ML20054G337

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Motion to Strike Portions of Gc Minor Prepared Direct Testimony Re Suffolk County Contention 28(a)(iv) & Shoreham Opponents Coalition Contention 7A(4) Re Safety Parameter Display Sys.Certificate of Svc Encl.Related Correspondence
ML20054G337
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/15/1982
From: Flanagan D
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8206210454
Download: ML20054G337 (9)
v • d • e


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HELATED

  • CORRESPONDEN(3

\ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 

 ,                     Before the Atomic Safety and Licensing Board In the Matter of                                                     )
                                                                                 )

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL) 

                                                                                 )

(Shoreham Nuclear Power Station, ) Unit 1) ) Motion of The Long Island Lighting Company to Strike Portions of the " PREPARED DIRECT TESTIMONY OF GREGORY C. MINOR REGARDING SUFFOLK COUNTY CONTENTION 28(a)(iv) AND SOC CONTENTION 7A(4 ) SAFETY PARAMETER DISPLAY SYSTEM" By this motion, the Long Island Lighting Company re-quests that portions of the " Prepared Direct Testimony of dregory C. Minor Regarding Suffolk County Contention 28a(iv) and SOC Contention 7A(4) Safety Parameter Display System" be struck as not relevant to the contention. Suffolk County Contention 28afiv) and SOC Contention 7A(4) read: The short-term design of the Safety Parameters Display Console (NUREG-0737, Items I.D. 2) proposed by LILCO does not provide a high reliability display console in that the CRT and plant computer are not safety-related equipment and cannot be re]ied upon to function during and following an accident. For this reason, Shoreham violates 10 CFR 50, Appendix A, Criterion 13. (enphasis added). The testimony of Gregory C. Minor addresses matters that go far beyond the concern of these contentions. m ( ,' . ^ F206210454 B20615 g ij j 

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LILCO believes that the fo))owing portions of Minor's testimony are outside the scope of these contentions and, therefore, should be struck.

1. Testimony at page 3.

In addition, the Shoreham plan for SPDS is defined in a LILCO document, " Permanent Emergency Response Facilities, Design Criteria and Description-SNPS-Unit 1" (unda-ted but provided with SNRC-643 in response to SOC's 4th Set of Interrogatories). This document, at page 20, defined the minimum data set to include a)) Type A, B, C,D, and E, inputs from Reg. Guide 1.97, Rev. 2 and meterological (sic) variables specified in pro-posed Rev. 1 of Reg. 1.23 and in NUREG-0654, Rev. 1, Appendix 2. Q. Does LILCO meet these requirements? A. No. LILCO has proposed an interim solu-tion which does not meet the requirements , listed in the documents mentioned. This is referred to as LILCO's interim SPDS. I LILCO contends its permanent solution will meet the requirements. s i This portion of the testimony is not concerned with the relia-bility or availability of the CRT and plant computer, but rather is concerned with the programming of the computer and which data will be reflected in the display. That question is radica))y different f rom the question of the reliability or availability of the computer.

2. Testimony at page 4.

Q. Do the NRC regulations and Functional Criteria (NUREG-0696) describe a non-seismic interim SPDS as satisfying the requirements of NUREG-0737 item I.D.2?

f , A. No. The contentions do not deal with whether the interim SPDS is or is required to be " seismic" or not. The vord "non-seismic" should be struck from the question.

3. Testimony at page 4.
l. The interim solution SPDS only supplies data to the control room, not to the EOF and TSC.
2. The interim solution uses a limited data set and does not include a)) Reg. Guide 1.97, Rev. 2 inputs.
3. The interim solution uses non-seismic devices, whereas, NUREG-0696 requirements call for the SPDS to be functional during and following an earthquake.

The contentions are not concerned with (i) whether the data should be presented in the EOF or TSC, (ii) the data inputs into the computer, or (iii) the seismic qualification of the SPDS.

4. Testimony at pages 4-5.

t

5. LILCO has not provided information for its interim SPDS regarding the requirements that it:
a. provide most current and accurato data available;
b. provide validation of data;
c. provide trending information;
d. be a condition in the Tech. Spec. for the plant;
e. be supplied by a Data Acquisition System where high reliability is paramount;
f. use safety-related interf aces to Class IE systems.

