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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20083B7331991-09-13013 September 1991 Notice of Appeal.* Informs of Notice of Appeals from Memos & Orders Denying Petitions for Intervention & Requests for Hearings ML20082G8551991-08-0606 August 1991 Notice of Relevant Decision & Significance.* W/Certificate of Svc ML20082B2271991-06-28028 June 1991 Notice of Appeal.* Denies School Districts Petition for Intervention & Request for Hearings in Matter as Well as ASLBs Dismissal of School District from Participation in above-captioned Proceeding ML20029A0231991-01-25025 January 1991 Notice of Typos in Petitioners Notice of Appeal & Petitioner Brief in Support of Appeal of ASLB 910108 Memorandum & Order (Both Filed on 910123).* W/Certificate of Svc. Served on 910125 ML20066E1331991-01-15015 January 1991 Requests limited-scope Exemption from Seismic Qualification Requirements of Criterion 2,App A,10CFR50 to Permit Deletion of 125-volt Dc Batteries 1R42*BA-A1 & 1R42*BA-C1 ML20029A0281991-01-0808 January 1991 Notice of Appeal.* Provides Notice of Appeal of 910108 Memorandum & Order (Ruling on Request for Intervention) in Proceeding Re Confirmatory Order Mod & Security Plan & Emergency Preparedness Amend ML20029A0111991-01-0808 January 1991 Application for Stay of Board 910108 Order.* Petitioners Move for Stay of 20-day Period to Amend Petitions Until Commission Decides on Appeal of Order or Pending Petition for Reconsideration.W/Certificate of Svc ML20058K4291990-11-28028 November 1990 Comment on Proposed NSHC Determination,Request for Hearing, Notice of Intent to Intervene & Opposition to Issuance of Amend by & on Behalf of Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy,Inc ML20062F7601990-11-15015 November 1990 Notice of Appearance.* Notice of Withdrawal & Certificate of Svc Encl ML20062C2501990-10-18018 October 1990 Establishment of Aslb.* Board Will Preside Over Proceeding Re Actions Taken by NRC & Long Island Lighting Co Re Shoreham Nuclear Power Station Unit 1,per Commission 901017 Memo.Served on 901022.W/Certificate of Svc ML20012C7601990-03-15015 March 1990 Request for Limited Scope Exemption from fitness-for-duty Requirements Imposed by 10CFR26.2 & That Exemption Be Granted & Remain in Effect Until NRC Approves Final Disposition of OL ML19332G6071989-12-15015 December 1989 Requests Exemption from Emergency Preparedness Requirements of 10CFR50.54(q) & to Implement Defueled Emergency Plan,Per Util Settlement Agreement W/State of Ny ML19353A9441989-12-0505 December 1989 Requests Exemption from Requirement of 10CFR50.71(e)(4) to File Annual Copy to Updated SAR by 891207.Required Update to Be Submitted on or Before 900601 & Will Reflect Condition of Plant as of Time Settlement Agreement Took Effect ML20244C2891989-04-17017 April 1989 Pages Affected by Rev 10A,890411.* Related Correspondence ML20235N2451989-02-24024 February 1989 Professional Qualifications of Lilco Witnesses on Exercise Contentions.* Certificate of Svc Encl.Related Correspondence ML20206M8951988-11-23023 November 1988 Notice of Appearance.* Author Enters Appearance in Proceeding on Behalf of Suffolk County.Certificate of Svc Encl ML20196F7381988-11-21021 November 1988 Errata to Board Decision LBP-88-24,changing Yr on Page III, Line 8 from 1988 to 1986.Served on 881205 ML20205D6871988-10-24024 October 1988 Notice of Appearance.* Author Enters Appearance in Proceeding on Behalf of Suffolk County.W/Certificate of Svc ML20205E0621988-10-21021 October 1988 Lilco Rept to Appeal Board on Progress & Effect of Town of Hempstead Case.* Article 2-B Re State & Local Natural & man-made Disaster Preparedness & Certificate of Svc Encl ML20155G9341988-10-0707 October 1988 Memorandum.* Advises That NRC Interpretation of ASLB 881006 Memorandum & Order That 24-h Period to Respond to Intervenors Motion Does Not Include Saturdays,Sundays & Federal Holidays Correct.Served on 881011 ML20154P5281988-09-27027 September 1988 Notice of Appeal.* Notices Appeal from ASLB Initial Decision LBP-88-24.Notices of Appeal from State of Ny & Town of Southampton,Govts Motion for Bifurcation of Appeal & Expedited Treatment of Issue & Brief on Appeal Encl ML20154P8021988-09-26026 September 1988 Notice of Aslab Reconstitution.Cn Kohl,Chairman & as Rosenthal & Ha Wilber,Members.Served on 880927 ML20207E5551988-08-15015 August 1988 Notice of Oral Argument.