ML20091C658
| ML20091C658 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/29/1991 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Ferguson G, Kline J, Margulies M Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091C661 | List: |
| References | |
| CON-#391-12068 OLA, NUDOCS 9108070052 | |
| Download: ML20091C658 (3) | |
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DONALD P. IRWIN reccewo%c (so4) 7ee.ero File No.: 24566.100000 raes..mc iso 4) 7ee-eais DIRrrt DIAL: (804) 788-8357 L
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July 29,1991 l
VIA TELECOPY v3 Administrative Law Judge Morton B. Margulies, Chairman h
Administrative Law Judge Jerry R. Kline
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Administrative Law Judge George A. Ferguson Atomic Safety and_ Licensing Board 5
7 U.S. Nuclear Regulatory Commission d
Washington, D.C. - 20555 s
l Docket No. 50-322-OLA:
l-Contention 5(d)(Physical Security Plan)
' Gentlemen:
In proposed Contention 5(d) and in argument at the prehearing conference on July 26, Petitioners alleged that LILCO had violated the Shoreham Security Settlement Agreement with Suffolk County in unspecified ways when it revised the number of armed responders in the Shoreham Physical Security Plan.
LILCO opposed this subpart of the contention on a variety of grounds not involving direct documentation on.the-issue.
Since - the conference, I have - confirmed that such documentation does exist in the form of a letter bearing serial number SNRC-1691, dated March 3.0,1990, and an attached affidavit of the same date, both of them signed by William E.
Steiger, Jr., Shoreham' plant manager at the time. Both were publicly filed with the NRC. I also enclose a contemporaneous internal Shoreham memorandum to file, no.90-066, 'which recounts the discussion with the cognizant Suffolk County Police Department official concerning
-- the proposed changes to the Security Plan. In order to complete the record,' and to assist in resolving the matter, I enclose these documents for the information of the Board and parties.
91080700D2 910729 PDR ADOCK 05000322
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HUNTON & WILLI AM S July 29,1991 Page 2 Mr. Steiger's Af6 davit attached to SNRC-1691 states, in pertinent part:
- 4. In accordance with paragraph X of the Final Security Settlement Agreemententitled,"Implementationof this Agreement, including Future Changes or Revisions," representatives of LILCO did consult with and solicit the guidance of the Suffolk County Police Department prior to seeking the above mentioned proposal to revise the Shoreham Physical Security Plan.
internal Shoreham memorandum to Sle, serial no.90-066 (March 28,1990), states, in pertinent part:
On January 4,1990, the Plant Manager, Jack Notaro, spoke with Deputy Chief Cosgrove, 6th Precinct, Suffolk County Police Department concerning the proposed request to amend the Shoreham Physical Security Plan.
Speci6cally discussed were the reduction in the number of vital areas, and the reduction in the number of armed responders.
Deputy Chief Cosgrove expressed no concerns with the proposed changes.
LILCO believes that these documents dispose of any issue as to LILCO's compliance with the Settlement Agreement in connection with the change in the size of the Shoreham armed responder force.
Respectfully submitted, f/,
Donald P. Irwin Attorney for Long Island Lighting Company Enclosures cc w/ enclosures. Attached Service List
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JJL I" '91 15:22 AT&T W 9025 P_LG YC pgg LONG ISLAND UGHTING COMPANY SHORENAM NUCLEAR POWER STATION P.O. SOM 918, NORTH CoVWT1tY ROAD e WADeMe STIVER M.y.1170s j
l WILLIAsf L STtt09M. m, assettAxt vsoe enageneori.asuCLtAa orenAnoose SNRC-1691 MAR 3 01990 U. S. Nuclear Requiatory Cosaission ATTN:
Document Control Desk Washington, D.C.
20555 Affidavit In Supp et of LILCO's Request to Amend the Shoreham Physical Security Plan Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Reft LILCO (W. E. Steiger, Jr.) letter SNBC-1672 to NRC (Document Control Desk) dated January 5, 1990; subject LILCO's Request to Amend the Shoreham Physical Security Plan Gentlemen:
The attached affidavit is provided in support of the request contained in the reference letter.
The affidavit containa information which demonstrates that LILCO complied with the terms and conditions of the November 1982 Final Security Settlement Agreement with Suffolk County and the NRC.
Please do not hesitate to call this office if you have any questiona or require additional infortsation.
Very truly yours, William E. Steiger, Jr.
Assistant Vice President wuclear Operations GJG/ap Enclosure cct S. Brown T. T. Martin L. Doerflein
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