ML20041F105

Suppl to 820306 Second Request for Production of Documents

ML20041F105
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/08/1982
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
Shared Package
ML20041F106	List: ML20041F105 ML20041F119
References
ISSUANCES-OL, NUDOCS 8203160194
Download: ML20041F105 (8)

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ntnx.tt,tn UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'82 iM 12 P 1 :22 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) g g

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(Shoreham Nuclear Power )

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SUPPLEMENT TO SUFFOLK COUNTY SECOND REQUEST FOR PRODUCTION OF DOCUMENTS BY  % //

LONG ISLAND LIGHTING COMPANY On March 6, 1982, Suffolk County filed a second request for produc-tion of documents by LILCO. The Coun:y hereby supplements the second request and requests that the following documents also be produced.

DEFINITIONS AND INSTRUCTIONS The definitions and instructions applicable to these Requests are the same as those set forth in Suffolk County Request for Production of Documents by Long Island Lighting Co=pany, dated March 5,1982.

DOCUMENTS TO BE PRODUCED Suffolk Co. Contentions 13-15

1. On March 22, 1978, LILCO provided an "index of Shoreham quality assurance (QA) records that 10 CFR Part 50, Appendix B, Criterion XVII requires LILCO to retain . . .."' Letter f rom F. C. Whittemore to I. Like, March 22, 1978.

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8203160194 820309 k PDR ADOCK 05000322 O PDR

a. The index provided by LILCO covered the period up to March 15, 1978. Provide the comparable index for the period March 15, 1978 to present.

b. Provide the following categories of documents identified in the previously supplied index, in each case providing not cnly those documents listed in the index through 9

. March 15, 1978 but also the documents,and revisions of documents,of the same category which have been added-to theindex in the period March 15, 1978 to the present:

(i) p.85 QAP-S-06.2 Control of Site ChyLNS OQAPS OQAI CONT S0QC Proc. & INST 08-31-77 (ii) p.85 SPI-IN-003 GE/NSS Spare Part Receipt Inspect.

(Including 7 MPL items listed on p.85)

(iii) p.85 SPI-IN-039 BOP Spare Pts Receiving Inspect.

(Including 4 items listed on p.85)

(iv) p.88 1A21.200 Re,ortable Items; SYS-200 (Including ,

5 categorier c-ted on p.88)

(v) p.183-4 1A95 Pers .nel (Including all lA95.220 startup rec. qual. & cert. plus all updates for new personnel)

(vi)p.185-199 1Bil. Reactor Assembly System (Included are RPV, Internals, Nozzles, CRD Housings)

(vii) p.200 1B21.010 System Wide Des. Info. (Includes PSI Weld List)

(viii) p.206-219 1B21'.220 Shop-Fabricated Pipe

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(Include all radiographs of 4 in. pipe.

12 in, pipe, and 24 in. pipe only) -

. (ix) p.231 lE21.320 Non-mechanical valves

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B21-F013L Main Steam Line B S/R valve (x) p.251-53 1Ct.1 Standby Liquid Contro1 System

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(Include all documents)

(xi) p.255 1C61 Reactor Remote Shutdown System (all documents)

I (xii) p.257 1C91 Plant. Computer System (all' documents)

(xiii) p.334 1E21.010 System Wide Infonnation/ Core

Spray System (xiv)' p.340 1E21.220 Shop Fabricated Pipe / Core spray I

(Include 'll a items pertaining to WR2-2-04, and WR2-2-05, and NR21-2-01)

(xv) p.345 1E21.250 Field Welds / Core Spray IC057-FW-04 SPL-WR2-2-2 to WR-2-2-4 (xvi) p.346 1E21.250 1C065-FW-01 SPL-WR2-2-5 to VLV-MOV035A (xvii) p.459-464 IM43.010^~ System Wide Design Info./ Fire Protection (All documents) i' (xviii) p.568 IN32 Turbine Control System (All documents)

(xvix)p.614-15 1P33 Sample System (All documents)

(xx) p.616 1P41-110 Pumps / Service Water System (All documents in this section) ,-

(xxi) p.739 1R36 AC Uninterruptable-Vital-Power Supply (All documents)

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.(xxii) p.797 IT23.010 Systemwide Design Info./ Reactor Primary Containment Liner System (All documents)

(xxiii) p.797 1T23.310 Manual valves / Suppression Chamber L

(All documents)

(xxiv) p.834 1T48-150 Primary Containment Atmosphere -

Hydrogen Centrol ,

(All documents)

(xxr) p.909 lY30.010 Systemwide Design Info./Concr. Batch (All documents) E (xxei ) - p.911 lY30.200 Concrete Test Reports (All documents)

c. Provide all copies, including, but not limited to the most recent versions, of the following documents not listed in-the index:

(1) LILCO QA/QC Audits (of the systems-identified in (b))'

(ii) S & W QA/QC Audits (of systems identified in (b))

(iii) Independent QA/QC Audits (of systems identified in (b) );

Also audits of subcontractors with QA' responsibility (iv) Qualification Records (of system / components identified =

in (b))

