ML20041E079
| ML20041E079 | |
| 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 | |
| NUDOCS 8203100116 | |
| Download: ML20041E079 (19) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'02 g N ^ *n A BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N RECEIVED e, e.
- MAR 091982m- C
) '
In the Matter of ) manmuumerumme y B mus umana
) ins LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322 .
(Shoreham Nuclear Power )
Station, Unit 1) )
)
SUFFOLK COUNTY INTERROGATORIES TO THE NRC STAFF Pursuant to 10 CFR }{ 2.720(h)(2)(ii) and 2.740b, the NRC Staff is requested by Suffolk County to answer separately and fully, under oath, each of the interrogatories set forth below, within fourteen (14) days after service hereof. These interroga-tories pertain to Suffolk County Contentions 1-5, 8-10, and 17.
Interrogatories regarding the remaining contentions will be filed shortly.
DEFINITIONS AND INSTRUCTIONS FOR ANSWERING INTERROGATORIES A. Wherever appropriate, the singular form of a word shall
! be interpreted as plural and vice versa.
I B. "And" as well as "or" shall be construed either dis-junctively or conjunctively as necessary to bring within the 1
l scope hereof any information (as defined herein) which might otherwise be construed to be outside the scope of these discovery i
l requests.
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- 8203100116 8203o5 -
I C. Wherever appropriate, the masculine form of a word shall be interpreted as feminine and vice versa.
D. The term " person" includes any natural person, firm, partnership, educational institution, joint venture, corporation, and any foreign or domestic government organization (including military and civilian), or group of natural persons or such enti-ties.
E. The term "information" shall be expansively construed and shall include, but not be limited to, facts, data, theories, f
analyses, opinions, images, impressions, concepts and formulae.
F. The term " document" means any tangible thing from or on which information can be stored, recorded, processed, transmit-ted, inscribed, or memorialized in any way by any means regard-less of technology or form and including but not being limited tot papers, books, accounts, newspaper and magazine articles, letters, photographs, objects, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, drawings, blueprints, plans, specifications, i
i manuals, procedures, transcripts, minutes, reports and recordings of telephone or other conversations, or on interviews, or of r
conferences, or of other meetings, occurrences, or transactions, a f fidavits, transcripts of depositions or hearings, statements, summaries, opinions, reports, tests, experiments, analyses, evaluations, contracts, agreements, ledgers, journals, books or records of account, receipts, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound recordings, computer printouts, data processing input and output, I
microfilms, all other records kept by electronic, photographic or mechanical means, and things similar to any of the foregoing.
Each copy of a document which contains any separate notations or writings thereon, and each draft of a document which differs in any way from the final version of the document, shall be deemed to be a separate document for purposes of these discovery r eq ue sts . (Versions of a document which differ in clearly nonsubstantive and unimportant ways from other versions of the document do not need to be considered as separate documents. )
G. The term " communication" includes every exchange of information by any means.
H. The term "LILCO" or "LILCO personnel" means Long Island Lighting Company, and any affiliate, agent, employee, consultant, contractor, technical advisor, representative (including, without limitation, attorneys and accountants and their respective agents and employees), or other person acting for or on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.
I. The term "Shoreham" means the Shoreham Nuclear Power Station, Unit 1, any part thereof, or any structure, system, component, ins trume ntation, equipment, or materials included in, or intended to be included in Shoreham.
J. The term " contractor" means any person, not affiliated with LILCO, who performed work relating to Shoreham, on behalf of LILCO and/or pursuant to a contract with LILCO. The term
" subcontractor" means any person, not affiliated with LILCO who performed work of any kind relating to Shoreham, on behalf of a
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contractor with whom the person was not affiliated, and pursuant to a contract with such contractor. A person other than a contractor who contracts with a subcontractor shall be deemed a subcontractor.
K. The words "concerning," " concerns," or any other deriv-ative thereof, include referring to, responding to, relating to, pertaining to, connected with, comprising, memorializing, com-menting on, regarding, discussing, showing, describing, reflect-ing, analyzing, supporting, contradicting and constituting.
L. Whenever in the interrogatories there is a request to identify a person that is a natural person, set forth:
(1) his name; (2) his last known residence address; (3) his last known business address; (4) his last known employer; (5) his title or position; (6) his areas of responsibility; (7) his business, professional, or other relationship with the NRC Staff; and (8) if any of the above information has changed subse-quent to the time period referenced in a particu-lar interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time refer-enced in the interrogatory.
