ML20052C595

Rept on Confidentiality of Stone & Webster Documents & Motion for Extension of Time to Rept on Use of Stone & Webster QA Documents.Certificate of Svc Encl

ML20052C595
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/29/1982
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8205050246
Download: ML20052C595 (5)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  %"

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) c

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LONG ISLAND LIGHTING COMPANY )

Docket No. 50-32.2 PLLL9 (Shoreham Nuclear Power Station,

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REPORT ON CONFIDENTIALITY OF STONE AND WEBSTER DO N ~,\

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AND MOTION FOR EXTENSION OF TIME TO REPORT ON UpEs 'E OF STONE AND WEBSTER QUALITY ASSURANCE DOCUMENTSB A M By its Order Regarding Interim Confidentiality of QTi&Y )

Certain Stone and Webster Documents, dated April 7, 1982, the Licensing Board granted interim confidentiality to certain designated documents of the Stone and Webster Engineering -

Corporation (" Stone and Webster"). Except for document No. 6 identified in Attachment A to that Order, these documents relate to the quality assurance contentions (SC 12-15); docu-ment 6 relates primarily to SC 27.* /

The Board ordered that on or before May 4, 1982, Suffolk County should designate what portions, if any, of the Stone and Webster documents it wishes to utilize in this proceeding.- By the same date, Stone and Webster is to designate those portions of the documents listed by the County which it desires to keep confidential.

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- Suffolk County counsel understand that document 7 does not exist and that document 6, a Stone and Webster specification for its radiation monitoring system, contains all the avail- l able data. It is noted that document 6 also relates to QA i matters and to emergency preparedness concerns.

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Suffolk County desires to use all of document 6 in its SC 27 testimony or in cross-examination of LILCO and Staff testimony on that contention. The County may also use the document on SC 12-15 and on emergency preparedness matters.

With respect to the remaining documents, Suffolk County moves the Board to postpone until May 25, 1982, the filing presently scheduled for May 4, 1982. The May 4 filing date was appropriate when the quality assurance testimony (Suffolk County Contentions 12-15) was due to be filed on May 25, 1982. p However, by the Board's Prehearing Conference Order, dated April 20, 1982 and by the parties' joint submission dated April 27, 1982, it is now established that the Quality Assurance testimony will not be submitted until June 22, 1982. This revi-sion in the schedule has resulted in Suffolk County consultants directing their primary attention to other issues and conten-tions, with less direct attention being directed to the Quality Assurance contentions. Accordingly, Suffolk County needs addi-tional time to designate with finality those portions of the Stone and Webster QA documents that it desires to utilize in this proceeding.

The undersigned counsel has spoken with counsel for Stone and Webster, who agrees that the deferral described above

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is appropriate. LILCO counsel and NRC Staff counsel also have no objection to this deferral.

Respectfully submitted, DAVID J. GILMARTIN Suffolk County Attorney ,

PATRICIA A. DEMPSEY '

Assistant Suffolk County Attorney Suffolk County Department of Law l Veterans Memorial Highway Hauppauge, New York 11788 i

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' l Herbert H. Brown Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, i HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N. W. - 8th Floor Washington, D. C. 20036 (202) 452-7000 Attorneys for Suffolk County April 29, 1982 I

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD E2 h'.1Y ~3 p3 pn

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

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(Shoreham Nuclear Power Station, )

Unit 1) )

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CERTIFICATE OF SERVICE I hereby certify that copies of the " REPORT ON CONFIDENTIALITY OF STONE AND WEBSTER DOCUMENTS AND MOTION FOR EXTENSION OF TIME TO REPORT ON USE OF STONE AND WEBSTER QUALITY ASSURANCE DOCUMENTS" have been served to the following on April 29, 1982 by U.S. mail, first class, except as ,

otherwise indicated. o Lawrence Brenner, Esq. / Howard L. Blau, Esq.

Administrative Judge 217 Newbridge Road Atomic Safety and Licensing Board Hicksville, New York 11801 U. S. Nuclear Regulatory, Commission Washington, D. C. 20555 W. Taylor Reveley III, Esq.

, Hunton & Williams Dr. James L. Carpenter j 707 East Main Street Administrative Judge P. O. Box 1535 Atomic Safety and Licensing Board Richmond, Virginia 23212 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Matthew J. Kelly, Esq.

• Staff Counsel Dr. Peter A. Morris f New York State Public Service Administrative Judge / Commission Atomic Safety and Licensing Board 3 Rockefeller Plaza i

U. S. Nuclear Regulatory Commission Albany, New York 12223 Washington, D. C. 20555 Stephen B. Latham, Esq.

Edward F. Barrett, Esq. Twomey, Latham & Shea Gsneral Counsel 33 West Second Street i Long Island Lighting Company P. O. Box 398 l

. 250 Old Court Road Riverhead, New York 11901 l

! Mineola, New York 11501 Marc W. Goldsmith Mr. Brian McCaffrey Energy Research Group, Inc.

Long Island Lighting Company 400-I Totten Pond Road 175 East Old Country Road Waltham, Massachusetts 02154 Hicksville, New York 11801 Mr. Jeff Smith I Ralph Shapiro, Esq. Shoreham Nuclear Power Station Cammer and Shapiro P. O. Box 618 l 9 East 40th Street Wading River, New York 11792 Nsw York, New York 10016

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D2vid H. Gilmartin, Esq. MHB Technical Associates Suffolk County Attorney 1723 Hamilton Avenue, Suite K County Executive / Legislative Bldg. San Jose, California 95125 Vaterans Memorial Highway Ecuppauge, New' York 11788 Bernard M.. Bordenick, Esq.

David A. Repka, Esq.

Hon. Peter Cohalan U.S. Nuclear Regulatory Commission Suffolk County Executive Washington, D. C. 20555 County Executive / Legislative Bldg.

Vaterans Memorial Highway Docketing and Service Section Hauppauge, New York 11788 Office of the Secretary U.S. Nuclear Regulatory Commission Jay Dunkleberger, Esq. Washington, D. C. 20555 NLw York State Energy Office Agsncy Building 2 Atomic Safety and Licensing Board Pane Empire State Plaza U.S. Nuclear Regulatory Commission Albany, New York 12223 Washington, D. C. 20555 Ezra I. Bialik, Esq. Atomic Safety and Licensing Appeal Assistant Attorney General /Boarc Environmental Protection Bureau U.S. Nuclear Regulatory Commission Nsw York State Department of Law Washington, D. C. 20555 2 World Trade Center Nsw York, New York 10047 G0orge Edgar, Esq. / ,

Morgan, Lewis & Bockius 1800 M St., N.W.-Suite 700 North Entrance Washington, D. C. 20036

~ .s Lawrence Coe Lanpher' KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N. W.

8th Floor Washington, D. C. 20036, April 29, 1982

[ Hand-delivered

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