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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18
[Table view] Category:NOTICES
MONTHYEARML20062F7601990-11-15015 November 1990 Notice of Appearance.* Notice of Withdrawal & Certificate of Svc Encl ML20062C2501990-10-18018 October 1990 Establishment of Aslb.* Board Will Preside Over Proceeding Re Actions Taken by NRC & Long Island Lighting Co Re Shoreham Nuclear Power Station Unit 1,per Commission 901017 Memo.Served on 901022.W/Certificate of Svc ML20206M8951988-11-23023 November 1988 Notice of Appearance.* Author Enters Appearance in Proceeding on Behalf of Suffolk County.Certificate of Svc Encl ML20205D6871988-10-24024 October 1988 Notice of Appearance.* Author Enters Appearance in Proceeding on Behalf of Suffolk County.W/Certificate of Svc ML20154P5281988-09-27027 September 1988 Notice of Appeal.* Notices Appeal from ASLB Initial Decision LBP-88-24.Notices of Appeal from State of Ny & Town of Southampton,Govts Motion for Bifurcation of Appeal & Expedited Treatment of Issue & Brief on Appeal Encl ML20154P8021988-09-26026 September 1988 Notice of Aslab Reconstitution.Cn Kohl,Chairman & as Rosenthal & Ha Wilber,Members.Served on 880927 ML20207E4401988-08-15015 August 1988 Notice of Oral Argument.* Notifies That Oral Argument on Joint Appeal of Suffolk County,State of Ny & Town of Southampton from Board 880509 Partial Initial Decision LBP-88-13 Will Be Heard on 880917.Served on 880816 ML20207E5551988-08-15015 August 1988 Notice of Oral Argument.* Oral Argument Will Be Heard on 880914 in Bethesda,Md Re Lilco Appeal of ASLB Initial Decision LBP-88-2.Served on 880816 ML20207E4801988-08-12012 August 1988 Reconstitution of Aslab.* TS Moore,Chairman & as Rosenthal & Ha Wilber,Members.Served on 880815 ML20196A9391988-06-20020 June 1988 Govts Notice of Appeal.* Appeal Board 880610 Order as Reconfirmed on 880617,resolving Legal Authority Contentions in Favor of Applicant,Per CLI-86-13.Certificate of Svc Encl ML20154H6941988-05-20020 May 1988 Notice of Appeal.* Suffolk County,State of Ny & Town of Southampton Notice of Appeal from ASLBP 880509 Partial Initial Decision on Suitability of Reception Ctrs. Certificate of Svc Encl ML20151F0341988-04-0808 April 1988 Notice of Oral Argument.* Oral Argument on Lilco Appeal of ASLB 871207 Partial Initial Decision LBP-87-32 Will Be Heard on 880428 in Bethesda,Md.Served on 880411 ML20150C7311988-03-15015 March 1988 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20150C6451988-03-15015 March 1988 Notice of Appearance.* Advises That Ma Young Will Enter Appearance in Proceeding.Certificate of Svc Encl ML20150C6421988-03-15015 March 1988 Notice of Appearance.* Notice of Appearance of Ma Young in Proceeding.Certificate of Svc Encl ML20150C7621988-03-10010 March 1988 Notice of Withdrawal of Gs Johnson as Counsel for Nrc. W/Certificate of Svc ML20196H8981988-03-0909 March 1988 Notice of Appearance.* Notice of Appearance of RA Sheffey in Proceeding.Certificate of Svc Encl ML20196J2231988-03-0707 March 1988 Notice of Appearance of LB Clark as Counsel for Nrc. W/Certificate of Svc ML20196H5551988-03-0707 March 1988 Notice of Appearance of Cl Ingebretson as Counsel for Lilco. W/Certificate of Svc ML20147H8341988-03-0404 March 1988 Notice of Deposition.* Oral Exam of J Sobotka on 880307 in Suffolk County,Ny Re Rev 9 to Plant Emergency Plan. Certificate of Svc Encl.Related Correspondence ML20148U4611988-01-25025 January 1988 Notice of Deposition.* Notice of Deposition Upon Oral Exam of DM Crocker on Lilco Proposal for Evacuating School Children from Plant 10 Mile EPZ During Radiological Emergency.Certificate of Svc Encl.Related Correspondence ML20147B9041988-01-13013 January 1988 Notice of Aslab Reconstitution.Cn Kohl,Chairman & as Rosenthal & WR Johnson Members.Served on 880114 ML20234C6841988-01-0404 January 1988 Notice of Aslab Reconstitution.* CN Kohl,Chairman & as Rosenthal & WR Johnson,Members.Served on 880105 ML20237E8321987-12-17017 December 1987 Notice of Appeal by Lilco from LBP-87-32.* Util Intends to Move Imminently for Expedited Consideration of Appeal by Immediate Certification to Commission or Expedited Briefing, Argument & Decision by Aslab.W/Certificate of Svc ML20236P8161987-11-13013 November 1987 Notice of Reconstitution of Board.* Jp Gleason,Chairman. Jr Kline and Fj Shon,Judges.Served on 871116 ML20235F2891987-09-21021 September 1987 Notice of Appearance.* Author Will Appear as Counsel for Applicant During Proceeding.W/Certificate of Svc ML20238F3371987-09-11011 September 1987 Notice of Appearance of Ds Harlow as Applicant Counsel in Proceeding.W/Certificate of Svc ML20238E5741987-09-0101 September 1987 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20237L6801987-08-31031 August 1987 Notice to Parties.* Notice Requesting Views of Parties Re Prioritizing Docketed Matters Concerning Emergency Planning & Whether Discrete Issues Should Be Assigned to Another Aslb.Served on 870901 ML20215M0391987-05-0808 May 1987 Notice of Appearance.