ML20050K613

Amended Response to Requests for Production of Documents

ML20050K613
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/09/1982
From:	Reveley W HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SUFFOLK COUNTY, NY
Shared Package
ML20050K631	List: ML20050K613 ML20050K923
References
ISSUANCES-OL, NUDOCS 8204140226
Download: ML20050K613 (11)

Text

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DOCKET NUU3:R d 4/q'b PROD. & UM. Tac.. . ,,,,l,;

~,r.r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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12 N190 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD u1 e 6 /q In the Matter of )

) p n',gCM LONG ISLAND LIGHTING COMPANY ) Docket No. 50-332 i G ,)

(Shoreham Nuclear Power Station, ) ?7/ pg[63gp.

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LILCO'S AMENDED RESPONSE TO SUFFOLK COUNTY'S REQUESTS FOR S U PRODUCTION OF DOCUMENTS I.

On March 26, 1982, LILCO filed its RESPONSE TO SUFFOLK .

COUNTY'S REQUEST FOR PRODUCTION OF DOCUMENTS. In thdt response, LILCO indicated it would make certain documents available to the County beginning March 26, 1962 through April 2, 1982.1/

LILCO has providea o vast amount of material thus far in response to the County's discovery requests.U As a result of discussions between the parties during this discovery period and beyond, including discussions following the filing of the County's motion to compel on April 2, LILCO hereby amends certain of its answers filed March 26, 1/ LILCO actually made documents available on Thursday, March 25.

2/ As of April 2, 14,000 pages of material had been copied at the County's request --

a fraction of the material LILCO has provided for the County's inspection. y s

I 8204140226 820409 / f PDR ADOCK 05000322 C PDR

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1 In some instances, the County has better detined its original requests, making LILCO's March 26 answers incomplete. And in some instances, LILCO has provided aaditional information in  ;

I response to follow-up questions by the County. J Part II below lists LILCO's amendeo responses to items l 2, 7, 8, 10, 14, 15 ana 31 of the County's first request for t

l production of documents ano to items 17 and 18 of the supplement to the County's secono production request. Part 111 discusses the Stone & Webster materials discusseo in the County's motion to compel. Part IV discusses the additional documents requested in the County's motion to compel in 1

response to item 37 of the County's first request for l

production of documents.

II.

A. Amended Responses to the Request for Production of Documents

2. Request. All Shoreham Emergency Operating Proceaures (the "29" Series).

Response. These documents were forwaraed to SOC and the County on March 17, 1982.

Amended Response. Only seven of the "29" Series Emergency Operating Procedures were forwaroed on March 17, 1982. A copy or the complete "29" Series has now been provided to the County.

7. Request. The most recent ano current revision of each of the following Shoreham Procedures:

(a) SP #23.133.01, " Remote Shutdown Panel Control System."

(b) SP d29.022.01, " Shutdown From Outside the Control Room Emergency Proceoure."

(c) SP #29.010.01, " Emergency Shutdown Proceoure."

(d) SP #29.015.01, " Loss of Electrical Power Emergency Procedure."

(e) Deleted by agreement of the parties.

(f) Deleted by agreement of the parties.

(g) SP v23.119.01, " Reactor Core Isolation Cooling System."

(h) Deleted by agreement of the parties.

(i) SP v23.]?2.01, " Service Water System."

(j) SP #23.118.01, "RBCLCWS."

(k) SP #21.006.01, "Itation Operator Training and Qualification Program."

Response. Available on site: (a), (b), (c), (d), (g),

(i) (j), and (k).

Amended Response. LILCO will provide tne County with copies of revisions (if any) to these proceoures as they are issued.

8. Request. The most recent and current revision ot each of the to11owing Shoreham Alarm Response Procedures:

(a) ARP 1051, "RSDS Transfer Switch in Emergency Pos11 tion Div. 1" (b) ARP 1364, "RSLS Transfer Switch in Emergency Position Div. II."

(c) ARP 1365, "RSDS Transfer Switch in Emergency Position Div. III."

(d) ARP (LTR) RSP Access Doors Open.

Response. Available on site: (a)-(c). (d) ARP (LTR)

RSP Access Doors Open is not yet complete. LlLCO will forwara a copy of the final document at a later date.

Amended Response. LILCO will provide on site an inoex of the Shoreham Alarm Response Procedures for inspection by the County on April 13, 1982.

10. Request. All updated and current Remote Shutdown System front view panel drawing (s).

Response.- The remote Shutdown System front view panel drawings are included in the response to 4 above.

l i Amended Response. The front view panel arawing included in the response to 4 was found by the County to be incomplete. An additional drawing ot the panel as insta11eo was made and provided.

14. Request. Report by Reinhart & Associates, Inc.

, concerning 1961/1982 pre-service inspection tests of the i

l Shoreham Reactor Pressuro Vessel (RPV).

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. 7 Response. Reinhart & Associates has not completed its report. A copy will be forwarded when the report is received by LILCO.

Amended Response. A copy of the dratt Reinhart report was providea to the County.

15. Request. Report by Nuclear Energy Services, Inc.

concerning 1981/1982 pre-service inspection tests of the Shoreham RPV.

Responrie . NES, Inc. has not completea its report. A copy will be forwarded when the report is received by LILCO.

Amended Response. A copy of the dratt NES, Inc. report was provided to the County.

31. Request. All emergency operating proceaures used by LILCO to describe recommended actions with regara to post-accident monitoring instruments and systems.

