ML20091G767
| ML20091G767 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/30/1984 |
| From: | Birkenheier J SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091G730 | List: |
| References | |
| OL-4, NUDOCS 8406040358 | |
| Download: ML20091G767 (51) | |
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'84 JJN -4 A10 51 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r FF:
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BRM;CH Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-4
)
(Low Power)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY'S FIRST DISCOVERY REQUEST TO LILCO RELATING TO LILCO'S APPLICATION FOR EXEMPTION Suffolk County hereby requests tha t LILCO respond to the discovery requests set forth below.
The definition of the term
" document" as used herein and other instructions concerning the response to the re, quests which follow, are the'same as that set forth on pages 1 and 2 of Attachment A of the letter dated April 11, 1984 from Douglas J.
Scheidt to T.S.
Ellis, III, a copy of which is attached hereto for convenience.
The documents requested below are to be produced at the offices of Kirkpatrick, Lockhart, Hill, Christopher & Phillips, 1900 M
- Street, N.W.,
Washington, D.C.,
or at such other locations as
'the parties may agree.
S W 40358 540530 PM ADOCK 05000322 1
O PDR j
7c 1.
Identify the names, occupations and affiliations of the witnesses who will be providing testimony on behalf of LILCO in support of the Application for Exe.nption dated May 22, 1984 (hereinafter, the " Application").
2.
For each witness identified in response to item 1, provide a copy of his or her resume.
3.
Provide 6 copies of Attachment 3 to the Testimony of W.
G.
Schiffmacher, dated April 20, 1984.
4.
With respect to the small building located immediately to the East of the four GM EMD DG units, - and identified by LILCO personnel during last week's site visit as the EMD Control Cubicle, provide the following information:
a.
The total weight of the cubicle including all neces-sary equipment inside it and other equipment that is part of,' attached to,_or directly supported by the cubicle.
b.
The exterior dimensions of the cubicle.
c.
Identify the location of.the center of gravity of the cubicle, with all necessary equipment inside it and other equipment that is part'of, attached to,-or directly supported by the cubicle.
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d.
Describe the design of'the foundation supporting the cubicle and the means, if any, by which the cubicle is anchored to the foundation.
Provide copies of all drawings and other documents, if any, which describe or depict the foundation or anchorage devices.
e.
Identify, describe and state the. location of all fixed. fire detection and mitigation systems and equipment in the cubicle.
Provide copies of all documents and drawings describing or depicting such systems and equipment.
If any such documents or drawings were provided in response to item 15 of the County's April 11, 1984 Document Request, identify such documents or drawings.
f.
Identify, describe and state the location of all electrical protection devices (e.g. under frequency.
protecti6n) employed in the cubicle, and identify the setpoints of each such device.
Provide copies of all documents and drawings depicting or describing such devices.
5.
With respect to each EMD diesel generator unit or module
--( each '" unit" being defined to include the diesel engine, the generator,.the' surrounding. housing, and enclosed 3-S
i equipment and materials), provide the following information:
- a..
The total weight of the EMD DG unit, including a full supply within the unit of necessary fuel, lubricants, coolant, and other materials.
b.
The exterior dimensions of the EMD DG unit.
c.
The center of gravity of the EMD DG unit including a full supply within the unit of necessary fuel, lubri-cants, coolant, and other materials.
d.
Describe the design of the foundation supporting the EMD DG unit, and the means, if any, by which the unit is anchored to the foundation.
Provide copies of all drawings and documents depicting or describing the foundation and anchorage devices.
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e.
Identify, describe and state the location of all fixed fire detection and mitigation systems and equipment in each EMD DG unit.
Provide copies of all documents or drawings describing or depicting such systems and equipment.
If any such drawings or documents were provided in response to_ item 15 of the County's April 11, 1984 Document Requests, identify-such documents or-drawings.
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6.
Provide copies of all electrical and mechanical drawings depicting the details of the electrical output connec-tions:
a.
between the EMD DG control cubicle and each EMD DG unit; and, c.
between the EMD DG control cubicle and 4 KV Bus 11.
7.
With respect to the fuel pipeline serving the EMD DG units, provide the following information:
a.
The specifications of the pipe, including the material, pipe thickness and diameter, and the exact centerline dimensions of each leg of the pipeline, including curvature radii of the elbows.
b.
Copies o*f all drawings or other documents depicting the piping layout from the tank truck to the point of entry to each EMD DG unit.
c.
Descriptions and specifications of the supports for the fuel pipe including material, dimensions, details of-the connection of each support to the pipe, and the locations of the supports along the pipeline.
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- O d.
Detailed specifications and the locations of the flexible joints in the fuel pipeline for the EMD DG units, including the design displacements and rota-tions of the flexible joints.
e.
The specifications of the means of connecting the pipe to each of the EMD DG units.
Provide copies of drawings and. documents depicting or describing such means of connection.
f.
The location or locations from which the tank truck will transfer fuel into the EMD DG fuel pipeline.
Provide copies-of all drawings and documents depicting or describing such location (s).
g.
For each location identified in response to (f),
prov,ide the specifications of the means of (i) o connecti,ng the tank truck to the pipeline and (ii) transferring fuel from the tank - truck into the pipe-line.
8.
Provide copies of all studies or analyses of, or other documents relating to, the potential effects of seismic events on:,
e n-a.
Any or all of the EMD DG units.
-b.
c.
The fuel line serving the EMD DG - units.
