ML20041E995
| ML20041E995 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/11/1982 |
| From: | Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | SHOREHAM OPPONENTS COALITION |
| References | |
| ISSUANCES-OL, NUDOCS 8203160072 | |
| Download: ML20041E995 (10) | |
Text
.
e 03/11/82 UNITED STATES OF AMERICA NUCLEAR ;tEGULATORY COMf1ISSION gg
_BEFORE THE ATOMIC SAFETY AND LICENSING BO c
x fyg7, % 2 In the Matter of
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pg LONG ISLAND LIGHTING COMPANY
}Q 8/9gg f Docket No.S0-322
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[f4 (Shoreham Nuclear Power Station.
Unit 1)
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(OL) 4
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NRC STAFF'S ANSWERS TO SOC'S THIRD SET O AND REQUESTS FOR PRODUCTION OF DOCUMENTS T THE NUCLEAR REGULATORY COMMISSION STAF In order to expedite this proceeding and to continue and facili the cooperative efforts between the NRC Staff (Staff) and I t ae n ervenor Shorehan Opponents Coalition with respect to discovery matters 1/
, the NRC Staff has determined to treat the above-captioned SOC I t n errogatories and Requests for the production of documents dated March 1
, 1982 as an informal discovery request.
The Staff's voluntary response to SOC's request should not be contrued as a Staff acknowledgement that SOC' discovery requests comply with the provisions of 10 C F R s
5 2.720(b)(2)(ii) or 6 2.744 as regards discovery against the Staff
_ SOC Contention 19 The July 29, 1981, SOC "Second Set of Interrogatories and Req m
for Production of Documents" referenced in SOC's March 1 uest
, 1982 discovery 1/
See "Sti the "***pulation Relating to NRC Staff ***" dated Ju
~
20, 1981 and m
dated August 6, 1981.
a kbohno!$$$$b2 DE3IGNATED ORIGINAL D
G PDR Certified By
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request was served on Applicant but not on the Staff. Accordingly, there is no outstanding discovery request as to Staff regarding Contention 19.
The Staff notes, however, that the July 29, 1981 SOC discovery request has been readdressed to Applicant on March 1,1982. The Staff will voluntarily provide comments to SOC on Applicant's responses at such time as Applicant may respond to the discovery requests in question.
50C Contention 19(a) 1.
Attached find letter dated February 4,1982 from Applicant (J. L. Smith) to Staff (Mr. Harold R. Denton). Additionally, see NRC Inspection Report 81-23, a copy of which is in the local public document roon.
(A copy has also been supplied Energy Research Group,Inc.)
SOC Interrogatory 3 1.
There are currently r.o NRC documents pertainjng to the Staff's Regulatory Guide 1.97 reviaw of the Shoreham plant since the Staff has not yet reviewed the Shoreham plant for conformance to Regulatory l
Guide 1.97.
The Staff is in the process of developing policy with regard to the method of review and schedule of review for compliance to Regulatory Guide 1.97. This policy will cover both operating plants and plants in the licensing process such as Shoreham.
2.
The Staff has received from LILC0 a scheduled implementation
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date for equipment identified in Reg. Guide 1.97, Rev. 2.
This document was transmitted to the Staff on July 13, 1981 in the form of affidavits of C. A. Daverio, T. F. Gerecke, B. R. McCaffrey and D. A. Robare. These l
i
O.
affidavits were filed in connection with Applicant's motion for sumary disposition of SOC Contention 3.
3.
The Staff has neither accepted nor rejected LILCO's scheduled implementation date. The Staff has not yet reviewed the Shoreham plant for conformance to Regulatory Guide 1.97, Rev. 2.
(See(1)above) 4.
This question as phrased is difficult to answer yes or no. As stated in NUREG-0737, " Clarification of THI Action Plan Requirements,"
the capacity for effluent monitoring of radioiodines for the accident condition shall be provided by the licensee with sampling conducted by adsorption on charcoal or other media. The licensee shall also provide onsite laboratory capabilities to analyze or measure these samples.
E.
