ML20054L236

Response to ASLB 820624 Request for Info Re Science Applications Inc Contract Work W/Nrc & as Util Probabilistic Risk Assessment Consultant.No Inconsistencies Exist. Certificate of Svc Encl

ML20054L236
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/01/1982
From:	Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
ISSUANCES-OL, NUDOCS 8207070295
Download: ML20054L236 (7)

Text

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. LILCO, July 1, 1982

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mdv UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

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

)

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

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(Shoreham Nuclear Power Station,)

Unit 1) )

LILCO'S RESPONSE TO THE BOARD'S REQUEST FOR INFORMATION CONCERNING SCIENCE APPLICATIONS, INC.

On June 24, 1982, the Board requested that the parties, the NRC Staff and LILCO in particular, provide information re-garding work that Science Applications, Inc. (SAI) is doing under contract for the NRC Staff. SAI is LILCO's PRA consul-tant and an SAI employee, Dr. Edward T. Burns, is a witness in this proceeding. The following information is provided in re-sponse to the Board's request.

SAI, like many consultants in the nuclear industry, has performed work for the NRC Staff in a wide range of areas. A listing of SAI's NRC contracts over the past few years is attached. The list does not include contracts with national laboratories since there is no easy way for SAI to distinguish C207070295 820701 PDR ADOCK 05000322 G PDR J5@ _

.. I whether the funds for a contract come from the NRC or the Department of Energy. SAI has, however , provided informat, ion on the contract of interest to this Board -- SAI's work for Lawrence Livermore Laboratory on systems interaction.

This work was performed by SAI's Energy Technology &

Engineering (ET&E) Group's Accident Consequence Division.b!

SAI, under contract with Lawrence Livermore Laboratory, sur-veyed available systems interaction methodologies and assessed the current state of the art. The purpose of the study was to aid in the development of a methodology for systems interaction studies. SAI's principal involvement was through one of its employees, a member of the WASH-1400 Reactor Safety Study and a recognized expert in the field. The work for Lawrence Livermore Laboratory resulted in the publication of NUREG/CR-1859, " Systems Interaction: State-of-the-Art Review."S!

1/ The ET&E Group within SAI is diverse both in its geography and expertise. The Group's management structure reflects this diversity. The Accident Consequence Division is located in Palo Alto and is part of the Physics & Safety Operation of the ET&E Group.

The work for LILCO was performed by ET&E's Power Engineering Services Division located until very recently in San Jose. The Power Engineering Services Division is part of the Engineering Analyses Operation of the ET&E Group.

These divisions report to separate Operations Managers.

The work performed for Lawrence Livermore Laboratory was done without knowledge of the performance requirements for LILCO and vice versa. There was no exchange of technical information between the organizations on their respective studies.

2/ Three other national laboratories also published reports on systems interaction for the NRC. The reports represent (Footnote Continued)

, I As an outgrowth of this systems interaction work for Lawrence Livermore Laboratory SAI prepared for and participated in one review meeting of the Indian Point Systems Interaction Study (being conducted by PASNY and EBASCO). SAI's role was as an expert reviewer to provide comments on the study to the NRC through Lawrence Livermore Laboratory.

The contract between Lawrence Livericore Laboratory and SAI has been inactive since December 1981 because of lack of funding. No future SAI participation in the Indian Point Systems Interaction Study is anticipated.

SAI has summarized its position on the present matter as follows:

SAI is a company of approximately 3500 employees distributed in 50 offices throughout the country.

SAI clients include private industry, the Defense Department, the NRC and National Laboratories.

SAI has provided consulting services to the NRC and to utilities SAI does employ as members of its staff experts in the field or probabilistic risk assessment; because of the limited number of such experts available, these people may consult at different times with both NRC and private industry On the subject of systems interaction, the NRC has performed at least four studies in an attempt to

( define a methodology i

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SAI participated as a contributor to one of these studies

( (Footnote Continued) diverse viewpoints from which the NRC presumably will mold its j systems interaction policy.

