ML20041E076

Request for Production of Documents Directed to Nrc.Related Correspondence

ML20041E076
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/05/1982
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8203100108
Download: ML20041E076 (6)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 22 Wo -8 p 0:06 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD r

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (Shoreham Nuclear Power ) Y N

Station, Unit 1) ) 46

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RECEIVED G- 3 SUFFOLK COUNTY REQUEST FOR

MAR 091982> r PRODUCTION OF DOCUMENTS BY THE E8%8 gN 0 NUCLEAR REGULATORY COMMISSION STAFF toc b

Pursuant to 10 C.F.R. SS 2.741, 2.744, the NRC Stat. '

requested by Suffolk County to produce for inspection and copying, at the NRC of fices in Bethesda, Maryland, or at another mutually agreed-upon location, the documents specified below that are within the Staff's (as defined herein) possession, custody, or control. Such production shall be no later than 30 days from the date of service of this request.

DEFINITIONS AND INSTRUCTIOI7S FOR DOCUMENT PRODUCTION ,

The definitions and instructions applicable to these Requests are the same as those set forth in Suffolk County Interrogatories to the NRC Staff filed simultaneously herewith, and hereby incorporated by reference, except that subparts L through P, and W of such Definitions and Instructions are not

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applicable to these Requestsi 8203100108 820305 PDR ADOCK 05000322 G PDR

, -2a DOCUMENTS TO BE PRODUCED BY NRC STAFF

1. All documents identified in response to Suffolk County Interrogatories to the NRC Staff, dated March 5, 1982.

Suffolk County Contention 1

2. All analyses and other documents concerning the determination and approval of the conditions listed in Shoreham's FSAR Section 7.5.1.4.3, " Conditions Assumed to Exist if the Control Room becomes Inaccessible," and all documents upon which such determination and approval were based, in whole or in part.

3. All analyses and other documents which identify or concern the establishment of acceptance criteria for Remote Shutdown Panel (RSP) design bases as described in Shoreham FSAR Section 7.5.1.4.2, " Design Bases," and all documents upon which such criteria were based.

4. All correspondence or other documents transmitted i to LILCO, to which LILCO responded with its letter #SNRC-6 38.

Suffolk County Contention 2

5. All documents which identify or concern any standards or criteria used or to be used by the NRC Staff in determining i

l l whe ther Shoreham complies with Regulatory Guide 1. 39 " Housekeeping Requirements for Water-Cooled Nuclear Power Plants" with respect I to diesel generator maintenance.

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6. All documents concerning the NRC Staff's review and analysis of, and conclusions concerning, Shoreham's compliance with Regulatory Guide 1. 39.

Suffolk County Contention 3 7, All documents which concern the NRC's review of Shoreham pursuant to Regulatory Guide 1.97, Revision 2 (and earlier revisions), with respect to detection of inadequate core cooling, including all documents which identify or concern appectance criteria used by the Staff.

Suffolk County Contention 4 .

8. All test results, analyses and other documents concern-ing the NRC Staf f's review and/or approval of pre-operational and startup pipe system testing, with respect to potential water hammer events, for the Zimmer and LaSalle plants, and concerning the specific criteria and/or standards applied in connection with such review and/or approval. Include all analyses or other i documents concerning the review or application of any reports, analyses or documents identified in response to this Request with respect to potential water hammer events at Shoreham.

9. All documents which identify or concern the criteria i

or standards used or to be used by the NRC Staff in approving Shoreham's pre-operational pipe system testing with respect to potential water hammer events.

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10. All documents concerning any 3'3R water hammer assess-ments, including documents, analyses or reports concerning such an assessment that was scheduled for completion in' January 1932.

4 Suffolk County contention 5

11. All analyses and documents which the NRC Staff relied upon (in whole or in part) , or concerning in any way, the deter-i mination of " system sensitivity" limi'ts (Position C.l.b) and Position 5, " Technical Specification for the Loose-Part Detection System" in Regulatory Guide 1.133. ,

12. All documents concerning LILCo's compliance with Regulatory position C.2 a-d " Establishing the Alert Level,"

i cited in Regulatory Guide 1.133.

Suffolk County Contention 9

13. All analyses conducted by or on behalf of the NRC, and all other documents, concerning NRC Generic Task A-43 and " Con-tainment E:ac; gen;y Sump Performance," particularily those documents prepared subsequent to the NRC's November 16, 1981 report, and all documents concerning the issue of blockage of ECCS pump suction as applied to Shoreham.

I Suffolk County Contention 13

14. All analyses or other documents concerning ECCS perform-ance, which have shcwn or concern whether the 40' Fahrenheit

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penalty--- Peak & Clad Temperature (PCT) limits -- are justified or unwarranted as an interim resolution of the concerns set forth P

in NUREG-0630.

15. All documents concerning Board Notification BN-81-49 regarding Japanese core spray tests, including correspondence between or among any of the following: the NRC Staff, LILCO, the BWR Owners Group, and the Licensing Review Group.

Suffolk County Contentions 13-15 4

16. All audit reports, analyses, or any other documents

-cencerning the QA programs (operations, design, and construction, as applicable) of and the effectiveness of the QA program implementation by, each of the following:

(a) LILCO i (b) Stone and Webster (c) Comstock (d) Courter (e) Jackson (f) Dravo

! (g) All other contractors at Shoreham (h) All other subcontractors at Shoreham.

Suffolk gounty Contention 17

17. All analyses, test results, and other documents concerning (a) the adequacy or inadequacy of response times with

, . . - respect to fires in the machine shop area of Shore;* am (note:

this area is intended to include the paint room, welding room, oil room, blast area and receiving and storage room) , and (b) the effect upon the safety of the Shoreham plant.of a fi're in the machine shop area.

Respectfully submitted, DAVID J. GILMARTIM Suffolk County Attorney PATRICIA A. DEMPSEY Assistant Suf folk County Attorney Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788

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W W &lL}K Herbert H. Brown Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Floor Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County March 5, 1982