* Oral Argument Will Be Heard on 880914 in Bethesda,Md Re Lilco Appeal of ASLB Initial Decision LBP-88-2.Served on 880816 ML20207E4401988-08-15015 August 1988 Notice of Oral Argument.* Notifies That Oral Argument on Joint Appeal of Suffolk County,State of Ny & Town of Southampton from Board 880509 Partial Initial Decision LBP-88-13 Will Be Heard on 880917.Served on 880816 ML20207E4801988-08-12012 August 1988 Reconstitution of Aslab.* TS Moore,Chairman & as Rosenthal & Ha Wilber,Members.Served on 880815 ML20196A9391988-06-20020 June 1988 Govts Notice of Appeal.* Appeal Board 880610 Order as Reconfirmed on 880617,resolving Legal Authority Contentions in Favor of Applicant,Per CLI-86-13.Certificate of Svc Encl ML20197E0541988-05-25025 May 1988 Memorandum.* Lists Conclusions on Issues Raised by Lilco Appeal from ASLB 871207 Partial Initial Decision Re Scope of Feb 1986 Emergency Preparedness Exercise at Facility.Appeal Technically Moot.Served on 880525 ML20154H6941988-05-20020 May 1988 Notice of Appeal.* Suffolk County,State of Ny & Town of Southampton Notice of Appeal from ASLBP 880509 Partial Initial Decision on Suitability of Reception Ctrs. Certificate of Svc Encl ML20151E9411988-04-0808 April 1988 Memorandum (Extension of Board Ruling & Opinion on Lilco Summary Disposition Motions of Legal Authority Realism Contentions & Guidiance to Parties on New Rule 10CFR50.347(c)(1)).* Served on 880411 ML20151F0341988-04-0808 April 1988 Notice of Oral Argument.* Oral Argument on Lilco Appeal of ASLB 871207 Partial Initial Decision LBP-87-32 Will Be Heard on 880428 in Bethesda,Md.Served on 880411 ML20148K2591988-03-29029 March 1988 Memorandum to Parties.* Attached Memo from Bp Cotter,Chief Administrative judge,self-explanatory.Parties to Proceeding Requested to Conform to Svc Request.Served on 880329 ML20150C6421988-03-15015 March 1988 Notice of Appearance.* Notice of Appearance of Ma Young in Proceeding.Certificate of Svc Encl ML20150C6451988-03-15015 March 1988 Notice of Appearance.* Advises That Ma Young Will Enter Appearance in Proceeding.Certificate of Svc Encl ML20150C7311988-03-15015 March 1988 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20150C7621988-03-10010 March 1988 Notice of Withdrawal of Gs Johnson as Counsel for Nrc. W/Certificate of Svc ML20196H8981988-03-0909 March 1988 Notice of Appearance.* Notice of Appearance of RA Sheffey in Proceeding.Certificate of Svc Encl ML20196J2231988-03-0707 March 1988 Notice of Appearance of LB Clark as Counsel for Nrc. W/Certificate of Svc ML20196H5551988-03-0707 March 1988 Notice of Appearance of Cl Ingebretson as Counsel for Lilco. W/Certificate of Svc ML20147H8341988-03-0404 March 1988 Notice of Deposition.* Oral Exam of J Sobotka on 880307 in Suffolk County,Ny Re Rev 9 to Plant Emergency Plan. Certificate of Svc Encl.Related Correspondence ML20196J0571988-03-0101 March 1988 NRC Staff Proposed Schedule for Hearing on Remaining Remand Issues.* Schedule for FEMA Review of Recent Revs to Util Plan Also Encl.Certificate of Svc Encl ML20148U4611988-01-25025 January 1988 Notice of Deposition.* Notice of Deposition Upon Oral Exam of DM Crocker on Lilco Proposal for Evacuating School Children from Plant 10 Mile EPZ During Radiological Emergency.Certificate of Svc Encl.Related Correspondence ML20195J0941988-01-15015 January 1988 Response of Govts to Board 871223 Confirmatory Memorandum & Order.* Ref Portions of Govts Previous Filings Make Clear That NRC Use of Word May in Providing Guidance to Boards Appears to Be Quite Delibrate.Certificate of Svc Encl ML20147B9041988-01-13013 January 1988 Notice of Aslab Reconstitution.Cn Kohl,Chairman & as Rosenthal & WR Johnson Members.Served on 880114 ML20234C6841988-01-0404 January 1988 Notice of Aslab Reconstitution.* CN Kohl,Chairman & as Rosenthal & WR Johnson,Members.Served on 880105 ML20237E8321987-12-17017 December 1987 Notice of Appeal by Lilco from LBP-87-32.* Util Intends to Move Imminently for Expedited Consideration of Appeal by Immediate Certification to Commission or Expedited Briefing, Argument & Decision by Aslab.W/Certificate of Svc 1992-02-26
[Table view] |
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e.