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SAI has also participated as a reviewer and adviser to the NRC on the PASNY/Ebasco systems interaction pilot program at Indian Point SAI is no longer an active consultant to Lawrence Livermore Laboratory on systems interaction No member of the SAI staff participated in both the Lawrence Livermore Laboratory sponsored review of Indian Point and the Shoreham PRA As to LILCO's involvement with SAI, contact was first made with the Power Engineering Services Division in late 1979 or early 1980. SAI provided LILCO with information on PRA's in general and SAI's capabilities in particular throughout 1980.

During this period LILCO also discussed PRAs with other poten-tial contractors. Formal competitive bids for the Shoreham PRA were submitted to LILCO in February 1981, and SAI was awarded the contract for phases I and II of the PRA in April 1981.1!

Counsel for LILCO has been aware of SAI's role in the Shoreham PRA as well as SAI's participation in the Limerick PRA. Counsel was also aware that SAI is a widely known expert in the PRA field and has done PRA work for other atilities.

Counsel did not know of SAI's involvement in the Indian Point Systems Interaction Study.

LILCO sees no conflict of interest in SAI's performance of work for utilities, LILCO in particular, on the one hand, 3/ For the Board's information, LILCO's other PRA expert wit-ness, Dr. Vojin Joksimovich, is employed by the NUS Corporation. NUS has also done work for the NRC Staff. In the PRA area, that work has consisted of conducting seminars on PRA methodology for NRC Staff personnel.

, 9 and the NRC Staff on the other. In the systems interaction area, SAI's work for the Lawrence Livermore Laboratory (under contract with the NRC Staff) was an assessment of the state of the art in systems interaction methodology done by a recognized expert in the field. It is appropriate for the NRC Staff or its contractor to seek the expert views of one of the handful 4

of pre-eminent organizations in the field. SAI's Indian Point work appears to have been merely an extension of this state of the art review.

In sum, the only bearing of SAI's prior systems inter-action work on this proceeding concerns not conflict of inter-est but whether Dr. Burns' testimony is consistent with the pertinent views of other SAI experts. Although LILCO does not believe any inconsistencies exist, the parties and the Board can certainly explore the area if they so desire.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

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W. Taylor yveley'<-III, IIU '

Donald P. Rwin V Anthony F. Earley, Jr.

Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: July 1, 1982 l

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LILCO, July 1, 1982 9

CERTIFICATE OF SERVICE 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 LILCO'S RESPONSE TO THE BOARD'S REQUEST FOR INFORMATION CONCERNING SCIENCE APPLICATIONS, INC., were served upon the following by first-class mail, postage prepaid, or by hand (as indicated by an asterisk), on July 1, 1982.

Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Boa 3 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 Bernard M. Bordenick, Esq.*

Commission Dav id A. Repka, Esq.

Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter

• Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.

Board Panel Attn: Patricia A. Dempsey, Esq.

l U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 l

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Secretary of the Commission Stephen B. Latham, Esq.

U.S. Nuclear Regulatory Twomey, Latham & Shea Commission 33 West Second Street Washington, D.C. 20555 P. O. Box 398 Riverhead, New York 11901 Herbert H. Brown, Esq.* Ralph Shapiro, Esq.

Lawrence Coe Lanpher, Esq. Cammer and Shapiro, P.C.

Karla J. Letsche, Esq. 9 East 40th Street Kirkpatrick, Lockhart, Hill, New York, New York 11901 Christopher & Phillips Albany, New York 12223 8th Floor 1900 M Street, N.W. Howard L. Blau, Esq.

Washington, D.C. 20036 217 Newbridge Road Hicksville, New York 11801 Mr. Mark W. Goldsmith Energy Research Group Matthew J. Kelly, Esq.

400-1 Totten Pond Road State of New York Waltham, Massachusetts 02154 Department of Public Service Three Empire State Plaza MHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue Suite K Mr. Jay Dunkleberger San Jose, California 95125 New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 Respectfully submitted, LONG ISLAND LIGHTING COMPANY

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68t W. Taylor (R'eveley, III[/ /

i Donald P. Irwin Anthony F. Earley, Jr.

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: July 1, 1982 i

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