ML20069H525
| ML20069H525 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/30/1983 |
| From: | Earley A LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20069H515 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8304060209 | |
| Download: ML20069H525 (9) | |
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LILCO, March 30755983
.g3 [P -1 Pl :17 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (OL)
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(Shoreham Nuclear Power Station, )
Unit 1)
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MOTION TO INCLUDE AN ADDITIONAL EXHIBIT IN THE QA/QC RECORD During cross-examination of the NRC Staff QA/QC witness panel, questions were asked concerning the LILCO QA audits reviewed by the witnesses in preparation for cross-examination.
During the hearings, LILCO suggested and the Board concurred that the parties should agree on a list and move it into evi-dence by stipulation.
Counsel for LILCO prepared such a list and submitted it to counsel for Guffolk County and the NRC Staff on December 23, 1982 (Enclosure 1).
On January 3, 1983, the Staff replied, indicating the list was correct.
No reply was received from the County.
At hearings during the week of February 24, counsel for LILCO asked counsel for the County about the list and was informed that it had not yet been reviewed.
By letter dated March 7, 1983 (Enclosure 2), LILCO renewed its request that the 8304060209 83'0330 PDR ADOCK 05000322 g
. County indicate its agreement or disagreement with the list.
No reply was received.
During the week of March 21, counsel for LILCO again talked to County's counsel about the list and was informed that the County did not intend to review the list until after April 7.
Although LILCO did not need the list as part of its Proposed Findings of Fact on SC/ SOC 7B, the possibility exists that it may prove useful in the upcoming filings by the County, NRC Staff and LILCO.
Therefore, based on Mr. Bordenick's rep-resentations in his letter of January 3, 1983, LILCO moves to have the " List of LILCO/S&W Audits Reviewed by NRC Staff Witnesses in Preparation Cor Oral Testimony" admitted into evi-dence in this proceeding.
Respectfully Submitted, LONG ISLAND LIGHTING COMPANY
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Anth8ny F.
arle Hunton & Williams P.O. Box 1535 Richmond, Virginia 23212 DATE:
March 30, 1983
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ENCLOSURE 1 e
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...6 Lawrence Coe Lanpher, Esq.;
Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.
8th Floor Washington, D.C.
20036 Bernard M. Bordenick, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Larry and Bernie:
During our cross-examination of the Staff QA panel, we asked the witnesses about which LILCO QA audits and quarterly reports they had reviewed in pre-paration for their oral testimony (Tr.17,323).
They said they had reviewed the material listed in Larry's Earlier in the December 2 letter and December 10 memo.
cross-examination, 1 believe they also said they had looked at the Quarterly Reports in SC Eftibit 63.
The enclosed list is a summary of the LILCO audits andThis Quarterly Reports contained"in those documents.
is the same list that we gave you on Wednesday, December 22.
I would appreciate it if Bernie could have the witnesses review the list to verify its accuracy.
Assuming it is correct, we will move the list into evidence, as we had previously indicated (Tr.17,323).
Please let me know if you have any problems with this proposal so we can work them out.
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s Howrow & WILLIAxe Lawrence Coe Lanpher, Esq.
Bernard M. Bordenick, Esq.
December 23, 1982 Page Two Best wishes for the holidays.
Sincerely, b
Anthony F. Earley, Jr.
221/765 Enclosure G
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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January 3, 1983 Anthony F. Earley, Jr., Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richnond, Virginia 23212 In the Ma'tter of Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (0L)
Dear Mr. Earley:
This is to advise that the " List of LILCO/SAW Audits Reviewed by NRC Staff Witnesses in Preparation for Oral Testimony", which was attached to your letter addressed to me and Larry I.anpher dated December 23, 1982, is accurate.
Sincerely.
M Bernard M. Bordenick Counsel for NRC Staff cc: Lawrence Brenner, Esq.
Dr. James L. Carpenter Dr. Peter A. Morris Matthew J. Kelly, Esq.
l Ralph Shapiro, Esq.
Howard L. Blau, Esq.
j W. Taylor Reveley III, Esq.
Cherif Sedkey, Esq.
Stephen B. Latham, Esq.
John F. Shea, III, Esq.
Herbert H. Brown, Esq.
Daniel f. Brown, Esq.
Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board Panel Karla Letsche, Esq.
Lawrence Coe Lanpher, Esq.
Edward M. Barrett Esq.
Mr. Brian McCaffrey Marc W. Goldsmith David H. Gilmartin, Esq.
