ML20024F345
| ML20024F345 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/06/1983 |
| From: | Monaghan J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SUFFOLK COUNTY, NY |
| References | |
| ISSUANCES-OL-3, NUDOCS 8309090296 | |
| Download: ML20024F345 (34) | |
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SeptemberUSFhRC,1983
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- UNITED' STATES OF AMERICA
. NUCLEAR, REGULATORY COMMISSION ,.
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J Before the7 Atomic Safet"y"and Licensing Board
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In thei Matter of ,
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LONG ISLAND LIGHTING COMPANY. ' ) Docket No. 50-322-OL-3
)l(Emergency Planning Proceeding)
(Shoreham Nuclear Power Station,' )'
Unit 1) )
ANSWERS TO SUFFOLE COUNTY INTERROGATORIES TO LONG ISLAND LIGHTING COMPANY Purcuant to 10 C.F.R. 5 .2. 740b of the Nuc.leaz. Regulai.ory Com-a mission's Rules of Practice, Long Island Lighting Company, by s
counsel, sets forth its answers and objections to Suffolk County Interrogatories To Long Island Lighting Company.
I.2 G E N E R A L' O B J E C T I O N S Long Island Lighting Company makes the following general
< objections, whether or not separately set forth, to each of Suffolk Co'unty's interrogatories.
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- 1. .LILCO objects to Suffolk County's interrogatories to the
, _ extent that they seek disclosure of information pro-
- tected by the attorney-client privilege, the work prod-
, c uct doc. trine, or'any other applicable privilege or doc-trine.
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- 2. I,ILCO objects to Suffolk County's interrogatories to the eittent that they are overly broad, unduly burdensome,
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. e and seek information not reasonably calculated to lead to:the. discovery of admissible. evidence.
- 3. LILCO objects to Suffolk County's interrogatories to the extent'that.they call for information in a form differ-ent from tha't maintained by LILCO in the ordinary course of its business.
- 4. LILCO objects to Suffolk County's interrogatories to the extent that it seeks information and documents not in the possession, custody or control of LILCO or LILCO's consultants.
-1 Il~. ANSWERS AND OBJECTIONS TO INTERROGATORIES
[ . Suffolk Countiv Interrogatory No. 1
' Describe Ahe "specified communications equipment designed to ensure _the> prompt transmission of information to WALK for dissemination to 'public," ao stated in LILCO's let-terofagreementwithMALK. Has such equipment been
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installed and made operational? If not, what is the schedule in this regard?.- Provide copies of all_ documents concerning such equipment, its installation, and its op'eration.
^
, LILCO's Response to Suffolk County Interrogatory No. 1 The equipment referred to in the letter of agreement betweenLILbOandWALKisa.dedicatedtelephoneline. The dedicated' telephone line links the local EOC and. WALK in Patchogue. As with the other dedicated lines used by LERO
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(Plan at 3.4-4) this is a two-terminal line which automatically rings at one location when the handset is lifted from the cradle at the other location. Its operation is independent from telephone company switching.
The dedicated telephone line between LILCO and WALK has not been installed yet, but is scheduled to be installed by September 26, 1983. Attached is a copy of the LILCO tele-phone installation requisition. To the best of LILCO's knowledge and belief, LILCO does not possess any other docu-ments responsive to this request.
Suffolk County Interrogatory No. 2 Has WALK installed an 80 DW AGP for backup generation?
If not, when will it be installed? Who is the manufacturer of the backup generator? Provide all documents concerning the 80 DW AGP to be used by WALK.
LILCO Response to Suffolk County Interrogatory No. 2 WALK has installed an 80 KW diesel gene ator. The manu-facturer of the generator is Kohler. Enclosed with this response is a LILCO report describing the generator and a report on a test of the generator. To the best of LILCO's i knowledge and belief, LILCO does not possess any other docu-ments responsive to this request.
Suffolk County Interrogatory No. 3 l LILCO's letters of intent with four bus companies note that the agreements are subject to prior rights of local
. school districts under contract to the bus companies. For each bus company with which LILCO has an agreement identify:
- a. The school districts which have prior rights to the buses
- b. The number of buses to which each school district has prior rights.
LILCO's Response to Suffolk County Interrogatory No. 3 The numbers of buses described below are those committed to school districts by the bus companies from their entire inventory of buses.
- An asterisk indicates that LILCO was unable to obtain the information requested from the bus companies.
Number of Bus Company School District Buses Committed Baumann & Sons Buses, *
- Inc.
Huntington Coach Corp. Huntington #3 So.'Huntington #13 Harborfields Public 107 Schools #6 Cold Spring Harbor #2 Seaman Bus Co., Inc. Shoreham/ Wading River 26 Various Parochial Schools 4 Miller Place 1 J
Suburbia Bus Corp. Miller Place 14 Middle Island Central 90 Three Village Central 65 The'following bus companies have signed letters of agreement with LILCO subsequent to the submittal of Revision 1 to the Plan. A copy of the-letter of agreement for each of rv-----g ,------.sw------ m-em-,-- "m s e - - - -r----- ---- ,--,wm ,pv , .-s, , -
the bus companies that entered into the agreement subsequent to Revision 1 is enclosed.