If any such documents were provided in response to items 26 or 31 of the County's April 11, 1984 Document Request, please identify such documents.
9.
Provide copies of all electrical and mechanical drawings and specifications of the battery system for the EMD DG units, including documents depicting the connection of the battery to each separate DG unit.,
10.
Provide all documents, drawings _and specifications depicting or describing the fuel pumping system for the EMD DG units, including that located in the " mother" die-sel unit 402.,
11.
With respect to'the fuel oil system for each EMD DG unit provide the following information s Copies of all drawings and other documents depicting a.
or describing the fuel oil supply and transfer system, including the interconnections between each EMD IX3 unit. <
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n b.
Copies of all drawings and other documents depicting or describing the fuel oil. tank on each EMD DG unit, including the level alarms, and where they are fi t-ted.
c.
Copies of all drawings and other documents depicting or. describing the fuel oil transfer pump for each EMD DG unit.
d.
Identify the capacities and ratings of the fuel oil transfer pump for each EMD DG unit.
a.
Identify the fuel oil consumption rates for each pos-tulated load for each EMD DG unit.
12.
With respect to the jacket cooling water system for each
- EMD DG unit, provide copies of all drawings and other.
- documents concerning.the jacket cooling water system.
i 13.
Identify, describe, and state the location of-all instru-mentation on each EMD DG. unit, including-thermometers, pressure guages, manometers, pyrometers, level switches and guages, and all alarm systems.
Provide copies of all drawings and documents which describe or depict such in '
strumentation.
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-14.
Provide a-detailed description and the design specifica-P tions of the starting and charging systems for each EMD DG unit, including, but not limited to:
(i) manufacturer, (ii) material, (iii) circuitry, (iv)-component parts, (v) 4 model' number,-(vi) operation limitations, and (vii) operating mechanisms for the (a) starting motors, (b) bat-tery, (c) its charger,-(d) the auxiliary transformer sup-plying the charger, and (e) the distribution systen sup-plying the auxiliary transformer.
Specify the number'of battery cells, and describe and provide drawings depicti6g the-intercell electrical connections.
Provide copies of i
^
any' drawings or documents depicting or describing each
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such system.
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L 15.
Provide copies of all records of performance kept during 2
all biweekl'y tests performed by' LILCO for each EMD ' unit.
i 4
.16. ~ ' Identify'the' location (s) of storage place (s) for lubrica-tion oil for the D4D DG units, and state the amount of'lu-brication oil for the EMD DG units stored in each such lo-cation.
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117.- - Identifyithe lubrication : oil; storage capacity of each.EMD DG' unit.
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.18.
With respect _ to the tank truck that will be used to store fuel oil for the EMD units, provide the following infor-mation:
a.
Total weight, when the tank is fully loaded, of (i) the tank and (ii) the entire tank truck.
b.
The exterior dimensions-of the tank and the entire tank truck.
c.
The_ location of the center of gravity of the tank and of the. fully loaded truck.
d.
Copies of all analyses or studies, related to the seismic characteristics or capabilities of (i) the entire tank truck (ii) the tank located on the truck and (iii) the transfer mechanism connecting the tank to the DMD fuel line.
The drawings and design details of fire detection and e.
mitigation equipment located on the tank truck.
f.
"The. design drawings, dimensions and capacity of~the catch basin, if any, which will surround the tank-truck.
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19.
With respect to the structure in which the 20 MW gas tur-bine is installed, provi'e the following information:
a.
The weight of the structure, including the gas tur-bine, all enclosed equipment and all other equipment that is part of, attached to, or directly supported by the structure, and a full supply of necessary
- fuel, lubricants, coolant and other materials.
b, The exterior dimensions of the structure.
c.
Identify-the center of gravity of the gas turbine, including the support frame for the turbine, all at-tached equipment and a full supply of necessary fuel, lubricantsr coolant and other materials.
Provide copies of all drawings and other documents depicting or describing such center of gravity.
d.
Describe'the design of the foundation supporting the structure and turbine frame, and the means, if any, by which the structure and.the turbine frame are an-chored. to the foundation.
Provide copies of all
- drawings or other documents depicting or describing such foundation or anchorage devices.
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. Identify, describe and state the location of all fixed fire detection and mitigation systems and equipment in the structure.
Provide copies of all drawings and other documents depicting or describing such systems and equipment.
If responsive documents or drawings were provided in response to item 15 of the County's April 11, 1984 Document Requests, iden-tify such documents or drawings.
f.
. Identify, describe and state the location of all electrical protection devices (e.g. under frequency protection) employed in the structure, and identify 4
the set points of each such device.
Provide copies of all drawings and other documents depicting or describing such devices.
o 20.
With respect to the building located along side and to the West of the 2D MW gas turbine structure, and identified by LILCO personnel during last week's visit as the " Gas Tur-bine Control Cubicle," provide the following information:
a.
The weight of the cubicle,. including all enclosed equipment' and all other equipment that ~is part of, attached to, or directly supported by the cubicle.
c.
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- b. :
The exterior dimensions of the cubicle.
c.
Identify the location of the center of gravity of the cubicle, including all-enclosed equipment and all other equipment that is part of, attached to, or di-rectly supported by the cubicle.
Provide copies of all drawings and other documents depicting or describing such center of gravity.
d.
Describe the design of the foundation supporting the cubicle, and the means, if any, by which the cubicle is anchored'to the foundation.