* Informs That AF Johnson Will Enter Appearance in Proceeding.Certificate of Svc Encl ML20215L0261987-05-0404 May 1987 Lilco Notice of Intent to File Rebuttal Testimony.* Rebuttal Testimony Will Focus on Traffic Analyses.Certificate of Svc Encl.Related Correspondence ML20210B7381987-04-27027 April 1987 Notice of Appearance.* Gr Kors Will Appear in Proceeding. Certificate of Svc Encl ML20209E7971987-04-24024 April 1987 Notice of Appearance.* Advises That RR Ross Will Enter Appearance in Proceeding.Certificate of Svc Encl ML20212K3871987-03-0404 March 1987 Notice to Parties of Prior Prof Associations.* Discloses Prof Associations.Associations Will Have No Effect on Ability to Render Fair & Impartial Decision During Proceeding.Served on 870305 ML20211F4951987-02-18018 February 1987 Notice of Deposition.* L Czech Deposition on Contentions Ex 15 & 16 Re Emergency Preparedness Exercise Scheduled for 870225.Certificate of Svc.Related Correspondence ML20211F4751987-02-18018 February 1987 Notice of Deposition.* J Baranski Deposition on Contentions Ex 15 & 16 Re Emergency Preparedness Exercise Scheduled for 870225.Related Correspondence ML20211F4601987-02-18018 February 1987 Notice of Deposition.* J Papile Deposition on Contentions Ex 15 & 16 Re Emergency Preparedness Exercise Scheduled for 870225.Related Correspondence ML20211A1171987-02-14014 February 1987 Notice of Deposition.* Saegert Will Provide Deposition on 870302 in Washington,Dc Re Suitability of Three Reception Ctrs for Evacuees Designated in Emergency Plan.Related Correspondence ML20211A2261987-02-14014 February 1987 Notice of Deposition.* M Mayer Will Provide Deposition on 870303 in Washington,Dc Re Suitability of Three Reception Ctrs for Evacuees Designated in Emergency Plan.Related Correspondence ML20211A2881987-02-14014 February 1987 Notice of Deposition.* D Harris Will Provide Deposition on 870304 in Washington,Dc Re Suitability of Three Reception Ctrs for Evacuees Designated in Emergency Plan.Related Correspondence ML20211A4091987-02-14014 February 1987 Notice of Deposition.* Gc Minor Will Provide Deposition on 870305 in Washington,Dc Re Suitability of Three Reception Ctrs for Evacuees Designated in Emergency Plan.Certificate of Svc Encl.Related Correspondence ML20211A2161987-02-12012 February 1987 Notice of Deposition.* Re Linnemann Will Provide Deposition on 870305 in Washington,Dc Re Reception Ctrs Designated in Util Plan,Radiological Health & Safety & Other Pertinent Matters Re Use of Reception Ctrs.Related Correspondence ML20211A2781987-02-12012 February 1987 Notice of Deposition.* DE Donaldson Will Provide Deposition on 870304 in Washington,Dc Re Monitoring & Decontamination at Reception Ctrs Designated by Util Plan,Procedures, Equipment & Staffing at Ctrs.Related Correspondence ML20211A4021987-02-12012 February 1987 Notice of Deposition.* Rj Watts Will Provide Deposition on 870303 in Hauppauge,Ny Re Monitoring & Decontamination at Reception Ctrs & Containment of Washwater from Decontamination Process.Related Correspondence ML20211A3201987-02-12012 February 1987 Notice of Deposition.* CA Daverio Will Provide Deposition on 870302 in Hauppauge,Ny Re Monitoring & Decontamination Procedures at Reception Ctrs,Personnel & Equipment & Other Pertinent Matters.Related Correspondence ML20211A3601987-02-12012 February 1987 Notice of Deposition.* Eb Lieberman Will Provide Deposition on 870224 in Hauppauge,Ny Re Number of Vehicles Brought Into Reception Ctrs & Transportation & Traffic within & Surrounding Reception Ctr.Related Correspondence ML20209A7751987-01-30030 January 1987 Notice of Deposition.* Notice of 870203 Deposition of J Papile,Director,New York State Radiological Emergency Preparedness Group in Albany,Ny.Certificate of Svc Encl. Related Correspondence ML20207Q2711987-01-21021 January 1987 Notice of Oral Argument.* Oral Arguments on FEMA Pending Petition Seeking Leave to Appeal Portions of Board 861211 Order in Emergency Planning Phase of Proceeding Scheduled for 870205 in Bethesda,Md.Served on 870123 ML20212D0481986-12-22022 December 1986 Notice of C Malina Deposition on 870126 in Washington,Dc Re Duties & Responsibilities as Federal Evaluator Used by FEMA to Evaluate Offsite Emergency Response by Util Local Emergency Response Organization.Related Correspondence ML20212D0861986-12-22022 December 1986 Notice of H Fish Deposition on 870122 in Washington,Dc Re Duties & Responsibilities as Federal Evaluator Used by FEMA to Evaluate Offsite Emergency Response by Util Local Emergency Response Organization.Related Correspondence 1990-11-15
