, New York

--Advanced U.S.N. Electronics Technician School Treasure Island, California

--General Electric Boiling Water Reactor Training Center Morris, Illinois

--Kepner Tregoe Problem / Solving Decision Making Course EXPERIENCE

SUMMARY

Currently General Electric Operations Manager at Long Island Lighting's Shoreham Nuclear Power Station. Prior to this, served as the General Electric Operations Superintendent and LILCO Nuclear Steam Supply System Lead S tartup Engineer also at Shoreham Nuclear Power Station. Held position as General Electric's Shift Supervisor at Tokai Nuclear Power Plant, Tokai, Japan (12 months) and James A. Fitzpatrick Nuclear Power Plant, Lycoming, New York (3 years). Completed the 12 week General Electric BWR Training course in Morris, Illinois.

Prior to joining the General Electric Company, served in the U.S. Navy for nine years. Two years were served as a Reactor Operator and additionally qualified as an Electric, Steam and Shutdown Reactor Plant Operator. Three years were served as a Reactor Control Division Supervisor at the S5G Nuclear Power Prototype in Idaho Palls, Idaho.

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s General Electric Company, Startup Test Operations, Shoreham New York (January 1982 to present)

Promoted to position of General Electric Company Operations Manager, member of the LILCO Startup Staff, Joint Test Group and Review of Operations Committee. Responsible for reviewing and approving system flushing procedures, checkout and initial operations procedures, and preoperational test pro-cedures and results. Responsible for review and approval of all Startup Test Procedures. Also reviewing acceptance tests and station operating procedures. Responsible for cognizance and implementation of licensing activities which require testing during the Preoperational Test phase.

Administrative responsibility for NSSS Startup effort and all General Electric Company engineers assigned to the Startup and Test effort. Provide technical guidance and work direction for startup engineers and test engineers. Provide liaison be-tween GE Design Engineering, Project Office and site personnel.

Starting 4/82, commenced position as BWR advisor to LILCO VP Nuclear.

General Electric Company, Startup Test Operations, Shoreham, New York (August 1977 to January 1982)

Assigned to the Shoreham Nuclear Power Station as General Electric Operations Superintendent within the Long Island Lighting Company's Startup Organization supervising General Electric Shift Test Engineers. Named Lead Startup Engineer for the Nuclear Steam Supply Systems within the LILCO organi-zation supervising the activities of all NSSS test engineers.

Responsible for review of and concurrence with all test pro-cedures and results for NSSS. Sets schedules and priorities for the test engineers and assists them with problem resolution.

General Electric Company, Startup Test Operations, Tokai, Japan (August 1976 to Auaust 1977)

Assigned to Japan Atomic Power Company's Tokai II Nuclear Power Plant as General Electric's Day Shift Supervisor providing tech-nical direction during preoperational test phase and supervising four General Electric Shift Supervisors. Prepared and directed Preoperational testing on two new General Electric systems, Reactor Recirculation System (with Flow Control Valve) and High Pressure Core Spray System. Prepared and directed the RCIC preoperational test. Assisted in the design modifications, special testing, scheduling and equipment procurement on the new Reactor Recirculation System.

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. s General Electric Conipany, Startup Test Operations, Lycoming, New York (August 1973 - April 1976)

Assigned to James A. Fitzpatrick Nuclear Power Plant as General Electric Shift Supervisor providing technical direction during the construction, checkout and initial operation, preoperational and startup testing phase. Wrote Preoperational tests for and directed testing of Control Rod Drive and the Standby Liquid Control systems. Directed the tc~ ting of the Radioactive Waste system. Certified as Senior Reactor Operator and assisted in finalizing and completed implementation of RHR system design modifications. Assisted in outage planning, scheduling and work direction during core plugging outage. Provided technical direction on shif t for plant operation during the Startup and testing phase.

General Electric Company, Startup Test Operations, Morris, Illinois (September 1973 to Dec. 1973)

Assigned to General Electric BWR Training Center for twelve week course resulting a General Electric Senior Reactor Operator certification.

U.S.N. SSG Nuclear Powered Prototype, Idaho Palls, Idaho (January 1970 to Dec. 1972)

Qualified as Reactor, Electric, Steam, and Shutdown Reactor Plant Operator. As Reactor Controls Division Supervisor, supervised reactor operators in the performance of operations, maintenance and testing of reactor controls equipment. Was additionally responsible for the training and certification of reactor operator trainees.