(v) As-built drawings (of systems / components / structures identified in (b))

(vi) Resolution of E&DCRS (of. systems / components / structures identified in (b))

(vii) Resolutions of I&E Reports / Findings (of systems /

components / structures identified in (b))

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Suffolk Co. Contention 19

2. The most recent and current revision of the following Shoreham procedures as described in FSAR Table 13.5.1-1:

(a) Administrative Procedures #2, 4, 6, and 9; (b) Operating Procedures #2(b), (c), (d) , (1) , (m) , (n) , (o) ,

(p), (q), (t), (u) , (w) , (x) , (y) , (z) , (aa) , (ae) , (ag) ,

(ah), (am), (as), (at), (au), (ba), (bg), (bi), and (bk); and (c) Operating Procedures #3(g), (k), (m), (n) , (p) , (q) , (r) , (s) ,

(t), (u).

3. All correspondence and other documents prepared by the Institute of Nuclear Power Operations (INPO), concerning nuclear power plant procedure design, development, auditing, and implementation.

4. All analyses, test results, and other documents concerning all operating procedures that have been subject to Control Room walk-through tests.

5. All documents concerning LILCO's proposed or actual schedule for

" periodic" procedure reviews after initial approval as required by FSAR Section 13.5.1, and all analyses, information, and other documents concern-ing all plant and/or personnel related events that would necessitate un-scheduled review of procedures, j 6. All documents concerning'the means by which operators (both in the main control room and at the remote shutdown panel), are made aware of field modifications requiring the issuance of a temporary procedure.

7. All documents, including but not limited to the preliminary assessment report prepared by the General Physics Corporation, concerning the Shoreham Control Room audit performed by the General Physics Corporation; in addition, provide a copy of the letter SNRC-536.

8. A copy of the draft BWR Owner's Group Emergency Procedures Guidelines as submitted to the NRC on June 30, 1980, all subsequent revisions of these guidelines, all correspondence between or among LILCO, the NRC, the BWR Owner's Group or other parties, and all other documents concerning such procedures or their implementation at Shoreham, i

9. All documents describing or concerning the'use of any'INPO Task Analysis techniques in the evaluation of operator and shif t supervisor activi-ties during various plant events at Shoreham.

10. Copies of the following correspondence from LILCO to the NRC in which LILCO responded to the requirem,ents of TMI Action Plan, item I.C:

j (a) Item I.C.3 - May 15, 1981 submittal; (b) Items I.C.2, I.C.4, I.C.5, and I.C.6 - July 31 and' August 7, 1981 submittals.

11. All analyses, test results, and other documents concerning the ,

system that has been proposed and/or established at Shoreham to evaluate the effectiveness of the shift and relief turnover procedures, as required by TMI Action Item I.C.2.

12. A copy of the following checklists, and~all documents concerning their use:

(a) The checklist for the oncoming and offgoia; control room operators and the oncoming shift supervisor to complete and sign; (b) The checklist or log for the oncoming and offgoing auxiliary operators and technicians to complete and sign.

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13. A copy of LILCO's response to the July 31, 19S0 NRC letter on the subject: " Interim Criteria of Shift Staffing,"and all analyses, pro-cedures and other documents concerning that subject.

14. All analyses, procedures and other documents concerning overtime

. work for senior reactor operators, reactor operators, shift technical advisors, and technicians.

15. A copy of.LILCO's response to the NRC Generic Letter 81-04 of 2/25/81 concerning emergency proc'? Tes and training for station blackout events, and all procedores and ocher documents concerning that subject.

16. All test results, analyses, and other documents concerning the impact of Shoreham's radiation protection garments and breathing apparatus on an operator's ability to function at the control panel.

17. All documents which describe or concern the means by whici. LILCO has indexed and/or cross-referenced the Shoreham operating procedures, in-cluding but not limited to, a copy of any such index or cross-references; in addition, all documents which identify, describe or concern the diagnostic guidance available to a Shoreham operator for identifying the correct pro-cedures to be followed with respect to specific plant conditions.

lib . All documents which describe, identify or concern the organization of reference materials, including procedures, in the Shoreham control room and remote shutdown room.

19. A copy of each of the following procedures:

(a) SP62.032.60, " Respiratory Equipment Cleaning and Inspection" (b) SP62.032.70, " Control of Respiratory Equipment" (c) SP69.062.01, " Emergency Response Facilities Equipment Control and Readiness Check"

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(d) SP69.064.01, ' inventory of Emergency Kits" (e) SP69.060.01, " Emergency Response Training" (f) (Unnumbered SP) " Drills and Exarcises"~

(g) SP62.032.01, " Respiratory Protection Program".

20. A copy of the procedure that addresses the once-per-shift panel walkdown to be conducted by control room operators to de,tect failed lamps on the control panels, and all analyses, test results or other documents t

concerning such walkdown.

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

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Kerbert H. Br5wn //

Lawrence Coe Lanpher -

Karla J. Letche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, NW, 8th Floor Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County March 8, 1982