M. Whenever in the interrogatories there is a request to j identify a person that is not a natural person, states (1) the full name of such person, if known; (2) the nature or form of such person, if known; (3) the address of its principal place of business or the principal place where such person is to be found; (4) whether the NRC Staff has or has had any relationship or affiliation with such person, its affiliates or subsidiaries, and, if so, a description of such relationship; and (5) if any of the above information has changed
- subsequent to the time period referenced in a particular interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time referenced in the interrogatory.
N. Whenever in the interrogatories there is a request to identify or describe a document:
(1) set fo rth:
(a) the date of the document; (b) the type or nature of the document; (c) the length of the document; (d) the location of the document; (e) a brief description of the contents of the document; and
(2) identify:
(a) the author, signatories and any other person who originated, prepared or participated in the preparation of the document; (b) all persons to whom the document was addressed and all persons to whom cepies of the document were to be or have been sent; and (c) all persons whom the NRC Staff knows or believes to have possession, custody or control of the document and of any copies thereof.
- O. Whenever in the interrogatories below there is a request to identify a communication
(1) stater (a) the date of the communication; (b) the place of the making and the place of receipt of the communication; (c) the type and means of the communication; l (d) the substance of the communication; and (2) identify:
(a) each person making the communication, and his location at the time the communication was made; (b) each person to whom the communication was made, and his location at the time; l
(c) all other persons present during, participat-ing in, or receiving the communication and the location of each such person at the time; (d) each document concerning such communication; and (e) each document upon which the communication is based or which is referred to in the communi-cation.
P. With respect to each interrogatory answer, identify each document which forms a basis for the answer given, is relied upon or which was reviewed, in whole or in part, in preparing the answers, or which in any way corroborates or concerns the answer given. A document to be so identified may be produced in lieu of the elements of such identification. In such case, h oweve r, please specifically identify the document in the answer to the interrog story in sufficient detail so that Suffolk County can readily locate the document among all documents produced by the NRC Staff.
Q. Where exact information cannot be furnished, estimated information should be supplied to the extent possible. Where estimated information is used, the answer should so state and should indicate the basis upon which the estimate was made. If possible, the upper and lower boundaries of the estimate should be given.
R. If the NRC Staff objects to or claims a privilege (attorney-client, work product, or otherwise) with respect to any i
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interroga tory, in whole or in part, or seeks to withhold docu-ments or information because of the alleged proprietary nature of the data, set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the Board to determine the validity of your objection or claim of privilege. This descr,iption by the NRC Staff should include with respect to any document: the author, addressor, addressee, recipients of indicated and " blind" copies, date of preparation, subject matter, purpose for which it was prepared, number of pages, attachments or appendices, all persons to whom distributed, shown or explained, present custodian, all persons believed to have a copy of the document, and the nature of the privilege or objection asserted.
S. If any document called for herein has been destroyed, that document is to be identified as in "R" above. The NRC Staff also is requested to state the date of destruction, place and manner of destruction, persons authorizing destruction, and person destroying the document.
T. Information furnished in answer to an interrogatory may be furnished by reference to the answer provided for another interroga to ry , provided the other referenced answer fully responds to each request for information contained in the interroga to ry . Separate answers should be provided for each interrogatory and each subpart thereof, unless a complete answer to each interrogatory may best be presented through combining answers. The County is interested in this regard in receiving the relevant data asked for and any means of providing such data which is less time-consuming for the responder but which is nevertheless complete will satisfy the intent of these interroga-tories.
U. Each interrogatory shall be construed to impose upon the NRC Staff the continuing obligation to supplement the answer thereto as required by the NRC's Rules of Practice.
V. As used herein:
(1 ) " Settlement Agreement" means the unexecuted Sixth Stipulation and Settlement Agreement between the NRC Staff and Suffolk County.
(2) " Analysis" means research, investigation, audit, inspection, review, testing, monitoring, or any other method'or form of examining data and/or forming conclusions or recommendations.
(3) "NRC" means the Nuclear Regulatory Commission and its staff, any division or section thereof, any staff member thereof, or any agent, consultant, contractor, technical advisor, employee, or representative (including but not limited to attorneys and accountants and their employees and agents) of the NRC.
W. If the NRC Staf f is unable to answer any interrogatory or portion thereof, identify the person whom the NRC Staff believes has the knowledge or information which the interrogstory addresses.