Number of Bus Company School District Buses Committed Port Bus Company *
- Coram Bus Service *
- Educational Bus Lindenhurst #4 38 Transportation, Inc. Copaigue 36 Massapequa 22 Amityville 1 Deer Park 1 Lindenhurst *4 30 Vans Starlite Commack 44 Hermon E. Swezey Co. Southaven 1 Other districts within -
BOCES II on an "as needed" basis United Bus Corp. Middle County 90 Patchogue-Medford Hauppague-Union Free 46 William Floyd #32 64 Suffolk County Interrogatory No. 4 Cn what basis is it estimated that, on average, route buses will be 74 percent full after completing a route? See App. A at-IV-66b, Rev. 1.
LILCO's Response to Suffolk County Interrogatory No. 4 i
l As a matter of judgment, it was assumec that buses returning to.a transfer point after traversing a route would contain 30 people. This figure represents 75 percent of the seating capacity of the bus and 58 percent of the total capacity of the bus (assuming 12 standees). This assumption has two effects:
- a. More buses are assigned to the route than would have been if full loading were assumed.
- b. Sufficient additional capacity is provided to handle surges in demand during the evacuation.
Suffolk County Interrogatory No. 5 Explain the basis for all time estimates presented on pr.ge IV-86b, Rev. 1, of App. A. Provide all documents con-cerning such estimates, including those upon which the esti-matec are based.
LILCO's Response to Suffolk County Interrogatory No. 5 gee attached Table A.
puffolk County Interrogatory No. 6 Identify the persons or entities responsible for analyz-ing and/or deriving the time and vehicle requirement esti-mates set forth at pages IV-190 to 192, Rev. 1, of App. A.
Provide copies of all documents concerning such estimates, including those upon which the estimates are based.
LILCO's Response to Suffolk County Interrogatory No. 6 The person responsible for analyzing and deriving the l . time and vehicle requirement estimates is Reuben Goldblatt, i
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Senior Analyst, KLD Associates, 300 Broadway, Huntington Sta-tion, New York, 11746. Copies of all documents concerning such estimates are enclosed with this response.
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Suffolk County No. 7 Describe all compensation, benefits or incentives of any type, if any, that LILCO has offered or given, or expects to offer or give to LILCO employees who elect to become emergen-cy workers under the LILCO plan.
LILCO Response to Suffolk County Interrogatory No. 7 As stated in response to Suffolk County Requests 80 and 81 of July 18, 1983, LILCO will compensate LILCO employees who elect to become emergency workers at their normal rate of pay for training and for duties performed during actual emer-gencies. In addition, LILCO employees who are members of LERO will receive the usual benefits received by LILCO em-ployees including indemnification of emergency response per-sonnel for injuries and disabilities to themselves or to third parties and coverage under the LILCO Vehicle Lease Agreement for employees' vehicles used during drills or dur-ing an actual emergency.
Suffolk County Interrogatory No. 8 Describe all compensation, benefits or incentives of any type that LILCO has offered or expects to offer to non-LILCO l
employees who elect to become emergency workers under the LILCO plan.
LILCO Response to Suffolk County Interrogatory No. 8 As stated in response to Suffolk County Requests 80 and 81 of July 18, 1983, LILCO will compensate non-LILCO l
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employees who elect to become emergency workers at their normal rate of pay for training and for duties performed dur-ing actual emergencies and will indemnify emergency response personnel for injuries and disabilities to themselves or to third parties.
Suffolk County Interrogatory No. 9 In its " Answer to Suffolk County's Motion for Rejection of LILCO Transition Plan and for Certification to the Commis-sion," dated August 8, 1903, LILCO stated that 30 people were engaged full time in nothing but performing the tasks needed to put in place a workable emergency plan. Identify those 30 individuals.
LILCO's Response to Suffolk County Interrogatory No. 9 LILCO objects to Suffolk County Interrogatory No. 9 to the extent that it seeks information about the residence address of the individuals engaged in developing the emergen-cy plan on the grounds that such information is not relevant to the subject matter of these proceedings nor is it calcu-lated to lead to the discovery of admissible evidence. With-out waiving its objection, LILCO provides the rest of the re-quested information in the attached Table B.
Suffolk County Interrogatory No ljl For each person identiff.ea in response to the previous question,-identify (a) his or her LILCO position; (b) his or her LERO position if any; and (c) the tasks he or she is
responsible for performing in connection with putting the LILCO plan in place.
LILCO's Response to Suffolk County Interrogatory No. 10 See LILCO's Response to Interrogatory No. 9.
Suffolk County Interrogatory No. 11 State the total number of individuals to whom the "LILCO Response Organization Participation Form" was given. Iden-tify the basis upon which such individuals were selected or identified.
LILCO's Response to Suffolk County Interrogatory No. 11 The "LILCO Response Organization Participant Form" was given to 1,719 LILCO employees. As stated in the letter from LILCO's counsel to Karla J. Letsche of August 29, 1983, the following method was used to select the LILCO employees who would receive the LILCO Emergency Response Participant Form.
