ML20063P091

Motion for Further ASLB Direction on Conduct of QA cross-examination.Steps Listed to Ensure Fair & Efficient Litigation of QA Issues.Certificate of Svc Encl

ML20063P091
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/05/1982
From:	Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8210120307
Download: ML20063P091 (60)

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LILCG, Octob$r 5, 1982 00CKETED UStGC )

jg @,1 -8 50 58 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION fj,Fj.

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Before the Atomic Safety and Licensing Board j In the Matter of )

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

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(Shoreham Nuclear Power Station, )

Unit 1) )

LILCO'S MOTION FOR FURTHER BOARD DIRECTION ON THE CONDUCT OF QA CROSS-EXAMINATION I. Introduction This pleading in submitted in response to suffolk County's letters of September 30 and October 1 (Attachments 1-4), which add numerous new findings and audits to the list already provided to the Board and parties. LILCO is surprised and frustrated with this latest attempt at QA document designa-tion and will demonstrate:

(1) that the County has expanded sub-stantially the list of documents to be used on cross-examination; (2) that the County's new, expanded listing is contrary to the spirit of the Board's September 22 directive; 1

(3) that, contrary to the indications given by the County, it had not prepared its cross-examination prior to tha start of the QA testimony, and has only now done so;

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(4) that given the bulk of material now designated for cross-examination, it is likely (unless the Board intervenes) that LILCO's witnesses will be on the witness stand 6-10 more weeks, an unfair and intol-erable result; (5) that the County has failed to abide by the agreements concerning scheduling reached by the parties and approved by the

+ Board on August 27; and (6) that the County's repeated failure to specify documents adequately has jeopardized the ability of LILCO's witnesses to prepare for cross-examination.

Consequently, LILCO asks that the Board take the following steps in order to ensure the fair and efficient liti-gation of QA issues:

(1) Exclude from use on cross-examination (except in the limited circum-stances where unexpected developments warrant l their use) all newly designated material in the County's September 30 and October 1 let-ters; (2) Order the County to provide the Board and parties with a stipulation contain-ing the following information for each group of findings it intends to use:

(a) a statement or description of what the County contends each group of findings represents; (b) a statement concerning whether the County contends that the group of findings represents a pattern and, if so, what " pattern" is represented and how the County defines " pattern"; and J

(c) whether the Ccunty contends the pattern represents a "QA breakdown" and, if so, the County's definition of what constitutes a "QA breakdown"; and (3) Limit the County to two additional weeks for the cross-examination of LILCO's QA witnesses.

II. A Brief History of the QA Documen_t Disputo

1. On August 27, LILCO, Suffolk County and the NRC Staff presented the Board with an agreement on scheduling for the coming weeks. See Tr. 9959 (Attachment 5). Among other matters, the parties proposed that (a) QA hearings not start until September 14, (b) the County would designate the QA docu-ments to be used in cross-examination, and (c) the County would attempt to complete cross-examination of the LILCO witnesses by September 24. With respect to document designation, the par-ties agreed that a "first cut" would be provided by September 7 and that a final list would be forthcoming on September 13.

See Tr. 9947, 9956. The parties and the Board understood that the County was not promising to complete by the 24th but was

" hopeful and will (make] every effort to complete its cross-examination of the LILCO panel by September 24." Tr.

9947-48 (Letsche). Underlying this whole agreement was the assumption that giving the County two weeks to prepare its QA

I cross-examination would make the litigation much more efficient.1/ Mr. Reveley made clear that timely litigation was of " transcendent significance." Tr. 9940. The prime reason for LILCO's desire for expeditious QA hearings was the presence of two key managers on the LILCO panel. In response to the Board's request that L'ILCO present witnesses with direct knowl-edge of the subject matter, Mr. Museler, the Manager of i

l Construction and Engineering, and Mr. Youngling, the Start-Up Manager, were included as witnesses. Both of these men play vital roles in the completion of the Shoreham plant and are very knowledgeable in QA matters. Thus, their involvement in QA testimony is vital even though it is already having an adverse effect on the progress of the plant. At the same time, however, their additional involvement beyond one additional week is unnecessary and unwarranted.2/

2. On September 7, counsel for the County sent LILCO's counsel a letter with the "first cut" listing of documents l

f 1/ As a matter of fact, since Mr. Lanpher was only present at hearings for part of one day during the week of August 24, the County would effectively have three weeks to prepare. Also, other lawyers and consultants were presumably already at work preparing for QA cross-examination.

2/ LILCO acknowledges the courtesy of the Board and County in allowing Mr. Youngling to be absent on certain days during the first two weeks of QA hearings. That flexibility will not exist in Bethesda.

(Attachment 6). In a conference call to the Board later that day, LILCO expressed its view that the County's letter fell far short of what had been envisioned by the Board and LILCO. The County stated that it was only a "first cut" and that more spe-cificity wo'uld follow.

3. Telephone calls and letters were exchanged throughout the week of September 7. See Attachments 7 (LILCO letter to SC dated September 9), 8 (SC letter to LILCO dated September 10) and 9 (LILCO letter to SC dated September 11).

By the end of the week it was apparent that the County believed it had adequately specified the documents to be used.

Attachment 8 at 1. LILCO disagreed (see Attachment 9) because, in its view, the list of documents was still wholly unmanagea-ble. Attachment 10 is a compilation of the documents that had been designated as of late Saturday afternoon, September 11, which shows that hundreds of documents containing thousands of pages remained on the County's list. No significant changes were made prior to the start of cross-examination on September 14.

4. After the hearings recessed on September 14, the l County narrowed one minor aspect of the list, LILCO Quarterly l

l Reports, to include eleven specific reports. Each Quarterly l

Report, though, references the results of numerous audits conducted by various QA organizations.

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l S. On September 15, following an early recess to allow the County to reorganize its cross-examination at the Board's request, LILCO received a handwritten list of subject areas and documents to be covered on cross-examination. Attachment 11.

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! . It included 10 subject matter areas and nino categories of documents. The County had also indicated to LILCO that "calcu-lations" would be the first area covered, followed by "FSAR i Control" and "E&DCR's," not necessarily in that order.

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6. On September 16, the Board also received the County's latest list of documents. The Board expressoci concern that specific documents were being focused on "so very late."

Tr. 10,281. The County stated that "except for items which were produced pursuant to rubpoena . . . this is very close to a complete list." Tr. 10,281-82. When cross-examination on calculations started, the Board asked whether there would be any core lengthy exhibits besides the Stone & Webster EA and FQC audits. The County said no. Tr. 10,307-08. Yet the new designation is in direct conflict with these representations.

Nor can the County excuse its tardiness by arguing all the new l

documents were produced pursuant to the subpoena; the newly designated audits were produced months ago.

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7. On Friday, September 17, the Board expressed con-cern about the progress of the hearing after spending two days i

without finishing calculations and suggested that the County find a more efficient way to proceed. Tr. 10,611-15. Mr.

Lanpher agreed to consider the Board's comments but spe-cifically noted that the area of calculations had about three times as many findings as other subject areas. Tr. 10,614.

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The unmistakable implication'was that other areas would not be as lengthy. In fact, the better part of a week was spent on calculations, an area not even mentioned in the County's direct testimony. Equally surprising, none of the audit findings used thus far or designated for future use are includec in the County's direct testimony.

8. On Monday, September 20, the County provided fur-ther information, narrowing the subject matter areas and docu-ments. Attachment 12 lists the five subject areas that remained as well as the specific documents designated for the E&DCR and storage / housekeeping areas. The list changed the l sequence of subject areas; storage / housekeeping now preceded FSAR conformance. In addition, when describing its new propo-l l sal to the Board on September 21 (Tr. 10,623), the County also indicated it would cover the subject of " Drawings". The County stated it was hopeful that the pattern examination could be done by the end of the week. Tr. 10,625. It is difficult to I

see how this hope could have been expressed in light of the new designations.

9. On Tuesday, September 21, the County added five additional Quarterly Reports to their list, bringing the total to 16. And, following the hearings that day, six LILCO Field QA Reports were designated. It should be noted that the County's September 10 letter indicated it did not intend to use any LILCO Field QA Reports.

10. On Wednesday, September 22, LILCO, once again, raised the issue of inadequate specificity in the County's designation of documents. Tr. 10,868-71. LILCO pointed out that despite repeated attempts to narrow the list so LILCO's witnesses could adequately prepare, the number of documents remained unmanageable. After hearing the arguments of counsel, the Board ordered the County to provide, in addition to the list of designated documents, a list of the precise findings to be used on cross-examination. Tr. 10,875-76. It was LILCO's understanding that the County was to designate findings from the documents previously identified. The list for E&DCR's was to be provided during the noon break and a list for the balance of the cross-examination was to be submitted by October 1.

Attachment 13 is the E&DCR listing given to LILCO.

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11. On September 30 and October 1, LILCO received let-ters from Suffolk County listing the findings to be used during the balance of cross-examination. Attachments 1-4. These l

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letters added many additional findings and audits to those previously designated. In terms of numbers, the County desig-nated over 175 findings on storage / housekeeping, 344 findings on document control and 20 findings on drawings. Compare this to the 50 or so findings on calculations and the 40 or ao findings on E&DCR's (with almost the same number still to go) covered in the cross-examination to date. Besides the excep-tionally large number of findings, many new audits were added to the list previously provided to the Board and parties:

(1) Contrary to the County's September 10 letter (Attachment 8) and the list of documents provided to the Board on September 16 (Attachment 11), neither of which included LILCO Field QA audits, the County has now designated approximately 96 new findings on storage /nousekeeping and 68 new findings on document control from LILCO Field QA audits.