. LILCO, July 1, 1982
.):
mdv UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station,)
Unit 1) )
LILCO'S RESPONSE TO THE BOARD'S REQUEST FOR INFORMATION CONCERNING SCIENCE APPLICATIONS, INC.
On June 24, 1982, the Board requested that the parties, the NRC Staff and LILCO in particular, provide information re-garding work that Science Applications, Inc. (SAI) is doing under contract for the NRC Staff. SAI is LILCO's PRA consul-tant and an SAI employee, Dr. Edward T. Burns, is a witness in this proceeding. The following information is provided in re-sponse to the Board's request.
SAI, like many consultants in the nuclear industry, has performed work for the NRC Staff in a wide range of areas. A listing of SAI's NRC contracts over the past few years is attached. The list does not include contracts with national laboratories since there is no easy way for SAI to distinguish C207070295 820701 PDR ADOCK 05000322 G PDR J5@ _
.. I whether the funds for a contract come from the NRC or the Department of Energy. SAI has, however , provided informat, ion on the contract of interest to this Board -- SAI's work for Lawrence Livermore Laboratory on systems interaction.
This work was performed by SAI's Energy Technology &
Engineering (ET&E) Group's Accident Consequence Division.b!
SAI, under contract with Lawrence Livermore Laboratory, sur-veyed available systems interaction methodologies and assessed the current state of the art. The purpose of the study was to aid in the development of a methodology for systems interaction studies. SAI's principal involvement was through one of its employees, a member of the WASH-1400 Reactor Safety Study and a recognized expert in the field. The work for Lawrence Livermore Laboratory resulted in the publication of NUREG/CR-1859, " Systems Interaction: State-of-the-Art Review."S!
1/ The ET&E Group within SAI is diverse both in its geography and expertise. The Group's management structure reflects this diversity. The Accident Consequence Division is located in Palo Alto and is part of the Physics & Safety Operation of the ET&E Group.
The work for LILCO was performed by ET&E's Power Engineering Services Division located until very recently in San Jose. The Power Engineering Services Division is part of the Engineering Analyses Operation of the ET&E Group.
These divisions report to separate Operations Managers.
The work performed for Lawrence Livermore Laboratory was done without knowledge of the performance requirements for LILCO and vice versa. There was no exchange of technical information between the organizations on their respective studies.
2/ Three other national laboratories also published reports on systems interaction for the NRC. The reports represent (Footnote Continued)
, I As an outgrowth of this systems interaction work for Lawrence Livermore Laboratory SAI prepared for and participated in one review meeting of the Indian Point Systems Interaction Study (being conducted by PASNY and EBASCO). SAI's role was as an expert reviewer to provide comments on the study to the NRC through Lawrence Livermore Laboratory.
The contract between Lawrence Livericore Laboratory and SAI has been inactive since December 1981 because of lack of funding. No future SAI participation in the Indian Point Systems Interaction Study is anticipated.
SAI has summarized its position on the present matter as follows:
SAI is a company of approximately 3500 employees distributed in 50 offices throughout the country.
SAI clients include private industry, the Defense Department, the NRC and National Laboratories.
SAI has provided consulting services to the NRC and to utilities SAI does employ as members of its staff experts in the field or probabilistic risk assessment; because of the limited number of such experts available, these people may consult at different times with both NRC and private industry On the subject of systems interaction, the NRC has performed at least four studies in an attempt to
( define a methodology i
l --
SAI participated as a contributor to one of these studies
( (Footnote Continued) diverse viewpoints from which the NRC presumably will mold its j systems interaction policy.