First, LILCO employees were selected as potential members of the LERO organization by matching the skills required for their LILCO job with the skills required by the LERO job descriptions. In selecting potential LERO personnel, LILCO avoided selecting some personnel whose jobs were with emer-gency restoration organizations in order to maintain its emergency restoration capability in the event that a radio-logical incident occurred at the same time that a storm brought down power. lines. The LILCO employees selected as potential members of LERO were asked to attend an orientation
session. At that session, all LILCO attendees were given the "LILCO Response Organization Participant Form" to complete.
Suffolk County Interrogatory No. 12 Identify and describe all information that has been or is intended to be provided to LILCO personnel, subsequent to February 1, 1982, concerning emergency preparedness at Shoreham, including, but not limited to, any information con-cerning participation of LILCO employees in off-site emergen-cy response, LERO, or LERO training. Identify the persons or entities who provide such information to LILCO personnel and describe the means by which it was provided.
LILCO's Response to Suffolk County Interrogatory No. 12 LILCO personnel have received the following information regarding emergency preparedness at Shoreham:
- 1. LILCO Bulletin (provided by LILCO to Suffolk County) --
distributed by LILCO Employee Communications department to all LILCO work locations and mailed to all LILCO employees.
- 2. "LERO, Local Emergency Response Organization, Training Source Material" (provided by LILCO to Suffolk County-
) -- provided to LILCO orientation session coordinators by Local Emergency Response Implementing Organization (LERIO) personnel.
- 3. "Shoreham Emergency Plan, Local Emergency Response Orga-nization, Employee Information" (provided by LILCO to
Suffolk County) and videotape (copy enclosed with this response) -- provided to all LILCO employees by LERIO personnel.
- 4. " Facts About Radiation, LERO and Your Job" (provided by LILCO to Suffolk County), LERO training workbook (pro-vided by LILCO to Suffolk County), LERO training video-tapes (provided by LILCO to Suffolk County), LERO " pep talk" and videotape (copy enclosed with this response),
, and.the lERO emergency worker questionnaire (copy-enclosed with this response) - provided to all LILCO l
I members of LERO by LERIO personnel.
- 5. SNPS Local Radiological Emergency Response Plan and i
Implementing Procedures (provided by LILCO to Suffolk County) -- provided to all LERO senior coordinators by LERIO personnel.
- 6. "Today" (copy enclosed with this response) -- posted at and copies provided at all LILCO work locations by LILCO Employee Communications department.
Suffolk County Interrogatory No. 13 It is not clear from LILCO's Response to Suffolk County Request.ll of July 18, 1983.whether that response referred to f
documents' filed with the Disaster Preparedr. ass Commission or I
Governor'Cuomo's Shoreham Commission. Please clarify this ambiguity and provide copies of all documents sent to or received from the Disaster Preparedness Commission.
LILCO's Response to Suffolk County Interrogatory No. 13 The documents indicated in response to Request 11 were filed as follows: (1) the June 28, 1983 submittal was to Governor Cuomo's Shoreham Commission; (2) the Plan, a copy of Revision 1, and the cover letters transmitting those docu-ments were sent to the Disaster Preparedness Commission.
Suffolk County Interrogatory No. 14 Identify all non-LILCO personnel who have been asked or invited by LILCO to participate in (a) Shoreham-related off-site emergency response; and (b) training related to off-site emergency response.
LILCO's Response to Suffolk County Interrogatory No. 14 To the extent that Suffolk County's Interrogatory No. 14 seeks information concerning the identity of non-LILCO orga-nizations which are in the process of negotiating with LILCO the fact and extent of their participation in Shoreham-
. related off-site emergency response and which have not yet executed letters of agreement to perform or to assist in the performance of emergency services, LILCO objects to Suffolk County's Interrogatory No. 14 on the grounds that such infor-mation is not relevant and that provision of such information would be premature, speculative and would frustrate LILCO's negotiations with the non-LILCO organizations. To the extent that LILCO has reached agreements with non-LILCO organiza-tions to participate in Shoreham-related off-site emergency i
response and training related to off-site emergency response, LILCO states that the following non-LILCO organizations have been $nvited by LILCO to participate in Shoreham-related off-site emergency response and in training related to off-site emergency response.
- 1. American Red Cross
- 2. Peconic Ambulance Service Co.
- 3. WEIR Metro Ambulance Service Inc.
- 4. WALK AM/FM
- 5. Department of Energy-Brookhave'. Area Office
- 6. United States Coast Guard Suffolk County Interrogatory No. 15 How much fuel can be stored in each of the sixteen loca-tions identified by LILCO in response to Suffolk County Request 32?
LILCO's Response to Suffolk County Interrogatory No. 15 CAPACITY GARAGE (GALLONS)
Bellmore 22,000 Brentwood 40,000 Bridgehampton 8,000 Garden City 2,000 Garden City-(1) 23,000 Hewlett 36,000 Hicksville 40,000 Mineola 10,000 Patchogue 13,000 Riverhead 20,000 Roslyn 20,000 PLANTS Glenwood Landing 1,000
. g Northport 4,000 Port Jefferson 1,000 Shoreham 6,000 254,000 (1) Newsday Building Suffolk County Interrogatory No. 16 Identify street addresses for each of the locations of the identified fuel storage locations.
