ML20083P474

Response to Suffolk County 840412 Document Discovery Requests.Certificate of Svc Encl.Related Correspondence

ML20083P474
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/16/1984
From:	Rolfe R HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
OL-4, NUDOCS 8404200024
Download: ML20083P474 (10)

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\ s LILCC00g31 16, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION q n g e n . i t ' '-

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G hoi Before the Atomic Safety and--Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4

) (Low Power)

(Shoreham Muclear Power Station, )

Unit 1) )

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LILCO'S RE$FONSE TO SUFFOLK COUNTY'S APRIL 12, 1984 DOCUMENT DISCOVERY REQUESTS LILCO hereby responds to Suffolk County's Documcht Discovery Requests dated April 12, 1984 (the second ' request).

General Response LILCO received at approximately 5:45 p.m. on April 12, 1984,

! the second Document Discovery Requests by the County. Subject to l

the same objections as LILCO expressed as to the County's Document Discovery Requests dated April 11, 1984, LILCO attemp'ted to locate all documents responsive to the second requests.

Below is a detailed description of LILCO's response to the I second document requests. The response begins with Roquest No. 5 l because Request Nos. 1-4 were clarifications of-the April 11,

1984 document request. These clarifications were addressed in l . ,

LILCO's response to the April 11, 1984 Request. Responsive documentswithheldunderaclaimofworkproductpriviledeor trial preparation privilege are identified on Attachment A- 1 hereto. LILCO is in a position immediately to address the I 1

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County's disagreement, if any, with the privileged claimed as to any of these documents.

Specific Fesponses

5. Documents pertaining to the statement at page 22 of the LILCO Motion that LILCO will "take steps to place the reactor in a cold shutdown in the event of . . . an indication of seismic activity of .01g on the on the [ sic] Shoreham seismic monitors."

Without limiting the scope of this request but by way of illustration, the documents include:

(a) documents describing the Shoreham seismic monitors, including specifications, capability, and locations RESPONSE: LILCO produced documents responsive to this request. The Technical Specifications and the FSAR already in the possession of the County, also contain responsive information.

(b) documents describing or relating in any way to how much time is predicted to pass between a recording of 0.01g and a recording of 0.1 or 0.2g; and RESPONSE: LILCO did not locate any documents in its possession responsive to this request.

(c) documents describing the procedure (s) which cperators will follow to determine whether there is a seismic condition which requires placing the plant in cold shutdown.

RESPONSE: LILCO produced documents responsive to this request.

6. Documents describing or relating in any way to the duration and sequence of operation of each of the Phases (I-IV) described in the LILCO Motion. Without limiting the scope of this request but by way of illustration, the documents include:

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(a) Documents pertaining to the actual activities (including tests at various power levels) which will be conducted in each Phase; RESPONSE: LILCO produced documents responsive to this request pursuant to the April 11, 1984 Document Discovery Request No. 33.

(b) Documents pertaining to the duration of each phase and the anticipated duration of the entire low power test program; RESPONSE: LILCO produced documents responsive to this request.

(c) Documents pertaining to the duration of actual operation at each power level; RESPONSE: LILCO produced documents responsive to this request.

(d) Documents pertaining to the actual sequence of each activity and duration thereof in the event LILCO's Motion is granted; RESPONSE: LILCO produced documents responsive to this I

request.

(e) Documents pertaining to the " progressive steps" referenced at the bottom of page 11 of '

the LILCO Motion.

RESPONSE: LILCO produced documents responsive to this request.

7. Documents describing all instrumentation and control systems which will be used to initiate operation, control, or protection of the AC power sources relied upon by LILCO in the Motion, including instruments mounted on the specific _ equipment; l control room mounted equipment; and other equipment for control, monitoring, and protection of the additional power sources.

RESPONSE: LILCO produced documents in existence and responsive to this request pursuant to the April- 11, 1984 Document Discovery Request Nos. 10, 12 and 14.

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8. Documents identifying, describing or in any way relating to any preoperation, demonstration, or other tests or procedures to verify the validity and reliability of the interconnected network of new AC power equipment and existing AC power equipment, including how the system would be tested during operation.

