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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20150D4711988-07-0606 July 1988 Suffolk County Answers to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10.* W/Supporting Documentation & Certificate of Svc. Related Correspondence ML20150D5071988-07-0505 July 1988 State of Ny Response to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10 to Suffolk County,State of Ny & Town of Southampton.* W/Certificate of Svc.Related Correspondence ML20155C0791988-06-0707 June 1988 Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* Notices of Depositions & Certificate of Svc Encl.Related Correspondence ML20155C5671988-06-0303 June 1988 State of Ny Response to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl. Related Correspondence ML20151T6251988-04-22022 April 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Licensee.* W/Certificate of Svc. Related Correspondence ML20151T4391988-04-22022 April 1988 Govt Answer & Addl Objections to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Answers & Objections Listed.Notification to County Executive & Certificate of Svc Encl.Related Correspondence ML20151T5701988-04-22022 April 1988 Govt Answers to NRC Staff Interrogatories Re Contentions 1-2,4-8 & 10.* W/Certificate of Svc.Related Correspondence ML20151T8001988-04-20020 April 1988 Govts Objections to Lilco Second Set of Interrogatories Re Consumptions 1-2,4-8, & 10.* Certificate of Svc Encl.Related Correspondence ML20148S8381988-04-12012 April 1988 Suffolk County Fifth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20151F2041988-04-0909 April 1988 Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20151A0691988-04-0101 April 1988 Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20148L9181988-03-31031 March 1988 NRC Staff First Set of Interrogatories to Suffolk County,Ny State & Town of Southampton Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20150F8941988-03-30030 March 1988 Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc. Related Correspondence ML20148L9021988-03-28028 March 1988 Suffolk County Supplemental Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl. Related Correspondence ML20148K2151988-03-25025 March 1988 Lilco Responses & Objections to Suffolk County Third Set of Interrogatories & Requests for Production of Documents Re Emergency Broadcast Sys.* W/Supporting Documentation & Certificate of Svc.Related Correspondence ML20148K4421988-03-24024 March 1988 Lilco Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Suffolk County,State of Ny & Town of Southampton.* Certificate of Svc Encl.Related Correspondence ML20148K1771988-03-24024 March 1988 Lilco Second Set of Requests for Production of Documents Re Lilco Emergency Broadcast Sys to Suffolk County.* Util Makes No Admission or Representation About Proper Scope of Issues to Be Decided.W/Certificate of Svc.Related Correspondence ML20148K2201988-03-23023 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Realism.* W/Certificate of Svc.Related Correspondence ML20148K1571988-03-23023 March 1988 Suffolk County Response to Lilco First Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20148K3881988-03-23023 March 1988 Response of Suffolk County to Lilco 880311 Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl ML20150D1571988-03-18018 March 1988 Response of State of Ny to NRC Staff First Set of Interrogatories & Requests for Production of Documents Re Hosp Evcacuation Time Estimates.* Certificate of Svc Encl. Related Correspondence ML20150D0791988-03-16016 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to NRC Staff & Fema.* Certificate of Svc Encl.Related Correspondence ML20150D0121988-03-15015 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* Certificate of Svc Encl.Related Correspondence ML20150C6511988-03-15015 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Hosp Evacuation Time Estimates.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20150A8081988-03-11011 March 1988 Suffolk County Third Set of Interrogatories & Requests for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20150A9581988-03-11011 March 1988 Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* W/Certificate of Svc. Related Correspondence ML20150A9421988-03-11011 March 1988 Lilco Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Related Documentation & Certificate of Svc Encl ML20150A9521988-03-11011 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Related Correspondence ML20150C9911988-03-11011 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Objections Stated. W/Certificate of Svc.Related Correspondence ML20150A8561988-03-10010 March 1988 Suffolk County Responses & Objections to Lilco First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20150A8431988-03-10010 March 1988 Suffolk County Responses & Objections to NRC Staff First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Related Correspondence ML20150A8881988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents.* Related Correspondence ML20150A9111988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents.* Util Objects to Interrogatory 1 as Vague,Overbroad & Unduly Burdensome.W/Certificate of Svc.Related Correspondence ML20150A9341988-03-0909 March 1988 Suffolk County Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl ML20150A9641988-03-0909 March 1988 Lilco First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* W/Certificate of Svc. Related Correspondence ML20150A9671988-03-0909 March 1988 State of Ny First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* W/Certificate of Svc.Related Correspondence ML20196H3941988-03-0707 March 1988 Lilco Second Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20196H4361988-03-0707 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8421988-03-0404 March 1988 Response of State of Ny to Lilco Second Set of Requests for Admissions Re Role Conflict of School Bus Drivers.* Lilco Second Set of Requests for Admissions Deemed Untimely. Certificate of Svc Encl.Related Correspondence ML17342B4211988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8061988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20147H8571988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H7901988-03-0303 March 1988 Suffolk County Second Supplemental Response to Lilco Second Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Lilco Interrogatories 28 & 29 Addressed.Related Correspondence ML20147H7991988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8121988-03-0303 March 1988 Suffolk County Fourth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20196G1121988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* Related Correspondence ML20196G1301988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Hosp Evacuation Issue.* Definitions & Instructions for Answering Interrogatories Encl.W/Certificate of Svc.Related Correspondence ML20196G1081988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8031988-02-29029 February 1988 Lilco Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20196G1371988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence 1988-07-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
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- 82 TP2 26 Pi :17 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 5 2 (Shoreham Nuclear Power Station,
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RESPONSE OF LONG ISLAND LIGHTING COMP Y)x +'.* p,X7 sV .