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INTERROGATORIES Suf folk County Contention No. 1.
- 1. State the NRC Staff's position with respect to Suf folk County Contention 1, and with respect to such position identify:
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- a. The bases for the position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-gations or reports, upon which the NRC Staf f relies for support of or which concern its position; and
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc.) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
- 2. Has the NRC Staff or any other person conducted any evaluations or analyses of the Shoreham Remote Shutdown System discussed in Item 7.4.3. of the Shoreham Supplemental Safety Evaluation Report (NUREG 0420), or of the emergency procedures with respect to the Remote Shutdown System. If yes, identify all documents concerning such evaluations or analyses. If the answer to this interrogatory is no, what is the schedule for addressing Item 7.4.3. of the SSER?
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Su f fo lk Co . Contention 2.
- 3. State the NRC Staff's position with respect to Suffolk County Contention 2 and with respect to such position identify:
L
- a. The bases for such position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-gations or reports, upon which the NRC Staff relies for support of or which concern its position; and
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc.) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
- 4. Identify all standards and/or criteria used or to be used by the NRC Staf f to determine whether Shoreham adequately complies with Regulatory Guide 1.39 " Housekeeping Requirements for Water-Cooled Nuclear Power Plants" with respect to diesel generator maintenance.
Suf folk Co. Contention 3.
- 5. State the NRC Staff's position with respect to Su f folk County Contention 3 and with respect to such position identify:
- a. The bases for such position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-gations or reports, upon which the NRC Staff relies for support of or which concern its position; and 11 -
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc.) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
- 6. Set forth the scheduled implementation dates which have been determined by the NRC Staff for each item of equipment iden-tified in Regulatory Guide 1.97, revision 2, concerning the detection of Inadequate Core Cooling.
Su f fo lk Co . Contention 4.
- 7. State the NRC Staff's position with respect to Suffolk County contention 4 and with respect to such position identify:
- a. The bases for such position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-gations or reports, upon which the NRC Staff relies for support of or which concern its position; and
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc. ) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
- 8. Has the NRC Staff reviewed and/or approved pre-operational and start-up pipe system testing, with respect to potential water hammer events, for the Zimmer and LaSalle plants? If so, identify all documents concerning such review and/or approval.
- 9. Do the results from pre-operational and start-up pipe system testing at the Zimmer and LaSalle plants indicate that systems potentially affected by water hammer will, during their service lifetimes, withstand flow-induced vibrations of operation without loss of integrity? Identify all documents concerning such testing, results, and conclusions therefrom.
Su f folk Co. Contention 5.
- 10. State the NRC Staff's position with respect to Suffolk County Contention 5 and with respect to such position identify:
- a. The bases for such position; and
- b. All analyses, correspondence, and other documents,
! including test results, research, audits, investi-gations or reports, upon which the NRC Staff relies for support of or which concern its position.
- 11. Identify and describe all standards and acceptance criteria upon which the NRC Staff bases, or will base, its acceptance or rejection of the Shoreham Loose Parts Monitoring System (LPMS), including in your answer the number of spurious alarms which the NRC Staff considers acceptable. Identify all analyses and documents concerning such standards and criteria, and the results of their application to Shoreham.
- 12. Identify and describe all standards and criteria used by the NRC Staff in reviewing and evaluating Shoreham's operator
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training and procedures for LPMS alarm response. Identify all l
analyses and documents concerning such standards and criteria, and concerning the NRC Staff's review and evaluation of the Shoreham training and procedures for LPMS alarm response.
1 Su f folk Co. Contention 8.
- 13. State the NRC Staff's position with respect to Suffolk County Contention 8 and with respect to such position identify:
- a. The bases for such position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-gations or reports, upon which the NRC Staff relies for support of or which concern its position; and
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc.) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
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Suf folk Co. Contention 9.
- 14. State the NRC Staff's position with respect to Su f folk l
County Contention 9 and with respect to such position identify:
' a. The bases for such position; l
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-j gations or reports, upon which the NRC Staf f
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relies for support of or which concern its position; and
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc.) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
- 15. Identify the bases for the NRC Staff's acceptance of Shoreham's ECCS pump suction strainers, and identify all analyses, test results, acceptance criteria and standards upon which such acceptance was based, or which concern such acceptance.
- 16. Has the NRC Staff examined the issue of blockage of ECCS pump suction, as discussed in NRC Generic Task A-43,
" Containment Emergency Sump Performance" with respect to Shoreham? If yes, identify all analyses and documents congerning such examination.