U.S.N. USS Skate SSN 578, Groton, Connecticut (April 1967 to January 19E9)

Qualified as Reactor, Electric, Steam and shutdown Reactor area operator. Responsible for operation and maintenance of electronic reactor control equipment.

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t N ICllOLAS , KENT R.

September 27, 1947 Married - one child IIcalth - Excellant Education - Purdue University, West Lafayette, B.S. Mechanical Engineering (w/ honors) 1973-1975 Drake University, Des Moines, Iowa, Business, 1965-1967 Twin Lakes Iligh School, Monticello, Indiana, College Prepa ra ti on , 1961-1965 Training Programs - Nuclear Engineer Training Course, June, 1978 BWRTC, S.R.O. Certification, 1976, (Mar.-June)

Experience Summary Jan. 1982 GENERAL ELECTRIC OPERATIONS SUPERINTENDENT to date Lead Startup Engineer - Shoreham Nuclear Power Station Unit No. 1, Shoreham, New York Lead Startup Engineer for the Nuclear Steam Supply Systems within the LILCO organization, supervising fourteen Test Engineers. Responsible for review of, concurrence with, and results for NSSS procedures.

Set schedules and priorities for the Test Engineers and assist them with problem resolution. Starting August, 1982, commenced position as BWR advisor to LILCO SNPS-1 Plant Manager and the Chief Operating Engineer.

Feb. 1981 GENERAL ELECTRIC, NED-STO l Jan. 1982 Senior Test Engineer - Shoreham Nuclear Power Station l Unit No. 1, Shoreham, New York l

l Supervision of four Test Engineers, responsible for Nuclear Boiler; Reactor Recirculation, Control Rod Drive, Reactor Core Isolation Cooling, Iligh Pressure Coolant Injection, and Dry Well Floor Seal Systems.

l 1980-1981 GENERAL ELECTRIC, NEO-STO Test Engineer - Shoreham Nuclear Power Station l

Unit No. 1, Shoreham, New York l

Responsible for supervision and surveillance of the check out and initial operation related to the liigh Pressure Coolant Injection and Dry Well Ploor Seal Systems. These duties also included developing test packages, checking validity and acceptability of test results, and writing flush procedures.

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s 1979-1980 GENERAL ELECTRIC, NEO-STO Mar.-June G.E. Shift Supervisor - Caorso, Italy Responsible for selected maintenance items and coordination of the Startup test program on shift.

1977-1979 GENERAL ELECTRIC , NEO-STO Mar.-Mar. G.E. Shift Supervisor - Caorso, Italy Provided on shift supervision for customer operators prior to fuel load, and coordination of the test program during Startup at a turn-key project.

1976-1977 GENERAL ELECTRIC, NEO-STO May-Mar. G.E. shift Supervisor - Brunswick, N.C.

Preop Engineer for Containment Atmospheric Control and Containment Atmospheric Dilution Systems. G.E.

Shift Supervisor providing technical supervision and instruction to coordinate safe Nuclear Startup Test program on an 800 MWe unit.

1971-1973 U.S. Navy Sept.-Mar. Nuclear Submarine Electrical Operator Provide safe operation of electrical motors and generators associated with the Nuclear Power Plant and maintenance of same.

1969-1971 U.S. Navy Oct.-June Nuclear Power Plant Instructor Training and evaluating operators for Nuclear Sub-marine duty.

1967-1968 U.S. Navy Aug.-Oct. Maintenance Electrician Operation of conventional power plant electrical panel and repairs of electrical motors and generators.

Other Skills

--High proficiency in applied mathematical concepts

--Italian: speach good reading, writing - fair 1-7 s

4 Item 2 REVIEW OF OPERATIONS COMMITTEE AND NUCLEAR REVIEW BOARD LILCO has established a comprehensive system of nianned and periodic audits to verify implementation of Quality Assurance Program requirements utilizing a formal connittee method which functions at two levels: (1) at the station operation level via the Review of Operations Committee (ROC); and (2) at the corporate level via the Nuclear Review Board (NRB), which is independent of direct responsibility for plant operation.