(2) Contrary to the County's September 10 letter and the September 16 listing, neither of which included LILCO QA Division audits, the County has now designated ap-proximately 135 new findings from LILCO QA Division audits.

(3) Contrary to the County's September 10 letter and the September 16 listing, 4

neither of which included Courter audits, the ,

County has now designated 34 new findings from Courter audits.

(4) Contrary to the County's representa-tion to the Board on September 16 (Tr.

10,307-08) that there would be no large groups of documents other than the EA and FQC audits, the County, in its new, expanded listing, included at least 50 new LILCO Field audits, 50 new LILCO QA Division audits and 18 new Courter audits.

(5) Contrary to the information provided by the County on September 21 that certain Quarterly Reports were only designated for use in connection with E&DCR's (see Tr.

10,873), the County has now included six additional Quarterly Reports on the subject of storage / housekeeping. Additionally, despite the Board's explicit direction (Tr.

10,876), the County failed to give specific cites to the findings to be used in Quarterly Reports.

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Finally, the order of subject matter areas changed once again; FSAR conformance now follows both storage / housekeeping and document control. .

12. On Tuesday, October 5, LILCO 2ent Suffolk County a i letter (Attachment 13) expressing surprise at the contents of l the September 30 and October 1 letters. As the letter l

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(1) The expanded number of findings l

seems to ensure 6-10 more weeks of hearings.

Even if the current rate of progress could be l

l doubled, about 4-5 weeks would be needed to l

cover the new findings alone. Nothing has yet been said about the extent of the cross-examination of LILCO's witnesses on j their direct testimony, including the OQA program.

(2) The size of the list is inconsistent with the representation made to the Board on September 17 that calculations was the 1

largest subject area to be covered.

Moreover, it is inconsistent with the state-I ments made on several occasions that the l

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County would try to complete the cross-examination of LILCO's witnesses in two weeks. .

(3) The numerous new, additional findings and audits materially affect the ability of LILCO's witnesses to prepare ade-quately to give the Board a true and complete picture of the facts.

(4) The failure of the County to include these documants in its direct case undermines the County's argument that the material is necessary for its case. Indeed, there is no mention at all in the County's direct testi-mony of the subject area of calculations, which consumed most of a week of hearings.

(5) The new and expanded list evidences a disregard for the agreements reached among the parties and approved by the Board on August 27. The County was given time to pre-pare cross-examination so it could give LILCO a complete list of documents prior to hear-ings and so the hearing would proceed

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expeditiously. As noted on page 4 above, r

LILCO is particularly concerned about the absence of Messrs. Museler and Youngling from their normel duties. Clearly, the County did not prepare, as agreed, since it is only now identifying large numbers of documents. And if the County was prepared, LILCO fails to understand how the County could agree to l

attempt to complete the cross-examination in i

two weeks and why, at the repeated urging of

. LILCO and the Board, it did not identify a

! complete list of documents sooner.

In summary, these events demonstrate the County's repeated failure to specify adequately the documents to be used '

in the cross-examination of LILCO's QA panel. The new, expanded list provided on September 30 and October 1 is telling ,

evidence that the County has disregarded the August 27 agreement among the parties that essentially all QA documents would be specified prior to the start of cross-examination. It also shows a disregard for the representations made to LILCO and the Board, both verbally and in writing, concerning QA documents. The only reasonable conclusion that can be drawn is that the County was ill prepared for the QA cross-examination t

despite the two week hiatus in the hearings granted for that precise purpose. The new, expanded listing also makes a

. mockery of the August 27 agreement that the County would try to complete its cross-examination in two weeks. Indeed, one won-ders how this representation could have been made since the County is only now determining what documents to use.

The large number of new documents that have been desig-nated at this late date makes it difficult, if not impossible, for LILCO's witnesses to prepare adequately for questioning.

They have already been burdened by the County's failure to designate documents in accordance with the August 27 agreement.

Moreover, based on progress thus far, they are faced with the i

prospect of 6-10 more weeks on the witness stand, even assuming a substantial improvement in the rate of progress. This is wholly unwarranted and intolerable. Consequently, LILCO asks the Board for the relief set out below.

III. Relief Requested i

As a result of the above, LILCO requests that the Board take three steps.

1. The Board should prohibit the County from using any of the newly designated material contained in the County's September 30 and October 1 letters. This includes all of the LILCO QA Division audits, Courter audits and LILCO Field QA audits designated in the document control area, and all of the LILCO Field QA audits and Quarterly Reports in the stor-age / housekeeping area. This prohibition, of course, would be j subject to the flexibility the Board has previously indicated-l

( is appropriate; unexpected developments in cross-examination i

could warrant the use of a particular audit for a limited, spe-cific purpose. See, e.g., Tr. 10,880.

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2. The Board should order the County to prepare a j stipulation that includes the following:

(a) a statement or description of what the. County contends each group of findings represents; (b) a statement concerning whether the County contends that the group of findings represents a pattern and, if so, what pattern is represented and how the County defines the pattern; and J (c) whether the County contends the pat-

tern represents a QA breakdown and, if so, l the County's definition of what constitutes a QA breakdown.

! Once this information is presented to the Board and LILCO, the County can then cross-examine on whether the LILCO witnesses concur with the County's conclusions and, if not, the reasons for the disagreement. This will, in large measure, avoid the l

l need for finding-by-finding cross-examination. It might, however, still be necessary to discuss a number of the specific findings in the context of LILCO's disagreement with the County's conclusions. On balance, this approach should result in fair and efficient litigation of the QA issues.

(3) The Board should place a two week limit on the remainder of the County's cross-examination of the LILCO panel.

No more then one week of the examination should involve Mr.

Museler or Mr. Youngling.

LILCO requests that the Board convene a conference call at its earliest convenience to consider this motion.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY b w w A 1

.' S . Elli II P ' '

AnthonyF.[Earley,Jr.

Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212 DATED: October 5, 1982 16-

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ATTACHMENT 1 KruwPATRICK, LOCKHART, HrLL, CHRzerorHzR Sc PHILLIPS A Faerymmeste Incz.cssse A Paarmassesut companarnow 1900 M STREET, N. W.

WAsurworow, D. C. 20006 TEL3FNOWs (mos) det-f000 IR FITTSBLM CABLE WIFBI EmafRBtE.td*****T,dospens e EcTCEISON TELER 440e09 NTPM IJI se00 082733 BCItaING wart =='s as==cr mi4L wr==== September 30, 1982 Fm==c===. Fe==mvi=ia =See 202/452-7011 Anthony F. Earley, Jr., Esq. (BY TELECOPIER)

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212

Dear Tony:

As I indicated to you yesterday by phone, I am today providing a detailed breakdown of the documents we intend to utilize in connection with examination of the LILCO witnesses in the category of storage and housekeeping.

We have broken the category down into seven groupings

,fo documents with the intention being to proceed through each, grouping completely before proceeding to the next. We will begin with Group I and proceed to Group VII. These groups are described in the attachments hereto. As we dis-cussed yesterday, however, we will discuss early next week l possible means to shorten an audit-by-audit examination.

< I note that there is one additional category of documents l

which we intend to use, but which is not listed on the enclosure -- the LILCO surveillance reports relating to storage.

I cannot determine which of these reports we will use until we have heard from LILCO relating to our proposed stipulation. I understand that we will likely hear from you regarding that later this week.

If you have any questions, please do not hesitate to contact me.

Sincerely yours, Lawrence Coe Lanpher LCL/dk Enclosures cc: Lawrence J. Brenner Bernard M. Bordenick

DOCUMENTS TO BE USED IN STORAGE / HOUSEKEEPING EXAMINATION GROUP I II III IV V VI

• VII M]C: _

13, D.4 8, 05782 & 13, D.8 13, D.9 0, 3 13, D.6 8, 3 & A.O.

D.7 p. 3 15, D.7 21, B.9 11, 3 15, D.2 15, D.8 05736 13, B.13 17, D.4 D.14 20, D.5 32, D.3 17, D.5 21, D.ll D.5 20, D.4 D.15 21, D.13 34, N.2 23, D.5(5)

D.12 23, D.5(1) 21, D.7 D.16 23, K.5 24, B.4 D.5 (2) D.8 D.17 24, p. 2 of 27, B.9 D.5 (3) 23, D.5(3) D.18 3, item B.7 D.6 p. 2 of 3.1.1 B.8 D.7 3 25, D.6 24, K.6 D.8 D.7 K.7 24, D.3 26, K.4 25, K.3 D.5 32, B.3 34, N.2 27, D.7 34, N.2 36, p. 1 & 30, N.1 1.3 32, D.3 40, 1.3 33, p. 2 of 3

D.4 34, K.3 N.2 35, p. 2 of 3

2.3 36, p. 1, its 3.1.2 &

obs. 1.2 40, 1.3 FIELD AUDIT: 238, 4.3 226, 4.4 376, 4.1 226, 4.1 226, 4.3 340, 4.2 376, 4.2 4.14 425, 4.4 340, 4.1 425, 4.2 376, 4.6 4.7 238, 4.9 443, 4.1 376, 4.3 470, 4.1 425, 4.5 4.8 340, 4.3 470, 4.9 679, 4.2 4.5 1298, 4.1 443, 4.4 371, 4.1 4.3 4.3 803, 4.4 601, 4.4 4.2 601, 4.1 699, 4.1 1086, 4.2 721, 4.4 4.3 4.2 4.3 1275, 4.1 4.4 4.3 721, 4.3 1325, 3.2 1301, 4.2 4.1

GROUP I II III IV V VI VII FIELD AUDIT (Cont'd): 1016, 4.1 376, 4.4 656, 4.2 4.2 425, 4.1 721, 4.1 4.3 4.3 4.2 1086, 4.4 443, 4.4 740, 4.1 1213, 4.1 444, 4.1 4.2 4.2 4.2 4.3 1425, 4.1 4.4 803, 4.3 1

470, 4.2 4.4 648, 4.3 934, 4.1 803, 2.1 4.2 4.1 4.3 4.2 4.4 1183, 4.1 980, 4.1 4.2 4.2 4.3 4.3 1275, 4.2 1016, 4.6 1026, 4.1 4.2 1086, 4.1 4.2 1180, 4.1 4.3 1204, 4.1 4.2 1234, 4.1 1301, 4.1 1313, 4.1 4.2 QUARTERLY 5/30/80

[ REPORTS TO 7/22/80 MANAGEMENT: 11/13/80 2/17/81 8/31/81 12/ 3/81 1

ATTACllMENT 2 i

KruxPATRICK, LOCKHART, HILL, CunisTornen Sc PurLLres r

A Paarsamemar Incs.mosso A PaormassonaL CesponAfson 1900 M Sranar, N. W.

