ML20055B520
| ML20055B520 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/20/1982 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8207220450 | |
| Download: ML20055B520 (5) | |
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00CXETED UNITED STATES OF AMERICA USt;RC NUCLEAR REGULATORY COMMISSION
$? 11 21 m.ia Before the Atomic Safety and Licensing Board -
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In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 0.L.
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO TESTIMONY ON WATER HAMMER PROCEDURES AND TRAINING l
In response to statements by the Board on June 1, 1982 (Tr. pages 2681-83), LILCO submitted on July 9, 1982 additional direct testimony relating to Suffolk County Contention 4 --
The Board's statements indicated that any such additional testimony was to address the issues of procedures, training, in-service testing, and surveillance relating "specifically" to water hammer.
(Tr. 2682).
Although some portions of the July 9 testimony do relate to water hammer pro-cedures and training, large portions of that testimony have nothing to do with water hammer.
Thus, the following portions of the July 9 testimony should be stricken because they go beyond the scope of the additional testimony permitted by the Board:
8207220450 820720 PDR ADOCK 05000322 O
,D5 6
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(a)
The answer to Question 6 (pages 3-4), except the first sentence; and (b)
Questions and Answers 7 through 12 (pages 4-7).
These portions of the LILCO testimony should be stricken because they do not deal with the issue of how water hammer is addressed in SNPS procedures and training,-and therefore the testimony is irrelevant to SC Contention 4 and goes beyond the limited scope permitted by the Board on June 1.
- Indeed, this portion of LILCO's additional SC 4 testimony has nothing to do with water hammer.
Rather, it contains a description, in the most general terms, of how Shoreham pre-operational test procedures and plant procedures are prepared and reviewed.
It does not include any information that is in any way probative of how -- or if -- such procedures take into account the possible 4
occurrence, or prevention or mitigation of water hammer events.
Indeed, Questions and Answers 4 and 5, as well as Question 6 of the LILCO additional testimony, indicate that Shoreham does not have procedures specifically for the prevention or minimization of water hammer, nor do the shoreham operating procedures indicate i
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i l
that specific steps are included for the purpose of minimizing or precluding water hammer.
Question and Answer 3 attempts to explain how the Shoreham procedures purport to address water l
hammer concerns.
It is evident that the information contained l
in Answer 6 and Questions and Answers 7 through 12, add nothing to that explanation that is pertinent to water hammer.
i Therefore, those portions of the LILCO testimony are irrelevant to the limited issues which this additional testimony I
was designed to address, Suffolk CountyJsubmits that those portions of the LILCO testimony should thus be stricken.
Respectfully submitted, DAVID J. GILMARTIN PATRICIA A. DEMPSEY Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 1
Herbert H. Brown
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Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M~ Street,~N.W~
Washington, D.C.
20036 (202) 452-7000 Attorneys for Suffolk County July 20, 1982 S
' ~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
I
)
Docket No. 50-322 (OL)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the "SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO TESTIMONY ON WATER HAMMER PROCEDURES AND TRAINING" were served to the following by U.S. Mail, first class, except as otherwise noted, on the 20th day of July,1982.
Lawrence Brenner, Esq. (*)
Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S.
Nuclear Regulatory Commission New York, New York 10016 Washington, D.C.
20555 Howard L.
Blau, Esq.
Dr. James L.
Carpenter
(*)
217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission _
W.
Taylor _Reveley III, Esq. (*)
i Washington, D.C.
20555 Hunton & Williams P.O. Box 1535 Dr. Peter A. Morris (*)
Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C.
20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq.
Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Stephen B.
Latham, Esq. (*)
Mineola, New York 11501 Twomey, Latham & Shea Attorneys at Law Mr. Brian McCaffrey P.O.
Box 398 Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 Hicksville, New York 11801
n.
d Marc W.
Goldsmith Mr. Jeff Smith Energy Research Group, Inc.
Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O.
Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.
~
New York Public Service Commission MHB Technical Associates The Governor Nelson A.
Rockefeller 1723 Hamilton Avenue Building Suite K Empire State Plaza San Jose, California 95125 Albany, New York 12223 Hon. Peter Cohalan David H. Gilmartin, Esq.
Suffolk County Executive Suffolk County Attorney County Executive / Legislative County Executive / Legislative Bldg.
Building Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Atomic Safety and Licensing Ezra I.
Bialik, Esq.
Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Bureau Washington, D.C.
20555 New York State Department of Law Docketing and Service Section 2 World Trade Center
. Office of the Secretary New York, New York 10047 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Bernard M. Bordenick, Esq.
(*)
U.S. Nuclear Regulatory David A.
Repka, Esq.
Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart Diamond
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Matthew J.
Kelly, Esq.
EnvifonmeMt/ Energy Writer Staff Counsel, New York State NEWSDAY Public Service Commission Long Island, New York 11747 3 Rockefeller Plaza Albany, New York 12223 Cherif Sedky, Esq.
Kirkpatrick, Lockhart, Johnson & Hutchison 1500 Oliver Building Pittsburgh, Penn. 15222 Ot*wn.tr Lawrence Coe Lanphs'r KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036 July 20, 1982