Suf folk Co. Contention 10.
- 17. State the NRC Staff's position with respect' to Suffolk County Contention 10 and with respect to such position identify:
- a. The bases for such position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-j gations or reports, upon which the NRC Staf f relies for support of or which concern its position; and s
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc. ) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses end other documents concerning whether these criteria have been satisfied by LILCO.
Suffolk Co. Contention 17.
- 18. State the NRC Staff's position with respect to Suffolk County Contention 17 and with respect to such position identify:
- a. The bases for such position;
- b. All analyses, correspondence, and other documents, including test results, research, audits, investi-gations or reports, upon which the NRC Staf f relies for support of or which concern its position; and
- c. The acceptance criteria (Regulatory Guide, Standard Review Plan, etc.) utilized by the NRC Staff to reach its position with respect to this Contention, and all analyses and other documents concerning whether these criteria have been satisfied by LILCO.
- 19. Identify all potential toxic gas hazards which the NRC Staff believes are or may be present in the Shoreham control room. Identify: (a) all reviews, test results, analyses and/or other documents concerning such potential hazards performed by or on behalf of the NRC Staff; (b) all acceptance criteria and/or standards utilized by the NRC Staff in performing such reviews or o e o analyses; and (c) all documents concerning such reviews, analyses, criteria or standards.
- 20. State the NRC Staff's position concerning the adequacy of LILCO's training program and detection system in providing detection, warning, and timely use of respirators with respect to all potential toxic gas hazards in the control room, and identify all analyses, test results and documents which concern such position or upon which such position is based.
Respectfully submitted DAVID J. GILMARTIN Suf folk County Attorney PATRICIA A. DEMPSEY Assistant Suffolk County Attorney Suf folk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 h n '
Herbert H. Brown Lawrence Coe Lanpher Karla J. Lets ch e 1
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Floor Washington, D.C. 20036 (202) 452-7000 Attorneys for Suf folk County
! March 5, 1982
.. * * ; s m r. e73;. r n o t-ver -
UNITED STATES OF AMERICA , _ , ' . .
NUCLEAR REGULATORY COMMISSION ".,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARDj A!0 :04 l', .
) CO :J . /
In the Matter of ) :1MKh
)
'LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322 (OL)
(Shoreham Nuclear Power Station, )
Unit 1) - . )
)
CERTIFICATE OF SERVICE I hereby certify that copies of the Suffolk County Inter-rogatories and Requests for Production of Documents directed at the Long Island Lighting Company and the NRC Staff have been served this 5th day of March, 1982 by U.S. Mail, first class, (except as otherwise noted) to the following:
Lawrence Brenner, Esq. Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Howard L. Blau, Esq.
Dr. James L. Carpenter 217 Newbridge Road Administrative Judge Hicksville, New York 11801 '
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W. Taylor Reveley III, Esq. ( *)
Washington, D.C. 20555 Hunton & Williams P.O. Box 1535 Mr. Frederick J. Shon Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board Jeffrey Cohen, Esq.
U.S. Nuclear Regulatory Commission Deputy Commissioner & Counsel Washington, D.C. 20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Stephen B. Latham, Esq.
Mineola, New York 11501 Twomey, Latham & Shea Attorneys at Law Mr. Brian McCaffrey P.O. Box 398 Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 Hicksville, New York 11801 i
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Marc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.
New York Public Service Commission MHB Technical Associates The Governor Nelson A. Rockefeller 1723 Hamilton Avenue Building Suite K Empire State Plaza San Jose, California 95125 Albany, New York 12223 Hon. Peter Cohalan David H. Gilmartin, Esq. Suffolk County Executive Suffolk County Attorney County Executive / Legislative County Executive / Legislative Bldg. Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Atomic Safety and Licensing Ezra I. Bialik, Esq.
Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Bureau Washington, D.C. 20555 New York State Department of Law
. Docketing and Service Section 2 World Trade Center Of fice of the Secretary New York, New York 10047 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Bernard M. Bordenick, Esq. (#) U.S. Nuclear Regulatory David A. Repka, Esq. Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 1
March 5, 1982 (2mewe> C#, sv5 ^
Lawrence Coe Lanpher '
' (*) Federal Express KIRKPATRICK, LOCKHART, HILL,
(#) By Hand CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Floor Washington, D.C. 20555 1
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