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20083B7331991-09-13013 September 1991 Notice of Appeal.* Informs of Notice of Appeals from Memos & Orders Denying Petitions for Intervention & Requests for Hearings ML20082G8551991-08-0606 August 1991 Notice of Relevant Decision & Significance.* W/Certificate of Svc ML20082B2271991-06-28028 June 1991 Notice of Appeal.* Denies School Districts Petition for Intervention & Request for Hearings in Matter as Well as ASLBs Dismissal of School District from Participation in above-captioned Proceeding ML20029A0231991-01-25025 January 1991 Notice of Typos in Petitioners Notice of Appeal & Petitioner Brief in Support of Appeal of ASLB 910108 Memorandum & Order (Both Filed on 910123).* W/Certificate of Svc. Served on 910125 ML20066E1331991-01-15015 January 1991 Requests limited-scope Exemption from Seismic Qualification Requirements of Criterion 2,App A,10CFR50 to Permit Deletion of 125-volt Dc Batteries 1R42*BA-A1 & 1R42*BA-C1 ML20029A0281991-01-0808 January 1991 Notice of Appeal.* Provides Notice of Appeal of 910108 Memorandum & Order (Ruling on Request for Intervention) in Proceeding Re Confirmatory Order Mod & Security Plan & Emergency Preparedness Amend ML20029A0111991-01-0808 January 1991 Application for Stay of Board 910108 Order.* Petitioners Move for Stay of 20-day Period to Amend Petitions Until Commission Decides on Appeal of Order or Pending Petition for Reconsideration.W/Certificate of Svc ML20058K4291990-11-28028 November 1990 Comment on Proposed NSHC Determination,Request for Hearing, Notice of Intent to Intervene & Opposition to Issuance of Amend by & on Behalf of Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy,Inc ML20062F7601990-11-15015 November 1990 Notice of Appearance.* Notice of Withdrawal & Certificate of Svc Encl ML20062C2501990-10-18018 October 1990 Establishment of Aslb.* Board Will Preside Over Proceeding Re Actions Taken by NRC & Long Island Lighting Co Re Shoreham Nuclear Power Station Unit 1,per Commission 901017 Memo.Served on 901022.W/Certificate of Svc ML20012C7601990-03-15015 March 1990 Request for Limited Scope Exemption from fitness-for-duty Requirements Imposed by 10CFR26.2 & That Exemption Be Granted & Remain in Effect Until NRC Approves Final Disposition of OL ML19332G6071989-12-15015 December 1989 Requests Exemption from Emergency Preparedness Requirements of 10CFR50.54(q) & to Implement Defueled Emergency Plan,Per Util Settlement Agreement W/State of Ny ML19353A9441989-12-0505 December 1989 Requests Exemption from Requirement of 10CFR50.71(e)(4) to File Annual Copy to Updated SAR by 891207.Required Update to Be Submitted on or Before 900601 & Will Reflect Condition of Plant as of Time Settlement Agreement Took Effect ML20244C2891989-04-17017 April 1989 Pages Affected by Rev 10A,890411.* Related Correspondence ML20235N2451989-02-24024 February 1989 Professional Qualifications of Lilco Witnesses on Exercise Contentions.* Certificate of Svc Encl.Related Correspondence ML20206M8951988-11-23023 November 1988 Notice of Appearance.* Author Enters Appearance in Proceeding on Behalf of Suffolk County.Certificate of Svc Encl ML20196F7381988-11-21021 November 1988 Errata to Board Decision LBP-88-24,changing Yr on Page III, Line 8 from 1988 to 1986.Served on 881205 ML20205D6871988-10-24024 October 1988 Notice of Appearance.* Author Enters Appearance in Proceeding on Behalf of Suffolk County.W/Certificate of Svc ML20205E0621988-10-21021 October 1988 Lilco Rept to Appeal Board on Progress & Effect of Town of Hempstead Case.* Article 2-B Re State & Local Natural & man-made Disaster Preparedness & Certificate of Svc Encl ML20155G9341988-10-0707 October 1988 Memorandum.* Advises That NRC Interpretation of ASLB 881006 Memorandum & Order That 24-h Period to Respond to Intervenors Motion Does Not Include Saturdays,Sundays & Federal Holidays Correct.Served on 881011 ML20154P5281988-09-27027 September 1988 Notice of Appeal.* Notices Appeal from ASLB Initial Decision LBP-88-24.Notices of Appeal from State of Ny & Town of Southampton,Govts Motion for Bifurcation of Appeal & Expedited Treatment of Issue & Brief on Appeal Encl ML20154P8021988-09-26026 September 1988 Notice of Aslab Reconstitution.Cn Kohl,Chairman & as Rosenthal & Ha Wilber,Members.Served on 880927 ML20207E5551988-08-15015 August 1988 Notice of Oral Argument.* Oral Argument Will Be Heard on 880914 in Bethesda,Md Re Lilco Appeal of ASLB Initial Decision LBP-88-2.Served on 880816 ML20207E4401988-08-15015 August 1988 Notice of Oral Argument.* Notifies That Oral Argument on Joint Appeal of Suffolk County,State of Ny & Town of Southampton from Board 880509 Partial Initial Decision LBP-88-13 Will Be Heard on 880917.Served on 880816 ML20207E4801988-08-12012 August 1988 Reconstitution of Aslab.* TS Moore,Chairman & as Rosenthal & Ha Wilber,Members.Served on 880815 ML20196A9391988-06-20020 June 1988 Govts Notice of Appeal.* Appeal Board 880610 Order as Reconfirmed on 880617,resolving Legal Authority Contentions in Favor of Applicant,Per CLI-86-13.Certificate of Svc Encl ML20197E0541988-05-25025 May 1988 Memorandum.* Lists Conclusions on Issues Raised by Lilco Appeal from ASLB 871207 Partial Initial Decision Re Scope of Feb 1986 Emergency Preparedness Exercise at Facility.Appeal Technically Moot.Served on 880525 ML20154H6941988-05-20020 May 1988 Notice of Appeal.* Suffolk County,State of Ny & Town of Southampton Notice of Appeal from ASLBP 880509 Partial Initial Decision on Suitability of Reception Ctrs. Certificate of Svc Encl ML20151E9411988-04-0808 April 1988 Memorandum (Extension of Board Ruling & Opinion on Lilco Summary Disposition Motions of Legal Authority Realism Contentions & Guidiance to Parties on New Rule 10CFR50.347(c)(1)).