REVIEU OF OPERATIONS COMMITTEE The Review of Operations Committee (ROC) has been functional since February, 1976, meeting at an average interval of once overy four weeks. ROC provides a continuing review of plant operations to assist the Plant Manager in keeping abreast of general plant operating conditions. ROC also serves to screen subjects of potential concern to LILCO's Nuclear Review Board (NRB) or to perform preliminary investigations as requested by the NRB. It is not the purpose of the Committee to relieve the Plant Manager of the responsibility for overall safety of plant operations or for the referral of appropriate matters to the NRB.

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s In accordance with the Shoreham Draft Technical Specifications which are currently undergoing fin.tl NRC Staff review, ROC membership is comprised of the following: ,

Chairman: plant Manager J. Rivello Alternate Chairman: Chief Operating Engineer W. E. Steiger Alternate Chairman: Chief Technical Engineer L. J. Calone Member: Technical Support Manager R. A. Loper Member: Operations Engineer J. A. Notaro Member: Maintenance Engineer R. Gutmann Member: Instrument and Control Engineer W. E. Gtnther Member: Reactor Engineer J. A. Saalice Member: Ilealth Physics Engineer M. L. Miele in addition, I,II,C O has supplemented the ROC membership with the following:

Member: Operating Quality Assurance Engineer A. R. Muller Member: Radiochemistry Engineer J. Schmitt Member: Plant Administrative Coordinator J. 11 . Kellers Member: Security Supervisor R. Reen N_UCLEAR HEVIIM BOARD The function of the Nuclear Review Board (NRB) is to pr' ovide the management of Long Island Lighting Company, through the Vice President-Nuclear, a mechanism for independently ascer-taining that activities related to nuclear station operations are performed safely and efficiently in accordance with Company policies and regulatory requirements.

The Nuclear Review Board has been established and functional since April 1982. The NRB performs review and audit functions of designated activities in the areas of nuclear power nlant operations, nuclear engineering. chemistry and radiochemistry 2-2 s

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engineering, metallurgy, instrumentation and controls, and quality assurance practicos.

The NRR membership is made up of LILCo and consultant personnel as follows: ,

Company Members '

R. A. Kubinak, Chairman s Manager, Nuclear Operations Support Department A. T. Baker Manager, Substation and Equipment Engineering D. J. Binder Manager, Nuclear Engineerinq T. F. Gerecke Manager, Quality Assurance it . Rivello Shoreham Plant Manager '

Consu1 tant Members R. R. Bowers Manager, Ilealth Physics Services, NUS Corporation e

Dr. R. M. Crawford '

Vice President, Scientific Applications, Inc. ,

R. C. Christianson Senior Consultant, General Electric Co.

F. C. DuVall President, NUS Training Corp.

Dr. D. C. Rorer

J e n i e r Physicist, Brookhaven National Lab.

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s Item 3 ROBERT A. KUBINAK, Manager Nuclear Operations Support Department .

Long Island Lighting Company -

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s The Manager, Nuclear Operations Support Department, reports to the Vice President-Nuclear and has the responsibility to ,

provide headquarters technical and non-technical support for the operating Nuclear Station. The prime objective of this support effort is to enhance the safe, reliable and

, economic operation of the nuclear facility by maintaining an 1 effective interface and flow of information between the (nuclear _ station and regulatory agencies, company departments and outside resources. Within this objective, the Department is '

charged with the specific responsibility of accomplishing '

long range operating type functions based in headquarters.

These include administration of' the corporate Nuclear Review i Board, conduct of special studiek, Jong range outage planning, compliance with Federal and' State Law, s records manage:nent ,

proj ect participation and coordination for maj or nuclear. plant additions and modifications, regulatory-representation, industry representation, evaluation of plant performance, coordination of corporate nuclear policy, the conduct of special prcgrams, nuclear budget and cost control, independent safety engineering-ctudies and nuclear training coordination.

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( Graduated from Rensselaer Polytechnic Institute in 1953 with a Bachelors degree in Electrical Engineering (BEE). Received

! a Masters of Business Administration (MBA) from Dowling College in 1979 Complete the requirements for a Master of Science (MS)

- Degree in computer scient!e in December 1982 from Polytechnic

! Institute of New York.

Received a New York State Professional Engineering License in 1975 Completed the General Electric Boiling Water Reactor Simulator

- Training Program and was cerSified as a Senior Reactor Operator.

