ML20070H763

Responses to ASLB 821130 Requests for Info Re IE Insp Repts. Certificate of Svc Encl

ML20070H763
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/21/1982
From:	Twana Ellis HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
ISSUANCES-OL, NUDOCS 8212270196
Download: ML20070H763 (5)

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LILCO, D:ccmbar 21,'1982 l

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1 UNITED STATES OF AMERjIC@ 23 NUCLEAR REGULATORY COMMSSSION Before the Atomic Safety and Licensing Board In the Matter of )

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

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(Snoreham Nuclear Power Station, )

Unit 1) )

Responses to the Board's Request for Information Concerning Certain I&E Reports On November 30, 1982, the Board made several requests for information concerning matters contained in recent NRC I&E Reports on Shoreham. LILCO's responses are contained in the attached letter from William J. Museler to LILCO's counsel dated December 18, 1982.

Specifically, with respect to I&E Report 50-322/82-29, the Board asked for information concerning the matter included on page 6 of the report involving:

a change that was made without any E&DCR being issued, and an E&DCR was never issued until the staff inspector discovered it quite sometime later, and LILCO thereafter issued the E&DCR. It was apparently a non-safety related change; however, consistent with the testimony we have [ heard] and what the report itself states, it was LILCO's practice to issue E&DCRs in the same way for those mat-ters as for safety related. We want to get a good understanding as to what happened here and what that says about LILCO's procedures.

/T B212270196 B21221

- PDR ADOCK 05000322 lO. . . -

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If a change could go that long undetected without an E&DCR being issued, we want to know what happened in the particular item and how the process could have allowed it to occur that way and then go undetected thereafter.

So, that would be the initial change proce-dures, the audits, the verifications, the field quality control whatever should have been involved in QA.

Tr. 14,793-14 (Brenner). The information concerning this mat-ter is provided in Iteu 2 of Mr. Museler's letter.

The second Board request concerned the matters covered on pages 9-10 of I&E 50-322/82-29:

In there, the inspector questioned the lack of QA/QC reviews on the flood protection analysis, and also on the core drilling pro-cedures; that is, the procedure for drilling for penetrations through concrete, which in turn, affects rebar in the concrete. The inspector was told that at least in part,

, there was no QA/QC performed because these items were not safety related, but that char-acterization may only apply to the flood pro-tection analysis. I'm not sure right now.

But in any event, we would like to know whether the inspector's version of what LILCO's reasons were are accurate, and whether that --and if so, how LILCO people could believe that in light of all the testi-many as to the importance of looking at non-safety related matters for their impact on safety. When you read the report you will see that the very analysis being performed for flood protection at least was to assess its impact on safety-related matters.

And beyond the full explanation of the par-ticular matters involved here, what that says about the overall implementation of the pro-gram in terms of the evidence that we have heard as to how the program was proposed to be implemented, and how cognizant personnel could belie've that no QA/QC was necessary.

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l Tr. 14,794-95 (Brenner). The information concerning this mat-i ter is provided in Items 3 and 4 of Mr. Museler's letter.

Finally, with respect to I&E Report 50-322/82-26, the Board expressed interest in the matter cited as a Severity Level V violation, described on pages 8-9 of the report:

It involves the fact that drawings were not updated, contrary to E&DCRs which had been issued. And -- well, the description is in there. While the description is in there, it talks about how this preliminary report by the inspector, the revisions to the drawings were issued incorrectly, indicating that the E&DCRs had been incorporated when in fact they had not been.

The log also incorrectly indicated the drawings had been updated, and of course, through the testimony we are familiar with these procedures by now and our question is similar to the ones we asked: what happened, and what does that mean in terms of the way this program is being implemented in. the con-text of the testimony that we have heard.

Tr. 14,858-59 (Brenner). The information concerning this mat-ter is contained in Item 1 of Mr. Museler's letter.

We trust the enclosed material responds to the Board's questions concerning these I&E reports.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY d  ;'

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T. S. Ellts, III *

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Anthony F. Earley, Jr.

Hunton & Williams Poat Office Box 1535 Richmond, Virginia 23212 DATED: December 21, 1982 i

LILCO, Dectmber 21, 1982 l

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CERTIFICATE OF SERVICE , gg 23 In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL) i I hereby certify that cooies of RESPONSES TO THE BOARD'S

I REQUEST FOR INFORMATION CONCERNING CERTAIN I&E REPORTS were served upon the following by first-class mail, postage prepaid, by Federal Express (as indicated by an asterisk) , or by hand (as indicated by two asterisks) on December 21, 1982.

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

Pashington, D.C. 20555 Commission Washington, D.C. 20555 I

Dr. James H. Carpenter **

Administrative Judge Daniel P. Brown, Esq.

l Atomic Safety and Licensing Attorney l Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel j Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission i Washington, D.C. 20555 l

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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 Haupnauge, New York 11787 Herbert H. Brown, Esq.**

Lawrence Coe Lanpher, Esq. Stephen B. Latham, Esq.*

Karla J. Letsche, Esq. Twomey, Latham & Shea Kirkpatrick, Lockhart, Hill, 33 Mest Second Street Christopher & Phillips P. O. Box 398 8th Floor Riverhead, New York 11901 1900 M Street, N.M.

Mashington, D.C. 20036 Ralph Shapiro, Esq.*

Cammer and Shapiro, P.C.

Mr. Mark 13 Goldsmith 9 East 40th Street Energy Research Group New York, New York 10016 4001 Totten Pond Poad Waltham, Massachusetts 02154 Howard L. Blau, Esq.

217 Newbridge Road MHB Technical Associates Hicksville, New York 11801 1723 Hamilton Avenue Suite K Matthew J. Kelly, Esq.

San Jose, California 95125 State of New York Department of Public Service Mr. Jay Dunkleberger Three Emoire State Plaza New York State Energy Office Albany, New York 12223 Agency Building 2 Empire State Plaza Albany, New York 12223 I j' -j.-/' .l < >

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T. S. E l l i s ,i I I I Anthony F. Earley, Jr. j 'j Hunton & Milliams Post Office Box 1535 Richmond, Virginia 23212 DATED: December 21, 1982  !