* Served on 880411 ML20151F0341988-04-0808 April 1988 Notice of Oral Argument.* Oral Argument on Lilco Appeal of ASLB 871207 Partial Initial Decision LBP-87-32 Will Be Heard on 880428 in Bethesda,Md.Served on 880411 ML20148K2591988-03-29029 March 1988 Memorandum to Parties.* Attached Memo from Bp Cotter,Chief Administrative judge,self-explanatory.Parties to Proceeding Requested to Conform to Svc Request.Served on 880329 ML20150C6421988-03-15015 March 1988 Notice of Appearance.* Notice of Appearance of Ma Young in Proceeding.Certificate of Svc Encl ML20150C6451988-03-15015 March 1988 Notice of Appearance.* Advises That Ma Young Will Enter Appearance in Proceeding.Certificate of Svc Encl ML20150C7311988-03-15015 March 1988 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20150C7621988-03-10010 March 1988 Notice of Withdrawal of Gs Johnson as Counsel for Nrc. W/Certificate of Svc ML20196H8981988-03-0909 March 1988 Notice of Appearance.* Notice of Appearance of RA Sheffey in Proceeding.Certificate of Svc Encl ML20196J2231988-03-0707 March 1988 Notice of Appearance of LB Clark as Counsel for Nrc. W/Certificate of Svc ML20196H5551988-03-0707 March 1988 Notice of Appearance of Cl Ingebretson as Counsel for Lilco. W/Certificate of Svc ML20147H8341988-03-0404 March 1988 Notice of Deposition.* Oral Exam of J Sobotka on 880307 in Suffolk County,Ny Re Rev 9 to Plant Emergency Plan. Certificate of Svc Encl.Related Correspondence ML20196J0571988-03-0101 March 1988 NRC Staff Proposed Schedule for Hearing on Remaining Remand Issues.* Schedule for FEMA Review of Recent Revs to Util Plan Also Encl.Certificate of Svc Encl ML20148U4611988-01-25025 January 1988 Notice of Deposition.* Notice of Deposition Upon Oral Exam of DM Crocker on Lilco Proposal for Evacuating School Children from Plant 10 Mile EPZ During Radiological Emergency.Certificate of Svc Encl.Related Correspondence ML20195J0941988-01-15015 January 1988 Response of Govts to Board 871223 Confirmatory Memorandum & Order.* Ref Portions of Govts Previous Filings Make Clear That NRC Use of Word May in Providing Guidance to Boards Appears to Be Quite Delibrate.Certificate of Svc Encl ML20147B9041988-01-13013 January 1988 Notice of Aslab Reconstitution.Cn Kohl,Chairman & as Rosenthal & WR Johnson Members.Served on 880114 ML20234C6841988-01-0404 January 1988 Notice of Aslab Reconstitution.* CN Kohl,Chairman & as Rosenthal & WR Johnson,Members.Served on 880105 ML20237E8321987-12-17017 December 1987 Notice of Appeal by Lilco from LBP-87-32.* Util Intends to Move Imminently for Expedited Consideration of Appeal by Immediate Certification to Commission or Expedited Briefing, Argument & Decision by Aslab.W/Certificate of Svc 1992-02-26
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pnugu wWi3Yp[2'[8'3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 90CKETED USNRC Before the Atomic Safety and Licensing;3oggd
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In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 O.L.
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(Shoreham Nuclear Power Station, )
Unit 1) )
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SUFFOLK COUNTY'S NOTICE OF POTENTIAL MOTION TO ADMIT NEW CONTENTION ON DIESEL GENERATORS A week ago Friday, on August 12, 1983, the crankshaft on Shoreham emergency diesel generator no. 102 broke in two
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during testing of the diesel with the "new-style" cylinder heads installed. Counsel for LILCO notified Suffolk County's counsel of this matter on Saturday. Neither' LILCO nor the 1/
NRC Staff know what caused the crankshaft to fail, and the 2/
failure analysis effort may take a significant time.-
On August 18, 1983, the County sent LILCO a Request
[
for Discovery regarding the crankshaft failure (a copy of which is attached hereto as Exhibit 4) and sent the Staff a similar l
1/ See "LILCO Report and Request for Temporary Deferral,"
dated August 15, 1983; and "NRC Staff Response to 'LILCO Report and Request for Temporary Deferral' of Filing of Testimony and Evidentiary Hearings on Emergency Diesel Generators," dated August 16, 1983.
2/ Ibid. See LILCO News Release, dated August 18, 1983 (attached hereto as Exhibit 1). See also article from Newsday, August 17, 1983, p. 3 (attached hereto as Exhibit 2); article from The Wall Street Journal, August 19, 1983, p. 5 (attached hereto as Exhibit 3).
8308240168 830822 PDR ADOCK 05000322 G PDR h
y
(? ,)
request (a copy of which is attached hereto as Exhibit 5) .
These requests are in connection with the County's pending contentions concerning the Shoreham diesel generators (cylinder heads and vibration), which may be related to the crankshaft failure. LILCO has not yet responded to the County's Request for Discovery, which is intended to permit the County to observe and monitor the attempt to ascertain the cause(s) of the broken crankshaft.
