ML20091D150
| ML20091D150 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/23/1984 |
| From: | Rolfe R LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091D144 | List: |
| References | |
| OL-4, NUDOCS 8405310053 | |
| Download: ML20091D150 (11) | |
Text
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LILCO, May 23, 1984 UNITED STATES OF AMERICA
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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-4
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(Low Power)
(Shoreham Nuclear Power Station, )
Unit 1)
)
REQUEST FOR PRODUCTION OF DOCUMENTS TO:
Lawrence Coe Lanpher, Esq.
Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.
8th Floor.
Washington, D.C. 20008 Counsel for Suffolk County j
Long Island Lighting Company (LILCO), by counsel, requests that Suffolk County produce and permit LILCO to inspect and copy the following documents in Suffolk County's possession, custody or centrol.
Such documents should be produced at the office of Hunton & Williams, 707 East Main l
l Post Office-Box 1535, Richmond, Virginia on or before
- Street, l
June 6, 1984 at 10:00 a.m.
8405310053 840530 l
PDR ADOCK 05000322 l
PDR i
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If any documents otherwise respensive to these requests are withheld by the County under a claim of any privilege or the County's response shoula not produced for any other reason, author, all recipients and the subject matter specify the'date, of the document in sufficient detail so that the document may be identified and the claim of privilege evaluated.
Resumes of all witnesses whom the County expects to 1.
call at the hearings in this proceeding.
2.
All documents reflecting, containing, discussing, pertaining to or generated as a result of a work concerning, plan for comparative assessment of LILC,O's power system configuration for use during low power testing as proposed by LILCO with the power system configuration described in LILCO's ESAR for Shoreham.
i discussing, All documents reflecting,.containing, 3.
pertaining to or generated as a result of any concerning, l
comparative assessment of LILCO's power system configuration for use during low power testing as proposed by LILCO with the power system configuratien described LILCO's FSAR for Shoreham.
l 4.
All documents reflecting, containing, discussing, l
concerning, pertaining to, generated as a result of, or supporting any opinion intended to be expressed at the hearings i
I
f or in any testimony to be filed in this proceeding by any o the following:
(a)
Robert K. Weatherwax; George Dennis Ely;
-(b)
(c)
Ancesh Bakshi; (d)
Dr. Christian Meyer; (e). Gregory C. Minor; Professor Jose M. Reesset; (f)
(g)
Dale Bridenbaugh; (h)
Richard Hubbard; Mohamed M. El-Casseir; (i)
Stanley Christensen; (j)
(k)
Richard Roberts; (1)
Phillip McGuire; any other consultant er other person whom the County expects to call as a witness (m) at the hearing in this proceeding.
discussing, All documents reflecting, containing, S.
y concerning, pertaining to er generated as a result of an l
(i) analysis or report of the study, investigation, (iv)
(iii) general performance, reliability, (ii) cperation, f any ability to operate during or after a seismic event o (vi) procedures for or magnitude, (v) quality assurance, de in operating any of the following to which reference is ma i
LILCo's Supplemental Motion and Application for Exempt on:
,1
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the GM EMD diesels; (a) the to MW gas turbine; (bl any or all of the gas turbines at (c)
Holtaville; the gas turbine at Southcld; (d) the gas turbine at East Hampton;
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(e) the gas turbines at any of LILCO'S (f) major gen 2 rating stations; LILCO's interconnections with the New York Power Pool or New England Power (g)
Exchange; (h), LILCO's transmission lines or related equipment or facilities serving l
Shoreham either directly or indirectly.
discussing, All documents reflecting, containing, i
6.
sult of any concerning, pertaining to or generated as a re investigations, reports or studies
- analyses, for operation of
- cpinions, l
i concerning operating procedures or train ngst 5 above.
any of the power sources described in Reque containing, discussing, All documents reflecting, 7
result of any concerning, pertaining to or generated as ainvestigation l
opinion, report,
- analysis, to Shoreham or
- study, concerning LILCO's ability to restore AC power AC power to Shoreham the time within which LILCO can restore Request 5 above.
using any of the power sources described in
All documents reflecting, containing, discussing, 8.
concerning, pertaining to or generated as a result of any analysis or investigation opinion, study, calculation, report, concerning or otherwise pertaining to the length of time within which AC power must be restored to shoreham in the event of any of the accidents or transients included in the Chapter 15 in Shoreham's FSAR or for any other accident or safety analysis transient which the County contends or may contend is relevant in any way to the public health and safety issues to be heard incident to LILCO's Supplemental Motion or Application for Exenption.
All notes, correspondence with any person, 9.
documents, charts, graphs, drawings, ealculations, computer and other writings and recordings of any tapes or printouts, kind generated by or on behalf of any of the following persons analysis, study, in connection with any investigation, report, calculation or opinion concerning any aspect of LILCO's Supple-f mental Motion for Low Power License or Application for Exemption:
(a)
Robert K Weatherwax; (b)
George Dennis Ely; (c)
Aneesh Bakshi; (d)
Dr. Christian Meyer; i
l I
. (e)
Gregory C. Minor; (f)
Professor Jose M. Roesset; (g)
Dale Bridenbaugh; (h)
Richard Hebbard; (i)
Mohamed M. El-Gasseir; (j)
Stanley Christensen; (k)
Richard Roberts; (1)
Phillip McGuire; (m) any other consultant or other person whom the County expects to call as a witness at the hearing in this proceeding.
10.
All documents reflecting, containing, discussing, concerning, pertaining to or generated as a result of any review, opinion, study or analysis by any employee or consul-tant of the County concerning the Supplemental Evaluation Report issued (Supplanent No. 5) by the NRC Staff for Shoreham.
11.