Provide copies of all drawings and other documents depicting or describing such foundation and anchorage devices.
e.
Identify, describe'and state the location of all fixed fire detection and mitigation systems and
~ equipmen,t:in the cubicle.
Provide copies of all drawings and other documents depicting or-describing such systems and equipment.
If responsive drawings or documents were'provided in response to item 15 of
'the County's April 11, 1984 Document Requests, iden-
-tify such drawings or-documents.
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i f.
Identify, describe and state the location of all electrical protection devices (e.g. under frequency protection) devices employed in the cubicle, and identify the setpoints of each such device.
Provide copies of all drawings and other documents depicting or describing such devices.
21.
With respect to the bolts or pins supporting the 20 MW gas
'I turbine on the frame inside the gas turbine structure, provide the following information:
a.
The dimensions of all support bolts and pins.
b.
The materials of the bolts and pins.
c.
The design stresses or forces in each'such bolt or pin, as well as the actual stresses or forces in the bolts or pins computed for normal operating conditions.
d.
Provide copies of all drawings or documents depicting er describing all details of the support frame for the 20 MW gas turbine.
22.
State the weight of the 20 MW gas turbine including a full supply of necessary fuel, coolant, lubricants, and other.
materials.
4.
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- 23. ' Identify the location of the center of gravity of the 20 MW. gas turbine, including a full supply of necessary fuel: coolant, lubricants and other materials.
Provide copies'of all drawings and other documents depicting or describing the location of such center of gravity.
.24.-
Describe the design of the foundation supporting the 20 MW gas turbine support frame and the means, if any, by which the turbine support frame is anchored to the found ation.
Provide copies of all drawings and other documents describing or depicting such foundation or anchorage de-vices.
'25.
Provide copies of all analyses or studies of, or other documents-relating to,.the potential effects of a seismic event on:
a.
. Toe structure in which the 20 MW gas turbine is lo-cated.
b.
'The 20 MW gas. turbine and its support frame.
- c..
-The Gas Turbine Control Cubicle.
d.
.The fuel line serving the 20 MW gas' turbine.
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1me 900,000 gallon fuel storage tank.
'If any such documents were provided in response to items 26 or 31 of_the County's April 11, 1984 Document Request, 4
or clarification item 3 of April 12, 1984, please identify such documents.
26.
Provide all qualification data relating to (i) seismic motion and (ii) vibration for the electrical protection equipment, if any, in (a) the EMD DG control cubicle or (b) the 20 MW gas turbine control cubicle.
Provide copies of all documents that relate to such qualification data.
27.
With-respect to the compressed air storage tank for the 20 MW gas turbine, provide the following information:
a.
The storage capacity (volume under standard conditions) of the compressed air storage tank.
b.
The design storage pressure.
c.
The expected usage.of compressed air per start at-tempt, and the minimum pressure at which a successful start can be made.
d.
Provide copies of any drawings depicting the ' storage tank-and all interconnections, pipes or fittings lietween the tank and the air-. compressor..
- 28. - With respect to'the fuel line running from the 900,000 gallon storage tank to the 20 MW gas turbine:
a.
Provide the specifications of the pipe, including material, pipe thickness and diameter, and the exac t centerline dimensions of each leg of the pipeline, including curvature radii of the elbows.
b.
Provide copies of all drawings and other documents depicting or describing the piping layout from the 900,000 gallon storage tank to the 20 MW gas turbine.
c.
Provide descriptions and specifications of the supports for the fuel pipe, including material, di-mensions, the means of connection of the supports to the pipe,. and the exact locations of the supports along the pipeline.
4 Provide 'etailed specifications and the locations of d.
d all flexible joints in the fuel pipeline connected to the 20 MW gas turbine, _ including the design displace-ments and rotations of the flexible joints.
29.
Provide the.following information with respect to'each of the following: (i) 13 KV to-69 KV trans former in the 69 KV switchyard; (ii) the RSS-transformer; and, (iii) the NSS trans fo rmer :
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Total weight, including internal liquids.
b.
Exterior dimensions.
c.
Describe the design of the foundation supporting the transformer and the means, if any, by which the transformer is anchored to the foundation.
Provide copies of all drawings and other documents depicting or describing such foundation and anchorage devices.
d.
Describe the design of the transformer internals (e.g., windings and core), including, the weights and centers of gravity of the internals, and methods of attachment of the internals to the transform base and tank.
e.
Identify the location of the center of gravity of the transformer, including internal liquids.
Provide copies o'f all drawings or.other documents concerning the location of such center of-gravity.
30.
Provide the following information with respect to (i) in-sulators of flexible design, and (ii) insulators of rigid design used on the 138 KV transmission lines, including the line connected to the NSS Transformer:.
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- D a.
The strength and stiffness of the insulators in the axial direction.
b.
Quantify the maximum calculated forces to which the insulators within the boundaries of the Sherchan cite are subjected (i) due to normal operating loads and (ii) due to seismic ground motion.
c.
Identify the locations of those insulators within the boundaries of the Shoreham site, which experience the maximum forces identified in response to subpart b-above.
d.
Provide copies of drawings and design specifications, including overall and cross-sectional dimensions, of the transmission poles, towers or other structures which support the insulators identified in response to subpart c above.
e.
Identify the materials of which the transmission poles, towers and other supports described in re-sponse to subpart d above are made.
f.
Describe the methods of fastening the insulators identified in response to subpart c above to the transmission poles, towers or other structures that support them. L
O 31.