Again items a, b, c, and e all deal with the data that is to be supplied to, or presented by, the computer, not with 

                                      - . _ _                                                                                                      l

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I whether or not the computer will be reliable and available. Likewise, item e, technical specifications, and item f, inter-faces to Class IE systems, are not at issue in the conten-tions. 

       . 5.       Testimony on page 5.

An equally serious problem is that the limi-ted data set and lack of data supplied to support personnel located cutside the control room will limit the support the operators would otherwise have available to assist in diagnosis and/or mitigation of an accident. Whether the appropriate data are procrammed in the computer is a dif ferent question than the availability of the computer. In addition, the Contentions do not deal with where the CRT's are located.

6. Testimony at page 6.
                              . . .                its human factors review of the dis-plays, its analysis of timeliness and accu-racy of trending capabilities, its data veri-fication techniques.                      . .

This portion of the testimony should be struck. Nowhere do the contentions refer to human factors implications of the interim SPDS, the timeliness and the accuracy of trending capabilities, or its data verification techniques.

7. Testimony, Attachment 1 This attachment discusses the many NUREG-0696 require-ments and compares them to the interim SPDS.

e, * " These requirements are not discussed in the Contentions. Accordingly all portions, excepting the discussion of availabi-l ity on p. A-3, should be struck. Had Suffolk County and SOC desired to litigate all of NUREG-0696 requirements it could easily have placed them into issue. They have not done so, and the portions of this testi-mony described above go beyond the scope of the contentions. Since the scope of issues in this proceeding is defined by the contentions as admitted, that testimony which is beyond them should be struck. Respectfully submitted, LONG ISLAND LIGilTING COMPANY mrw G WFK Donald P. Irwin G Daniel O. Flanagan IlUNTON & WILLIAMS 707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED: June 15, 1982 i l l 

        ,s' I

e In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) Docket No. 50-322 (OL) I hereby certify that copies of

1. Motion of The Long Island Lighting Company
     .                         to Strike Portions of the " PREPARED DIRECT TESTIMONY OF GREGORY C. MINOR REGARDING SUFFOLK COUNTY CONTENTION 28 (a) (iv) AND SOC CONTENTION 7A(4) SAFETY PARAMETER DISPLAY SYSTEM";
2. LILCO'S PLAN FOR THE CROSS EXAMINATION OF GREGORY C. MINOR ON SUFFOLK COUNTY CONTENTION 28a (iv) AND SOC CONTENTION 7A(4) -- SAFETY PARAMETER DISPLAY SYSTEM; and
3. LILCO'S PLAN FOR THE CROSS EXAMINATION OF GREGORY C. MINOR ON SOC CONTENTION 9(c) --

NOTIFICATION THAT A SAFETY SYSTEM HAS BEEN DISABLED were served upon the following by first-class mail, postage prepaid, on June 15, 1982 or by hand on June 15, 1982 (as indicated by an asterisk), except for items 2 and 3 which were served only on the Board: Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris

  • U.S. Nuclear Regulatory
 )          Administrative Judge                                                  Commission Atomic Safety and Licensing                  Washington, D.C.                      20555 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.        20555 i

Dr. James H. Carpenter

  • Bernard M. Bordenick, Esq.*

Administrative Judge David A. Repka, Esq. Atomic Safety and Licensing U.S. Nuclear Regulatory q Board Panel Commission d 4 U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 David J. Gilmartin, Esq. Attn: Patricia A. Dempsey, Esq. 

   .                                                         Secretary of the Commission        County Attorney U.S. Nuclear Regulatory            Suffolk County Department of Law Commission                     Veterans Memorial Highway Washington, D.C. 20555         Hauppauge, New York 11787 hh iij!hi Herbert H. Brown, Esq.*

Lawrence Coe Lanpher, Esq. Howard L. Blau, Esq. 217 Newbridge Road mW Karla J. Letsche, Esq. Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Matthew J. Kelly, Esq. 8th Floor New York State Energy Office 1900 M Street, N.W. Agency Building 2 Washington, D.C. 20036 Empire State Plaza 