RESPONSE: Documents responsive to this request will not be prepared until after the installation of the equipment.

9. Documents relating to the man-hour assertions in the Notaro Affidavit and the length of time involved at each power level.

RESPONSE: LILCO produced documents responsive to this request.

10. For the AC power sources relied upon by LILCO, all docunents which identify or relate in any way to applicable regulatory guides and applicable standards and the degree of compliance with each. For example, separation; single failure criteria, fire protection; periodic testing; independence of onsite systems; installation; maintenance; bypassed and inoperable status indication.

PESPONSE: The County already has in its possession the documents necessary to determine any regulatory guides or standards applicable to the AC power sources. LILCO produced l

documents pursuant to the April 11, 1984 Document Discovery Request from which the County will be able to assess the l compliance of the power sources with those standards.

11. Documents relating in any way to-the LILCO position (e.g. , ' LILCO Motion at 3) that during Phases I and II, AC power-is not necessary to satisfy the NRC's regulations.

RESPONSE: The County already has LILCO's Supplemental Motion for a Low Power License and its supporting affidavits. . j The FSAR, also.in the County's possession, contains information I responsive to this request.

12. Resumes of all persons LILCO intends to use as witnesses.

4 RESPONSE: LILCO produced documents responsive to this

, request.

13. Documents that relate in any way to the statement in the LILCO Motion (p. 10) that "LILCO's Phase I and II program is designed to provide Shoreham's operating personnel with more-BWR experience and training than would result from a conventional program."

RESPONSE: The County already has a copy of the I

Notaro Affidavit. LILCO also produced training documents pursuant to the April 11, 1984 Document Requests Nos. 6 and 7.

LILCO does not currently have any other documents in its possession responsive to this request.

14. Documents that relate in any way to the statement in j the LILCO Motion (p. 11) that during Phase II, "many events-analyzed in Chapter 15 simply could-not occur or would be very unlikely when compared to the situation during normal operations."

RESPONSE: Chapter 15 of the FSAR, already in the County's possession, contains information responsive to this request..

15. Documents t' hat relate in any way to "LILCO's intention-to perform expanded training throughout low power testing" (LILCO Motion at 12).

RESPONSE: See response to Request No. 13 above.

16. Documents that relate irt any way to.LILCO's view that operation of Shoreham in' Phases III and IV " poses far-less risk to the public health and safety than-does operation'of the plant 1

at 100% rated-power" (LILCO Motion at 12).

RESPONSE: - The County has copies of :the affidavits supporting LILCO's Supplemental Motion. Chapter 15Lof the FSAR, already in the County's possession, also contains information' responsive to this request.

17. . Documents that identify the " applicable requirements of eth'e Shoreham Technical Specifications" (LILCO Motion at 14) which~

. LILCO believes must be met for-Phases III and IV.

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RESPONSE: The County has been provided with the latest Shoreham Technical Specifications. Additional Technical Specifications that will be responsive to this request are currently being drafted.

18. Documents showing transmission and distribution operation procedures which will be used instead of normal load dispatching and grid integrity protection procedures.

RESPONSE: LILCO produced documents responsive to this request pursuant to the April 11, 1984 Document Discovery Requests No. 5.

19. Documents showing the effect of an overload on the mobile diesels and the 20 MW gas turbine.

RESPONSE: LILCO did nct locate any documents in its possession responsive to this request.

20. Documents showing how the electrical' cables for the mobile diesels are sheathed, protected and mounted.

RESPONSE: LILCO produced documents responsive to this request pursuant to the April 11, 1984 Document Discovery Requests No. 9.

21. Documents showing the procedures for startup, l synchronization and load sequencing of the mobile diesel generators.

RESPONSE: LILCO produced documents responsive to this request pursuant to the April 11, 1984 Document Discovery Requests No. 5.

22. Documents, including analyses, calculations and assumptions, showing how many of the four mobile diesel generators are required to supply the minimum loads on the bus.

See transcript of March 29, 1984 meeting, a: pages 10-11.