With respect to the oil circuit breakers located on the 138 KV lines between the 138 KV switchyard incoming lines and the nonemergency switchgear room, provide the follow-ing information:
a.
The weight of each such circuit breaker when filled.
b.
The exterior dimensions of each such circuit breaker.
c.
Describe the design of the foundation for each such circuit breaker, and the means, if any, by which each such circuit breaker is anchored to its foundation.
Provide copies of all drawings and other documents depicting or describing such foundations and an-chorage devices.
. d.
Identify the location of the center of gravity of-each such circuit breaker when filled.
Provide copies o'f all drawings and other documents depicting or describing the location of the center of gravity of each such circuit breaker.
e.
Identify the maximum stress calculated in the insula-tor bushings for each such oil circuit breaker during
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Provide the accleration (in g's) at which such oil circuit breaker insulators are calculated to fa il,
and all documents which concern derivation or calcu-lation of this predicted failure point.
32.
With respect to the metal support' post supporting the out-put connections and devices of the 20 MW gas turbine at the point of transition from overhead conductors to buried cablos, provide the following information:
a.
The weight, dimensions, wall thickness, materials, and all other design data relating to the post.
b.
Describe the loads and stresses, both static and dy-namic, calculated to be experienced by this post.
State the locations of each such load and stress.
, Provide copies of all documents and drawir.gs which depict or describe such loads and stresses.
c.
State the dimensions and design specifications of the concrete foundation of the post.
Provide copies of all drawings and other documents depicting or
. describing the founda tion.
d.-
Describe *.he means by which the post is fastened to its founda tion..
Provide copies of all drawings and
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la other documents depicting or describing such means of fastening, such as anchor bolts.
33.
With respect to the 900,000 gallon fuel storage tank provid e the following information:
a.
Height and diameter.
'b.
. Thickness of its wall.
c.
The material of which it is made.
k d.
Provide detailed specifications of the foundation of the storage tank.
e.
Describe the method of anchoring the storage tank to its foundation.
Provide copies of all drawings and other documents depicting the fouridation and an-r j'
chorage devices.
f.
Provide copier of all drawings and other documents I
depicting the storage tank.
34.
Provide copies of all studies or analyses of, or other documents relating to possible effects of seismic events on the towers carrying the 69'KV or.138 KV transmission lines that enter the Shoreham plant.-
If documents W
1.
-a responsive to this request were provided in response to
. items 26 or 31 of the County's Request of April 11, 1984, or clarification item 3 of April 12, 1984, please identify those documents.
35.
Describe in detail the sequence of events required to ac-tivate the 69 KV alternate line.
Provide copies of all drawings and other documents that depict or describe such seouence of events, or equipment or systems used to imple-ment such activation.
Identify and describe all compo-nents or devices required to implement such activation.
36.
With respect to the study titled " Seismic Fragilities of Structures and Components at the Shoreham Nuclear Power Station", Report No. SMA 14304-01, performed by Structural Mechanics Associates (SMA), for the NUS Corporation s Was this, work performed as a subcontract to NUS under a.
a prime contract between NUS and LILCO?
If not, who sponsored the NUS work?
b.
Provide a copy of the latest version of the SMA report.
c.
Describe the scope and status of the NUS probabilistic risk assessment for SNPS which is referred to in the SMA study.
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i d.
Provide a copy of the NUS risk assessment and all
' analyses and data pertaining to it.
37.
Provide a copy of all draft and final versions of the Se-vere Accident Risk Assessment (" SARA") for Shoreham.
38.
With respect to the Severe - Accident Risk Assessment for Shoreham, provide:
a) a statement of work and schedule for its comple-
- tion, b) a description of its current status, and copies of all available analyses and data relating to that study, and c) a description of any analysis in ' the SARA which addresses off-site or on-site power loss.
39.
Provide a det' ailed master diagram (s) of the circuitry.
connecting the main transformers, the normal station service (NSS) and reserve station service (RSS) transform-ers, 69 KV and 138 KV switchyards, the 4160-V and'480-V AC Systems, the-DC-Bus S3 stems by division, the 20 ftw and 55 MW. gas turbines and their common transformer, the 20 MW gas turbine starting system components (including battery, 24 -
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charger, air _ compressor, and auxiliary transformer),
diesel generators, and batteries and accessories (de-tailing devices including circuit breakers, switches, and specifying voltage and current limitations, and device identifiers).
The diagrams should be fegible (unlike Exhibit C and Attachment 9 of the Affidavit and Testimony of W.G.
Schiffmacher, respectively).
1 40.
Provide (i)'. maintenance records, schedules, and proce-dures; and (ii) test results, schedules and* procedures, for:
a) the RSS transformer, b) the NSS transformer, and c) the 13 KV to 69 KV transformer-in the 69 KV switch-yard.
e 41.
Provide.a detailed diagram of the 69 KV line that bypasses the 69 KV switchyard.
42.
Provid e, where applicable, the (i) manufacturer, (ii) material, (iii)' circuitry, (iv) component parts, (v) model number, (vi) operation limitations, (vii) operating mecha-nism, and'(viii) any other distinguishing specifications 25 -
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l for the following items:
A.
The cooling system for each EMD DG unit, including coolant source (s), any intake or discharge l
facilities, and pumping equipment and power sources.
l Also state and describe the cooling cycle type.
B.
Electrical and mechanical connections between the diesels, the components of the starting mechanisms, fuel lines, sources and pumps, and cooling cycle, coolant cource(s) and pumps.