WAMMINGTON, D. C. 20000 retarssons (sos) des roco na psTTesemos CABLE MIFBIl SISEPAT3 ate.RaGEAST,dOWNeDN & Bt1CRISON TELES 440909 NIPit VI 3600 oEJYBE BUILDING

. m. . mm.c, min. ===. = October 1, 1982 mr..c.on. ..m uni . .

202/452-7011 * = * = =

Anthony F. Earley, Jr., Esq. (BY TELECOPIER)

IIunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212

Dear Tony:

This letter concerns the County's examination of an alleged pattern of breakdowns in the document control area. For con-venience of presentation, the County's examination will be in 6 Groups or areas, which generally can be described as follows:

Group 1: Inadequate or missing procedures and similar problems Group 2: Distribution / transmittal problems Group 3: Problems with filing, indexing and other record keeping functions Group 4: Legibility problems Group 5: Failure to keep documents up-to-date Group 6: Miscellaneous [this group will likely be reduced on further review. I will advise you next week).

Documents in each group are identified in the attachments hereto. I expect to proceed with the groups beginning with Group 1.

As with storage matters, I will speak with you next week regarding possible means to streamline the examination.

Sincerely yours, W

LCL/dk Lawrenc Coe Lanpher Enclosures cc: Lawrence J. Brenner Bernard M. Bordenick

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ENGINEERING ASSURANCE AND FIELD QUALITY CONTROL AUDITS TO BE USED IN DOCUMENT CONTROL EXAMINATION GROUP 1:

EA 22, A.O. 26 EA 21, 012 EA 12, 2.B.1 EA 18, p. 2, #3 EA 40, 156 EA 21, 013, #6 EA 15, 1.4, #3 GROUP 2:

EA 24, 047 EA 25, 060, 064 EA 14, 2.C.7, Att. 2 EA 13, 2.C.2 FQC 8, 05788 FQC 14, B.3 FQC 17, D.2, F.2 FQC 18, K.7 05789, #2 D.1 FQC 19, D.2, F.1 FQC 23, 3.1.1.B 05790, #1 F.3 FQC 24, F.2, K.4 D.3 FOC 26, L.4, A-D, F, J FQC 30, K.3 FQC 25, D.4, F.1 D.4 FQC 32, D.1, D.2 F.4 1

GROUP 3:

EA 22, 024 EA 26, 065 EA 15, p. 3, #4 EAO, pp. 48-49 EA 27, 075, #1 EA 29, 091 EA 21, 013, #5 EA 23, 042, #4, #7 EA 30, 102, #2 FQC 8, 05790, #3 FQC 9, 06680, FQC 12, 07807 FQC 16, B.1 FQC 17, D.l.2 06681, #1 FQC 22, B.5 B.2.A F.1 FQC 19, D.5, D.6, FQC 26, L.4, E, G, H F.2 FQC 32, K.2 GROUP 4:

l EA 23, 041, #5 FQC 22, D.1 FQC 8, 05789, il FQC 9, 06676, #2 1

FQC 26, K.3 FQC 22, D.1 05790, #2 06682, #2 FQC 23, F.3, F.5 FQC 25, K.1 FQC 27, K.2 FQC 28, K.2 FQC 29, K.2 FQC 30, K.2 FQC 31, K.2 GROUP 5:

EA 22, 025 EA 18, p. 2, #4 EA.22, 021 EA 23, 037 EA 27, 078 EA 38, 141 EA 19, 2.B.2 EA 17, p. 3, #6 EA 21, 016 EA 22, 020 2.B.3 EA 24, 050 EA 26, 066, 067 EA 27, 074 EA 28, 082 EA 30, 097, 104 EA 34, 119 EA 35, 122 EA 37, 137, p.2 EA 39, 152

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j GROUP 5 (Cont'd): I I  ;

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EA 40, pp. 1, 2 FQC 9, 06676, #1 FQC 14, A.1 FQC 16, B.2.A-E 155 FQC 17, D.l.1 B.2 D.2 159 FOC 18, B.1 D.2 D.4 i FOC 20, D.3 FQC 19, K.1 D.3 FQC 22, L.4 FQC 23, L.1 FOC 32, B.2 i

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1Pj ADDITIONAL AUDITS REPORTING DOCUMENT CONTROL PROBLEMS (NOTE: Document portion to be used and Group Category noted with each audit.]

i I. LILCO OA Audits Audits of subcontractors and internal audits, by LILCO QA auditors, arranged by year.

1970 Stone & Webster (S&W) Audit #1A - Engineering Assurance Administrative Procedures, Finding 1, Group I; Finding 2, Group 6 Audit #1B - Engineering Specification, Findings 1, 2 & 3, Group 1; Finding 5, Group 6 a

Audit #lC - Procurement Quality Control, Finding 1, Group 1; Findings 2-3, Group 6 i Audit #1D - Engineering Assurance, Internal Audits, Finding 2, Group 6; Findings 3 & 4, Group 5 Audit #1E - Engineering Assurance, Drawings & Sketches, Finding 1, Group 4 1971 S&W Audit #2A - Follow-up of Audit #1 (1970), Summary, Group 1 S&W Audit #2C - Engineering Assurance, Specification Review, Finding 1, Group 1 S&W Audit #2D - Engineering Assurance, Internal Audits, p. 2, Group 1 i LILCO Internal Audit #3 - Engineering, I.1, I.2, Group 6; IV. 1& 2, Group 2; IV. 4, V. 2, Group 3 LILCO Internal Audit #3A - Follow-up of #3, 7.1, Group 5; V. 2. Group 6; IV. 1, 2, & 4, Group 3 1972 LILCO Internal Audit #4 - Purchasing Department, p. 4, #4, p. 9, #1, Group 5 Site QA Audit #1 - Receiving Inspection, Finding 1, Group 1: Findings 2-12, Group 6 4

1P; 1973 3rd Audit of LILCO Purchasing Department, pp. 3-4, Group 6 i Site QA Audit #2 - Construction Site, p. 1, #5, Group 1 Follow-up of Site QA Audit #2, p. 1, 1 3, Group 1 i

S&W Audit #3 - General, Finding 3b, Group 5; Finding 3C, Group 6 Site QA Audit #7 - Site Purchasing, Findings 2 and 3 (a-d), Group 4 Site QA Audit #8 - Second Follow-up of Audit #2, p. 1, #3, Group 1 S&W Procurement Quality Control, Findings 1-3, Group 6; Finding 4, Group 1 Fourth Audit of LILCO Purchasing Dept., Findings 1 & 2, Group 1 1974 Site QA Audit #9 - Non-destructive Testing, p. 1, #2, p. 2, #1(b), Group 5 QA Audit #4 - SNPS S&W Project, IV. 1, IV. 3.1, Group 5; IV. 4, IV. 5, Group 6 Fifth Audit of LILCO Purchasing Department, Finding 4, Group 4 Shoreham Project Audit, III.B.4, Group 4 1975 S&W Field Quality Control (QC) Audit #1, Findings A.1, A.3, B.1, B.3, B.4, C.5-6, Group 1; Finding C.1-3, Group 6

, S&W Procurement Quality Control Audit #1, Attachment 1, p. 1, Attachment 1, p.2, Group 1 Follow-up of LILCO Purchasing Department Audit's #4 and 5 (1973, 1974), III.A.2, Group 1 Follow-up of QA Audit #5, SNPS S&W Project, III.C.2, Group 1 Follow-up of S&W Field QC Audit #1, III.B.1, Group 1 QA Audit #6, SNPS S&W Project, Findings 1 & 4, Group 1; Finding 2, Group 6 QA Audit #1-75 S&W Procurement QC, III.B.1.a.2.3, Group 1 i

' QA Audit #5 - LILCO Shoreham Project, Finding 3, Group 2 QA Audit #6 - LILCO Purchasing Department, Finding a & Recommendation a, Group 1; Finding B, Group 2 1

1976 QA Audit #1-76 S&W Procurement QC, Finding 1, Group 1; Finding 2, Group 5 Follow-up of QA Audit #6, SNPS S&W Project (1975), Finding 1, Group 1; Finding 3, Group 6

,l QA Audit #1 - S&W Procurement QC District Office, Findings 1 and 2, Group 6 i

QA Audit #76 LILCO Purchasing Department, III.C.1, Group 1 QA Audit #76 LILCO Site Engineering QA, Findings 1 and 2, Group 6 J

-m

g. .- .