LILCO's Response to Suffolk County Interrogatory No. 16 The following are street addresses for each of the loca-tions of the identified fuel storage locations:
Bellmore Operations Center Corporate Offices 2400 Sunrise Highway 250 Old Country Road Bellmore, NY Mineola, NY Brentwood Operations Cente'- Patchogue Operations Center 1650 Islip Avenue 448 East Main Street Brentwood, NY Patchogue, NY Bridgehampton District Office Riverhead Operations Center Montauk Highway Doctor's Path Bridgehampton, NY Riverhead, NY LILCO General Office Bldg. Roslyn Operations Center 550 Stewart Avenue 250 Willis Avenue Garden City, NY Roslyn, NY LILCO General Office Bldg. Glenwood Gas Plant 600 Stewart Avenue Shore Road Garden City, NY Glenwood Landing, NY Greenlawn-LILCO Northport Power Station Lake and Pulaski Road Waterside Avenue at Huntington, NY Eatons Neck Road Northport, NY Hewlett Operations Center Port Jefferson Power Station 455 Mill Road Beach Street N/O Rte. 25A Hewlett, NY Port Jefferson, NY
Hicksville Operations Center Shoreham Nuclear Power Station 175 E. Old Country Road North Country Road Hicksville, NY Wading River, NY Suffolk County' Interrogatory No. 17 Identify the portions of section 3.5 of the Plan to r
which LILCO's response to Suffolk County Request 51 of July 18, 1983, refers. Provide copies of all documents concerning the dose projections update procedures referenced in that response.
LILCO's Response to Suffolk County Interrogatory No. 17 The referenced portion of Rev. 1 of the Plan is denoted by a vertical line in the margin in section 3.5 at page 3.5.3. Although the computer method is not specifically ref-erenced, the DOE-RAP team uses the IRDAM model described in NUREG/CR 3012.
Suffolk County Interrogatory No. 18 Will LILCO emergency workers be compensated for time spent working during a Shoreham emergency? If so, in what form and how much?
LILCO's Response to Suffolk County Interrogatory No. 18 See LILCO's Response to Interrogatory No. 7.
Suffolk County Interrogatory No. 19 Will non-LILCO emergency workers be compensated for time spent working during a Shoreham emergency? If so, who will pay them, in what form will they be compensated, and how much will they be compensated?
LILCO's Response to Suffolk County Interrogatory No. 19 See LILCO's Response to Interrogatory No. 8.
Suffolk County Interrogatory No. 20 '
Are the " fuel trucks" identified by LILCO in the last <
paragraph of its response to Suffolk County Request 32 the same trucks as the " field trucks (gasoline)" identified in the first sentence of that response?
LILCO's Response to Suffolk County Interrogatory No. 20 Yes.
Suffolk County Interrogatory No. 21 Identify all communications Elaine B. Robinson has made or received concerning handicapped persons in the EPZ.
LILCO's Response to Suffolk County Interrogatory No. 21 Elaine B. Robinson has sent a letter and a postage pre-paid reply postcard to all residents within the plume expo-sure EPZ. The postage prepaid reply postcards contained pro-visions for handicapped persons to identify themselves to LILCO. Copies of the letter and postcard arc enclosed.
Suffolk County Interrogatory No. 22 f
Does LILCO assert that there are no documents concerning the survey entitled " Marketing Evaluations: Shoreham Resi-
[ dential Home. Construction Study (No. 705)," other than the survey questionnaire and those already provided to LILCO? If such documents exist, provide copies.
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LILCO's Response to Suffolk County Interrogatory No. 22 LILCO has received a cover letter transmitting the sur-vey " Marketing Evaluations: Shoreham Residential Home Con-struction Study (No. 705)." A copy of that letter is enclosed. In addition, Marketing Evaluations Incorporated has prepared a document describing the curvey methodology and sample size. A copy of that document is enclosed. To the best of LILCO's knowledge and belief, there are no other doc-uments responsive to this request.
Suffolk County Interrogatory No. 23 Identify by date, location and proceeding all prior tes-timony concerning emergency preparedness given by each of the persons LILCO intends to call as a witness, including those identified in response to Suffolk County Request 1 of July 18, 1983, before any judicial, administrative, or legislative body, including deposition testimony.
LILCO's Response to Suffolk County Interrogatory No. 23 Without waiving its objection either to the relevance of the PRA, radiological consequence analyses,-EPZ criteria, and the health effects of radiation to or to the relevance of testimony by Edward T. Burns, Vojin Joksimovich, Thomas E.
Potter, Saul D. Levine, G. Hoyt Whipple and Leonard Hamilton to the subject matter of this proceeding, LILCO states that the persons listed below whom LILCO may call as witnesses, have given prior testimony concerning emergency preparedness.
1
In addition, a number of persons whom LILCO has listed as potential witnesses gave depositions and submitted prefiled
-testimony on behalf of LILCC during Phase I of the emergency planning proceeding and testified before the Suffolk County Legislature in January 1983. Suffolk County is well aware of that prior testimony; in addition, suffolk County possesses a
-copy of the Phase I prefiled testimony and depositions, and the testimony before the Suffolk County Legislature.