(Also provide copies of any line diagrams showing such electrical and mechan-ical connections and power supply sources and connec-tions for the battery. )
C.
The following circuit breakers:
l.
I 1.
Numbers ACB-1, 2, 3 and 4 (between each of the l
mobile diesel generators and the bus shared by them).
2.
Number 11.18 (between the diesel generators' bus and the 4 KV Bus Number 11).
3.
All 4 KV circuit breakers in the 4 KV switchgear-l:
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(Numbers' 400, 410 through 417, 420, 424, 430, W
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L 435, 440, 444, 450, 455, 460, 464, 470 and two unidentified breakers between the 480 V switchgear and buses 11 and 12).
4.
All 480 V circuit brcnkere in the normal 480 V system.
5.
All 480 V circuit breakers supplying the emer-gency 480 V buses.
6.
All 69 KV circuit breakers (Numbers 8Z -110 and 640, and the supply breaker to the 20 MW gas turbine ~GT-002).
7..
Also with respect to each circuit breaker listed in Subparts 1 through 6 above, identify and de-scribe any dual-coil features, operation and au-
.tomatic transfer capability.
D.
The following switches:
1.
Switch between'the normal station service trans-former (NSST-003) and circuit breaker Number 450 (leading.to Bus 11).
2.
All other 4 KV switches in the normal 4 KV
. system.
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'All 480 V switches in the 480 V switchgear.
4.
All 69 KV switches (Numbers 63F, 66F, 67F, 613, 616, 617, 623, 633, 640 and 643).
5.
The supply switch to the 20 MW gas turbine GT-002.
E.
The following buses:
1.
The normal large motor 4 KV buses (Numbers lA and 1B).
2.
The normal small motor 4 KV buses (Mumbers 11 and 12).
3.-
The emergency station service 4 KV buses (Nu,mbers 101, 102'and 103).
4.
The emergency 480 V buses (Numbers 111, 112 and
'113).
5.
The 480 V system buses (Number llA through llD and 12A through 12D).
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The mobile diesel generators' 4 KV bus.
7.
The 20 MW and 55 MW gas-to-bines' 13 KV bus.
F.
All voltage regulators to or from any of the buses listed above.
G.
The 4 KV-480 V transformers (Numbers T-Olla through T-OllD, T-012A through T-012D, and T101, T102 and T103).
H.
The 13-69 KV step-up transformer for gas turbines GT-001 and GT-002.
I.
The 13,800-120/240 V step-down transformer for the 20 MW gas turbine.
J.
The air start motor, pressurized air-storage vessel, and air ompressor for the 20 MW gas turbine.-
K.-
DC-powered distribution system, and associated bat-tery and its charger for the. 20 MW gas turbine.
L.
Fuel pumps and sources of pumping power.for the 20 MW gas turbine.
M.
Auxiliary transforr.er supplying power to the -air com-pressor, battery charger, and the AC fuel pump.
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Cooling cycle type, coolant source (s), any discharge or intake facilities, and. pumping equipment and power sources for the 20 MW gas turbine.
O.
Line diagram showing electrical and mechanical con-nections between the 20 MW gas turbine, its trans-fo rmer, the components of the starting mechanism, fuel lines, sources and pumps, and cooling cycle, coolant source (s) and pumps (Also indicate, describe and state location of power supply sources and con-nections for the battery, air compressor, and AC fuel pump).
43.
Provide detailed information, line diagrams, and physical layout' maps of any ~ changes in the proposed alternate ac power sources made or intended to be made in response to the requirements specified bythe NRC staff in Supplement
. Number 5 of the Safety Evaluation Report, April 1984, Docket No. 50-322, including, but.not limited to:
a.
Details of all circuit modifications, specifying the af fected switches, circuit breakers, and buses.and, providing the information items listed in Discovery Request Number 41.
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A listing and copies of the updated final emergency operation procedures for the proposed alternate ac power sources, including the 20 MW gas turbine and the EMD DGs, and specifying the sequences of actions and the progression of the positions of the circuit breakers and switches throughout the emergency period.
Identify all devices mentioned in the proce-dures and provide copies of all irawings or line dia-grams depicting such devices.
44.
Provide structural design specifications for both sections of the underground 69 KV line (from Wildwood to the Shoreham 69 KV switchyard and from there on to the reserve station service (RSS) transformer).
45.
With respect to the four EMD DG units, provides a.
Number of times each unit has undergone engine over-haul or repowering, time elapsed between each such service, parts replaced and age of replacement.
b.
The' operational configurations of the units during their deployment at the Connecticut site including the starting equipment and connections to load.
- 31
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46.
For the 20 MW gas turbine, provider a.
Operation and maintenance history (including weekly records) for the gas turbine prior to replacement of the fuel control and the starting air systems, i.e.,
the operation and maintenance history of the 20 MW Pratt-Whitney gas turbine, previously designated as the West Babylon Unit 1; specify failures, failure modes, starting di'f ficulties, and operation policy constraints (if any).
b.
Details specifying the modifications made on the West Babylon Unit 1, including replacement parts, age, and reliability.
47.
Provide information on source and location of the source o f control - power for the following automatic circuit breakers:
(a)
Numbers 8Z-100, 11.1B, 640, 1310 and 1330.
(b)
All the circuit breakers in the 138-KV switchyard.
(c)
All the circuit breakers inthe'4-KV switchgear.
