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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20150D4711988-07-0606 July 1988 Suffolk County Answers to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10.* W/Supporting Documentation & Certificate of Svc. Related Correspondence ML20150D5071988-07-0505 July 1988 State of Ny Response to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10 to Suffolk County,State of Ny & Town of Southampton.* W/Certificate of Svc.Related Correspondence ML20155C0791988-06-0707 June 1988 Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* Notices of Depositions & Certificate of Svc Encl.Related Correspondence ML20155C5671988-06-0303 June 1988 State of Ny Response to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl. Related Correspondence ML20151T6251988-04-22022 April 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Licensee.* W/Certificate of Svc. Related Correspondence ML20151T4391988-04-22022 April 1988 Govt Answer & Addl Objections to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Answers & Objections Listed.Notification to County Executive & Certificate of Svc Encl.Related Correspondence ML20151T5701988-04-22022 April 1988 Govt Answers to NRC Staff Interrogatories Re Contentions 1-2,4-8 & 10.* W/Certificate of Svc.Related Correspondence ML20151T8001988-04-20020 April 1988 Govts Objections to Lilco Second Set of Interrogatories Re Consumptions 1-2,4-8, & 10.* Certificate of Svc Encl.Related Correspondence ML20148S8381988-04-12012 April 1988 Suffolk County Fifth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20151F2041988-04-0909 April 1988 Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20151A0691988-04-0101 April 1988 Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20148L9181988-03-31031 March 1988 NRC Staff First Set of Interrogatories to Suffolk County,Ny State & Town of Southampton Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20150F8941988-03-30030 March 1988 Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc. Related Correspondence ML20148L9021988-03-28028 March 1988 Suffolk County Supplemental Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl. Related Correspondence ML20148K2151988-03-25025 March 1988 Lilco Responses & Objections to Suffolk County Third Set of Interrogatories & Requests for Production of Documents Re Emergency Broadcast Sys.* W/Supporting Documentation & Certificate of Svc.Related Correspondence ML20148K4421988-03-24024 March 1988 Lilco Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Suffolk County,State of Ny & Town of Southampton.* Certificate of Svc Encl.Related Correspondence ML20148K1771988-03-24024 March 1988 Lilco Second Set of Requests for Production of Documents Re Lilco Emergency Broadcast Sys to Suffolk County.* Util Makes No Admission or Representation About Proper Scope of Issues to Be Decided.W/Certificate of Svc.Related Correspondence ML20148K2201988-03-23023 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Realism.* W/Certificate of Svc.Related Correspondence ML20148K1571988-03-23023 March 1988 Suffolk County Response to Lilco First Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20148K3881988-03-23023 March 1988 Response of Suffolk County to Lilco 880311 Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl ML20150D1571988-03-18018 March 1988 Response of State of Ny to NRC Staff First Set of Interrogatories & Requests for Production of Documents Re Hosp Evcacuation Time Estimates.* Certificate of Svc Encl. Related Correspondence ML20150D0791988-03-16016 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to NRC Staff & Fema.* Certificate of Svc Encl.Related Correspondence ML20150D0121988-03-15015 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* Certificate of Svc Encl.Related Correspondence ML20150C6511988-03-15015 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Hosp Evacuation Time Estimates.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20150A8081988-03-11011 March 1988 Suffolk County Third Set of Interrogatories & Requests for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20150A9581988-03-11011 March 1988 Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* W/Certificate of Svc. Related Correspondence ML20150A9421988-03-11011 March 1988 Lilco Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Related Documentation & Certificate of Svc Encl ML20150A9521988-03-11011 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Related Correspondence ML20150C9911988-03-11011 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Objections Stated. W/Certificate of Svc.Related Correspondence ML20150A8561988-03-10010 March 1988 Suffolk County Responses & Objections to Lilco First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20150A8431988-03-10010 March 1988 Suffolk County Responses & Objections to NRC Staff First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Related Correspondence ML20150A8881988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents.* Related Correspondence ML20150A9111988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents.* Util Objects to Interrogatory 1 as Vague,Overbroad & Unduly Burdensome.W/Certificate of Svc.Related Correspondence ML20150A9341988-03-0909 March 1988 Suffolk County Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl ML20150A9641988-03-0909 March 1988 Lilco First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* W/Certificate of Svc. Related Correspondence ML20150A9671988-03-0909 March 1988 State of Ny First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* W/Certificate of Svc.Related Correspondence ML20196H3941988-03-0707 March 1988 Lilco Second Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20196H4361988-03-0707 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8421988-03-0404 March 1988 Response of State of Ny to Lilco Second Set of Requests for Admissions Re Role Conflict of School Bus Drivers.* Lilco Second Set of Requests for Admissions Deemed Untimely. Certificate of Svc Encl.Related Correspondence ML17342B4211988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8061988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20147H8571988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H7901988-03-0303 March 1988 Suffolk County Second Supplemental Response to Lilco Second Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Lilco Interrogatories 28 & 29 Addressed.Related Correspondence ML20147H7991988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8121988-03-0303 March 1988 Suffolk County Fourth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20196G1121988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* Related Correspondence ML20196G1301988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Hosp Evacuation Issue.* Definitions & Instructions for Answering Interrogatories Encl.W/Certificate of Svc.Related Correspondence ML20196G1081988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8031988-02-29029 February 1988 Lilco Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20196G1371988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence 1988-07-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
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Text
. , ,
"'*W GWutESPrxnen; UNITED STATES OF AMERICA " j ;,4 -. .. ./
NUCLEAR REGULATORY COMMISSION s BEFORE
"' THE ATOMIC SAFETY AND LICENSING BOARD '82 K'n -a 99 :gs'
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY )
) Docket No. 50 $ N-@L N
(Shoreham Nuclear Power ) q Station, Unit 1) )
) RECEIVED <
G-SUFFOLK COUNTY REQUEST FOR
- MAR 091982> r PRODUCTION OF DOCUMENTS BY LONG ISLAND LIGHTING COMPANY
{RQ%f' nx Pursuant to 10 CFR $ 2.741, LILCO is requeste County to produce for inspection and copying, at the Shoreham plant or at another mutually agreed-upon location, the documents specified below that are within LILCO'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 INSTRUCTIONS FOR DOCUMENT PRODUCTION The definitions and instructions applicable to these Requests are the same as those set forth in Suffolk County Interrogatories to LILCO, filed simultaneo; sly herewith, and hereby incorporated by reference, except that subparts L through P, and W, of such Definitions and Instructions are not applicable to these Requests.
h j i
8203100111 820305 PDR ADOCK 05000322 O PDR
- 0 0 DOCUMENTS TO BE PRODUCED
- 1. All documents identified in response to Suffolk County's Interrogatories to LILCO, dated Marcl. 5, 1982. /
- 2. All Shoreham Emergency Operating Procedures (the "29" Series).
- 3. The most recent and current version of the Shoreham Technical Specifications.
- 4. The most recent and current revision of FSAR Fig. 7.4.1-5A through E, " Remote Shutdown System IED."
- 5. The most recent and current revision of " Remote Shutdown System Design Spec," noted as Reference 2 in FSAR Fig.
7.4.1-6A, and all documents, analyses, and criteria upon which such design specification was based.
- 6. A copy of the most recent and current revision of " Figure 1" (Typical Valve Control) as referenced in FSAR Fig. 7.4.1-6A.
- 7. The most recent and current revision of each of the following Shoreham Procedures:
(a) SP #23.133.01, " Remote Shutdown Panel Control System. "
(b) SP #29.022.01, " Shutdown From Outside the Control Room Emergency Procedure. "
(c) SP #29.010.01, " Emergency Shutdown Procedure."
(d) SP #29.015.01, " Loss of Electrical Power Emergency Procedure."
- / Some of the documents requested in Nos. 2-40 are covered by Request 1. These requests are not intended to be dupli-cative but rather are listed separately herein to more adequately identify certain of the documents requested by the County.
(e) SP #23.101.01, " Auxiliary Boiler System."
(f) SP #23.201.01, " Automatic Depressurization System."
(g) SP #23.119.01, " Reactor Core Isolation Cooling System. "
(h) SP #23.707.01, " Fuel Pool Cooling System."
(i) SP #23.122.01, " Service Water System."
(j) SP #23.118.01, "RBCLCWS."
(k) SP #21.006.01, " Station Operator Training and Qualification Program."
- 8. The most recent and current revision of each of the following Shoreham Alarm Response Procedures:
(a) ARP 1051, "RSDS Transfer Switch in Emergency Position Div. 1."
(b) ARP 1364, "RSDS Transfer Switch in Emergency Position Div. II."
(c) ARP 1365, "RSDS Transfer Switch in Emergency Position Div. III."
(d) ARP (LTR) "RSP Access Doors Open."
- 9. The most recent and current revision of FSAR Fig. 7.4.1-6A and B, " Remote Shutdown System FCD."
i
- 10. All updated and current Remote Shutdown System panel drawing (s).
- 11. All training manuals and procedures, including current versions, for operator training regarding emergency use of the Remote Shutdown Panel.
- 12. The current Shoreham Shift Turnover Procedure.