Dr. Dennis S. Mileti -
- 1. Louisiana Power & Light, Waterford III -- special hear-ing regarding the role of the public pre-emergency bro-chure, February 1983.
- 2. Suffolk County legislature, January 1983.
- 3. Pacific Gac & Electric Co., Diablo Canyon -- NRC hear-ings on emergency planning, January 1982.
- 4. NRC hearings on offshore power systems regarding the impact of floating nuclear power plants on tourist be-havior, Bethesda, May 1977 and-July 1978.
- 5. Senate Subcommittee on Science, Technology and Space in the matter of National Earthquake Hazards Reduction Act, Washington, D.C., April 1980.
- 6. Prepared testimony for the legislature of the State of California on the role of the Governor regarding what he does and does not do after a scientifically credible earthquake prediction, Sacramento, 1976-77
- 7. Earthquake Hazards Reduction Program -- United States Congressional Panel for FEMA, 1982-83 year-long program review.
- 8. Earthquake Hazards Reduction Act ---program of the United States Geological Survey of 1982.
- 9. Reviewed final regulations for flood plan management and protection of wetlands for FEMA at the request of its director. See 45 Fed. Reg. 59,520-38 (1980).
{' 10. Review and evaluation of Applied Research Program of the National Science Foundation, 1978-79.
- 11. San Luis Obispo County School Board regarding Diablo Canyon. July 1983.
k' Dr. Russell R. Dynes -
- 1. NRC hearings on Indian Point. Transcript following page 11,936,
- 2. Three Mile Island restart hearing -- 1980.
Dr. Matthew C. Cordaro -
- 1. Presentation to the Governor's Shoreham Commission, Urban Development Corporation, New York, NY. June 28, 1993.
- 2. Company's Position on Emergency Radiologic Preparedness, Before The New York State Assembly Special Committee on Nuclear Power Safety, Hauppauge, NY, September 3, 1982.
- 3. Status of Emergency Planning - (Informational Meeting scheduled by Suffolk County Legislator Anthony Noto),
Babylon High School, Babylon, NY, June 15, 1982.
- 4. .The Report Under Chapter 708 of New York State Law (State of Emergency Preparedness for Incidents at Nuclear Power Plants) Before Representatives of the Di-saster Preparedness Commission, Stony Brook University, November 18, 1981.
- 5. Testimony Before Health Committee of The Suffolk County Legislature on Emergency Planning, Shoreham-Wading River High School, May 8, 1980.
- 6. Company's Position on Emergency Preparedness Before The New York State Assembly Special Committee on Nuclear Power Safety, Hauppauge, NY, August 29, 1979.
William G. Schiffmacher -
- 1. ACRS Hearings September 29-30, 1981
Thomaa E. Potter -
- 1. Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit 2) Operating Licensing Proceeding, 1978.
- 2. Power Authority of the State of New York (Indian Point)
- a. prefiled testimony, January 24, 1983, March 22, 198,3
- b. oral testimony, transcript pages 7627-7696, 8185-8239, 8344-8367, 12650-12706, 12781-12800.
Suffolk County Interrogatory No. 24 Define the following terms as used by LILCO in its response to Suffolk County Request 77 of July 18, 1983.
(a) Received (b) In hand (c) Installed (d) Or. hand (e) In place (f) Operational In particular, clarify the differences, if any, among the status indicated by the terms " Received," "In hand," and "On hand;" and the differences, if any, among the status indicated by the terms " Installed," "In place," and " Opera-tional."
LILCO's Response to Suffolk County Interrogatory No. 24 The' term "In hand" was a typographical error and should be read "On hand." "On hand" is the term applied to items previously in LILCO's possession. " Received" is the term
applied to items presently in LILCO's possession after recently being ordered. Installed," "In place," and " Opera-
.tional" are equivalent terms meaning that the equipment is ready for use.
Suffolk County Interrogatory No. 25 In its Response to Suffolk County Request 20 of July 18, 1983, LILCO identified only a report to be produced by Pickard, Lowe and Garrick, which was provided on August 17.
Are there no documents that are responsive to Suffolk County Request 20 other than the report produced by Pickard, Lowe and Garrick? If other such documents exist, provide copies.
LILCO's Response to Suffolk County Interrogatory No. 25 To LILCO's knowledge and belief, there are no other doc-uments other than the Pickard, Love & Garrick study already provided to Suffolk County, that are responsive to this re-quest.
Suffolk County Interrogatory No. 26 Identify the location, including street addresses at which each of the fuel trucks identified in LILCO's response to Suffolk County Request 32 of July 18, 1983, is stored.
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LILCO's Response to Suffolk County Interrogatory No. 26 LOCATION NUMBER OF TRUCKS Bellmore 1 Brentwood 2 Bridgehampton 1 Garden City 1 Greenlawn 1 Hewlett 2 Hicksville 2 Patchogue 1 Riverhead 1 Roslyn 1 The addresses of these locations are identified in LILCO's Response to Suffolk County Interrogatory No. 16.