Mr. Jeff Smith MHB Technical Associates Hon. Peter Cohalan Mr. Jay Dunkleberger Docketing and Service Section
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ENCLUSU16, 3 HUNT ON Sc WILLIAM S 707 EAST MAIN STRECT P. o. Box 1535 Rzcantoarn,VrmozwxA 23212
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Lawrence Coe Lanpher,.Esq.
Kirkpatrick, Lockhart, Hill, Christopher & Phillips ~
1900 M Street, N.W.
8th Floor Washington, D.C.
20036
Dear Larry:
During the last week of hearings on Long Island, we discussed the list I sent you in December concerning the LILCO audits reviewed by the NRC Staff QA witnesses.
You had not reviewed the list.
For your convenience, I've enclosed a copy of my December 23 letter.
Bernie Bordenick has informed ne that the listing attached to the letter is accurate.
I would appreciate it if you would review the list and let me know if.you concur so it can be submitted to the Board as promised (Tr. 17,323).
Sincerely, 4
Anthony F. Earley, Jr.
221/765 Enclosure
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ENCLOSURE i LIST OF LILCO/S&W AUDITS REVIEWED BY NRC STAFF WITNESSES IN PREPARATION FOR ORAL TESTIMONY Audits listed in- December 2,1982, letter from L. Lanpher to B. Bordenick:
FQC 21, B.9, D.
14 F.A.
803, 4.1 F.A.
340, 4.1 FQC 34, N.2 F.A. 376, 4.3 F.A. 1275, 4.2 F.A.
679, 4.2 F.A.
1086, 4.1, 4.2 F.A. 699, 4.1 F.A. 1180, 4.1, 4.3 F.A. 721, 4.3 F.A. 1301, 4.1 FQC 21, D.18 F.A. 1313, 4.1, 4.2 FQC 23, D.5(2)
. Quarterly Report 5/30/80 F.A. 443, 4.1 Quarterly Report 7/22/80 F.A.
679, 4.3 Quarterly Report 11/13/80 F.A. 740, 4.2 Quarterly Report 2/17/81 Quarterly Report 8/31/81 Quarterly Report 12/3/81 Audits listed in December 10, 1982, handwrittea memo from L. Lanpher to B. Bordenick:
EA 19, 2.B.2 EA 22, 021(2) y EA 23, 037 EA 27, 078 FQC 14, A.1 FQC 14, B.2, D.2, D.3, D.4 EA 18, p.2 44 EA 30, 104(4)
EA 38, 141(1)-(2)
Quarterly Reports listed in SC Exhibi't 63:
May 4, 1978 August 31, 1978 November 3, 1978 January 29, 1979 April 16, 1979 August 20, 1979 May 30, 1980 July 22, 1980 November 13, 1980 February 17, 1981 August 31, 1981 December 3, 1981 e
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LILCO, March 30, 1983 CERTIFICATE _O_F SERVICE In the Matter of
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LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of Motion to Include an
.\\dditional Exhibit in the QA/QC Record and Additional Transcript Corrections were served this date upon the following by first-class mail, postage prepaid.
Lawrence Brenner, Esq.
Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A.
Morris Commission l
Administrative Judge Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing j
Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Commission Was.hington, D.C.
20555 Dr. James H. Carpenter Administrative Judge Daniel F. Brown, Esq.
Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing j
U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 i.
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. Bernard M. Bordenick, Esq.
David J. Gilmartin, Esq.
David A.
Repka, Esq.
Attn:
Patricia A. Dempsey, Esq.
U.S.
Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C.
20555 Veterans Memorial Highway Hauppauge, New York 11787 Berbert H.
Brown, Esq.
Stephen B.
Latham, Esq.
Lawrence Coe Lanpher, Esq.
Twomey, Latham & Shea Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick, Lockhart, Hill, P. O. Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor 1900 M Street, N.W.
Ralph Shapiro, Esq.
Washington, D.C.
20036 Cammer and Shapiro, P.C.
9 East 40th Street Mr. Marc W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, Esq.
Waltham, Massachusetts 02154 3045 Porter Street Washington, D.C.
20008 MHB Technical Associates 1723 Hamilton Avenue Howard L. Blau Suite K 217 Newbridge Road San Jose, California 95125 Hicksville, New York 11801 Mr. Jay Dunkleberger Matthew J. Kelly, Esq.
New York State Energy Office State of New York Agency Building 2 Department of Public Service Empire State Plaza Three Empire State Plaza Albany, New York 12223 Albany, New York 12223 wd[
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Anthony F p arley, Jr. g"
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j Bunton & Williams 707 East Main Street P.O.
Box 1535 Richmond, Virginia 23212 DATED:
March 30, 1983
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