- 13. Letter #SNRC-638 and a copy of LILCO's forthcoming response to NRC request numbers 223.93 through .99 (see Attachment 1
I hereto). If LILCO's response is not yet available, please advise as to when it will be available.
- 14. Report by Reinhart & Associates, Inc. concerning 1981/1982 pre-service inspection tests of the Shoreham Reactor Pressure Vessel (RPV), and all documents, including under-lying work papers, research and analyses, concerning such report.
- 15. Report by Nuclear Energy Services, Inc. concerning 1981/
1982 pre-service inspection tests of the Shoreham RPV, and all documents, including underlying work papers, research
- and analyses, concerning such report.
- 16. All analyses, test results, and other documents concerning i whether the Shoreham systems affected by water hammer will, during their service lifetimes, withstand flow-induced vibrations.
- 17. All pre-operational test results of water hammer-related tests performed on Shoreham's ECCS and steam system piping.
- 18. All documents evidencing that Shoreham has implemented the steps set forth in Section III.1 of the Settlement Agreement.
- 19. All analyses, diagrams, test results, and other documents concerning the design and capabilities of Shoreham's Loose Parts Monitoring (LPM) System, particularly concerning how the system will identify, record and pinpoint.the location and cause of each LPM system signal.
- 20. All training materials and operational procedure documents concerning Shoreham's LPM system.
- 21. All analyses and other documents which were used to support, or which concern General Electric's position on LPM Systems as presented to the ACRS Meeting of the Subcommittee on Electrical Systems, Control and Instrumention on Loose Parts Monitoring Systems, on Thursday, July 20, 1978.
- 22. All documents describing and all analyses, research and other documents concerning General Electric's current position as to the reliability and meaningful detection capability of the LPM Systems currently available for BWR's.
- 23. All analyses, test results, or other documents which demonstrate that " adequate net positive suction head to the ECCS pumps is provided with 50% of the free strainer area clogged," as stated in FSAR Section 6.3.2.20.1, or which concern such issue.
- 24. A copy of the following correspondence from LILCO to the NRC regarding ECCS pump blockage:
(a) SNRC-598 (b) SNRC-602
- 25. The Environmental Qualification Report and all data, I
i analyses, test results and other documents supporting or l
concerning such report, for the following equipment described in LILCO's Environmental Qualification Status l
Report, Report Number PES-800, Job 1160002, dated 1-18-82:
! (a) Level Transmitter for Reactor Level Trip, manufactured by Rosemount, Model 1151, (equipment ID: *lB21*LT154C; vendor ID: B21-N080C);
i .
l l
I (b) Suppression Pool Level Transmitter, manufactured by Rosemount, #1152DP4A22 PB (equipment / vendor-ID: '
.lZ93*LT001B);
(c) Fuel Zone Level Indicating Transmitter, manufactured by Barton Model 760 (equipment ID: .lB21* LIT 007A; vendor ID: B21-NO37A);
(d) Reactor Containment Electrical Penetrations, manufactured by General Electric, Series 200 low voltage, (equipment ID: .1T23*Z-EB2);
(e) Position Switches / Primary Containment Purge Valves, manufactured by NAMCO, Model #EA740-20001 (equipment ID: .lT46*PN5038A); and (f) Radiation Detector / Containment High Range, manufactured by Kamen (equipment ID: *1D21*RE085A).
- 26. A copy of Specification SH1-473, which is identified as applicable to Level Transmitters in LILCO's Environmental Qualification Report for Class IE Equipment.
- 27. A copy of each of the following:
(a) Specification SH1-003 (b) Specification SH1-134 (c) Specification SH1-475 l (d) Specification SH1-172 (e) Specification SH1-406
- 28. All drawings which show the location and mounting of effluent sampling points for monitoring releases at each I
potential release point at Shoreham.
- 30. A copy of Regulatory Guide 1.97-Draft 3, October 1980, as used by LILCO as the design basis for the shielding and sampling media on the Station vent and RBSVS.
- 31. All procedures and emergency operating procedures used by LILCO to describe recommended actions with regard to post-accident monitoring instruments and systems.
- 32. All analyses or other documents concerning ECCS performance which have shown the 40' Fahrenheit penalty in Peak Clad Temperature (PCT) limits to be justified or unwarranted as an interim resolution of the concerns set forth in NUREG-0630.
- 33. The most recent and current revision of LILCO's operations OA program manual and all implementing procedures and other documents which concern whether and how the requirements of 10 CFR $50 Appendix B will be satisfied.