    "*"'?                                                                                       Albany, New York 12223 b[hi                                                    Mr. Mark H. Goldsmith Q                                                        Energy Research Group 400-1 Totten Pond Road Mr. Jay Dunkleberger New York State Energy Office Waltham, Massachusetts     02154   Agency Building 2 Empire State Plaza MHB Technical Associates           Albany, New York 12223 1723 Hamilton Avenue                                             ,

Suite K Stephen B. Latham, Esq. m San Jose, California 95125 Twomey, Latham & Shea 3 ... 33 West Second Street Ralph Shapiro, Esq. P. O. Box 398 

     "' 4                                                    Cammer and Shapiro, P.C.           Riverhead, New York 11901 9 East 40th Street New York, N.Y. 10016 1

bc b 4tcYt Daniel O. Planagang Hunton & Williams 707 East Main Street y} g;ge j P. O. Box 1535 Richmond, Virginia 23212 DATED: June 15, 1982 i 

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In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) Docket No. 50-322 (OL) I hereby certify that copies of

1. Motion of The Long Island Lighting Company
 .                        to Strike Portions of the " PREPARED DIRECT TESTIMONY OF GREGORY C. MINOR REGARDING SUFFOLK COUNTY CONTENTION 28 (a) (iv) AND SOC CONTENTION 7A(4) SAFETY PARAMETER DISPLAY SYSTEM";
2. LILCO'S PLAN FOR THE CROSS EXAMINATION OF GREGORY C. MINOR ON SUFFOLK COUNTY CONTENTION 28a(iv) AND SOC CONTENTION 7A(4) -- SAFETY PARAMETER DISPLAY SYSTEM; and
3. LILCO'S PLAN FOR THE CROSS EXAMINATION OF GREGORY C. MINOR ON SOC CONTENTION 9(c) --

NOTIFICATION THAT A SAFETY SYSTEM HAS BEEN DISABLED were served upon the following by first-class mail, postage prepaid, on June 15, 1982 or by hand on June 15, 1982 (as indicated by an asterisk), except for items 2 and 3 which were , served only on the Board: Lawrence Brenner, Esq.* Atomic Safety and Licensing ( Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory ( Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 l Commission l Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris

  • U.S. Nuclear Regulatory

( Administrative Judge Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory % Commission l Washington, D.C. 20555 I 

    ~

GM;iCf U o Dr. James H. Carpenter

  • Bernard M. Bordenick, Esq.*

Administrative Judge David A. Repka, Esq. Atomic Safety and Licensing U.S. Nuclear Regulatory e Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 g[l$[d Commission Washington, D.C. 20555 David J. Gilmartin, Esq. Attn: Patricia A. Dempsey, Esq. 

 .           Secretary of the Commission      County Attorney U.S. Nuclear Regulatory          Suffolk County Department of Law Commission                     Veterans Memorial Highway Washington, D.C. 20555         Hauppauge, New York 11787 NM9         Herbert H. Brown, Esq.*          Howard L. Blau, Esq.
 ;Ii$2i      Lawrence Coe Lanpher, Esq.       217 Newbridge Road ISh         Karla J. Letsche, Esq.           Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips         Matthew J. Kelly, Esq.

8th Floor New York State Energy Office 1900 M Screet, N.W. Agency Building 2 Washington, D.C. 20036 Empire State Plaza 7?p Albany, New York 12223 

  *I i       Mr. Mark H. Goldsmith Energy Research Group            Mr. Jay Dunkleberger fhm%       400-1 Totten Pond Road           New York State Energy Office Waltham, Massachusetts   02154   Agency Building 2 Empire State Plaza MHB Technical Associates         Albany, New York 12223 1723 Hamilton Avenue                                          .

Suite K Stephen B. Latham, Esq. 

  -my        San Jose, California 95125       Twomey, Latham & Shea 33 West Second Street lb f       Ralph Shapiro, Esq.              P. O. Box 398 i
  -{-gj                                       Riverhead, New York 11901 l             Cammer and Shapiro, P.C.

k 9 East 40th Street New York, N.Y. 10016 l l Co b 41c%t Daniel O. Flanagan i Hunton & Williams 707 East Main Street 77.4 P. O. Box 1535 igit Richmond, Virginia 23212 l DATED: June 15, 1982 l l l MY7 - 2-}}

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