I
-4_
SAI has also participated as a reviewer and adviser to the NRC on the PASNY/Ebasco systems interaction pilot program at Indian Point SAI is no longer an active consultant to Lawrence Livermore Laboratory on systems interaction No member of the SAI staff participated in both the Lawrence Livermore Laboratory sponsored review of Indian Point and the Shoreham PRA As to LILCO's involvement with SAI, contact was first made with the Power Engineering Services Division in late 1979 or early 1980. SAI provided LILCO with information on PRA's in general and SAI's capabilities in particular throughout 1980.
During this period LILCO also discussed PRAs with other poten-tial contractors. Formal competitive bids for the Shoreham PRA were submitted to LILCO in February 1981, and SAI was awarded the contract for phases I and II of the PRA in April 1981.1!
Counsel for LILCO has been aware of SAI's role in the Shoreham PRA as well as SAI's participation in the Limerick PRA. Counsel was also aware that SAI is a widely known expert in the PRA field and has done PRA work for other atilities.
Counsel did not know of SAI's involvement in the Indian Point Systems Interaction Study.
LILCO sees no conflict of interest in SAI's performance of work for utilities, LILCO in particular, on the one hand, 3/ For the Board's information, LILCO's other PRA expert wit-ness, Dr. Vojin Joksimovich, is employed by the NUS Corporation. NUS has also done work for the NRC Staff. In the PRA area, that work has consisted of conducting seminars on PRA methodology for NRC Staff personnel.
, 9 and the NRC Staff on the other. In the systems interaction area, SAI's work for the Lawrence Livermore Laboratory (under contract with the NRC Staff) was an assessment of the state of the art in systems interaction methodology done by a recognized expert in the field. It is appropriate for the NRC Staff or its contractor to seek the expert views of one of the handful 4
of pre-eminent organizations in the field. SAI's Indian Point work appears to have been merely an extension of this state of the art review.
In sum, the only bearing of SAI's prior systems inter-action work on this proceeding concerns not conflict of inter-est but whether Dr. Burns' testimony is consistent with the pertinent views of other SAI experts. Although LILCO does not believe any inconsistencies exist, the parties and the Board can certainly explore the area if they so desire.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
/
/ / $
t %. . (h CLtA 4's lil }
W. Taylor yveley'<-III, IIU '
Donald P. Rwin V Anthony F. Earley, Jr.
Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: July 1, 1982 l
l
LILCO, July 1, 1982 9
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 RESPONSE TO THE BOARD'S REQUEST FOR INFORMATION CONCERNING SCIENCE APPLICATIONS, INC., were served upon the following by first-class mail, postage prepaid, or by hand (as indicated by an asterisk), on July 1, 1982.
Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Boa 3 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 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris
- U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Bernard M. Bordenick, Esq.*
Commission Dav id A. Repka, Esq.
Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter
- Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.
Board Panel Attn: Patricia A. Dempsey, Esq.
l U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 l
l l
\
Secretary of the Commission Stephen B. Latham, Esq.
U.S. Nuclear Regulatory Twomey, Latham & Shea Commission 33 West Second Street Washington, D.C. 20555 P. O. Box 398 Riverhead, New York 11901 Herbert H. Brown, Esq.* Ralph Shapiro, Esq.
Lawrence Coe Lanpher, Esq. Cammer and Shapiro, P.C.
Karla J. Letsche, Esq. 9 East 40th Street Kirkpatrick, Lockhart, Hill, New York, New York 11901 Christopher & Phillips Albany, New York 12223 8th Floor 1900 M Street, N.W. Howard L. Blau, Esq.
Washington, D.C. 20036 217 Newbridge Road Hicksville, New York 11801 Mr. Mark W. Goldsmith Energy Research Group Matthew J. Kelly, Esq.
400-1 Totten Pond Road State of New York Waltham, Massachusetts 02154 Department of Public Service Three Empire State Plaza MHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue Suite K Mr. Jay Dunkleberger San Jose, California 95125 New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 Respectfully submitted, LONG ISLAND LIGHTING COMPANY
,dcaA h.
68t W. Taylor (R'eveley, III[/ /
i Donald P. Irwin Anthony F. Earley, Jr.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: July 1, 1982 i
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