ML20041E392

Third Set of Interrogatories & Requests for Production of Documents.Notice of Appearance Encl.Related Correspondence

ML20041E392
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/01/1982
From:	SHOREHAM OPPONENTS COALITION
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20041E388	List: ML20041E387 ML20041E389 ML20041E392
References
NUDOCS 8203100459
Download: ML20041E392 (6)

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UNITED STATES OF AMEltICA NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

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(Shoreham Nuclear Power Station, ) .

Unit 1) )

SOC'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO THE NUCLEAR REGULATORY COMMISSION STAFF (NRC STAFF)

I.

The Shoreham Opponents Coalition (SOC) serves on the Nuclear Regulatory Commission Staff (NRC or Staff) the i n te r rog ator.ies and requests for production of documents that appear below. A sworn .

response to them must be provided to SOC in accordance with the terms of 10HCFR Section 2.720(h)2ii and 2.744. If the a. 4

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any q'uestion is not known when the response is filed, the answer must be provided as soon as the missing information becomes .

dvailable.

The attaches series of questions include both interrogatories They have been included

'and requests for production of documents.

in a single document to facilit.ite understandinq of th" cont e x t in which either answern to -interrogatories or production of documents 0203100459 920301 PDR G

ADOCK 05000322 PDR -

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2 is requested. Furthermore, SOC has tried to provide, in a ningl.

document, the range of issues and facts pertaining to the NRC i

. Staff's review of the Shoreham facility, which are of concern to l 1

SOC in Docket No. 50-322 ',egarding the $0C conte'ntions presently r

4' admitted in that proceeding.

i For each SOC contention interrogatories have been distinguishad from requests for production of documents according to the following code:

! (no asterisk) = Interrogatory

• = Request for production of documents

• • = Interrogatory and Request for production of documents

• With regard to SOC's requests for production of documents, -

p each and every request pertains to a specific SOC contention which

has been admitted by the Board in Docket No. 50-322. Withoot.

production by the Staff of the requested documents, as well a s.

i answers to the interrogatories, SOC will be without the necessary -

l information to properly evaluate determinations and resolutions on i

' technical issues made by Staff with regard to SOC's content ions .

i Accordingly, SOC respectfully urges the Presiding Officer and I

Executive Director of Operations to order answer these

! interrogatories and the production of documents in accordance with

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I 10 CFR 2.720(h)2ii and 2.744.

! .As used [n the interrogatories and request for production of documents, the following definitions apply as indicated:

1. '"NRC," means Nuclear Regulatory Commission, its officers, i '

staff, agents, employees, and consultants.

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3/1/82 2,. " Facts," include the calculational or other assumptions, if any, underlying various assertions of fact. " Including" and

" include," as used in these interrogatories, mean " including but no limited to." -

3. " Document" or " documents," mean any handwritten, typed, printed, recorded or graphic matter however produced or reproduced, including material stored for use in automatic data processing systems, whether or not in the possession, custody or control of the NRC and whether or not claimed to be pr'ivileged.

against discovery on any ground, including: reports; records; lists; memoranda; correspondence; telegrams; schedules; photographs, sound recording; films; hand, machine and' computer calculations; computer codes; data; and written statements of -

witnesses or other persons having knowledge of the facts'.

. 4 " Studies or observations," include physical, empirical, calculational, assumptional, and other types of work, whether recorded in writing or not.

Please provide answers to the following questions which I

pertain to specific SOC contentions in Docket No. 50-322.

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i SOC CONTENTION 19

• On July 29, 1981, SOC served on NRC Staf f its "Second Set of Interrogatories and Request for Production of ,

Documents" pertaining to SOC Contention 19. Formal answers tu those interrogatories were deferred pending the outcome ,f informal discovery meetings between the parties and a ruling.

by the Board on the December 2, 1981 Motion for Acceptance of SOC Contentions. In view of the Board's acceptance of .

Contention 19 as stated by the parties in'tnat Motion, SOC -

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hereby formally requents ans'wern to its July 29, 1981 .

j - interrogatories and documents requests. In addition, SOC hereby submits the following additional discovery request'.

SOC CONTENTION 19(a) .

1.* Provide copies of any and all correspondence, studies, reports and analyses which pertain to the pre-serv. ice inspection of the Shorehan reactor pressure vessel .

conducted during Decemoer of 1981, including any and all reports prepared oy any outside consultants retained by LILCO cr the MRC for the PSI. .

III.

In addition to providing answers and documents in response to SOC Contention 19, SOC-submits thc following ,

additional discovery' requests to the NRC: .

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SOC CONTENTION 3 1.* Provide copies of any and all NRC documents which i pertain to Staff's Regulatory Guide 1.97 review of the 1 Shoreham plant.

Has the NRC Staf f received f rom LILCO a scheduled

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implementation date for each of the pieces of equipment identified in Regulatory Guide 1.97 Rev. 2?

j 3.** If the-answer to 2 is- affirmative, has Staff ac'cepted or rejected LILCO's scheduled implementation date? Pru/ide i

copies of all Staff documents concerning Staff's acceptance or-rejection of LILCO's schedulei '

im >1ementation date.

t i 4. Is it Staff's positian toat kequlat ory Gui*ir. I. 7 hev.

i 2, NUREG 0578 or NUREG 0717 r e q u i r en co n t i n a .> uc. 0r: - l . 0 -

l monitoring or cont inuouc < >n-l i v- camplimi :>f haluu. a effluent?

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March 1, 1982 5.** What is Staff's position concerning LILCO's proposed monitoring of halogen effluent? Provide copies of all Staff documents in support of Staff's position.

SOC CONTENTION 6(ali Provide copies of a1,1 Staff documbots pertaining to the

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Staff QA/QC review, inspection and/or audit of the Shoreham nuclear plant conducted during February, 1982.

SOC CONTENTION 7(a)2 1.* Provide copies of all Staff documents which relate to any meetings between Staff and LILCO during February, 1982 concerning the Shoreham control room.

2. Which criteria were utilized by NRC Staff during its

control room audit of Shoreham?

3. Were the criteria contained in NUREG 0700 specifically utilized by NRC Staff in its control room audit for Shoreham? '

4. If the answer to 3 is negative, will the Shoreham control room audit be updated to meet the NUREG 0700

-criteria?

5.* Provide copies of all documents which set forth the criteria used by Staff in its Shoreham control room a2dit. '

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. c gb UNITED STATES i' /J'.ER I CA NUCLEAR REGULATUAY COMMISSION Ir t h e; 't;st t e r of )

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14):;G I S L A 'J D LIGHTING CO1PANY ) Docket No. 50-322

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( S h t r o h ern rJuel o er Power St ation, )

1) )

NOTICE OF APPEARANCE Pleau<e nute the appearance ci the undersigned, who has Leen edmitted to practice law before the Supreme Court of the State of N (: a i'o r k as one of the counsel for the Shorehan opponents Coalit on in tne above-captioned docket. Please take further notice that the name of the firm has been changed to: Twomey, I,a.an and Shea.

.e The firT audress remains the n ame ll #

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John F. Shea, III Twoney, I,atham & Shea l'o s t Office i30 x 398 i< i > e r h r- a d , .u w 'M r '- 11901

( 5 i <i . /?/-21dl at ~',') : .la r c r. 1, 1982 G