- 34. Copies of the QA Manuals for Shoreham, and implementing procedures of each of the following:
(a) Stone & Webster; (b) Comstock; i
(c) Courter; (d) Jackson; (e) Dravo; and I
( f) other contractors and subcontractors
- 35. All documents concerning the interface between the Shoreham OA program and the programs of all Shoreham contractors and subcontractors.
l
- 36. The most current revision of LILCO's OA manual and pro-cedures for non-operational activities (including design, construction and procurement) and all documents which concern whether and how the Part 50, Appendix B requirements are satisfied.
- 37. All audits, analyses, investigations, studies, reviews, or other documents prepared or conducted by or on behalf of any person, concerning the effectiveness of the QA programs of:
(a) Comstock; (b) Stone & Webster; (c) Courter; (d) Jackson; (e) Dravo; (f) LILCO; (g) other contractors; and (h) other subcontractors
- 38. All non-conformance 'aon-compliance logs or listings, showing the dates on which each non-conformance/non-compliance was entered and cleared for:
(a) LILCO's OA program; (b) Stone & Webster's QA program; (c) Comstock's QA program; (d) Courter's QA program; (e) Jackson's QA program; (f) Dravo's QA program; and (g) The QA program of any other contractors or subcontractors.
_g-
- 39. All audits and other documents concerning the initiation and closing of the non-conformances/non-compliances identified in the response to Request No. 38.
- 40. Copies of all contracts, including contract endorsements, revisions, or modifications, between LILCO and any contractor or between a contractor and any subcontractor who provided any type of QA/OC activity related to Shoreham.
Respectfully submitted, DAVID J. GILMARTIN Suffolk County Attorney PATRICIA A. DEMPSEY Assistant Suffolk County Attorney Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 Herbert H. Brown f Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, NW, 8th Floor Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County March 5, 1982 f
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223.23 In Table 1 of SNRC-638, assuming a sincie failure of the SRV valves at the RSP, credit is being taken for 55e RCIC system to reduce reactor pres sure. Verification should 5e provided that the RCIC turbine steam flow is sufficient to reduce reactor pressure to -
achieve cold shutdown. The time to reach cold shutdown using the RCIC system should Se provided.
223.94 In Table 1 of SNRC-638, assuming a single failure to the Reactor Building Closed Loop Cooling Water System (RSCLCW), credit is heing taken for the LPCI system to achiere cold shutdown. Does this mean that the 5 loop of RECLCW will 5e ased for LPCI operation? If so, bow is the transfer of control made, where are the 5 loop controls, and does this require continuous local operation?
223.95 In Table 1 of SNRC-638, assuming a single failure of the Reactor Recirculating System, credit is taken for long ter= cooling using the LPCI system of the RER system. Explain t5e conflict between this statenent and note 3 in Ta51e i that sta'.es : Eat the Reactor Recircu-lating System is recuired to prevent sEcrt cycling t5e core during RER cooling for cold sEntdown. Also, it i~s not apparent to the staff why the Reactor Recirculating Syste= is included in Ta51e 1 since the capability of remote sEutdown must Se provided even with the assumption of a loss of offrite power. .
223.96 la SNRC-638, the applicant stated that assuming a single failure, the plant can be 5 rough.t to Ect sEutdown wit 5out leaving the RSP. Ex plain the discrepancy between this statement and t5e informaf ton presented
in SNRC-638 Ta51e 2 wh.ich indicates :dat Reacter water l evel and Reactor Pressure indtrations are at locations c:Eer than t5e RSP. '
223.97 In Ta51e 2 of SNRC-638, explain why an alternate' indication for Reactor ,,,-
Pressure (lC61-PI'0C6{ is not required ano w5y Reactor tenperature indication is not needed during the 2750 to 2120 shutdown phase where the reac:or pressure gauge is inaccurate.
223.9E Explain the discrepancy 5etween statements in Ee ecergency procedures j for shutdown from outside the control room which indicate teat auto-I matic ESF functions are lost during a transfer of control and the statement ~ in SNRC-633 tha' ESF systems not controll ed from tEs ESP, -
i wnich have automatic features, will function as designed.
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223 % As a result of a review of the SEcreham SER by the Region (
six additional instances regar. ding Engineered Safety Features I (ESFL reset (IE Sull etin SQ-a61 were discovered. These instances l are discussed in Inspection Report 5G-322/ 81 -0 6 dated June 5,1981 l 5ecause of these discrecanctes, tee staff is questioning the applicant's cricinal ESF rese: review and :Ea Easis for the study's conclusions.
The staff has concluded, teat :Eis item needs furtEer review Ey the
~
applicant and requests that an updated su5mittal concerning ESF rese:
he provided.
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