(d). Switch breaker for the 20 MW (GT-002) gas turbine.
J
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~
(e)
Mobile diesel generators' individual switch breakers.
48.
Provide copies of all documents, responsive to the re-quests contained in Attachment A to the letter dated April 11, 1984 from Douglas J.
Scheidt to T.S.
Ellis and attached to the letter dated April 12, 1984 from Douglas J.
Scheidt to T.S.
Ellis, that have been located, gener-ated, created, revised, modified or finalized since the l
date of LILCO's responses thereto.
i 49.
State the basis for the assertion in the Application (at f
page 7) that the activities to be conducted during LILCO's proposed low power testing program "obviously.
.. are authorized by law," and provide copies of all documents upon which LILCO relies for support for such assertion.
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50.
Identify each of the, exceptional circumstances upon which LILCO intends,to rely for support of its request that its Application be granted, and provide copios of all documents upon Which LILCO relies to support the exis'tence of such exceptional circumstances.
51.
State the basis for LILCO's assertion (at footnote 10, i
page 35 of the Application) that "nothing in LILCO's ex--
emption request has any impact on security," and
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e provide copies of all documents upon which LILCO relies for support for such assertion.
52.
State the basis and provide copies of al1 documents relied upon for support for the following assertione la
- ka Sn-plication:
a.
"The Shoreham proceeding has become prejudicially burdensome to LILCO."
(p. 17);
b.
"Many of LILCO's people have been compelled to devote inordinate amounts of their time and energy to licensing struggles."
(p. 17);
c.
The Shoreham proceeding "has been prejudicial to LILCO because it has created the perception that licensing litigation over Shoreham may never end (p. 18);
d.
The Shoreham proceeding "has been prejudicial to LILCO hecause it has created the perception that the plant may never come on line because a merits decision on its operation will be delayed for one reason or another, over and over again." (p. 18);
34
it.
1 l
e.
"The prejudice to LILCO caused by the [Shoreham pro-ceeding] is not justified by its substantive results to date." (p. 18).
i l
50.
With respect to the assertion listed in subpart (b) of l
[
item 52 above, identify the "LILCO people" who, in LILCO's i
l view, have opent " inordinate" amounts of time on licensing matters, and for each individual identify the time (dates and hours) which LILCO believes to have been " inordinate,"
j and the reason such time is believed to have been "inordi-nate."
54.; With respect to the assertion in the Application (at 17-18) that the licensing litigation "has also cost LILCO substantial sums of money," identify the amounts of money i
spent by LILCO, the dates spent, and the recipiants, as follows:
a.
legal fees on work relating to NRC licensing proceed-t i
ings; t
t l
b.
legal fees on work relating to litigation involving i
-Shoreham other than that before the NRC; c.
consultant and other expert witness fees and related j,
e costs for work relating to NRC proceedinos involving j
Shoreham; 4
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d.
consultant and. expert witness fees and related costs for work relating to litigation, other than before
-the NRC, involving Shoreham; e.
costs related to the filing of LILCC's 1003 Low Power License Motion; f.
costs related to the filing of LILCO's March 20, 1984 Low Power License Motion and the documents and activities, including testimony and hearings, related thereto; and g.
all costs related to LILCO's decision to create the proposed AC system that is the subject of the Appli-cation and the implementation of that decision.
-55.
Provide copies of all documents which relate in any way-to
~ the answers to the. preceding request.
~
56.
State: the basis for the assertion', at p.
20 of the Appli-cation, that the requested exception "will accelerate Shoreham's availability to. reduce this country's reliance-on ' foreign oil," and ' provide ' copies of all~ documents upon which.LILCO relies for support for such. assertion.
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l 57.
By how much time, in LILCO's view, would the granting of an exception from GDC 17 " accelerate" Shoreham's avail-
~
ability?
What is the basis for LILCO 's view?
Provide all documents that relate in any way to this matter.
58.
What constitutes " availability" as used in the statement referenced in item 56 above?
59.
Quantify the assertion, at page 20 of the Application, that "a substantial portion of New York State's electric power" is dependent upon foreign oil imports, and provide copies of all documents upon which LILCO relies for support for such assertion.
60.
Identify _the total quantities and types of foreign petro-leum products used by LILCO, from 1981 to date, to gener-ate _ electricity, and provide the following information concerning such foreign petroleum products used by LILCO:
a.
The quantity and prices of such - foreign petroleum products actually consumed on a monthly basis (from 1981 to.date) in each of LILCO's power plants.
-b.
the nations in which such petroleum products were produced.
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the quantities of the products that were produced in each nation.
d.
the nations in which such products were refined.
e.
the quantities of the products refined in each nation.
l f.
the name and location of each of LILCO's suppliers of the products.
~61.
Identify the quantities and prices of domestic (including Alaska) petroleum products consumed, on a monthly basis,.
in each of LILCO's power plants from 1981 to date.
62.
Identify the type and' volume of petroleum products LILCO has had in storage from 1981 to date, and identify the storage locations and storage costs.
63.
' Identify the huantities and locations of all~ crude" oil re-serves and crude oil production owned by_LILCO at any_ time during:.the _ period fl981 to date.
.64.
Of th'e. quantities _of'(a) foreign,.and (b) domestic, petro-leum products consumed in LILCO's power plants ~from 1981 to date, what quantity perl year has_been purchased by.-
~
LILCOLunder-: firm contracts and what' quantity per-year under, spot market' contracts?