1977 QA Audit #77 LILCO Shoreham Project, Finding 1, Group 3 QA Audit #77 S&W, Findings 3 and 4, Group 1 QA Audit #77 S&W Field Extension Office, Finding 5, Group 3 QA Audit #78 Field QA and Engineering-QA, III.B, Group 1 QA Audit #78 S&W Site Extension Office, p. 9, Group 3 QA Audit #78 LILCO Shoreham Project, Finding 1, Group 3 QA Audit #78 S&W, Findings 2 and 5, Group 1 QA Audit #78-2, 78 S&W PQC offices, Atlanta & Pittsburgh, 1.1 & 2, Group 2: 1.3, Group 3 1979 QA Audit #79 S&W, Finding 1, Group 1; Open Item 1, Group 6 1981 QA Audit #81 LILCO Shoreham Project, lb, Open Item 1, Group 1, #4, Group 2; Recommenda-tion, Group 3; la, 2 & 3, Group 6 QA Audit #81 LILCO Purchasing Department, Finding 1 and Open Item 1, Group 1; Finding 2, Group 6 QA Audit #81 S&W, Findings 1-3, Group 1

t..

,. _ _ - . ~ _

es :

II. LILCO Organizational Audits - Courter and Company Audits of Courter and Company, by LILCO QA auditors, in chronological order:

Audit No. Date 94 11/26/79 60, 6p, Group 1 97 1/23/80 1.1, 1.2, Group 6 108 3/17/80 9, Group 3 113 4/23/80 10 (a-g), Group 6 l 98 7/80 - 9/80 Conclusion, Group 6 127 10/29/80-11/21/80 1, Group 5 126 11/24/80 Conclusion, Group 6 129 12/ 1/80 26b, Group 3 135 12/29/80 13(d), Group 5 136 1/15/81 15 (b) (B) , Group 5 145 4/ 3/81 6, Group 5; 11, Group 6; 25(a-c), Group 3 146 4/24/81 10, Group 1 152 6/25/81 7, Group 6; 13.2, Group 5 157 7/ 2/81 11, Group 6; 12, Group 5 160 7/21/81 Findings 6 & 10, Group 3; Findings 9, llb, lid, llf, 14, 16, Group 2 162 9/14/81 22, 23, Group 6 163 10/ 6/81 2-4, Group 6 171 12/15/81 17, Group 6

en , .

III. LILCO FIELD AUDITS -

Audits of all activities and companies involved in the Shoreham I Project. Individual audits have a single, specific subject activity and organization.

. Audits were conducted by the LILCO Field QA Division ~. They are listed by year:

Year Field Audit No.

1971 10 2, Group 3 1974 87 4.1, Group 3; 4.2, 4.3, Group 6; 4.4, Group 1 156 4.1, 4.2, Group 1 1975 225 4.1, 4.2, Group 5 228 4.2, Group 3 320 4.2, Group 6 1976 359 4.1, Group 3 373 4.1-4.4, Group 2 433 4.1-4.4, Group 3 1977 563 4.1-4.4, Group 3; 4.6, Group 4 636 4.1, 4.2, 4.4, 4.6, Group 3 1978 685 4.1, 4.3, 4.5, Group 3 789 4.2, 4.3, Group 3 837 4.4, Group 6 873 4.4, Group 1 1979 903 4.4, 4.8, Group 3 974 4.1, 4.2, 4.4, Group 6 990 4.1, Group 3; 4.2, Group 1 994 4.1,. Group 3 1015 4.1, 4.3, Group 6 1033 4.1, Group 1

e- . ,

Year Field Audit No.

1980 1097 4.1-4.7, Group 6 1104 4.2, Group 6 1115 4.1, 4.2, Group 3 1150 4.3, Group 6 1163 4.1, 4.2, Group 1 1195 4 . 2 ., 4.3, Group 6 1981 (January 1-July 31) 1265 4.1, Group 3 1287 4.1, Group 6 (August 1-December 31) 1327 4.1, Group 5 1338 4.1, Group 6 1345 4.1, Group 3 1354 4.1, Group 1

ATTACHMENT 3 o

/ EIRKPATRICE, LOCKHART, HILL, CHRISTOPHER Sc PIIILLIPS A PArrasseure Incs.conwa A PmOrmessonAs. COsuomarion 1900 M STREET, N. W.

WAmuxxotow, D. C. 20006 TOLEFEBONE (308) 488 7000 IN FtrTSat EON CABLE! MIFRI IIEEFATEMI.IDCEEART.dOENSON & ETTt3150M TELE 1 440809 HIPH (, 3500 CE2VEB ECIISING

-cnBE3 =EcrouL=cEEEE October 1, 1982 ,Ir=BcBO FE==m,Ama .

202/452-7011 m = - =**

Anthony F. Earley, Jr., Esq.

Hunton & Williams 707 East Main Street P.O. 1535 Richmond, Virginia 23212

Dear Tony:

By separate letters dated yesterday and today, I have advised LILCO (as the Board requested) of specific documents which will be used by the County to document a pattern of QA/QC breakdowns relating to storage / housekeeping and document control. This letter is to provide further guidance relating to the County's intended examination at the conclusion of this recess.

The County has concluded its examination related to control of calculations. When the hearing resumes, the County will complete examination regarding E&DCR's, including the E&DCR verification program. The County will then have four other

" pattern" areas which it intends to pursue: storage / housekeeping; document control; failure to design and construct the facility in accordance with FSAR commitments; and deficiencies in drawings, sketches and diagrams.

Regarding the FSAR area, the County's examination will not focus on audit findings, but rather will center on the following documents:

-- The seven plant configuration reports produced by LILCO pursuant to Subpoena Item 1.

i

-- SNRC-716, June 21, 1982, insofar as it relates to the plant configuration review.

-- CAT inspection, Appendix B, and discussion portions relating to the Appendix B findings.

l

KuwxPATIB CK, tOCEMART, HarA, CuareroPuma & PunLLTPS

/

Anthony F. Earley, Jr., Esq.

October 1, 1982 Page 2 LILCO July 28 response to CAT inspection.

The County's final area of " pattern" examination will concern deficiencies in drawings, sketches and diagrams.

These deficiencies center on both substantive errors /

inconsistencies in the drawings, and the failure to effect required reviews. A listing of the documents to be used in this examination is attached to this letter.

The County intends, after E&DCR's, to take up issues in the following order: storage /housakeeping, document control, FSAR, and drawings.

Sincerel yours, Lawrence Coe Lanpher LCL/dk Enclosure cc: Lawrence J. Brenner Bernard M. Bordenick l

I ENGINEERING ASSURANCE AUDITS TO BE USED TO DOCUMENT DEFICIENCIES IN DRAWINGS, SKETCHES AND DIAGRAMS EA Audit No. Page/ Finding 00 Page 7 1 Page 7 2 Page 7 4 Pages 2 - 3 8 P. 2, C.2 and C.4 12 Attachment 3 13 C.3, C.4 22 A.O. 019 29 A.O. 092 093 30 A.O. 103 33 A.O. 115

, 34 A.O. 119, Logic Diagrams l Flow Diagrams Piping Diagrams A.O. 121 39 A.O. 149 40 p. 2 and A.O. 156 l

l

ATTACHMENT 4 4

KrRxPATRICK, LOCKHART, HILL, CHRISTOPHER 8e PHILLies A Pantammener Incamerso A Poormestonaa. Coasnaarios 1900 M Sramar, N. W.

WAmurnomw, D. C. 20006 1CLEP3 BONE ISOS) 485=7000 IN PETTSBL10E CARLE MIPNI ggggPATSKI,iAMERABT,dOEWSOm & WC1CRIBON TELEX 440800 MIPN UI 8800 ORJYEB Sc1IRIWG worr.. . mi..cr min. =c=... October 1, 1982 ,m ..c.. ,....rs, ...

202/452-7011 * =a aaaa Anthony F. Earley, Jr., Esq.

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212

Dear Tony:

In my letter dated September 30, 1982 regarding the County's " storage / housekeeping" examination, I detailed seven groups of documents which we intend to utilize. By this letter, I am specifically identifying the groups as to subject matter in the hope that this may serve in some way to expedite examination in this area. Accordingly, the storage / house-keeping groups may broadly be described as follows:

Group I:

QA/QC problems related to storage cards and the failure to effect inspections required by storage cards.

Group II:

Failure to protect equipment against weather.

j Group III_:

Failure to keep equipment covered and protected. This is primarily related to indoor storage as opposed to the Group II items.

I l Group IV:

Environmental maintenance, particularly the failure to keep the proper temperature and humidity conditions around stored equipment.

l I

l

o KIREPATRICE, I.AX3EMART, Exxx, Cumzeroenna & Puzzzres e

Anthony F. Earley, Jr., Esq.

Hunton & Williams October 1, 1982 Page 2 Group V:

General' housekeeping deficiencies, particularly failure to l

keep the site clean and free of debris.

Group VI:

Intermixing of inspected and uninspected goods.

Group VII:

Improper storage of hazardous, especially flamable, materials.

I trust this additional information (similar to that being provided today by separate letter in the document control area) l will be of assistance.

l l

Sincerel yours, L

/ f Lawrence Coe Lanpher LCL/dk cc: Lawrence J. Brenner Bernard M. Bordenick

r 5 ATTACHMENT 5

. m ' ,< ,

l I

Schedule Proposal i) 1.

Starting on Monday, August 30, and ending on Friday, September *

(or earlier, if possible), the parties are to meet day-in and day-out on Long Island to produce signed settlement agreements ons.