Tested'by Atomic Energy Commission examiners and received a '

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dual certificate as a Reactor Operator for Dresden Nuclear Power Plant Units #2 and #3 Completed the following industry seminars and training programs:

a)_ Introduction to Nuclear Power - NUS Corporation Radiation Protect' ion - LILCO Evening Institute (Instructor) b;))

c Nuclear Power - LILCO Evening Institute (Instructor) d) Quality Assurance for the Nuclear Industry - General Physics e) Ultrasonic Hondestructive Testing - Magnaflux Corporation f) Radiographic Examination - General Dynamics Corporation g) PWR Operation and Simulation - Westinghouse Corporation h)~ Nuclear Reactor Safety - MIT

1) Boiling Water Reactor Simulator - General Electric Company l i te >

4 1969 - 1978 Assigned as Plant Manager for the Shoreham Nuclear Power Station in 1969 Responsible for the establishment and training of the Shoreham plant staff to qualify for nuclear plant operation. Additional responsibilities included the representation of the Electric Production Department in Shoreham engineering activities with LILCO engineering groups, associated engineering firms and consultants. Engaged in technical licensing efforts with federal, state and local regulatory groups.

Assigned as a working member of the General Electric Startup team for the Commonwealth Edison Dresden Nuclear Station for Responsible Units #2 and #3 for a period of 15 months.

the startup and preoperational testing of the Reactor Recirculation System and the Circulating Water System includ-ing auxiliaries and support systems fromDirectlyinitial construction assisted the turnover through 100% power operations.

responsible engineers in the startup and testing of the Control Rod Drive System, Core Spray System, LP and HP Coolant Injection System, Isolation Condenser and the Contain-ment Leak Rate.

Assigned on shift as assistant to the General Electric Shift Superintendent. Operated at the reactor control board and performed three (3) reactor criticals andPerformed one (1) numerous turbine

- roll as unit was returning to service.

generator load changes while above and below 50% reactor power using recirculation flow and control rod positioning.

Performed an additional two (2) training criticals. Operated at the reactor control board and performed stuck control rod l

surveillance testing and control rod friction tests.

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Participated in unit startup and shutdown procedures which included surveillance testing, valve check-off list verifica-l tions, drywell inspection, and heatup and cooldown activities.

l Participated in fueling and refueling activities on both Unit #1 and #2 reactor fuel cores. Assisted in reactor core and l jet pump inspections, channeling, spent fuel inspection and sipping, reactor core radioactive source and instrumenta-tion removal and installation.

Prepared or verified procedures written for non-normal shift operation. Participated in daily plant staff coordination meetings and was an observer in periodic plant and Corporate Safety Review Committee meetings .

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s 1965-1969 Chief Engineer, Northport Power Station, in the Electric Production Department. Directed engineering, supervisory and non-supervisory personnel in the startup, operation and maintenance of two 400 MW steam generating units.

Initiated design reviews, recommended revisions, and directed field modifications. Responsible for economic studies and equipment evaluation.

1963 - 1965 .

Operations Engineer of the Glenwood Power Station.

Responsible for the direction of the operations personnel Developed operating in the operation of plant equipment.

procedures and techniques to optimize plant efficiency and reliability.

1961 - 1963 Maintenance Engineer at the Port Jefferson Power Station.

Responsible for the maintenance of power plant systems and equipment. Directed repair efforts through foremen and mechanics. Responsible for the design, instrumentation and installation of subsystems including power piping and electrical power distribution.

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1957 - 1961 Plant Instrument and Control Engineer at Port Jefferson Power Station. Directed the efforts of engineers and technicians in startup and maintenance of power plant electronics, pneumatic, and hydraulic control systems.

1955 - 1957 Assistant Engineer in the Electric Production Department.

l Training assignments included the startup of accessory

' electrical equipment, maintenance of power plant equipment; developing techniques to optimize equipment performance and reliability, completed assignments in the maintenance of l

power plant electrical instrumentation; and the analysis and reporting of performance data for electrical generating units.

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o-1953 - 1955 Radar Maintenance Officer with the U.S. Air Force Air Defense Command. Responsible _for the analysis of radar equipment performance and malfunctions, directed calibration and repair through maintenance technicians.

A member of the New York State Society of Professional Engineers.