138 --
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- 65. " Identify the quantity of natural gas consumed by each of LILCO's power plants from 1981 to date, and state the names-of the suppliers of such natural gas and the pricer paid.
66.
~ Identify the quantity and prices of coal consumed by each of LILCO's power plants from 1901 to date, and state the names of the suppliers of such coal.
67.
Provide all documents which relate in any way to items 60-66 above.
68.
At pages 19-20 of the Application, LILCO asserts, "the plant is now. ready to load fuel and conduct low power testing." Based on observations made during a site visit cus May 24, the County assumes the assertion is not liter-ally true'.
Identify all activities or approvals which must be undertaken, accomplished, completed, or obtained before (i)' fuel loading, and-(ii) low power testing,.could-actually commence,. and for.each such activityf or approval, state:
a.
.who must perform or approve it ;-
I b'. -
tihat'is involved in_the: activity or-approval;
- 39.-
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f.
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c.
how long LILCO believes the activity or approval would take.
69.
State the basis, and all underlying assumptions, for LILCO's assertion, at pages 20-21 of the Application, that approval of the exemption request will result in economic benefits of $90-135 million," and provide copies of all documents upon which LILCO relies for support or which relate in any way to this assertion.
70.
With respect to the assertion referenced in item 69 above, state:
a.
To whom is-the referenced " benefit" expected to ac-crue?
b.
When is the-referenced " benefit" expected to accrue?
71.
Provide copies of all documents which relate in any way to subparts a or b of item 70.
72.
ProvideEcopies of all analyses - or studies of, or other documents relating to :the cost of degommissioning Shoreham if the plant operated at five percent power"but not at any
~
higher power levels.
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F 73.
State the basis for the assertion, at page 21 of the Ap-plication, that "[i]f the low power testing program is al-ready completed [by the end of 1984], several months can be cut off the time it would otherwise take to achieve commercial operation," and provide copies of all documeats upon Which LILCO relies for support for such assertion.
74.
With respect to the assertion referenced in item 73 above, identify all assumptions which underlie the assertion, including all prerequisites which LILCO believes must be satisfied in order "to achieve commercial operation."
75.
State the basis for LILCO's assertion, at pages 21-23 of the Application, that GDC 17 is an " unnecessary regulatory requirement" Which should be eliminated, and provide copies of all documents upon which LILCO relies for support'of this assertion.
76.
Provide. copies of all documents-upon which LILCO relies
-for support for its assertion, at..page 23 of the Applica-tion, that there is an " internal ~ inconsistency -betwIen the g
Commission'sregulationpromotinglowpowerlicensithgand the now-mandated inflexibility of GDC 17."
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77.
Is it LILCO's position that the Commission has evidenced an intent to eliminate the requirement set forth in GDC 17 with respect to low power operation?
(See Application at 23.)
If yes, state the basis for that position and provide copies of all documents upon which LILCO relies for support for such position.
78.
At page 24 of the Application, LILCO asserts that "the Commission should recognize the benefits of interim low power licensing by granting the exemption Identify each and every " benefit" which LILCO asserts would accrue if its requested exemption were granted, and should be "recognised" by the Commission, and for each such benefit, identify (a) the beneficiary, (b) when such benefit would accrue, and (c) the assumptions or prerequi-sites-which must be satisfied in order for the benefit to Prov,ide copies of all documents upon which LILCO accrue.
relies for support-for its assertions.
k 79.
State the basis ' for the assertion, at page 25 of the Ap-3:
D plication,-that "two of the~three.TDI diesels have.suc-p p-:
cessfully completed their preoperational testing," and c
m e
Il provide. copies of all documents upon which LILCO relies 4
for support for such assertion.-
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h a-j
e
.p.
'd-80.
Provide copies of all documents upon which LILCO relies for support for its assertion that " installation and testing [of the Colt diesels] are expected to be completed by mid-1985."
(Application at 25.)
81.
Identify all " physical modifications" that (a) are neces-sary, and (b) "have begun," to accommodate the Colt die-sels, as stated at page 25 of the Application.
82.
Is it LILCO's position that the training described at pages 27-28 of the Application will not be conducted if the requested exemption is not granted?
83.
Provide copies of all documents relating to the " standard low power testing program" referenced at page 28 of the Application.
84.
Identify every difference between the " standard low power testing program" (Application at 28) _and the proposed LILCO training program.
- 85..
Is it LILCO's position that there is no domestic (i.e.
U.S.
produced and refined) fuel oil available to be used in LILCO's oil-fired power plants?
If the answer.is "yes",!what is thel basis for this position?
Produce all
. documents which relate in any way to this - position.. If p a
Lt
_9 the answer is "no",
why has LILCO not used such domestic fuel oil for its oil-fired plants?
Produce all documents which relate in any way to this position.
86.
Provide copies of all documents relating to the decision to install the 20 MW gas turbine on the Shoreham site.
1 87.
With respect to all current LILCO employees who are licensed reactor operators, provide the following infor-mation:
Identify each such individual hy name and current job a.
title.
Identify also whether each individual is a
L scheduled to be part of a regular operating shift.
b.
State the number of years of actual BWR operating ex-perience for each such individual.
c.
State the length of time each such individual has been employed by LILCO.
d.
Identify each such individual who has notified LILCO that he or she will. leave LILCO's employ, and state the date'on which he or she will' leave LILCO's employ.