LILC0's proposed monitoring of halogen effluents is acceptable to the Staff. This is discussed in Supplement No. 2 to the Shoreham Safety Evaluation Report (NUREG-0420).
SOC Contention 6(a)(i) 1.
The Staff's Inspectinn Report relating to the " Staff QA/QC review, inspection and/or audit of the Shoreham nuclear plant conducted during February,1982" is still under preparation. At such time as the report is completed and is available for public review, a copy will be placed in the local public document room for Shoreham. However, the Staff does not view that inspection report as being relevant to the contention in question.
SOC Contention 7(a)(2) 1.
A meeting summary relating to a meeting between Staff and Applicant during February,1982 is under preparation. A copy of the summary, when completed, will be forwarded to all parties to this proceeding.
2.
The criteria used by the NRC Staff during its control room audit of Shoreham were essentially those which were later published as NUREG-0700. At that time NUREG-0700 was going through a final technical and editorial review, so the criteria used at Shoreham were not identical to those now presented in NUREG-0700. However, the similarity of the draft version and the published version is such that most differences are relatively minor, generally falling into the category of editorial revision.
3.
As stated above, the NRC Staff used a draft version of NUREG-0700 in its audit of the Shoreham control room.' So, generally, the answer to this question is:
"Yes, the criteria from NUREG-0700 were used." This is not to say, however, that each specific guideline in NUREG-0700 was specifically applied to every aspect of the Shoreham control room.
It must be renembered that the NRC Staff conducted an audit of the control room. Due to the limitations of time and manpower, the NRC Staff cannot do a detailed control roon design review of every applicant's control room.
_ ~
o 5-4.
Not applicable in view of answer to 3 above.
5.
The only relevant document is NUREG-0700. From the nature of the above interrogatories, Staff assumes S0C a has copy of the NUREG in question.
Respectfully submitted, Buq nl. fb A4 [A&
Bernard M. Bordenick Counsel for NRC Staff Dated at Bethesda, Maryland this lith day of March,1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I
!)
LONG ISLAND LIGHTING COMPANY ll DocketNos.50-322(OL) i (Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF JERRY N. WILSON Now comes Jerry N. Wilson, and being duly sworn, deposes and says as follows:
1.
I am presently employed by the U.S. Nuclear Regulatory Comission as a Senior Policy Analyst in the Office of Policy Evaluation.
I am the former Licensing Project Manager for Shoreham.
2.
Iamdulyauthorizedtoanswerthefollowing' interrogatories submitted to the NRC Staff by the Shoreham Opponents Coalition on March 1,1982:
SOCContentions19and19(a);SOCContention6(a)(1),
Interrogatory 1; S0C Contention 7(a)(2), Interrogatory 1.
3.
I hereby certify that the answers given are true and correct to the best of my knowledge and belief.
%y>:.aho erry N. Wilson, P.E.
Subscribed and sworn to before this Sd4 day of March,1982 f (/
y My Comission expires:_
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICE ARD In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station Docket Nos. 50-322 (OL)
Unit 1)
)
AFFIDAVIT OF JERRY L. MAUCK Now comes Jerry L. Mauck, and being dul as follows:
y sworn, deposes and says 1.
I am employed by the U.S. Nuclear Regulat as a Reactor Engineer in the Instrumentation ory Commission Office of Nuclear Reactor Regulation and Control Systems Branch, 2.
I am duly authorized to answer the follo i submitted to the NRC Staff by the shoreham Opp w ng Interrogatories March 1,1982:
onents Coalition on SOC Contention 3, Interrogatories 15 3
I hereby certify that the answers given the best of my knowledge and belief are true and correct to Jpr Mauck ft f*
Subscribed and sworn to before me thisF#^~
W day of March,1982 Notary Publfc
$4 My Commission expires: M b19/ M
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the flatter of
)
LONG ISLAND LIGHTING C0ftPANY Docket Nos. 50-322 (OL)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF RICHARD J. ECKENRODE Now comes Richard J. Eckenrode, and being duly sworn, deposes and says as follows:
1.