Suffolk County believes that the crankshaft failure denenstrates that the rapid starting and the safe and reliable operation of the Shoreham emergency diesel generatcrs has not been ensured. While the County has little doubt that a new contention to this effect would meet all standards for reopening the record and the criteria for a late-filed 3/
contention,~ there seems no good reason to file a new contention prior to LILCO reaching its conclusions on the cause(s) of the failure. Indeed, if LILCO complies with the County's Request for Discovery, and the County agrees with LILCO's conclusions on i
- the cause (s) of the failure, with the significance thereof, and with LILCO's corrective and preventive action, the County might not file a new contention at all.
I
! The County is aware that " timeliness" is one of the tests which a late-filed contention must meet. In the County's interpretation of this standard, a new contention on the crank-3/ Both standards and criteria must be met, according to the Board's Memorandum and Order Ruling on Suffolk l County's Motion to Admit New Contention, LBP-83-30, 17 NRC (June 22, 1983). For a summary of these standards and criteria, see LBP-83-30 at 12.
shaft failure would be timely if filed within a reasonable time after the County learns of LILCO's conclusions regarding the cause (s) of the crankshaft failure. At that time the significance of the broken crankshaft issue and whether it presents genuine triable facts will be adequately sharpened to determine whether a new contention is appropriate.
On the other hand, if the County were to file a contention on the crankshaft failure before learning of the conclusions of LILCO's failure analysis, litigation would probably have to be deferred until those conclusions were known. Before then, neither party would nave a clear idea of the triable facts at issue. Hence, it would be absurd in this situation if the timeliness standard were interpreted to require filing of a new contention within a reasonable time after the breaking of the crankshaft, rather than after LILCO makes known its conclusions as to the cause (s) of the failure.
To the extent that one aspect of the timeliness criterion may bc to avoid surprise, this Notice serves to communicate the County's present intentions to the Board and to all parties.
If any party believes that the County's interpretation of the timeliness standard as applied to this matter is erroneous, it should raise that disagreement now. We should add that, in the context of timeliness, as well as the standard con-f cerning possible delay of the proceeding occasioned by a
late-filed contention, LILCO now estimates that Shoreham will not be ready for fuel load until sometime in the first i
quarter of 1984.-4/
Respectfully submitted, David J. Gilmartin J
Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 1-Herbert H. Br en /
Lawrence Coe, anpher Alan Roy Dynner K1KKPATRICK, LOCKflART, HILL, CHRISTOPHER A PHILLIPS 1900 M Street, N,W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County August 22, 1983 4/ See Exhibits 1 and 3.
% MAN, Mana2er NFAM#tM
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,SD EXHIBIT 1 i
FOR IMMEDIATE RELT3.5E August 18, 1983 Long Island Lighting Company today announced that it has increased frc=
$50 to $75 million the a=ount of a sale of preferred stock scheduled for August 22.
At present, there is no new infor=ation available as to the status of the diesel generator which experienced a crankshaf: failure during a pre-operational test. The Cocpany is today filing a Current Report on Forn E-K with the Securities and Exchange Cc=:ission te report en the 2ecent developecnts at Shorehan raprding the diesel generator. The text. of the Form 8-K fellows:
Cm August 12, 1983, during testing, the crankshaf t of one of the three coergency diesel generators at Sborcha=
failed. The crankshaft was initially thought to have been cracked, but was in fact broken. Successful co=pletion of testing of all three generators is a prerequisite for permission to load fuel and to begin low-power testing.
Although an analysis of the cause of the crankshaft failure has begun, until such analysis has been cocpleted, the Cocpany is unable to predict when fuel loading and cocnercial operation will occur. Under the most favorable circu= stances, correction of the dacage caused by the failed crankshaft as well as a deter =ination of the adequacy of all three diesel generators, in light of such failure, could be accc=plished by la.:e Novecher 1983.
-MORE-l
"Morsavar, the Comptny dess not know at present to what extent there will be delays in the co==ence=ent of the diesel generator hearings by the Ato=ic Safety and licensing Board thathasbeenconsider$ngtheCo=pany'sapplicationforan operating license. These hearings were to have begun on August 29, 1983, but have been suspended until additional information concerning the crankshaf t failure is available.
The Company believes that the diesel generator hearings will be lengthier than originally conte = plated. Thus the Company believes that, under the most favorable assu=ptions, fuel loading will not take place until some time during the first quarter of 1984. Under more adverse assu=ptions, fuel loading would begin significantly later. The Company's previous estimates that the successful co=pletion of power ascensien tests at Shoreham during the period between fuel load and commercial operation would require approximately six to nine months assumed timely authorization from the Nuclear Regulatory Cem:ission to increase levels of power beyond 5%. While the Co=pany believes that the emergency response planning hearings can still be conducted concurrently with those
! relating to the diesel generators, it cannot provide any assurance that the commencement of the e=ergency response planning hearings will not also be delayed. Any delays in the receipt of such timely authorization or in the emergency response planning hearings may delay the date of commercial operation. The Company believes that the ,
likelihood of such delays has increased as a result of the developments regarding the emergency diesel generators.
-MORE-i
* "Engad upon cn assu=ed co=mircial opsration date of May 1,1984, th2 Compcny had astimatsd the total cost cf the Shoreham unit at approximately $3.4 billion. Under all assumptions, the Cocpany now believes that co=:ercial operation by May 1, 198'4 is no longer achievable. Although the Company cannot provide an estimate of when coc=ercial operation vill take place, it does esti= ate that delay in the co=mencement of co==ercial eperation increases the cost of the unit approxi=ately $35 million to $45 cillion a conth.