Suffnik County Interrogatory No. 27 Does LILCO have permits concerning automotive fuel other
-than storage permits? If yes, provide copies of all such permits.
LILCO's Response to Suffolk County Interrogatory No. 27 LILCO does not have any permits concerning automotive fuel other than storage permits.
Suffolk County Interrogatory No. 28 With respect to LILCO's response to Suffolk County Request 85, describe in detail the manner in which LILCO "up-dated" the information allegedly provided by the County including but not limited to, all tests, analyses, measure-ments, assumptions and literature used in this regard. Were all documents concerning the " updating" process included in the index provided by counsel on August 10, 1983? If not,
s provide copies of all such documents not included in that index.
LILCO's Response to Suffolk County Interrogatory No. 28 LILCO did not " update" the information relied on in sup-port of the estimated service demand for high occupancy vehi-cles in each zone, as stated in Appendix A, pages IV-87 through IV-178. The " updating" referred to in response to Suffolk County Request 85 of July 18, 1983, was done by Suffolk County when it revised the preliminary for discussion only draft of September 1979 entitled "The Transportation Element for Evacuation in the Vicinity of the Shoreham Nucle-ar Power Station," and produced the draft "Suffolk County Radiological Emergency Response Plan." To the best of LILCO's kncwledge and belief, no other documents exist that are responsive to this request.
Suffolk County Interrogatory No. 29 Do LILCO and its experts rely on any documents, other than those identified in LILCO's response to Suffolk County Request 86 of July 18, 1983, to support _LILCO's selection of the boundaries of the 10-mile EPZ? If there are any other documents,. provide copies.
LILCO's Response to Suffolk County Interrogatory No. 29 Without waiving its objection to a 20-mile EPZ, LILCO' states that it adopted the 10-mile boundary of the EPZ pro-vided for in the NRC regulations, selected by Suffolk County
planners, and concurred in by the Suffolk County Department of Transportation and the Suffolk County Police Department.
In addition to the documents listed in LILCO's response to Suffolk County Request 86 of July 18, 1983, the following documents are relied upon:
- 1. Memorandum, March 2, 1982, from Robert C.
Meunkle to Lee E. Koppelman.
- 2. Letter, March 27, 1980, from Richard A.
Strang to Case Rotteveel.
- 3. Letter, June 25, 1979, from Donald J.
Dilworth to John P. Sheridan.
- 4. Letter, June 6, 1979, from John P. Sheridan to Donald J. Dilworth.
Copies of the documents listed in this response are enclosed.
Suffolk County Interrogatory No. 30 On what basis are the " selected" persons, to be equipped with pagers, determined? (See Figure 3.3.6, Rev.
1). Who is responsible for making such determinations?
Provide copies of all documents concerning (a) the deter-minatio'n that only " selected" persons should be equipped with pagers, and (b) the determination as to which LERO workers will be or have been " selected".
LILCO's Response to Suffolk County Interrogatory No. 30 The " selected" persons to be equipped with pagers have not yet been determined. No documents describing either the basis for the selection or the actual
selections exist. The determination that only " selected" persons should be equipped with pagers was made consistent with the planning basis that was being developed. In i
part, this was to be constant with the notification meth-odology presented in the Suffolk County plan.
Suffolk County Interrogatory No. 31 Identify the relocation centers for each school in the 10-mile EPZ other than those in the Shoreham-Wading River school district, (See page 3.6-7, line 17-18, LILCO Transition Plan, Rev. 1).
LILCO's Response to Suffolk County Interrogatory No. 31 As indicated in LILCO's response to Suffolk County's June 14 Discovery Request 3, the Plan is being revised to reflect the fact that schools outside the Shoreham-Wading
- River central school district are not assigned to reloca-tion centers.
Suffolk County Interrogatory No. 32 Identify and provide a copy of the " emergency educa- '
! tion information" that will be provided to communities outside the EPZ. (See page 3.8-2, lines 37-38, LILCO Transition Plan,.Rev. 1). Identify the communities to which such information will be provided.
LILCO's Response to-Suffolk County Interrogatory No. 32 The " emergency education information" referred to has not yet been prepared and, therefore, is not presently
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l' available. When the " emergency education information" becomes available, it will be provided to counsel for i Suffolk County. This information will be offered to all customers throughout the LILCO service area. This in-cludes all Nassau and Suffolk Countys and the Rockaway J' Peninsula.
Suffolk County Interrogatory No. 33
. Describe the means by which the emergency information i-
- discussed in the question above will be provided.
LILCO's Response to Suffolk County Interrogatory No. 33 t The " emergency education information" will be avail-able at: (1) all customer relations district offices, (2) the education center at Shoreham, (3) by request from the Community. Relations Department, and (4) at presentations l
p by the LILCO Speakers Bureau. As part of the " emergency '
education information" p'ogram, r LILCO is developing mate-
~ rials.to make the public aware of the availability of this 4
information.
i Suffolk County Interrogatory No. 34 i
Has the public information brochure been revised sub-
- sequent to the version sent out with Revision O of the Plan? (See LILCO's Objections to Revised Emergency Plan-ning Contentions at 18). Provide a copy of the revised ,
t 4
brochure if one exists.