SC 5 '

Loose Parts Monitoring SC 24/ SOC 19 ((c) . and . (p)

Cracking of Materials SC 26 -

, ALARA SC/ SOC 18 HF - Equipment SC 19' HF - Human Factors Procedures (plus Supplemental Water I

Hammer Information)

SC 20 "

HF - S.imulator SC 25/ SOC 19(a)

RPV Integrity and Testing SC/S C'22 -

Supplemental SRV Information SC 1 RSP 2.

If these settlement agreements do not wholly resolve each of the affected contentions, the remaining disputes will be litigated during the week of September 7 3.

The parties will report to, the Board by Friday, September en whether any such disputes exist.

4. QA hearings will begin on September 14, 5.

On August 31, LILCO will file a motion to strike portions of the County's QA testimony, l

C. b

. ...-- +

6.

On September 7, the County will provide the Board and Ii Parties with a list designating the documents to be used in the County's cross-examination of LILC0!s QA witnesses.  !

7.

The County will meet with LILCO during the week of September 7 (e) to better fe s the QA issues, especially opera-tional QA, and (b) to agree sn stipulations of fact.

! 8.

The County expects that it should be able to complete its cross-examination'of LILCO's QA witnesses by September 24, 9.

During the week of September 7 the parties will meet on l Long Island to pursue the narrowing and/or resolution of Phase I emergency planning issues.

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707 East. Main street'. '

Richmondb Viaginia 23212 s

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Dear.". ,

.a. dd. .Weny ,

.. .,: 5 .

' '. As L.5 we discussed earlier, $uffolk County is prov1&img LIMO with'a Titt of documents which we are likely to see in saamina-tion af the LILc0 QA/QC panel. 1ts will .expoet. .to gossive a -

similar.. identification of domsmente1:p-M== your genoss-e'xahination'of Dick Rubbard, to be receivoa at 3aaet.;ene week

~

before that enemination .begins. , a.

9 ,.

I emphasize that the documents' identified bIslow constitute l

l a:afirst cut," with the 11 .being that same. documents will l be deleted and o Fu p h ti 'into particular documents may beoces pe sent only f tthe: Saot.

• making

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, advance identifloation impossihne'.pg,, .g .-(gg-

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LIN C' panel

. . -whiht . listed separat41 yse may. == mm.

regarding the FSAR.and any of" da or

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Edecenettj$e

. attached to the,prefiles testimenps h,9.E .v.;.<.e.(.4 .

- We have received two shipmente of.Soonments rouant to the county's subpoena request.and the soard's re s. We expect that most of these docemente.w113,be mood.

~ .. .

-The following. documents, previously,provided in'aiscovery, I are'11kely l to.be wtilised:

. ( ,Q, . .. .

j' supC FCC Audits, moe.1'-(2/8/71 'thru"41' (2/12/92)'

. SWBC Program Audits, NDe.,"1 (2/ 4) thre'S. (2/81)

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( EG[J. u ,w ATTACHMENT 7

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D HUNTON & WILLIAus f 707 East MAIN Starct P. o. Box 1535

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• oi,*/ "., * *.*o*. ... . .. September 9, 1982 ""**

.o. . .. . . . . o .

ca.tc, o..L .o. .oe t...

Lawrence Coe Lanpher, Esq. ,

Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.

Washington, D.C. 20036

Dear Larry:

As we discussed in our telephone conversation yester-day, we sent you by Federal Express a copy of the Stone &

l Webster N&D trend analysis. I will call this afternoon to dis-cuss the list of N&D's you intend to use on cross-examination after you have had a chance to review that analysis. As you know, there are a number of other matters we need to cover.

The following summary reflects the current status of document designation for cross-examination.

With respect to the FSAR, you indicated that, in addi-tion to Chapter 17, you may use the Section 3.1 commitment regarding GDC 1 and the Appendix 3B commitment to regulatory guides dealing with quality assurance. Your September 7 letter also indicated that you may examine on the documents referenced in or attached to LILCO's prefiled testimony.

As I told you, we hope you can narrow the list of docu-ments produced pursuant to the County's subpoena. To that end, we discussed a number of categories of documents that are par-ticularly large and in need of specification. You indicated l

you would be able to discuss the following categories today:

! 1. quarterly and monthly audit reports; y

2. notes of conference; / '

/

3. CCF'ar , r' y ..

4. project procedures; and n ,

5. GE customer CAR evaluation reps.es.

l To' L. Lep NJL G am . T CHUNTow os&M1 Sc WILLIAMS lY, Lawrence Coe Lanpher, Esq. -

~

! September 9, 1982 Page 2 r

i In addition, you indicated that on Friday you would tell us which surveillance reports you intend to use. While narrowing l

these categories is most Important, we would also appreciate specification as to any other documents in the subpoena request you intend to use. ,

l With respect to SWEC FOC audits and EA audits, you l reiterated your intention to use all of the audits referenced -

in your September 7 letter in cross-examination. You also l indicated that you would probably use all of the referenced l SWEC program audits. These categories contain over 90 audit reports. As I told you, we think it will be impossible to com-(

plete cross-examination of LILCO's panel on just these docu-ments in two weeks unicas the scope is limited. I understand you need to use a number of these audits to attempt to show the pattern you believe exists but there should still be a substan-tial number of audits that can be eliminated from the cross-examination. We would appreciate reconsideration of your position.

With respect to N&D's, you indicated that you would be -

in a position to specify those you intend to use once you have had the opportunity to review the Stone & Webster document we sent you.

You indicated that the LILCO Quality Systems Division audits, LILCO Field QA audits, LILCO Corrective Action Requests and E&DCR's may not be used in your cross-examination. We agreed to discuss this further on Friday. --

With respect to I&E audits of General Electric and Stone & Webster, you said you would advise me this afternoon of your intentions.

i Finally, we discussed our desire to have mcre spe-cificity with regard to I&E reports issued since March 1982.

l You agreed to review these reports and to discuss them further today. The remaining items in your September 7 letter, the SALP documents and LILCO's response, the Teledyne core spray documents and the July 28, 1982 LILCO CAT inspection response, are adequately particularized.

I am in the process of draf ting a proposed stipulation concerning the questions and answers in LILCO's prefiled

n $. Q k

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\ T xf) j Howrow & WILLIAMS r

Lawrence Coe Lanpher; Esq.

September 9; 1982 Page 3 testimony that should not be in controversy. I will try to get the draft to you aa soon as possible.

Sincerely yours,

/

OL4 Anthony . Earley, Jr.

AFE/403 l

l 1

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ATTACHMENT 8 l ,

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i EIREPATRICK, T~=mr, HrLI.. ,CarazsTOPMza & Pia '

LLxes Atb i.eu. 4p c_ .,,,

1900 M STamar,'N. W.

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September 10, 1982 .c ...

202/452-7011 w =a ====

l Anthony F. Earley, Jr., Esq.

Hunton & Williams F.O. Box 1535 707 East Main Street Richmond, Virginia 23212 l

Dear Tony:

This letter supplements my letter to Tim Ellis, dated September 7, 1982, and also' responds to your letter of September 9, 1982. This letter also addresses certain matters we discussed late in the afternoon on September 9, 1982.

i With respect to documents we intend to use in QA examination, I reiterate my oral statements to you that the County cannot definitively eliminate any documents from possible use in cross-examination. Thus, the County expressly reserves the right to use any documents, including those which I have indicated to you we do not presently intend to use.

The listing of' documents in my September 7 letter is hereby reiterated with the following additional information which responds to questions you have raised. In providing.these addi-tional data, I want it to be clear that I do not agree with statements in your September 9 letter that relate to the need

, for further specification. The County has been making every

! effort to identify documents it intends to use and, in my view, has significantly focused such matters. The fact, however, that some documents or classes of documents may be large does not lead to the conclusion that some documents in that class should not be used, which appears to be your view. We cannot bind ourselves i' to eliminate relevant materials which are important to proof in this case just because such proof may be extensive. This is particularly the case since the LILCO testimony is extremely broad-ranging. Such testimony may require extensive examination, particularly regarding documents and programs which are referenced in that testimony.

L .

, 1 With rCsp;ct to dccumento producad puraucnt to subpoene, I raitorots thot we intand to uno rany of thace documento. In responso to opecific inquiries frcm you, I hava cdviscd h' (a) We probably will not use the project procedures (subpoena item 17);

(b) We will use the GE CAR evaluation reports (subpoena item 26), although we will attempt to, avoid the need for an in camera' session; (c) We' sill use ~the quarterly .and monthly reports (subpoena item 11) and the1 Notes of Conference (subpoena' item 19). .We cannot determine precisely .

which toocuments from these sets will be used.

This depends greatly on'the' responses to questions relating'to these documen'ts and ankwers,to other ~

i questions. I will attempt to pr9 vide advance l

notice if indepth inquiries are going to be' pursued with respect to particular reports.

(d) We will use surveillance reports (subpoena item 38). .However, given the large number, we shall l . inquire mainly into the scope and conclusions of the program and the items / attributes which are looked at, and will not generally pursue precise details about particular items in particular reports. I would expect, however, that at least one report from each surveillance report group will be marked as an exhibit so that the scope i of the reports may be documented and the state-ments in the testimony can be examined.

(c) We are still analyzing the N&Ds we may use. As I advised, we must first review the SWEC document re N&Ds which we only r'eceived yesterday at noon.

2. We pre =ently do net intend to use L7LCO QA Division A':d$ tr or LILCO Field C/, Auci.t a. We will likely use CARS and L; JRo cr. ' , no the cxter.t they are identified in ~other docu-ments (like EA and FOC audits) that we,use. We also do not presently intend to pursue LILCO LDRs,.,Cour;ter .NCRs, and Courter audits.

