ML20041E568

Second Request for Production of Documents Directed to Util

ML20041E568
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/06/1982
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
ISSUANCES-OL, NUDOCS 8203110092
Download: ML20041E568 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY BO RD y v y RECElygg .

R, 3 MAgj g $82hw

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In the Matter of )D

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LONG ISLAND LIGHTING COMPANY ) 1, //

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(Shoreham Nuclear Power )

S ta tion , Unit 1) )

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SUFFOLK COUNTY SECOND REQUEST FOR PRODUCTION OF DOCUMENTS BY LONG ISLAND LIGHTING COMPANY Pursuant to 10 C.F.R. S 2.741, LILCO is requested by Suffolk County to produce for insoection 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 l

later than 30 days from the date of service of this Request.

l DEFINITIONS AND INSTRdCTIONS FOR DOCUMENT PRODUCTION l

The definitions and instructions applicable to these l Requests are the same as those set forth in Suf folk County l

Interrogatories to LILCO, dated March 5, 1982, and hereby incorporated by reference, except that subparts L through P, and W of such Definitions and Instructions are not applicable to these Requests.

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DOCUMENTS TO BE PRODUCED

1. All documents identified in response to Suffolk County Second Set of Interrogatories to Long Island Lighting Company, dated March 6, 1982.

2. With regard to Section 17.2 of the FSAR where it states " Audits shall be conducted to predetermined schedules,"

4 please provide a copy of the current " predetermined" audit schedules.

3. A copy of the LILCO Inspection Plan for the Shoreham Nuclear Power Station construction and operations programs.

4. S&W Topical Report RP-8A " Radiation Shielding Design i and Analysis Approach for Light Water Reactor Power Plants,"

May 1975.

l 5. All documents related to seismic activity during the past 24 months in the northeastern United States or southeastern Canada, including:

l (1) Documents which concern the earthquake magnitudes; (2) Documents which concern the ground accelerations; l

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I (3) Documents which concern the accelograms or other seismic instrument readings or data recorded at the Shoreham plant, on Long Island, or elsewhere; (4) Documents which concern the free-field response of such seismic activity; (5) Docueents which concern the response spect a at the Shoreham plant, including any effects related to soil systems interaction or damping; and (6) Documents which concern the adequacy of Shoreham's seismic design in view of recent seismic activity in the northeastern United States or southeastern Canada.

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

Attorneys for Suffolk County March 6, 1982

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