Registered Professional Engineer, State of New York. AEC Certified Reactor Operator, Dresden Units #2 and #3, Commonwealth Edison Company.,

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s Item 4 PROFESSIONAL QUALIFICATIONS Brian R. McCaffrey Manager, Nuclear Compliance Nuclear Operations Support Department Long Island Lighting Company My name is Brian R. McC.affrey. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York. I have been employed by Long Island Lighting Company (LILCO) since 1973, and have been Manager, Nuclear Compliance and Safety for LILCO since November 1981, responsible for managing the Nuclear Compliance and Safety Division of the Nuclear Operations Support Department. In addition, I am responsible for managing and coordinating the Company's efforts in the ASLB Licensing Proceedings. The Nuclear Compliance and Safety Division will support the opera-tion of the Shoreham Station in coordination of all NRC

' licensing activities, the Nuclear Review Board and the management of the Independent Safety Engineering Group.

I graduated from the University of Notre Dame in 1967 with a Bachelor of Science Degree in Aerospace Engineering. I received a Master of Science Degree in Aerospace Engineering in 1972 from the Pennsylvania State University and a Master of Science Degree in Nuclear Engineering in 1978 from the

S Polytechnic Institute of New York. I completed a General Electric BWR Design Orientation Course in 1978.

My professional experience began with my employment with Grumman Aerospace Corporation in 1968. My primary respon-sibilities were in the areas of aircraft aerodynamics and flight test stability and control.

I joined LILCO in 1973. I have held the positions of Associate Engineer and Engineer in the Power Engineering Department (1973-1975), where I was involved with plant engineering for both fossil and nuclear power stations. I then became Senior Engineer in the Power Engineering Department (1975-1977), with responsibilities as Project Coordinator for gas turbine installations and Lead Mechanical Engineer for nuclear projects; Senior Licensing Engineer for Shoreham Nuclear Project (1977-1978), with responsibility for the licensing activities leading to an Operating License; and Project Engineer for Shoreham (1979-1980), with responsi-bilities that included directing Project Engineering and the Architect Engineer in engineering and procurement for Shoreham.

I was assigned in 1980 as Assistant Project Manager for Engineering and Licensing (in July 1981, retitled Manager--Project Engineering) for Shoreham. In that capacity I 4-2

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was responsible for the overall eng.ineering and licensing of the Shoreham Station. My organization directed and approved the engineering efforts of the Architect Engineer and Nuclear Steam Supplier, and was responsible for directing-the activities leading to an Operating License from the NRC. I
became Regulatory Supervisor in November, 1981 (retitled 1

Manager, Nuclear Compliance and Safety in October 1982).

I am a Registered Professional Engineer in the State of

! New York. In addition, I am a member of the American Society of Mechanical Engineers and the Long Island Section of the American Nuclear Society.

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CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I certify that copies of LILCO's Response to ASLB Information Requests were served upon the following by first-class mail, postage prepaid, by Federal Express (as indi-cated by an asterisk), or by hand (as indicated by two asterisks):

Lawrence Brenner, Esq.** Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris ** Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory l Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. James H. Carpenter **

Administrative Judge Daniel F. Brown, Esq.**

i Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing

U.S. Nuclear Regulatory Board Panel i Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission l Washington, D.C. 20555 i

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s-Bernard M. Bordenick, Esq.** David J. Gilmartin, Esq.

David A. Repka, Esq. Attn: Patricia A. Dempsey, Esq.

2 U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 Herbert H. Brown, Esq.** Stephen B. Latham, Esq.*

Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Karla J. Letsche, Esq. 33 West Second Street Kirkpatrick, Lockhart, Hill, P. O. Box 398 Christopher & Phillips Riverhead, New York 11901

, 8th Floor 1900 M Street, N.W. Ralph Shapiro, Esq.*

Washington, D.C. 20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Mark W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road Howard L. Blau, Esq.

Waltham, Massachusetts 02154 217 Newbridge Road Hicksville, New York 11801 MHB Technical Associates 1723 Hamilton Avenue Matthew J. Kelly, Esq.

Suite K State of New York San Jose, California 95125 Department of Public Service Three Empire State Plaza Mr. Jay Dunkleberger Albany, New York 12223 New York State Energy Office Agency Building 2 Empire State P3aza Albany, New York 12223

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A' 'r F . Earfey,'Jr.

Hunton & Williams 707 East Main Street

., P.O. Box 1535 Richmond, Virginia 23212 4

DATED: November 10, 1982

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