J. .

3. No determination has been reached on'which I&E Reports inspecting GE and SWEC will be used. ,

/

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. .s Errupararcz,Iecumant, Cua.f, Cast:;foruno O Pass.r.tys '

i Anthony F. Earley,'Jr., Esq.

\' September 10, 1982 -

Page 3 *- .-

4. 'We will use IEE Reports re Shoreham issued since March 1982 In our view, this is a clear, particularized list which needs no further~ delineation.

! In review of the documents produced pursuant to the subpoena, I have several inquiries:

1. Notes of Conference (item 19). . We asked that every 50th conference note be produced in order to ensure a random sample. LILCO produced numbers 101, 150, 200, 250, 300, 352, 400, 450, 452, 504, 650, 700, 750, 800, 850, 900, 940. This is not every 50th Note, plus there is a large gap between 504 and 650. As I regues,ted orally yesterday, please explain why these particular reports were produced. ... ,-

.. 4.

Further, the following Notes a're illegible in significant respects: Nos. 200, 250, 300, 352, 450, 452 and 504. Please send legible copies so that I receive them on Monday. If that is impossible, I would like them at the hearing on Tuesday.

2. In review of the items produced by subpoena, it is not clear that any documents were supplied to. respond to subpoena item 12. Please advise.

3. We received an April 1982 FQC audit in response to subpoena item 23. I believe a June audit was also to be provided, but was not. Please advise. '

This letter will. confirm that'yest'erday Alan Dynner and -

described for you the bases upon. whidh we feel .ooA issues can be resolved or substantially narrowed.tk We understand that you will discuss this information with your client and provide your views to us as s,oon.as possible.

Finally, pur'suant to our discussion, you are preparing proposed factual stipulations regarding the LILCO CA testimony.

We will review them as promptly as possible af ter they are received. .

Sincerely yours,

~

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Law ence <oe Lanpher -

LCL/dk .

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ATTACHMENT 9 Huwrow & WILLIAMS 707 East MAIN Sf act? P. o. Box 1535 e o e ? eveLoimo Racnwoxo, Vamotx A 23e1e e..e ,ces..,6,m ..... ,es_

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,o comsees rio ao nezro6a, Vene NaA ases4 co+ ens sson September 10, 1982 osace' osa' 'eo. =o. >= e-

. Lawrence Coe Lanpher, Esq.

Kirkpatrick, Lockhart, Hill, Christopher &,Phillips 1900 M Street, N.W.

Washington, D.C. 20036

Dear Larry:

In response to your September 10 letter, we do not agree that every effort has been made to identify the doeuraents to be used in cross-examination. We believe the Board had in mind much greater specificity than has yet to be achieved when they agreed to extend the starting date for QA to September 14.

I hope we can make more progress over the weekend.

In that regard, I called you around 3:30 p.m. on Friday afternoon as we had agreed on Thursday. You were on the phone so I left a message. At about 4:15 p.m., I called again and was informed that you had left for the day. I am disappointed that you did not contact me before leaving, given the need for timely identification of documents. I was in our hearing office all afternoon working with our witnesses and was waiting i

t for your call before sending the witnesses home.

l I hope we can talk early Saturday on these and the

[ other issues we need to cover.

Sincerely, M

Antho F. Earley, Jr.

e AFE/403

ATTACHMENT 10

't

.f j

DOCUMENTS DESIGNATED BY SUFFOLK COUNTY as of September 11, 1982 4

1. Stone & Webster Field QC Audits, numbers 8-41.

2. Stone & Webster program audits, numbers 1-8.

--County indicated that these will not be pursued in detail

3. Stone & Webster engineering assurance audits, numbers 0, 00, 1-39.

4. N&Ds--some unspecified selection of those provided in discovery (in excess of 300 were provided).

--County indicated it will probably focus on those mentioned the S&W Trend Analysis provided to the '

County

5. Operating QA procedures--all.

6. LILCO corrective action requests--some (approximately 90 provided in discovery).

7. E&DCRs--some (over 400 provided in discovery).

8. I&E reports on Stone & Webster--I&E reports 81-01 and 79-03.

9. I&E reports on Shoreham--all issued since March 1982 and the pertinent LILCO responses.

10. SALP review documents.

l l 11. Teledyne core spray related documents.

12. July 28, 1982, LILCO response to the CAT inspection.

I

13. FSAR Chapter 17, FSAR Section 3.1 (regarding GDC 1),

FSAR Appendix 3B (regarding regulatory guides dealing with quality assurance) and FSAR Table 3.2.1-1,

14. All documents referenced in or attached to LILCO's l prefiled testimony, i

l

l l

57

15. All documents received pursuant to the County's subpoena request (see the attached listing) with the following exceptions or limitations:

A. notes of conference--the County will use some but is not in a position to designate which ones B. change control forms (CCFs)--the County will probably not use these documents -

C. Project procedures--will not be used D. surveillance reports--the County will not generally pursue precise details about particular items and particular reports; inquiry will focus on scope l and conclusions of the program and the items / attributes looked at.

I I

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1

8/31/82 ATTACHMENT 10

,- #2 SUBPOENA t ' Iten # DESCRIPTION ITD4 # # No. of Pages i

1. T. F. Gerecke's BWR Analysis 13 1 3

2. Monthly Project Manhour Report 32 1 1

3. Seni-Annual Insp. Activities Reports 36

a. June 1-Nov.25, 1977 1 7 b.Dec.1.1977 - June 30,1978 1 8

c. July 1,1978 - Dec.31,1979 1 6 d.Jan.1 - June 30,1980 1 h

e. July 1 - Dec.31,1980 1 h f.Jan 1 - Dec.31,1981 1 h g.Jan.1 - Jun. 30, 1982 1 4

h. Checklist - Spee. Review 21 1 8

5. Quarterly Audit Reports 11 a.May 6, 1977 1 5

b. July 20,1977 1 13 c.Nov. 29,1977 1 lb

d. March 6, 1978 1 11 c.May k,1978 1 15 f.Aug. 31, 1978 1 15 g.Nov. 3, 1978 1 1h h.Jan. 29, 1979 1 13

1. April 16,1979 1 12 J . Aug.20,1979 1 11 W k.0ct. 30,1979 1 lb 1.Feb. 21, 1980 1 13 m.May 30,1980 1 11

n. July 22,1980 1 11 o.Nov. 13, 1980 1 11 p.Feb. 17, 1981 1 15

q. Aug. 31, 1981 1 25 r.Dec. 3, 1981 1 15

s. June 22,1982 1 30 Monthly Reports II a.Aug-Dec., 1973 1 ea. 5 l b.Jan-Dec., 1974 1 ea. 12 l

c.Jan-Sept., 1975 1 en. 9 d.Nov & Dec., 1975 1 ea. 2 e.Jan-June, 1976 1 ea. 7 f.Aug.-Dec., 1976 1 ea. ,

6 s.Jan.-Dec. , 1977 1 ea. 22 h.Jan.-Dec., 1978 1 es. 23 1.Jan-Dec., 1979 1 es. 25 j.Jan-Dec.,1980 1 ea. 16 k.Jan.-Dec., 1981 1 es. Ik 1.Jan.-July, 1982 1 ea. 10 sv

8/31/82

' SUBPOUIA Itess # DISCRIPTION ITE4 # # No. of Pages br

7. Training & EKPerlence Records 5 a.E.C. Bajada 1 5 b.E.P. Cassiano 1 6 c.R.V. DeRocher 1 6 d.T.F. Gerecke 1 6 e.R.E. Glazier 1 6 f.T.F. Joos 1 6 C.J.M. Kelly 1 6 h.J.J.McCarthy 1 6 1.E.J. Nicholas 1 6 j.V.E. Nicotra 1 6 k.F.X. Schoner 1 6 1.D. Shaw 1 6 m.J.G. Spolizino 1 6 Job Descriptions 5 a.Mana6er, QA Dept. 1 16 b.Hanager, Qual. Sys. Div. 1 12 c.Magr. Field Qual. Ass. Div. 1 18 d.Snr. QA Ihgineer 1 5

e. Sect. Sup. - Mech. Elec. NDT 1 12

f. Sect. Supv. - Civil. Environmental 1 13 g.QA Engineer 1 2 y h. Site QA Engineer 1 2 3  !!otes of Conference 19 a.Feb. 1, 1973 1 2

b. Sept 13, 1973 1 6

c. April 15, 197h 1 11 d.Dec. 6,197h 1 h

e. July 9, 1975 1 7 f.Jan. 7, 1976 . 1 2

, g. July 1h, 1976 1 h b.Feb. 9, 1977 1 5 i . i.0et. 12, 1977 1 h

!~ J. June 26, 1978 1 13 k.Jan. 19, 1979 1 7 1.0ct. 10, 1979 1 6 m.Dec. 10, 1980 1 h n.Nov. 19, 1981 1

• 3 o.Harch 25, 1982 1 15

p. Aug. 18, 1982 1 k q.Jan. 25, 1977 1 3 l

NRC Bulletin.

Circular Info.

Status Report 8/2k/82 k 1 11 NBC Insp.

