ML20052H027
| ML20052H027 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/13/1982 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20052H025 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8205190279 | |
| Download: ML20052H027 (4) | |
Text
.
s ' !*
3.
LILCO, May 13ln1982:
'8?
I'.!6' 17 F12 :15 U
UNITED STATES OF AMERICA C2 ? 3.1 '
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (OL)
)
4 (Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S PLAN FOR THE CROSS-EXAMINTION OF GREGORY C. MINOR REGARDING SC CONTENTION 28(a.)(iii) and SOC CONTENTION 7A(3)--IODINE MONITORING LILCO lists below the matters and issues it may' pursue in cross-examination pertaining to these contentions.
On May 13, LILCO filed a motion to strike this testimony as irrelevant to issues raised in the contentions.
Obviously, if the motion is successful, no cross-examination will occur.
Even if the motion is not siccessful, LILCO does not anticipate lengthy cross-examination.
The testimony involves speculation as to r
"possible sources of inaccuracies" rather than the presentation of factual information.
Thus, there is no reason for extensive cross-examination.
LILCO would very likely limit its question-ing to Mr. Minor's credentials (item (1) below) and to i
8205190279 820513 PDR ADOCK 05000322 O
l
. establishing his lack of any knowledge that inaccuracies do exist for Shoreham's iodine and particulate monitoring system (item 2(a) below).
Areas'of potential concern are:
(1) Qualifications:
(a) whether Mr. Minor has any experience in the design and operation of radiation monitoring sys-tems, particularly of the type used to monitor iodine at Shoreham; and (b) whether Mr. Minor,has ever been involved in assessing the accuracy of radiation monitoring equipment.
(2) Mr. Minor's testimony suggests (on pages 4-5), without setting forth any factual basis, that certain inaccur-acies exist in the monitoring of iodine and particu-lates at Shoreham.
For each of the alleged inaccura-cies listed in the testimony, LILCO intends to pursue three avenues of questioning:
(a) whether SC has any facts relating to the asserted inaccuracy for the iodine and particulate moni-toring equipment used at Shoreham; (b) whether there are any measures that can be taken to compensate for the asserted inaccuracy; and 4
. 9 (c) whether Mr. Minor knows if Shoreham has taken any of these compensating measures.
(3) Mr. Minor asserts that he cannot determine the extent to which the iodine and particulate monitors at 1
Shoreham comply with ANSI Standard 13.1-1969.
LILCO may explore Mr. Minor's views on what he considers the relevant portions of the standard and how they should be taken into account in designing iodine and particu-late monitoring systems.
(4) On page 5 of Mr. Minor's testimony he states that
"[e]ven if LILCO did fully comply with ANSI 13.1-1969, in the absence of a defined standard for the over-all release measurement accuracy and without a Shoreham-i specific analysis of the release measurement accuracy, there is no evidence that the Shoreham system provides adequate accuracy to meet the concerns expressed in NUREG-0737, Item II.F.1(2)."
LILCO intends to ex-plore:
(a) to what over-all release measurement accuracy Mr.
Minor is referring; (b) how Mr. Minor thinks a Shoreham-specific measure-ment accuracy would be determined; (c) whether such a determination would require the release of radioactive material into the atmosphere; and
e-a.
]
=
t 4
(d) whether Mr. Minor is familiar with how release measurement accuracy will be determined for l
Shoreham.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY y
L a ',te p YT A L' Y: :s,, v '_,.!] T W.
Taylpr Reveley, III
/
/
N Anthony F.
Earley, Jr.
/
Hunton & Williams P.
O.
Box 1535 Richmond, VN, 23212 DATED:
May 13, 1982 i
l' i
i t.
s e
e r
m e