Any delay in the commercial operation date of Shoreham and any change in its costs will nffect the assu=ptions and therefore the relief whi h the New York Public Service Cot =f asion may grant in the Company's pending electric rata case,
i
NEWSDAY August 17, 1983, p. 3 EXHIBIT 2
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Shoreham Damage Worse Than Believed Continued from l'ero 5. munt arcrate pmperly if the utility is to report says it is not pouible to deelde if would have to rewire. repipc ond notami- r-t on al+ rating 14cnae. *he new heads orn adequato until the cally rndenien nucports Inc tim rencr- Eiiled Nut is annlyzed The ether 1:'3 tests havo lwen succena.
!?:lwn 4 Creenman, on MitC official II,fio r id I tank ou t a fully completed.Salit anid.The fmal die- who menm Shanham t,wtlons, he luind for Aug. 22.imt it months. Ll!LO vmuld ch.o have in tent . rol test wn ' I "
down a wall in the buildine..rt.ecal it b1R bren mdefinitely pastroned.as hnvo l.{I. rssolve t ble a alter installing the new crtuipment and I"'leral liennngs on the tituta. .
g g then retent the building. The !?horchnm dic cIn. Inntailed in +n, chine, a= long ns they can ensure the The units wern made hy Transamerica la7.9 nmi 197'). h.tve harl numernus entf. the NIIC und the public that the Delaval, which has hten cited fier dic el "linpment problems, inriuding crnektd synerntors are reliable." ho paid."If they prcblems at other recetorn. V.'arrantics " unsier bcnds, cicessive vibration, rnn't l. monstrate that, they can't itm on two ni the three I.llf 0 units appear nusing bolta, defects in parti nnd misn- she gibint."
tn have espired. Vnrious NI'C reonrts li,:ned parts. I.:lf0 wns lined ilo.tXM ,g,, p.,tenlay, Gav. '.fario Cunmo's have idamed I.!ILO fir inamtennnce I.y thn HitC this part Apni for irrorrect rnmnuulon investic=tmg lhorehnm tidlures anel Delsvnt for mrinuinetunn; le tme. Neitber I.!!EO nnr NltC n'h- !n ord temmnny !.mm Ilrnnkhaven Na-defects. Delaval has declined to com. cials wnuld lir.t pomble rnumes for the tinnai labnratory scientists sup;nrting rnent. l'ut 1.llf0 vice prenident Irn renerntor probicmn. thitinur authon,ts- the plant and frem vamus nonkchnical l'rtilicher rnid.ycrteninv. if there t ttvo textbooks on dicaol renerntorn incli- residents nyposing it.
r.cmething h rn taat'a I; lsval'n fault.- r: te that crarits ran ncrur f om gmr warranty or no wntranty, we nre ping t imitarture. cnolmq, nr p hgnment <!iir- -- - -
in vek reemerv from Deinval."' M maintennnce. ,
no dicsci renerntnr tents enmnnacd %e Shoreham dicscis have been test-the Im.t nil'2 malelv trats scheduled for
- 4 manir times dunng the past two tFo !!horrham phmt 1+1hrn etw rr' inn. vor=, nnel rame of the problems h1ro Te of the three rencrn orn e nre r.rrdest b~en found during the tre.ta, tblit rsud.
In rupply !=iwcr ta r;.itciv enut ihn rr,c- P r r ampic,l.ilf0 rrrinted nli '.*l cyl-
*nr m orne Irtn<'t.nf .9etuir nta. but all ler brndg this year.1:nt on f l!C st,tf
EXHIBIT 3 1
4 9W P
TIIE WALL STREET JOURNAL y Friday. August 19, 1983 U i l ing won't occur until the first quarter of J* c0 Generator Woes J.A i.. unde, me,e ad e,se assumptions.
fuel loading would begin significantly later,"
Mean Nuclear Facility S' e " " " 7 *dd'd-The situation will push the date of com-mercial oleration beycod Ulco's target of
; To Face FurtherI;3elay wey 1, im the company said. it didn t esa o
mate a new target date, but plans six to nine j months for testing between fuel loading and av a wau. stater Joumman. Staff Repeww, CommeTClal operation.
MINEOLA, N.Y.-Img Island ughting "We won't know for several weeks ex- ,
Co. said new problems with diesel genera. actly what we're dealing with" In the gener-tors will force another delay in its schedule ator problem,'a spokesman said. The delay for bringing the Shoreham nuclear plant into may mean an adjustment in the 56.57e rate-operation. increase request pending before the state The ersnkshaft of one of the plant's three
, t emergency generators broke during a test The company made the disclosure in a Friday. The incident will delay further tests filing with the Securities and Exchange of the equipment r.nd probably prolong Nu clear Regulatory Commission hearings into Commission in conmuon wim an an-various problems the company has had with nounced increase to $75 million from $50 million in a sale of preferred stock sched-the generators. Ulco said.
uled for Monday. A spokesman said the
.Ulco was planning to load fuel at the move reflected good market conditions and plant in October, but now says that "under wasn't related to the diesel generator prob-the most favorable assumptions," fuel load- lems.
. _ - - - - , . _ - -- , - , ,_y ,. y~__,,,_r___. -__,,.,,._.y.,,,,-. , ,... , ._ ,,_._-.er_,_w.. _ _ , _ . _ . _ _ . . , . . . , . , - _ . _ _ . . - - . ,
~
b _ lif$7 EXHIBIT 4 ENNATRICK, IA>CKHART, HrLL. CHRISTOPHER & PHILLrrs A Pmmeste lacLesswo A PoorsassoNAL COE70EuTSON i
19o0 M Srnurr, N. W.
WASHINGTON, D. C. 20o36 tr2CPstows (sos) ase.tooo gy prrresemor CARLE NEPM2 ggag7AT.JG,wra ang,goceot 6 MMIJSON TutOh *eosos ansi c isoo oxiven sezzarvo
- -arra. . . ..er mit nex . August 18, 1983 c m ..c.... ,ryy m m .