TO SUFFOLK COUNTY INTERROGATORIES AND DOCU N,T REQUESTS ON SUFFOLK COUNTY CONTENTIONS 16 AND Un l
On April 1, 1982, "Suffolk County Interrogatories and 1
Document Requests on Suffolk County Contentions 16 and 20" were served on LILCO. This document contains LILCO's response to those interrogatories and document production requests.
I. CONTENTION 16 l
l Interrogatory 1: Provide copies of all Shoreham proce-dures developed for or relating to the ATWS event. Also pro-
! vide copies of all analyses or other documents which form the basis for or which relate to the procedure ( s) .
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~2-Response: Preliminary information was provided in SNRC-623 (October 1, 1981), which was sent to Suffolk County on March 17, 1982. The most recent SP #29.024.01 became effective on April 22, 1982. The SP and the procedures it references are enclosed. '
Interrogatory 2: Describe in detail the training program developed for training Shoreham operators on the correct actions to be taken in response to ATWS events.
Response: Shoreham Operations personnel are trained to take the correct action in response to ATWS events in the fol-lowing programs:
Cold License Operator Training Program Licensed Operator Requalification Training Program Hot License Operator Training Program Each Program includes the following segments related to ATWS event response training:
l 1. Classroom instruction in ATWS Systems configuration I
and operation. Systems included are: Control Rod Drive System, Reactor Protection System, and Reactor Manual Control Systam. Approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> are devoted to this segment.
- 2. Walk-through at the plant of the ATWS scenario. This segment includes " hands on" use of the Station syste-1 1
i operating procedures and ATWS emergency procedures.
l 1
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Walk-throughs are conducted using an operating crew concept in order to reinforce understanding of posi-tion responsibilities in the case of this unusual event. Approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> are devoted to this segment.
- 3. ATWS transient analysis instruction utilizing a dynamic control room simulator. This segment is conducted to allow operating crews to observe plant transient response and to practice required actions in the event of ATNS. Approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> are devoted to this segment using the Limerick Simulator Facility.
Interrogatory 3: Provide a complete description of the Recirculation Pump Trip features incorporated at the Shoreham Plant. Indicate if all modifications have been completed. If work remains to be done, indicate what work and provide the schedule for its implementation.
Response: The Shoreham Recirculation Pump Trip (RPT)
System trips the breakers in the power feed to each of the re-l circulation pump motors. The trip logic is activated upon re-ceipt of either a high reactor pressure or' low reactor water i
l level signal. All components and circuits in the RPT system are redundant and safety grade. All modifications have been completed.
l
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. Interrogatory 4: With regard to boron injection capa-bility, provide a full description of the system (s) in place at Shoreham, if not already set forth in the FSAR. Identify any changes from the. FSAR description and whether or not such changes have been made. Provide the schedule for implementa-tion of any changes yet to be done.
Response: The general system description is contained in ,
FSAR Section 4.2.3.4.
Interrogatory 5: Provide details'of any CRD system changes made or expected to be made as a result of NRC's report NUREG-0803.
Response: This information was provided in SNRC-659, (January 11, 1982), which was sent to Suffolk County on April 12, 1982.
Interrogatory 6: Has LILCO implemented or does LILCO in-tend to implement any system modifications to provide for auto-mated boron injection? If so, provide full details and the anticipated schedule if not yet completed.