! 8' Tracking System Dump Report 8/2k/82 h 1 13 Open Only Items

8/31/82 SUBPOENA Item # DESCRIPTION ITD4 # # No.of Pages 9 E&DCR's Req'd Ver. 8/05/82 L 1 50 E&DCR's Req'd Ver. 7/02/82 k 1 53 E&DCR's Req'd Ver. 6/03/82 h 1 62 1 l

10 Weekly "As-Built" Status Sch.8/5/82 kl 1 9 Weekly "As-Built" Status Sch.0/19/82 41 1 9 i

i Weekly "As-Built" Status Sch.0/26/82 kl 1 9 11 Consap Status Report No. 20 8/18/82 h2 & h3 1 10 Consap Status Report No.19 8/k/82 h2 & h3 1 6 tJonsap Status Report No. 18 7/21/82 h2 & 43 1 7 12 Cabtrap Status Report No. 6 7/28/82 kk 1 6

! Cabtrap Status Report No. 7 8/28/82 kk 1 6 Cabtrap Status Report No. 8 8/26/82 hk 1 6 i

13 Problem Reports PR-CS-27-S11 ding Link Terminal Blocks 15 1 7 2/2/81 Problem Report QA-2 Limitorque Manual & Motor h/16/80 15 1 h PR-P-137-Extraction Line & Heater 15 1 10

Lagging 3/30/81 l 'h System Ehg. Change 12-31-81 Control and Package Paocram 20 1 9

! 15 Engineering Assurance 23 1

( Audit Report - No.13 h-27-82 5

Audit Report No. 40 6-k-02 16 16 Procedure for Seismic CAT. I 5/3/82 29 1 29 As-Built Piping Review and Reconciliation No. h2

, 17 As-Built Drawing Changes 8/27/82

~

30 1 12 Procedure No. 38

, Septanber 1,1982 g, Subpoena No. of Description

( Itan # , Iten # Paaes 1 Surveillance Reports 38 a) WEID MATERIAL CCNIROL FIELD APPLICATION 6 001-273 273 b) ASdE IRESSURE TESTI!G 38 SURVDf NO. M3 01-28 ,

28 c) MEDIANICAL EQUIR4ENT - SIOfUGE- 38 y MF-128-MF-1 38 d) COURTER WELDDG PERFORMANCE 38 SURVEY NO. MH-01-102 102

.~ e) PRODUCTION 'IRAINIIG CENIIR 38 PROCEDUREVPERFORMAtCE QUALIFICATION SURVEY MI-1-MI-16 16 f) ELECIRICAL CABLE TERMINATIONS 38 SURVEY NO. EB-001-133 133 g) ELECIRICAL SICRAGE 38 SURVEY NO. EC-001-125 125 h) INSIRlNENIATION SIORAGE 01-87 38 87 W

i) S&W WELDING PERFORMANCE 38 SURVEY No. MA-38-NA-1 MB-01-139 139 j) S&W WEIDItG PEREORMAtCE 38 SURVEY 10. E-2 & 1 k) REACICR 00tMROLS INC.

WEIDDG PERECRMANCE AS4E III MD-1-42 42

1) ELECIRICAL CABLE INSIALLATION 38 l SURVEY NO. 1-128 128 e

W

Septanber 1,1982 Description Stbpoena No. of Itan #

Itan # # Daaes 2 Stat. Analysis of Field Concrete Test Reports 35 1 a) St-39 Mix N1 1 4 b) Mix 4K670 1 3 c) Mix 3K467U 1 8 d) Mix 3K677D 1 3 e) Mix 4K70 1 3 f) Mix 3000-U-3-67-A-5.75 1 4 g) Mix 3K7U 1 5 h) Mix 3K67U-7 1 17 i) Mix 3K67U 1 8 j) Mix 3K670 1 22 k) Mix 3K67U 1 30 3 Torrey Pines - Status Report 14 a) GA-C-16799 Rev. A 1 7 b) GAC-16820 1 40 c) Proposal-Prog. Plan 1 44 4 Plant Configuration Reports 1,27 & 29 a) PCRN B31 1 23 b) KRW Cll 1 40 c) PCRN C41 1 20 d) KRN E21 1 20 e) PCRN E32 1 30 f) PCRN E41 1 35 W g) PCRN E51 1 40 5 Training & Experience Records 6 a) R. D.'Argenta 1 6 b) L. B. Amick 1 7 c) R. L. Werner 1 6 i d) R. L. Doyle 1 9 e) J. E. Scott 1 9 f) W. J. French 1 10 g) D. Pietrowski '

1 9 h) G. W. Henry 1 3

1) A. C. 7bduro 1 10

)

j) J. H. Brady 1 11 k) T. Rose 1 9

1) A. R. Muller 1 9 m) L. A. Henry 1 9 n) E. P. Peacock 1 8 o) V. Platania 1

• 10 p) D. E. Maguire 1 14 q) R. Antonova 1 6 r) P. D. Jolmston .

., 1 5

}P 6 CW's p r d ')/ 20 a) B21/2 i 1 2 b) B31/04 1 2

,, c) C91/1 1 2 d) Ell /l 1 2 e) E21/05 1 2 f) E51/02 1 4

l page l Septa ter 1, 1982 I Subpoena Ie No. of i Itea # Descriction Itsn # # 9 9, g) G33/07 1 2 h) M41/05 1 3 i) M60/2 1 2 j) N32/01 1 2 k) 1N52/2 1 2

/- 1) N71/3 1 1 m) P11/02 1 2 n) 1P41/5 1 1 o),P42/03 1 2 p) P50/08 1 2

q) 1R24/1 1 2 r) R43/2 1 3 s) 1R81/1 1 2 t) T46.-2 1 1 u) T48/08 1 2 v) X40/02 1 2 w) 293/05 1 2 x) 297/01 1 11 7 Project Procedures 17 a) T of C 1 2 b) P201 1 4 c) P202 1 14 d) P203 1 10 e) P204 1 3 y f) P205 1 7 g) P301 1 5 h) P302 1 10 i) P303 1 13 j) P304 1 22 k) P305 1 5

1) P306 1 6 Y m) P307 1' 5 n) P308 1 5 o) P309 -

1 8 p) P401 1 10 q) P402 1 4 r) P403 1 6 s) P404 1 18 t) P405 1 8 u) P601 1 6 v) P602 1 5 8 Surveillance Rep. 0 %

Plant Panels 3 a)81-113 1 3 b)81-114 1 3 c)82-117 1 5 d)82-118 1 6 e)82-119 1 3 f)82-120 1 4 W

I Page Septsnber 1,1982

=

Itsn # Description 91 W na No. of

, Item # # Pages Surveillance Reports Start-up Manual 3 a)81-111 1 5 b)81-112 1 1 c)82-113 1 1 d)82-114 1 30 l

9 Trends @-(OS Annual Rep.) 46 a) Annual Report 1979 1 29 b) Annual Report 1980 1 28 c) Annual Report 1981 1 30 l 10 survey Single Units (MNPE) 47 1 11 11 Open Item Graph 4 a) NRC 'Ibtal Inspections 1 1 b) BCI's 1 1 12 Fuel Ioad Update Rep's 30 1 1 13 SCRC Meeting Recmm. 29 1 12 14 contaiment Insulation VLys 2 a) E C Item Response 81-02-02 1 4 F

b) Iocation Criteria 1 11 i

15 GE Analysis & Evaluation 26 a) Proprietary Agreenent 4 4 b) Customer CAR Eval. Rep. 7/20/82 1 5 c) " " "

1/25/82 1 5 d) "

7/30/81 1 5 e) 1/30/81 1 5 f) " " " "

8/4/80 1 5 g) " " " "

2/22/80 -

1 5 h) 7/24/79 1 5 i) 2/6/79 1 4 j) 12/11/78 1 5

k) "

10/10/78 1 5

1) 7/24/78 1 5 m) 7/8/78 1 6 n) 4/10/78 1 5 o) 1/25/78 1 5 p) " " " "

12/9/77 1 5

q) " " " "

10/7/77 1 5 r) " " " "

8/30/77 1 5 CAIC SHEET GE Analysis & Eval's 26 1 10 16 Position Analysis 6

, a) O@ IN3. 1 6 b) QC DG. ~1 4 i c) QTt D G. 1 4 d) QC INSP. 1 4

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ATTACHMENT 12 9

DOCUMENT DESIGNATION Provided in phone call by the County on September 20, 1982 Calculations 1,. Previously designated Stone & Webster Engineering Assurance audits

2. SEO audit #11 Areas to be covered A. Traceability B. Use of incorrect / unqualified data C. Errors or inconsistencies in calculations D. Timeliness or adequacy of corrective action E&DCRs

1. Field QA Audits 9, 10, 12, 14, 19, 22, 23, 25, 26, 33-35, 38, 39 l 2. Engineering Assurance Audits C, 13, 15, 19, 21-24, 27, 33, 37, 40

3. Quarterly Reports (11 previously designated)

4. CAT Inspection Documents

5. Testimony and Documents related'to E&DCR verification program.

6. E&DCR Logs (County interested in status)

T S

Areas to be covered A. Failure to complete forms B. Filing / Indexing C. Courter D. Corrective Action Storage and Handling

1. FQC Audits 8, 11, 13, 15, 17, 20, 21, 23, 24, 26, 27, 30, 32-36, 40, 41

2. Surveillance Reports on Storage (electrical, instrumentation, and mechanical)

-- County will ask general questions on these surveillance reports and then propose a stipulation

3. CAT Inspection documents

, FSAR Conformance

1. EA audits

2. Configuration reports (seven)

--this will be the County's principal focus

3. More documents will be designated later.

Document Control Documents not yet designated

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Kirkpatrick, Lockhart, Hill, Christopher & Phillips Eighth Floor 1900 M Street Washington, D.C. 20036

Dear Larry:

On Friday I received three letters from you which, to-gether with your September 30 letter, designate the audit find-ings and audits you now intend to use during the balance of your QA cross-examination. I am surprised and exasperated by the contents of those letters. It is obvious from the large number of new additional findings and audits designated that you are just now preparing your cross-examination, which is l

surprising given the two weeks hiatus prior to starting the QA testimony. There is no other reasonable explanation. This indicates a total lack of concern on the County's part for the efficient litigation of the QA issues and contradicts the County's professed concern with getting quickly to the merits l of the case. Importantly, it also d'emonstrates a disregard for our agreement, approved by the Board, that the two weeks prior to the start of the QA testimony would be used to prepare cross-examination to ensure timely litigation.