- _ _ ._. - - . , . - , _ . . . . . . , . . . . _ _ . . _ . _ . . . _ . _ _ . _ _ _ - - . . _ . _ _ . _ _ _ _ - - ~ __-
LILCO's Response to Suffolk County Interrogatory No. 34 Yes. The public information brochure has been revised. A revised version of the brochure was sent to all Plan holders, including suffolk County, on August 17, 1983.
4 Respectfully submitted, Ml'l4 pjbhald P.
W Monaghan/( j/
^
Irwin Wessine A.
Hunton & Williaims 707 East Main Street P.O.' Box 15635 Richmond, Virginia 23212 DATED: September 6, 1983
LILCO, September 6, 1983
, CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) "' '
Docket No. 50-322-OL-3 I, Jessine A. Monaghan, hereby ce'rtify th'at copies of -
, Answers to Suffolk County Ine.errogatories.to Long Island Lighting Company were served this date.upon the following by first-class mail, postage prepaid, or by Federal. Express (as indicated by an asterisk).
James A. Laurenson,* Secretary of the Commission Chairman U.S. Nuclear Regulatory '
Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing East-West Tower, Rm. 402A Appeal Board Panel ,
4350 East-West Hwy. U.S. Nu'elear Regulatory Betnesda, MD 20814 Commission Washington, D.C.' 20555 Dr. Jerry R. Kline* ,
Atomic Safety and Licensing Atomic Safety and' Licensing Board Board Panel ~
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 Bernard M. Bordenick, Esq.*
David A. Repka, Esq.
Mr. Frederick J. Shon* 'Edwin J. Reis, Esq.
Atomic Safety and Licensing U. S.. Nuclear Regulatory l
Board Commission i
U.S. Nuclear Regulatory ,
7735 Old Georgetown Road Commission (to mailroom)
East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.
Bethesda, MD 20814 d
l I
r w
l g
t i Eleancr L. Frucci, Esq.* '
Stewart M. Glass, Esq.*
Attopney. Regional Counsel
~- Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U. S. Nuclear Regulatory 26 Federal Plaza, Room 1349
- Commission New' York, New York 10278
.. . East-West Tower,'~ North Tower 4350 East-West Highway Stephen B. Latham, Esq.*
,Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street David J. Gilmartin, Esq. P.O. Box 398 Attn: Patricia A. Dempsey, Esq. Riverhead, New York 11901 County Attorney Suffolk County Department Ralph Shapiro, Esq.*
of Law Cammer & Shapiro, P.C.
Veterans Memorial Highway 9 East 40th Street Hauppauge, New York 11787 Nets York, New York 10016 Herbert H. Brown, Esq.* James Dougherty, Esq.*
Lawrence Coe Lanpher, Esq. 3045 Porter Street Christopher McMurray, Esq. Washington, D.C. 20008 Kirkpatrick, Lockhart, Hill Christopher & Phillips Howard L. Blau 8th Floor 217 Newbridge Road i 1900 M Street, N.W. Hicksville, New York 11801 Washington, D.C. 20036 Jonathan D. Feinberg, Esq.
Mr. Marc W. Goldsmith New York State Energy Research Group Department of Public Service 4001 fotten Pond Road Three Empire State Plaza Naltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates Spence W. Perry, Esq.*
1723 Hamilton Avenue Associate General Counsel Suite K Federal Emergency Management San Jose, California 95125 Agency 500 C Street, S.W.
~
Mr. Jay Dunkleberger Room 840 New York State Energy Office Washington, D.C. 20472
_ _ Agency Building 2 e, Empire State Plaza . Ms. Nora Bredes Albany, New York 12223 Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street
?- Smithtown, New York 11787 kUM/f) h. Monagh W
~
71 Jessine A.
Hunton & Williams 707 East Main Street P.O. Box 1535 kichmond, Virgin _ia, 23212 DATED:. Sept $mber 6, 1983 f sp .
n >
l TABLE A i
The estimates presented on page IV-86b are explained as follows:,
A B C C' D E F
$ 15 _j- 15 ,
20 (est. ) '
4, - - -
, _ _ _ _ 120 (e st. ) 225 Event ... Description A Declaration of Emergency B -
Notification of Government Agency; Bus C
Drivers notified. .
Public Not'2ication; Sirens activated C' Notification for Evacuation to Eegin D End of Public " Mobilization (Preparation)
Time;" Beginning of Public Evacuation ,
E Arrival of first Buses at Transfer Points; Beginning of Bus Runs over specified Routes F Departure of final buses from Transfer Points to travel to Relocation Centers i
Time Period Time (min.) . Explanation A-B < 15 Required by NUREG-0654 Pg. 1-3.
B-C '15 OPIP 3.3.4 states that the cus-tomer service operator has up to 10 minutes to contact the LERO Director of Local Response, who then will respond within 5 minutes.
/ , , _ . . _ .
, , .- - - , - , , - u- 'w * * * ' " ' " " ' "
t a
Time Period Time (min.) ,
Explanation C '- D 20 Mobilization time is defined as the period of time between the 3
order to evacuate and the time the first person leaves home.