- 44 -
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- 88.. With~ respect to all individuals other than licensed reac-tor operators, who are involved in the management chain of
~
command for SNPS, from operator supervisors through Chair-man of the Board, provide the following information:
a.
Identify each such individual by name and current job title.
b.
State the number of years of actual BWR operating ex-
~
perience for each such individual.
c.
State the length of time each such individual has f
been-employed by.LILCO.
-d.
Identify each.such individual who has notified LILCO that he or she will leave LILCO's employ, and state the.date on which he or she will leave LILCO's employ.
in' ividuals who have been hired by d
89.
With-respect to all
~
LILCO to serve as. reactor. operators of SNPS, but who have not yet begun. working for. LILCO at SNPS, provid e ; the fol-lowing 1in formation.
e
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P a.
Identify each such individual by name, current em-ployer and current job title.
O b.
State the number of years of actual BWR operating ex-perietace for each such individual.
c.
State whether each such individual is a licensed re-actor operator.
d.
State the date on which LILCO hired each such individual.
90.
At page 21 of the Application LILCO states that "it costs approximately S45 million per month for Shoreham to sit idle..."
With respect to this assertion, identify all items of cost that comprise the estimated monthly cost of
$45 million, including (a) the amount of each such item, (b) a description of each such item, and (c) identifica-tion of the party or parties to wh'ich payment is owed.
. = _ _ -
F-
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.- c,F Fespectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11786 HerbfrtT17 ~ Brown Lawvence Coe Lanpher Karla J.
Letsche John E.
Birkenheier KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Attorneys for Suf folk County DATED:
May 30, 1984
- 47'-
d 1
ATTACHMENT A 1
The County hereby requasts LILCO to produce the documents listed below.
For purpose's of this_ request, the word " documents" is'to be given its broadest meaning to include, without limi-
.tation, correspondence, memoranda, reports, notes, computer printouts and other forms of written data and material, all whether in draft or final form.
Furthermore, (i)
If a document has been prepared in several copies, or additional copies have been made that are not identical (or are no longer identical-by reason of any subsequent notation on or other modification of a copy),
each nonidentical copy is to be construed as a separate document if the notations or other modifications thereon are significant to the substance of the document. ' Identical copies need not be supplied.
(ii)
If any document' covered by these requests is withheld under a claim of privilege, furnish a list of such document (s) with the following information:
data, author, addressee or recipient,--persons to whom copies were
~
furnished, subject matter, the privilege which is' claimed, and the requests which call for such document (s)..
~
h, h.
01 i, - >
(iii)
If any requested document was but is no longer in your possession or subject to your control, state what dis-position was made of it.
~
Unless expressly limited, documents to be produced include not only those in the possession or subject to the control of LILCO, but also documents in the possession or subject to the control of LILCO's consultants, persons under contract with LILCO and vendors of equipment or services to LILCO.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-4
)
(Low Power)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County's First Discovery Request to LILCO Relating to LILCO's Application for Exemption have been served on the following this 30th day of May 1984, by U.S. mail, first class,'except as otherwise noted.
Judge Marshall E. Miller, Chairman Edward M.
Barrett, Esq.
Atomic Safety and Licensing Board Long Island Lighting Company U.S.. Nuclear Regulatory Commission 250.Old Country Road Washington, D.C.
20555 Mineola, New York 11501 Judge Glenn O.
Bright Honorable Peter Cohalan Atomic Safety and Li' censing Board Suffolk County Executive U.S.
Nuclear Regulatory Commission H. Lee Dennison Building Washington, D.C.
20555 Veterans Memorial Highway Hauppauge, New York 11788 Judge Elizabeth B. Johnson Oak Ridge National Laboratory Fabian Palomino, Esq.
P.O.
Box X,-Building 3500 Special Counsel to the Oak Ridge, Tennessee 37830 Governor Executive Chamber, Room 229 Eleanor L.
Frucci, Esq.
State Capitol Atomic Safety and. Licensing Board Albany, New York 12224 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555:
W.
Taylor Reveley, III, Esq.
Anthony F.
Earley,.Jr., Esq.
Bernard M..Bordenick,.Esq.
Robert M.'Rolfe, Esq.
.Edwin J. Reis, Esq.-
Hunton & Williams
? Office of' Exec.-Legal' Director.
-707 East Main Street
'U.S.
Nuclear Regulatory Commission
. Richmond, Virginia 23212 Washington, D.C.
20555
_hL Mr. Martin Suubert James Dougherty, Esq.
3045 Porter Street, N.W.
c/o Cong. William Carney 1113 Longworth House Office Washington, D.C.
20008 Building Washington, D.C.
20515 Mr. Brian McCaffrey Long Island Lighting Company Martin Bradley Ashare, Esq.
Shoreham Nuclear Power Sta.
P.O. Box 618 Suffolk County Attorney H. Lee Dennison Building North Country Road Veterans Memorial Highway Wading River, New York 11792 Hauppauge, New York 11788 Jay Dunklebergcr, Esq.
Docketing and Service Branch New York State Energy Office Office of the Secretary Agency Building 2 U.S. Nuclear Regulatory Cohmission Empire State Plaza Washington, D.C.
20555 Albany, New Ycrk 12223 Stephen B.
Latham, Esq.
John F.
Shea, Esq.
Twomey, Latham and Shea 33 West Second Street Riverhead, New York 11901 l
Y L
JohnsE. BirRenheier KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Dated: May 31, 1984 By Federal Express j
-