All documents reflecting, containing, discussing, concerning, pertaining to or generated as a result of any fault-tree analyses for Shoreham during 5% low power testing conditions as proposed by LILCO or any extended risk assessment for Shoreham.
12.
Copies of the following reports and analyses authored or co-authored by Robert Weatherwax:
L
l
. (a)
" Comments on Assessment of Accidental Pathways, subtask D Report (draft), A.D. Little, Inc., dated February, 1978" for Office of Radiation Programe, EPA, July 12, 1978;
'(b)
"Probabilistic Fission Power Plant Risk Analysis:
Its Virtues and Limitations" presented as an invited paper at the American Fiscal Society General Meeting, April, 1975, and published in nulletin of the Atomic Scientists, S ep t e.:. c r, 1975; (c)
"Probabilistic Risk Analysis of Nuclear Systems, Princeton University Seminar, May, 1975; (d)
" Applications of Multi-Phase Fault Tree Analysis," presented as part of Industry Course entitled RISK ANALYSIS given at Flow Research, Inc., Kent, Washington, February, 1973; (e)
"A Comparison of Fault Tree Quantification Techniques," presented to System Safety Society Symposium, University of Southern California, April, 1972.
13.
All reports, studies, investigations, analyses and any other documents reflecting, concerning, containing, discussing, pertaining to the effect of the SSE, were it to occur at or near Shoreham, on the supply of AC power to Shoreham.
LONG ISLAND LIGHTING OMPANY Ro5ert M. Rolfe
/
Anthony F. Earley, Jr.
I
nunten & williams Post Office Box 1535 Richmond, Virginia 23212 DATEDs May 23, 1984 e
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UNITED STATES OF AMERICA'
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00LKETED UN'RC NUCLEAR REGULATORY COMMISSION T4 MAY 30 A1155 Before the Commission OmCE 5 SEChtJ 00CKETitlG & SEF*
BRANCH
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-4 (Shoreham Nuclear Power Station,
)
(Low Power)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby-certify that copies of JOINT SUFFOLK COUNTY AND NEW
-YORK STATE SUPPLEMENT TO REQUESTS FOR CLARIFICATION OF COMMIS-SION'S MAY 16 ORDER, dated May 3Bn, 1984, have been served to the following this'3Gth day of May 1984 by U.S. mail, first class, by hand when indicated by two asterisks, and by telecopier when indicated by one asterisk.
Judge Marshall E.
- Miller, The Honorable Peter Cohalan Chairman Suffolk County Executive Atomic Safety and Licensing County Executive / Legislative Board Building U.S.
Nuclear Regulatory Veterans Memorial Highway Commission Hauppauge, New York 11788 East West Towers (North Tower) 4350 East-West Highway Edwin J.
Reis, Esq.
Bethesda, MD 20814 Bernard M.
Bordenick, Esq.
U.S.
Nuclear Regulatory Judge Glenn O.
Bright Commission Atomic Safety and Licensing Maryland National Bank Board Building U.S.
Nuclear Regulatory 7735 Old Georgetown Road l
Commission Bethesda, MD 20814 East West Towers (North Tower)
Attn:
NRC lst Floor Mail Foom 4350 East-West Highway Bethesda, MD 20814 Fabian Palomino, Esq.
Special Counsel to the Judge Elizabeth B.
Johnson ##
Governor Oak Ridge National Laboratory Executive Chamber, Room 229 P.O.
Box X, Building 3500 State Capitol Oak Ridge, Tennessee 37830 Albany, New York 12224
.. James.Dougherty, Esq.
Docketing and Service-Branch 3045 Porter St.reet Office of the Secretary Washington, DC 20008 U.S.
Nuclear Regulatory Commission Washington, D.C.
2055 Martin Bradley Ashare, Esq.
Stephen B.
Latham, Esq.
Suffolk County Attorney John F.
Shea, Esq.
H. Lee Dennison Building Twomey, Lat. ham & Shea
. Veterans-Memoria] Highway 33 West Second Street Hauppauge, New York 11788 Riverhead, New York 11901 Jay Dunkleberger, Esq.
Mr. Martin Suubert New York State Energy c/o Congressman William Carney Office 1113 Longworth House Office Agency Building 2 Building Empire State _ Plaza Washington, DC 20515 Albany, New York 12223 W.
Taylor Reveley, III, Esq.
Mr. Brian McCaffrey Anthony F. Early, Jr.,
Esq.
Long Island Lighting Cotipany Robert M.
Rolfe, Esq.
Shoreham Nuclear Power Station Hunton & Williams P.O.
Box 618 P.O.
Box 1535 North Country Road 707 East Main Street Wading River, New York 11792 Richmond, Virginia 23212 Eleanor L.
Frucci, Esq.
Edward M.
Barrett, Esq.
Atomic Safety and Licensing Long Island Lighting Company Board 250 Old Country Road U.S.
Nuclear Regulatory Mineola, New York 11501 Commission Washington, D.C.
20555 Nunzio J.
Palladino, Chairman **
Commissioner Victor Gilinsky**
U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Room 1124 Room 1103 1717 H St'eet, N.W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Commissioner James K. Asselstine** Commissioner Thomas M.
Roberts U.S.-Nuclear Begulatory U.S.
Nuclear Regulatory Commission Commission Room 1136 Room 1113 l ~' 17 H Street, N.V.
1717 H Screet, N.W.
Wash 3ngton, D.C.
20555 Washington, D.C.
20555
-3
' Commissioner Frederick M.
Bernthal **
U.S.. Nuclear Regulatory Commission Room 1156 1717 H Street, N.W.
Washington, D.C.
20555 g
ynr - -- s Herbert H.
Brown, Esq.
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, NW, Suite 800 Washington, DC 20036 Dated:
May 30, 1984 By Telecopy By Hand By Federal Express
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