This time is based on the re-sults of the National Center for Telephone Research survey l which indicated that one-half of all workers living in the
( EPZ travel less than 20 minutes.
The documents describing the NCTR survey have been delivered in a previous discovery.
B-E 120 This period of time consists of the time it takes bus drivers to l travel to their staging areas; l pick up their route packets; tr'avel to the bus depot; and drive a bus to a transfer point.
E-F 225 The period of time between the arrival of the first bus at a transfer point and the departure of the last bus from the transfer I
point heading towards a reloca-tion center. This time is based upon the estimated bus route travel times and bus schedule analyses. All documents per-taining to this work were l delivered in response to pre-l , vious discovery requests.
l 1
I l
, , TABLE B
+
Business LILCD LERO , ,
Mame Employer Address Position Position
- Responsibilities J. Cullmer LILCO 100N.OldCountryRd. Clerk Steno Mone Administrative Hicksville, NY Crade 5 C. Daverio LIII0 100 E. Old Country Rd. Emergency None .. Assisting in direction of Hicksville, NY Planning overall implementation Coordinator efforts T. Hill LILCO 100 E. Old Country Rd. Sr. Technical Logistics Support Purchasing Hicksville, NY Buyer Coordinator C. 14nda LIII0 100 E. Old Country Rd. Engineer Rad. Decon- Purchasing Hicksville, NY Emer. Wrkrs.
W. Renz LILCO 100.E. Old Country Rd. Offsite None Directing the equipmenc Hicksville, NY Emergency and facility support for Preparedness LERO Coordinator E. Robinson LIILO 100 E. Old Country Rd. Manager, Comus. None Directing contact with Hicksville, NY Reis. Dept. non-LILCO organizations P. Rolston LILCO 100 E. Old Country Rd. Clerk Typist None Administrative Hicksville, NY Crade 2 M. Sacca LILCO 100 E. Old Country Rd. Sr. Educational Mone Non-LIII0 organization Hicksville, NY Services Coord. contact staff D. Spagnucio LIII0 100 E. Old Country Rd. Hget. Trainee None Non-LILOD organization Hicksville, NY contact staff J. Sheehan,, LIII0 100 E. Old Country Rd. Educational None Trainer Hicksville, NY Services Coord. ,
K. Veselak LIII0 100 E. Old Country Rd. Clerk Steno None Administrati Hicksville, NY Crede 3 J. Weismantle LILCO 100 E. Old Country Rd. Manager-Power Manager of Local Directing overall efforts Hicksville, NY Engineering Response of the implementing organization
o Business LilID 1.ERO ..
Employer Address Position Position Responsibilities Name Stone & Webster one Penn Plaza N/A Now,. Project coordination.
B. Aidikoff
. Engineering Corp. New York, NY Hearing support.
Stone & Webster One Penn Plaza N/A None '*
Directing the technical A. Callendrello Engineering Corp. New York, NY support of LERO implementation i ~
V. Coldstein Stone & Webster One Penn Plaza N/A Mone Technical support staff Engineering Corp. New York, NY A..Holbert Stone & Webster One Penn Plaza N/A None Technical support staff Engineering Corp. New York, NY R. IsCoff Stone & Webster One Penn Plaza N/A None Technical support staff Engineering Corp. New York, NY Equipment and faci!!ty T. I.eissing Stone & Webster One Penn Plaza N/A None Engineering Corp. New York, NY specification P. Margolin Stone & Webster One Penn Plaza N/A None Hearing support Engineering Corp. New York, NY Stone & Webster One Penn Plaza N/A None Technical support staff K. Nattera
- Engineering Corp. New York, NY P. Savarese Stone & Webster One Penn Plaza N/A None Equipment and facility
' Engineering Corp. New York, NY specification I J. Sobotka Stone & Webster One Penn Flaza N/A None Technical Support
.. Engineering Corp. New York, NY t
A. Behr Impell 275 Broad Hollow Rd. N/A None Training noterial Melville, NY development D. A. Beres Impell 225 Broad Hollow Rd. N/A None Script & workbook Nelville, NY 11747 development, class instruction, drill scenario development
e c
Business LILCO LERO .
Employer Address Position Position Responsibilities Name Impell 225 Mroad Hollow Rd. N/A Hone Training material C. Berger Melville, NY development I*Pell 225 Broad Hollow Rd. N/A None p Script & workbook C. F. Carcia Melville, NY 11747 development, drill scenario development 223 Broad Hollow Rd. N/A Mon'e Script & workbook C. A. Heitz lopell Melville, NY 11747 development, class instruction, drill
- scenario development I*Pell 225 Broad Hollow Rd. N/A None Script & workbook
, . N. L. Molter Melville, NY 11747 development, class instruction, drill scenario development Impell 225 Broad Hollow Rd. N/A Mone Project coordination, R. A. Varley Melville, NY 11747 script & workbook development, class instruction, drill scenario development Ebasco Services Two World Trade Center N/A None Purchasing Support J. Livolsi Inc. New York, NY Ebasco Services hao World Trade Center N/A None Purchasing Support W. Muldoon Inc. New York, NY et d