202/452-7044 =e: = ==c
~
(BY TELECOPIER)
T. S. Ellis, Esq.
, Hunton & Williams 707 East Main Street .
P.O. Box 1535 Richmond, Virginia 23212 -
i pe: Recuest for Discovery
Dear Tim:
Last Saturday you informed me by telephone that the crankshaft on diesel generator No. 102 had broken in twc during testing with the "new-style" Transamerica Delaval cylinder heads installed. In the LILCO Report and Request for Temporary i Deferral, dated August 15, 1983, LILCO stated that the-cause ;
of the failure is unknown, and the time necessary to determine the cause and the ramifications of the failure is uncertain.
In LILCO's Supplemental Report on the Diesel Generators, dated August 16, LILCO stated that in its " preliminary view" the breaking of the crankshaft is act related to issues raised in Suffolk County's contention regarding the cracking of cylinder heads, but that "no firm conclusions" can yet be reached.
The NRC Staff, in its Response to the LILCO Report, dated August 16, 1983, indicated that the relationship between the crankshaft failure and the cylinder head issue "cannot be ascertained prior to dismantling the disabled diesel to determine the cause of failure." It also noted that the crankshaft failure may impact upon the County's contention regarding vibration of the Shoreham emergency diesels. The County, in its filing dated August 15, 1983, agreed that the 1 crankshaft failure may be related to both the cylinder head and the vibration issues, but no conclusions can be reached until the cause of the crankshaft breaking is ascertained.
Accordingly, matters relating to the crankshaft failure are clearly relevant to the County's diesel generator
6=-
6=-
KIREPATRICK. LOCKMART, HIn, Ca.nISTOPHER & Pruures T. S. Ellis, Esq.
August 18, 1983 Page 2 contentions. Therefore, Suffolk County is requesting cngoing discovery (as set forth below) as to the crankshaft failure until it is determined to the County's.or the Board's satis-f action that there is no relationship between the breaking of the crankshaft and either the cylinder head cracking issue er the vibration issue. The County hereby requests: -
- 1. That LILCO promptiv notifv the County of its plans (and any changes thereto) to determine the cause (s) of the crankshaft failure, including the kinds of examinations, tests and analyses it will carry out, the schedules for them, and the identification of persons who will be involved,in the failure analyses and their responsibilities..'
- 2. That LILCO give the County reasonable advance -
notice of all examinations, tests end analyses to be carried -
out in connection with the attempt to ' determine the cause (s )
of the crankshaft failure, including without limitation any diesel engine tear-down, and permit representatives and.
consultants of the County to witness such examinations,. tests and analyses.
- 3. That LILCO promptly provide the County with copies of all documents (as defined below), whether preliminary er final, as and when they come into LILCO's possession or under its control, pertaining to the crankshaft failure cr the attempt to determine the cause (s) of the failure. 1/
- 4. That LILCO give the County reasonable advance notice of all meetings concerning the crankshaft failure which are to be attended by NRC Staff personnel, er to which such Staff personnel are invited, and that representatives and consultants of the County be invited to attend such me~etings.
- 5. That LILCO promptly notify the County by telephone of any and all significant developments in the attempt to determine the cause (s) of the crankshaft failure.
For purposes of this request, the word " documents" is to be given its broadest meaning, to include, without-limitation,
-1/ An example would be the report on the analysis of the oil in diesel generator No. 102,. referred to by Mr. Novarro in his comments to the Cuomo Commission on August 17, 1983.
_ _ - ,_ . - = . -
. . _ . . . . = . - = . .. - _ - . . - - . . .
' h , , ,. q
~ EinxrArmacx, LocxxAmr, B12.L. Cantatoruza & Puzt.t.rP3 T. S. Elli.s,, Esq.
' August 18, 1983
' Page 3 .
[ ' :
A correspondence, memoranda, written data, photographs, reports,
, notes, drawings, computer printouts, written analyses, cnd I other forms'of written data and material.
- ~-
- - As you know, the Board's Memorandur and Order Deferring
- 7 -Filing of Testimony and Commencement of Hearing on riesel Generators, dated August 16, 1983, requires the parties to
~
i ,
. file by August 25 a status report r.egarding any progress in .
determining the cause (s) of the crankshaft failure, and expects the parties to coordinate their " efforts and views."
Other than your August 13 telephone call informing me of'the failure, the~ county has not received any.other information directly~from LILCO regarding the crankshaft failure. This discovery request _is consistent with the Board's August 16 Memorandum and Order, and obviously a rapid response by LILCO will be required if the County is to be capable of filing a l
s meaningful status report with the Board.
i.
Enclosed is a request to the Staff which we are delivering today concerning the crankshaft failure.
- , By the way, I should remind you that we have not yet i received from LILCO the documents which were th,e subject of a the County's August 12 Renewal of Motion to Compel Discovery, I and which the Board in a conference call suggested be supplied
- to the County.
i Very truly yours, Alan Rov Dvnner - -
?
- ARD/dk Enclosure cc
- Bernard M. Bordenick, Esq.
(By Telecopier)
?
4
. - .- __ , , - . - . . . , ~ . . , , , . . - - . _ . - _ _ _ _ _ . - _ , , , , , , _ . _ , _ , _ . , _ . - _ _ _ _ _ . _ , _ . _ . _ _ . , . . . . . . . . . _ , , _ . . . , _ _ _ . . _ , _ _ _ . _ _ . _
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, EXHIBIT 5 EIRKPATRICK LOCKHART, lITT T., CHRISTOPHER & PHILLIPS A PasrrwsmsETF INC3%Dawo A Paorsestowat Common.arsom
- 1900 M Srazzr, N. W.