Response. The post-accident monitoring system is a new addition to the Shoreham Nuclear Power Station. At the present l time, LILCO is reviewing a draft copy of the system aescrip-

! tion. LILCO will write a procedure for tne post-accident monitoring system once the system description has been issued l as a revision.

Amended Response. Our original response resultea from a misinterpretation of the question. No aratt system l

description of the post-accident monitoring system exists, and LILCO does not plan to write a procedure for that system.

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LILCO provided the County with a copy of the lesson plans that will be used to train operators on that system.

B. Amended Answers to the Supplement to Second Request for Production or Documents

17. Request. Describe the means by which LILCO has indexed and/or cross-referenced the Shoreham operating procedures, including a copy of any such inoex or cross-references; in addition, describe the diagnostic guidance available to an operator.

Response. Available on site.

Amended Response. Operators will be trained to respond to different operating situations. As a result ot that training, operators will be familiar with the correct

[

l procedures to follow in responaing to a particular situation.

t This training encompasses the " diagnostic guidance available to an operator."

l 18. Request. Describe the organization of reterence materials, including procedures, in the shoreham control room and remote shutdown room.

Response. The Shoreham control room contains a master i copy (MC-2) of all station procedures in addition to controlleo and working copies of requireo procedures and copies or other appropriate documents such as Technical Specifications, FSAR, etc. A set of the appropriate station proceaures (29.xxx.xx,

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l 22.xxx.xx, 23.xxx.xx, and 69.xxx.xx) are storea in the Remote Shu tdowra Panel room for reference by the operator. These include emergency proceaures, raciation protection procedures, shutdown procedures and system operating procedures for systems controlled at the RSP and/or required for safe shutdown of the plant.

Amended Response. Current plans call for the volumes holding the master copy or proceaures to be stored in the control room in bookshelves located on the outsiae wall ot the watch engineer's office.

III.

As the Board knows, certain of the documents requestea by the County are Stone & hebster (SWEC) manuals and specifications that SWEC considers to contain confidential commerical information. The Board having entered the Order submitted by the parties on April 6 to resolve the conflict that arose concerning those materials, the manuals and specifications have been mace available to the County for inspection.

In its March 26 response to the County's procuction requests, LILCO inaicated that these documents were available on site between March 26, 1962 and April 2, 1982. That answer was given due to LILCO's well founcea, gooo faith bellet, arter discussions with SWEC and the County, that a nondisclosure

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agreement could be promptly negotiated between sWEC ano the County.S! Although several draft agreements were exchanged, SWEC and the County were unable to agree upon certain terms.

Thus, the SWEC manuals were not inspected by the County between March 26 and April 2.

IV.

In its motion to compel, Suftolk County requested the Board to compel LILCO to produce documents related to these programs:

E&DCR Verification Program LILCO/SWEC As-Built Piping Program Final Stress Analysis Review Electrical Raceway Qualitication Final "A" Release Program Fuel Loaa Drawing Update.

Suffolk County contended that these programs are "Gluality]

A[ssurance] design control and design verirication auait programs" (Suffolk County's motion to compel ac 2) and therefore the documents relating to these programs are responsive to request number 37 in the County's first request for production.

3/ To the extent that the County's April 2 motion to compel suggests otherwise, it is wrong.

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. T LILCO continues to believe that the documents relating to these programs are not audits and are therefore outside the scope of County request number 37. However, to avoid further delay in bringing discovery to a close, LILCO has agreed to amend its response to item 37 to included additional information, as follows:

37. Additional Request. For each of the following programs, provide (i) a description of the scope of the program, (ii) the date it was initiated, (iii) the cate it will be completed, and (iv) copies or any reports on the progress of the review:

(a) E&DCR Verification Program (b) LILCO/SWEC As-Built Piping Program (c) Final Stress Analysis Review (d) Electrical Raceway Qualification (e) Final"A" Release Program (f) Fuel Load Drawing Update (g) FSAR Configuration Check.

Response.

I (a)(i) Procedures describing the program will be provided.

(ii) July, 1976

! (iii) After commercial operation.

(iv) LILCO's monthly reports beginning March 1962 l' and the program logs will be provioed.

(b)(i) Procedures describing the program will be provided.

(ii) September, 1981 L b

. .. ^T (iii) July, 1982 (iv) LILCO's reports will be providea.

(c)(1) Procedures describing the program will be provided.

(ii) December, 1981 (iii) August, 1982 (iv) LILCO's reports will be provided.

(d)(1) Procedures describing the program will be proviaed.

(ii) October, 1981 (iii) August, 1982 (iv) LILCO's reports will be provideo.

(e)(1) Procedures describing the program will be provided.

(ii) February, 1982 (iii) September, 1982 (iv) No LILCO reports exist.

(f)(1) Procedures describing the program will be proviceo.

(ii) March, 1981 l (iii) September, 1982 (iv) No LILCO reports exist.

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! (g)(i) Procedures describing the program will be providea.

I (ii) December, 1961 (iii) September, 1982 (iv) LILCO's reports trill be provided.

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.... ~3 LILCO has agreed to ship to the County (at its expense) copies of the documents listed in this response.A/

Respectfully submitteo,

. 7 l k'/ *t,-~ ; ' / ' ' j , *,i,! /

W. Taylor Reveley, Ill/

Anthony F. Earley, Jr/

Daniel O. Flanagan HUNTON & WILLIAMS 707 East Main Street P.O. Box 1535 Richmond, VA 23212 DATED:

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4/ 'Ihe County refused to first examine these materials on site to determine whether it required copies of all the documents.

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