Response: LILCO has not implemented any system modifica-tions to provide for automated boron injection, and at this time none are intended.
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Interrogatory 7: Has LILCO performed any analyses to de-termine the feasibility of making the standby liquid control system initiate automatically? If so, provide copies of all such analyses.
Response: No.
Interrogatory 8: Provide copies of all documents submit-ted by LILCO to the NRC Staff which relate to LILCO's method (s) for responding to an ATWS event.
Response: See SNRC-623, and also FSAR page 212-105a.
II. CONTENTION 20 Interrogatory 1: Produce all documents, including the Shoreham simulator design specification and accepted equipment supplier proposals, which evidence LILCO's commitment to pro-vide a shoreham-specific simulator for operator training.
Response 1: The documents that most strongly evidence LILCO's intent to purchase a Shoreham-specific simulator are enclosed. These documents are:
- a. A memorandum to Mr. M. S. Pollock, Vice President, Nuclear from J. J. Kearney, Jr., noting that the Board approved the purchase of a Shoreham simulator,
- b. A memorandum from James W. Dye, Jr., Senior Vice President of Operations, and Thomas H. O'Brien, Senior Vice-President of Finances, to Mr. Wilfred O.
Uhl, President of LILCO, proposing the purchase of a Shoreham simulator.
- c. Specification For Simulator Project Management Services, Training Program Development, Simulator Facility Management For Shoreham Nuclear Power Station, Unit 1.
- d. A purchase order issued to General Physics Corp.,
regarding services specified in item c, above,
- e. In draft form, " Specification For a Simulator For the Shoreham Nuclear Power Station, Unit 1."
Interrogatory 2: Produce all documents and drawings which describe or depict (a) the Dresden simulator, and/or ( b) the Limerick simulator, including the front panel arrangement of
, and controls used in the operation of the following systems:
l j (i) nuclear steam supply system (i.e., reactor i
l vessel and controls, reactor coolant system, reactor projection systems);
(ii) emergency safeguards systems; (iii) containment systems and containment isolation provisions; I
j (iv) radiation monitoring system; and l
( v) balance of plant systems.
. -7_
Response: LILCO has no current documents in its posses-sion that depict the Limerick or Dresden simulators.
Interrogatory 3: Provide a copy of the classroom training curriculum -for shoreham operators, including those portions pertaining to simulator training.
Response: Syllabuses containing this information for Dresden are enclosed. The syllabus for Limerick will be for-warded under separate cover. In addition two five-volume sets, one each for the Dresden and the shoreham training programs, will be made available for your review.
Interrogatory 4: Set forth in detail LILCO's schedule for (a) implementation of a shoreham-specific simulator for opera-tor training; (b) use of the Limerick simulator; and l
(c) discontinuance of use of the Dresden simulator.
Response: The schedule for implementation of a Shorenam specific simulator is:
- a. Revision of Bid Specifications -- May 1982
- b. Issue Bids -- June 1982
- c. Evaluate Bids -- August 1982
- d. Management approval of bids -- September 1982
- e. Board approval of bids -- October 1982
- f. Contract awarded -- October 1982 1
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- g. Simulator in service -- August 1985 The use of Dresden will be discontinued by October 1982. The Limerick simulator has been used in the past and will be used exclusively after October 1982.
Interrogatory 5: Provide a complete listing and descrip-tion of all transients and accidents which (a) the Dresden sim-ulator is capable of replicating or duplicating; and (b) the Limerick simulator is capable of replicating or duplicating.
Response: This information is included in the syllabuses that are provided in response to Interrogatory 3.
Interrogatory 6: With respect to each transient and acci-dent identified in response to subpart (a) and subpart ( b) of number 5 above, state the dynamic characteristics and operator response times for the referenced simulator, and also state the expected control response capability at Shoreham.
Response: A comparison between Limerick and Shoreham is under way and results will be forwarded upon completion.
! Operators returning from Dresden undergo a Shoreham-specific l
transient analysis training course, so no analysis between Dresden and Shoreham has been done.
l Interrogatory 7: What is the minimum number of people j LILCO intends to have trained on (a) the Dresden simulator, and I
( b) the Limerick simulator, for each of the following positions:
l l
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(i) Reactor Operator (RO)
(ii) Senior Reactor Operator (SRO)
(iii) Senior Reactor Operator Limited to Fuel Handling (SRO-R)
(iv) -Auxiliary Operator Response: At a minimum, LILCO intends to have the follow-ing trained at Dresden:
(a) Reactor Operator -- 14 (b) Senior Reactor Operator -- 16 (c) Senior Reactor Operator Limited to Fuel Handling -- 0 (d) Auxiliary Operator - 0 As a practical matter, the numbers will be much higher. For example, presently there are 38 Reactor Operators certified on the Dresden simulator, and 29 people are certified as Senior Reactor Operators. At present, ten equipment (auxiliary) oper-ators are being certified at Dresden.