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o p IIUNTON 8e WILLI AMM It is not hard to see how your latest, greatly ex-panded, listing of audits and findings will keep LILCO's QA panel on the stand for 6-10 more weeks. In the first two weeks of examination, you covered approximately 50 findings on caleu-lations and 40 findings on E&DCRs. That's a rate of about 50 findings per week. Your current listing includes the 35 or so findings left on E&DCRs plus over 175 findings on stor-age / housekeeping, 344 findings on document control and 20 find-ings on drawings. At the current rate, that means over 10 weeks of hearings; even half of that would be wholly unsatis-factory. Moreover, this does not include the examination on the E&DCR verification program and FSAR conformance that you indicated you would pursue. Furthermore, nothing has been said yet about the extent to which you will cross-examine LILCO's witnesses on their direct testimony, including the OQA program.

Thus, 6-10 more weeks does seem likely given your present intentions.

Several aspects of your latest list of findings are particularly objectionable. First, the size of the list is in-consistent with the representations made to the Board and par-ties on September 17. When Judge Brenner expressed concern about the length of the cross-examination, you indicated that the subject of calculations was, by a factor of three, the area with the largest number of findings. (Tr. 10,614). The impli-cation was that subsequent areas involved a lesser number of

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findings. We now know this is not the case. Moreover, given the size of this new list, I don't understand how you ever could have thought you could finish in 2-3 weers as we were initially led to believe.

As objectionable as the size of the list is the fact that it contains many substantive changes from what you have told me, and the Board, in the past. Let me list a few:

(1) In your September 10 letter to me, you confirmed earlier conversations indicating that you did not intend to use LILCO Fiel'3 QA audits. You changed your mind somewhat on September 21 when you gave me six Field QA audits you would be pursuing during the cross-examination on E&DCRs (see Tr. 10,870).

At the same time you also designated docu-ments for use on storage and handling, none of which were Field QA Audits. Now you have designated a total of 96 new, additional findings on storage and handling and at least 68 new, additional findings on document con-trol from Field QA audits. ,

(2) Your September 10 letter also confirmed that you did not intend to use any LILCO QA Division audits. By September 21, you had changed your intention and indicated you might use QA Division audits to the extent they were referenced in specified Quarterly Reports. The use of these documents was, however, 3imited to findings concerning E&DCR problems (see Tr. 10,873). Now, in the latest, greatly expanded listing, you include over 135 new findings from LILCO QA Division audits not previously identified.

(3) Your September 10 letter also confirmed that you did not intend to use any Courter audits. Throughout the many discussions on documents since then, you never mentioned any Courter audits. Nor were they included on the handwritten list given to the Board on September 16. And now, surprisingly, you list 34 findings from Courter audits.

_4 p.s H uxTow Sc WILLIAMS (4) When asked by the Board on September 16 whether the County expected to use any other large groups of documents similar to Suffolk County Exhibits Nos. 51 (EA Audits) and 56 (FQC Audits), you said no. (Tr. 10,307-8).

Yet in che new, expanded listing, there are at least 50 new LILCO Field QA Audits and 50 new LILCO QA Division-audits now designated for use.

(5) As mentioned in (2) above, you had only designated Quarterly Reports for use in con-nection with E&DCRs. Your September 29 stor-age / housekeeping list includes six Quarterly Reports.

Thus, LILCO's witnesses are faced with the prospect of having to re-familiarize themselves with a large number of documents they previously believed would not be used. This has to be done at the same time they are trying to deal with an ex-tremely large number of findings from documents already desig-nated. Your lack of preparation and repeated shifting of focus has made it very difficult, and maybe impossible, for our wit-nesses to give the Board a true and complete picture of the facts in the time available.

Your argument that the County thinks it necessary to use all of these documents to prove its case rings hollow, i

Most of the documents designated were provided to the County in March or April of this year. If you felt they were important, i they certainly could have been included as part of your direct testimony. To my recollection, not one of the audit reports l

used to date in your cross-examination is referenced in the County's direct testimony. In fact, it is striking that there i

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-S-g3 HUNTON 6t WI LLI AM S is no mention at all of the subject area of calculations which consumed most of a week and which you told the Board was the largest area of findings by a factor of three. Other than the CAT Inspection, I don't believe any of the audits you intend to use in the future are in the County's direct testimony. Again, if this material is important to your case, I fail to under-stand why it wasn't dealt with in your direct testimony.

Indeed, if the County was seriously interested in engaging the issue of whether " patterns of QA breakdowns" did exist, it would have made sense to lay out the basis for the belief so LILCO witnesses could be prepared to respond appropriately on cross-examination.

My final complaint about your latest document list is that it evidences a disregard for the agreement reached among l the parties back on August 27. As you know, we agreed to post-pone the start of the QA testimony for two weeks to ensure more efficient litigation of the subject. Although you did not promise you could be done in two weeks, the impression you gave l

us was that it would not take much longer than two weeks if you l

l had time to prepare. Tr. 9947-48. As I told you on several occasions, we were not pleased with the lack of specificity in i

i your designation at the end of the two weeks. It has now be-l come clear that you could not have been more specific because i .

[ you were not prepared. This is distressing since we, and the Board, agreed to the delay specifically so you could be

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Huxrox 8e WILLIAxs prepared. In fact, it is my recollection that you were only at the hearings part of one day during the prior week, giving you three weeks to prepare. How you choose to staff and prepare your case is your business until it impacts on the progress of the hearings. That impact now threatens to be quite signifi-cant. This latest QA development is an indication of the County's lack of concern with the efficient progress of these hearings.

To remedy the situation, several steps need to be taken.

First, I believe you should withdraw your designation of all of the LILCO Field QA Audits, LILCO QA Division Audits, Courter audits and LILCO Quarterly Reports in the areas of storage /nousekeeping and document control. This would not foreclose the possibility that, as a result of unexpected de-i velopments in cross-examination, you might use a particular audit for a limited, specific purpose; the Board has made clear its intention to allow some flexibility in this regard. I do, l however, believe that given your prior representations, whole-sale use of these audits now unfairly burdens LILCO's witnesses and threatens unnecessarily to prolong the cross-examination.

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Moreover, when the Board directed you to designate findings, we (and we think the Board) surely had in mind findings in the documents you had previously identified in your handwritten list given to the Board on September 16, as further narrowed by subsequent discussions.

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p; HUNTON & WILLIAMS Next, we need to engage seriously the question of how to handle the remaining cross-examination in an efficient man-ner. Your indication of the subject matter for groups of find-ings is helpful but falls far short of what I suggested in my October 1 letter. We need to make substantial and rapid pro-gress in precisely defining the County's concerns.

Accordingly, we plan to file today with the Board a motion reciting all this history, attaching all the pertinent cor-respondence and requesting relief of (a) exclusion of certain newly designated material, (b) mandatory statements by the County, along the lines set out in my October 1 letter, and (c) a two week time limit on the County's remaining QA cross-examination.

Singerely,

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ML L Anthony . Earley, Jr.

299/765 cc: Bernard M. Bordenick, Esq.

L CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I hereby certify that copies of LILCO'S MOTION FOR FURTHER BOARD DIRECTION ON THE CONDUCT OF QA CROSS-EXAMINATION were served upon the following by first-class mail, postage prepaid, or Federal Express (as indicated by an asterisk) on October 5, 1982:

Lawrence Brenner, Esq.* Secretary of the Commission Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission c/o Holiday Inn Atomic Safety and Licensing Valley Forge, Pennsylvania 19481 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris

• Commission l Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Atomic Safety and Licensing Commision ~

Board Panel l c/o Holiday Inn U.S. Nuclear Regulatory Commission Valley Forge, Pennsylvania 19461 Washington, D.C. 20555 Dr. James H. Carpenter

• Administrative Judge Daniel F. Brown, Esq.

Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 i

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( f Bernard M. Bordenick, Esq.* David J. Gilmartin, Esq.

Richard L. Black, Esq. Attn: Patricia A. Dempsey, Esq.

David A. Repka, Esq. County Attorney U.S. Nuclear Regulatory Suffolk County Department of Law Commission Veterans Memorial Highway Washington, D.C. 20555 Hauppauge, New York 11787 Herbert H. Brown, Esq.* Stephen B. Latham, Esq.

Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Karla J. Letsche, Esq. 33 West Second Street Kirkpatrick, Lockhart, Hill, P. O. Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor 1900 M Street, N.W. Ralph Shapiro, Esq.

Washington, D.C. 20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Mark W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road Howard L. Blau, Esq.

Waltham, Massachusetts 02154 217 Newbridge Road Hicksville, New York 11801 MHB Technical Associates 1723 Hamilton Avenue Matthew J. Kelly, Esq.

Suite K State of New York San Jose, California 95125 Department of Public Service Three Empire State Plaza Mr. Jay Dunkleberger Albany, New York 12223 New York State Energy Office '

i Agency Building 2 Empire State Plaza Albany, New York 12223 Anthiony F. p rle K Jr. /

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212