I am presently employed by the U.S. Nuclear Regulatory Comission as a Human Factors Engineer in the Human Factors Engineering Branch, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to answer the following lnterrogatories submitted to the NRC Staff by the Shoreham Opponents Coalition on March 1, 1982:
S0C Contention 7(a)(ii), Interrogatories 2-5.
3.
I hereby certify that the answers given are true and correct to the best of my knowledge and belief.
0-am RichardJ.Epenrode
,i Subscribed and sworn to before me this % day of March,1982.
/%00L&
Notary Public J
My Comission expires:
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L UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING B In the Matter of L0f4G ISLAND LIGHTING COMPANY Docket No. 50-322 (Shoreham Nuclear Power Station, (OL)
Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S ANSWERS TO SO OF INTERROGATORIES AND REQUESTS FOR PR THIRD SET NUCLEAR REGULATORY COMMISSION STAFF (NR THE WILSON." " AFFIDAVIT OF JERRY L. MAUCK, and " AFFIDAVIT IT OF JERRY N.
ECKENRODE" in the above-captioned proceeding have been se CHARD J.
following by deposit in the United States mail rved on the Comission's interna; mail system, this lith day of M egulatory
, 1982:
Lawrence Brenner, Esq.*
Administrative Judge Ralph Shapiro, Esq.
Atomic Safety and Licensing Board Camer and Shapiro U.S. Nuclear Regulatory Comission 9 East 40th Street Washington, D.C.
20555 New York, NY 10,016 Dr. James L. Carpenter
- Administrative Judge Atomic Safety and Licensing Board Howard L. Blau, Esq.
U.S. Nuclear Regulatory Comission Hicksville,ge Road 217 Newbrid Washington, DC 20555 NY 11801 Mr. Frederick J. Shon*
i Administrative Judge W. Taylor Reveley III, Esq.
Atomic Safety and Licensing Board Hunton & Williams U.S. Nuclear Regulatory Comission P.O. Box 1S35 Washington, DC 20555 Richmond, VA 23212 Edward M. Barrett, Esq.
Jeffrey Cohen, Esq.
General Counsel Deputy Comissioner and Counsel Long Island Lighting Company New York State Energy Office mi 250 Old County Road Agency Building 2 i
Mineola, NY 11501 Empire State Plaza 1
Albany, NY 12223 Mr. Brian McCaffrey Long Island Lighting Company 175 East 91d Country Road "O
Hicksvilles New York 11801 l
i Stephen B. Latham, Esq.
John F. Shea, III, Esq.
1 Twomey, Latham & Shea Mr. Jeff Smith Attorneys at Law Shoreham Nuclear Power Station P.O. Box 398 P.O. Box 618 33 West Second Street North Country Road Riverhead, NY 11901 Wading River, NY 11792 Marc W. Goldsmith Energy Research Group, Inc.
MHB Technical Associates 400-1 Totten Pond Road 1723 Hamilton Avenue Waltham, MA 02154 Suite K San Jose, CA 95125 Joel Blau, Esq.
New York Public Service Commission Hon. Peter Cohalan The Governor Nelson A. Rockefeller Suffolk County Executive Building County Executive / Legislative Bldg.
Emr:re State Plaza Veteran's Hauppauge, Memorial Highway Albany, NY 12223 NY 11788 David H. Gilmartin, Esq.
Ezra I. Bialik, Esq.
Suffolk County Attorney Assistant Attorney General County Executive / Legislative Bldg.
Environmental Protection Bureau Veteran's Memorial Highway New York State Department of Law Hauppauge, NY 2 World Trade Center 11788 New York, NY 10047 Atomic Safety and Licensing Board Panel
- Atomic fafety and Licensing U.S. Nuclear Regalatory Comission Appeal Board
- Washingtoa, DC U.S. Nuclear Re 20555 Washington, DC' gulatory Comission 20555 Docketing and Service Section*
Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Karla J. Letsche, Esq.
Kirkpatrick, Lockhart, Hill, Christophet & Phillips 1900 M Street, N.W.
8th Floor Washington, D.C.
20036 i
44
~Wi Lee Scott Dewey Counsel for NRC Staff i
_ _ _ _________________