The Limerick simulator will be used to requalify opera-tors.
Interrogatory 8: How many hours per week of simulator control room exercises will be provided each operator during the 12-week operator training course discussed in FSAR Section 13.2.1.1.3, and how many of such hours will an operator spend at (a) the Dresden simulator, and ( b) the Limerick simu-lator.
_lo_.
Response: Operators will receive 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of simulator training at Dresden. Hours devoted to specific simulator con-trol room exercises are detailed in the documents provided in response to Interrogatory 3. LILCO has not sent anyone to the 12 week cou'rse at Limerick.
Interrogatory 9: Identify and describe all events, tran-sients and accidents studied by Shoreham operators in the simu-lator control room exercises.
Response: See Documents provided in response to Interrogatory 3.
Interrogatory 10: Identify the criteria to be used by LILCO to determine that a particular simulator meets the re-quirements stated in FSAR Section 13.2.1.5. ("a complete and accurate nuclear power plant simulator"), i.e., identify the criteria used by LILCO to determine that a simulator duplicates or replicates the Shoreham control room. Produce all docu,ments which relate to these criteria.
Response: LILCO uses the criteria of 10 CFR Part 55, Appendix A to determine the suitability of other simulators for training purposes.
Interrogatory 11: (a) Identify the general qualifications of LILCO employees, or employees of Stone & Webster, General Electric, or other LILCO subcontractors, who will direct I
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operations from the EOF or TSC during emergency situations, ( b) for each of the following categories of personnel, describe the nature and extent of the Shoreham-specific training that they will receive:
( i) ' Headquarters Engineering (ii) Headquarters Operations Management Response: The control room personnel report directly to the operations manager who is located in the TSC center during emergency situations. The following personnel may fill the position of operations manager:
Primary - operating engineers Alternate - plant engineers-operators Both of these categories will have received Shoreham Specific Training.
l Interrogatory 12: (a) Identify the qualifications of the LILCO, G.E., Stone & Webster, other consultants and vendors' startup engineer personnel, who will assist newly-licensed Shoreham operators during the retraining period, as set forth in FSAR Section 13.2.1.6.3; and ( b) state how long such person-nel will be available.
Response: The Shoreham Startup Organization has the pri-mary responsibility to test the systems and components in ac-cordance with the regulatory requirements to allow for fueling of the Shoreham reactor. At the time of fuel load, the role of
Startup changes to one of supporting the various systems and components under the direction of the Plant Staff as the plant proceeds into the initial Startup test program and power ascen-sion to full power. During this period, several changes in the Startup Organization occur. These include the following:
A. The G.E. Operations Manager, who re-ports to the Startup Manager up until the time of fuel load, will report to the Shoreham Plant Manager. Along with the G.E. Operations Manager, the G.E. Operations Superintendent and the on Shift Startup Test Engineers will assume their shift responsibilities in providing technical direction relative to the nuclear steam supply system.
B. The remainder of the Startup Organization, including the Startup Manager, S&W Lead Advisory Engineer, and various Test Engineers will sup-port testing on systems that were not i able to have full integrated operation prior to fuel load (due to the lack of steam, inadequate temperature, etc.).
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! The description and responsibility of the various personnel i
i mentiotied in this letter are included in the Shoreham $tartup I
t
- Manual.
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Interrogatory 13: In PSAR Section 13.2.2.1.5, LILCO lists l _
j six methods to ensure operators' review of abnormal and emergency operating procedures. Is it LILCO's position that any one of the listed methods is adequate tu ensure an opera-tur 's review? If not, identify what combitiation(s) of such methods LILCO would consider adequate.
Resf otis e: Atiy of the first five methods listed in the FSAR will be used to ensure that att vperator has, in fact, I
- reviewed the procedures.
Respectfully Submitted,
- LONG ISLAND LIGHTING COMPANY l
j i b" $ ., *"
l W. Taylor Reveley, III ~
l
- Anthony P. Earley, Jr.
Dattiel 0. Flanagan
! Hunton & Williams P.O. Box 1535 Richmund, Virginia 23212 DATED: April 23, 1982 b
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