WASHINGTON, D. C. 20006 TELaFaroNE (aoe) maa.rooo IN Fr:Tsattmot MLE: W1FK1 11EEPATR3CE.im*T.J0ENtoN & ETRI1 SON TEIGA 4eosos mFM C3 3500 olmes acTLDIso v.mm . ===c? m2 2. wcx.m. August 18, 1983 cm..e.oa. rey,m m .u 202/452-7044 == : => *=o (BY TELECOPIER)
Bernard M. Bordenick, Esq.
U.S. Nuclear Regulatory Commission, Washington, D.C. 20555
Dear Bernie:
Attached is a Request for Discover 3 which we telecopied today to Mr. Ellis concerning the crankshaft failure in diesel generator No. 102 at Shoreham. For the reasons stated therein, Suffolk County also is requesting the cooperation of the Staff concerning that failure and the attempt to deterr.ine its cause;or causes, as follows:
- 1. That the Staff promptly notify the County of its plans (if any) to determine or assist in determining the cause (s) of the crankshaft failure, including what it intends to do and when.
- 2. That the Staff inform the County of, and permit County representatives to witness, examinations, tests or analyses carried out or witnessed by Staff personnel in l connection with the attempt to determine the cause (s) of i the crankshaft failure.
- 3. That the Staff promptly provide the County with copies of all documents, reports, analyses, and other data pertaining to the crankshaft failure or the attempt to deter-mine its cause (s) .
- 4. That the Staff give the County reasonable advance notice of all meetings with LILCO or its consultants concerning the c~rankshaft failure to be attended by Staff personnel, and that County representatives and consultants be invited to attend such meetings as observers.
t
- 5. That the Staff notify the County promptly by telephone of any and all significant developments in the l
l i
[
m e-- , - - - -w - --,,n,- - ,----e-- ,
- _. ~ _ . _. . - - .
~
L_=-
L....
KIREPATRICK, IX)CKHART, Hu.I., CuRI2Torxza & PnII.I.rrs Bernard M. Bordenick, Esq.
August 18, 1983
< Page 2 attempt to determine the cause (s) of the crankshaft failure.
Your cooperation in these reports will be greatly appreciated.
Very truly yours, Alan Roy Dynner ARD/dk .
Enclosure cc: T. S. Ellis, Esq.
(By Telecopier) -
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4.. . -- . - .
UNITED STATES OF AMERICA "r" -
NUCLEAR REGULATORY COMMISSION KETED Di.;
BEFORE THE ATOMIC SAFETY AND LICENSING B
) 83 Am 23 A11:25 In the Matter of )
) ..: .c snat.iM LONG ISIAND LIGHTING CCMPANY )
) DocketN(o.ClifTI5G 50* #24 (O. L. ) & SEE#
(Shoreham Nuclear Power Station, )
Unit 1) )
~
) _
CERTIFIC ATE OF SERVIC E I hereby certify that copies of SUFFOLK COUNTY'S ANSWER AND OPPOSITION TO LILCO'S MOTION FOR A PROTECTIVE ORDER, and SUFFOLK COUNTY'S NOTICE OF POTENTIAL MOTION TO ADMIT NEW CONTENTION ON DIESEL GENERATORS, dated August 22, 1983, have been served to the following this 22nd day of August, 1983 by U.S. mail, first class, except as otherwise noted.
(*) Lawrence J. 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. George A. Ferguson 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board School of Engineering (#) W. Taylor Reveley III, Esq.
Howard University Hunton & Williams 2300 6th Street, N. W. P.O. Box 1535 Washington, D. C. 20059 707 East Main St.
Richmond, Virginia 23212
(*) Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board I U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C. 20555 New York State Energy Office Agency Building 2 l Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company .
l 250 Old Country Road Mineola, New York 11501 Stephen B. Latham, Esq.
l Twomey, Latham & Shea Mr. Brian McCaffrey P. O. Box 3 98
- Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 l
Hicksville, New York 11001
-w - - - - - - -,.%-. -%. - . , , - - - - - - - - - - , , , , .---.# w..- , - - .-- , . - - -
, ~ . . . -. - . . . . . _ , . . . ..--. - - .. .. - - -
Marc W. Goldsmith Mr . Je f f 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, Ne'w York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rocke feller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York _12223 Hon. Peter Cohalan Suffolk County Executive David J. Gil martin, Esq. H. L'e e Dennison Suffolk County Attorney Building H. Lee Dennison Building Veterans Memorial Highway Veterans Aemorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik; Esq.
' Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D. C. 20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D. C. 20555 Appeal Board U.S. Nu clear Regulatory
(*) Bernard M. Bordenick, Esq. Commission David A. Repka, Esq.
Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Jonathan D. Feinberg, Esq.
Staff Counsel, New York Stuart Diamond State Public Service Comm.
Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223 Long Island, New York 11747 Stewart M. Glass, Esq.
Daniel F. Brown, Esq. Regional Counsel Atomic Sa fety and Federal Emergency Management Licensing Board Panel Agency /
U. S. Nuclear Regulatory Commission '
26 Federal Plaza ,
Washington, D.C. 20555 New York; New York 10278 James B. Dougherty, Esq.
3045 Porter Street, N. W.
Washington, D. C. 20008
/b -- _
Alan Roy D%ner' KIRKPATRIW , LOC KH A RT, HTLL, CHRISTOPHER & PHILLIPS DATE: August 22, 1983 1900 M Street, N.W., 8th Floor Washington, D. C . 20036
.(*) By Hand
(#) By Federal Express
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