RESPONSE: LILCO has not completed the analyses referred ' to in this request and, therefore, does not have documents available at this time.

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23. Documents showing the reliability of the air compressor on the 20 MW gas turbine.

RESPONSE: To the extent that documents responsive to this request exist, they would be found in the manuals produced pursuant to the April 11, 1984 Document Discovery Request No. 2.

Respectfully submitted, LONG,, ISLAND LIGHTING COMPANY f / / [& ( b '

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Robert M. Rolfe

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Anthony F. Earley, pr.

Hunton & Williams l P. O. Box 1535 Richmond, Virginia 23212 Dated: APRIL 16, 1984

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Documents Withheld Under Claim of Work ProQuct and Preparation for Litigation Privilege l Request

! No. Date Author / Recipient Carbon Copies Subject Matter 6 -

William Gunther -

Table and Appendices -

L Time Summary of the 5% Power Tests

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LOCA Analysis (likelihood of pipe break)

Analysis of result of Chapter 15 events 10 3/2/84 Dr. H. Chau -

NRC regulatory requirements H. Chau, D. Baker, l E. Kosgra, P. LaBlanc l

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• L All documents described herein were prepared by LILCO personnel in specific response to l counsel's request that certain information be gathered in preparation for drafting, revising

l. and filing LILCO's Supplemental Motion for Low Power License or in preparation for the hearings to commence April 24, 1984.

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LILCO, April 16ME1984 "3NRC 14 MH 19 N052 CERTIFICATE OF SERVICE 6:_ OF SEQttiTAF '

' ':CnETING & SEPVICI BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-4 (Low Power)

I hereby certify that copies of Response to April 12 Document Discovery Requests were served this date upon the following by first-class mail, postage prepaid, unless otherwise noted.

Judge Marshall E. Miller, Edward M. Barrett, Esq.

Chairman Long Island Lighting Company Atomic Safety and Licensing 250 Old Country Road Board Mineola, New York 11501 U.S. Nuclear Regulatory Commission The Honorable Peter Cohalan Washington, D.C. 20555 Suffolk County Executive County Executive / Legislative Judge Glenn O. Bright Building Atomic Safety and Licensing Veteran's Memorial Highway U.S. Nuclear Regulatory Hauppauge, New York 11788 Commission Washington, D.C. 20555 Judge Elizabeth B. Johnson Bernard M. Bordenick, Esq.

Oak Ridge National Laboratory Edwin J. Reis, Esq..

P.O. Box X, Building 3500 Office of the Executive Legal Oak Ridge, Tennessee 37830 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Eleanor L. Frucci, Esq. Fabian Palomino,.Esq.

Atomic Safety and Licensing Special Counsel to the Governor Board 1 Executive Chamber,-Room 229 U.S. Nuclear Regulatory State Capitol Commission Albany, New York 12224 Washington, D.C. 20555

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Alan R. Dynner , Esq.

• Jay Dunkleberger, Esq.

Herbert H. Brown, Esq. New York State Energy Office

, Lawrence Coe Lanpher, Esq. Agency Building 2 Kirkpatrick, Lockhart, Hill, Empire State Plaza Christopher & Phillips Albany, New York 12223 8th Floor 1900 M Street, N.W. Mr. Martin Suubert Washing ton , D.C. 20036 c/o Congressman William Carney 1113 Longworth House Offt.ce Building Washington, D.C. 20515 James Dougherty, Esq. Mr. Brian McCaffrey 3045 Porter Street Nuclear Operations Support Washing ton , D.C. 20003 Long Island Lighting Company P.O. Box 618 Wading River, New York 11792 Martin Bradley Ashare, Esq. Docketing and Service Suffolk County Attorney Branch (3) 1 H. Lee Dennison Building Office of the Secretary Veterans Itemorial Highway U.S. Nuclear Regulatory '

Hauppauge, New York 11788 Washing ,p.C. 20555 ,

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Hunton & Williams ,

707 East Main Street /

P.O. Box 1535 ,/

Richmond, Virginia 23212 DATED: April 16, 1984

• By Federal. Express 1

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