ML20054H265

Second Request for Production of Emergency Planning Documents.Certificate of Svc Encl

ML20054H265
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/18/1982
From:	Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
ISSUANCES-OL, NUDOCS 8206230172
Download: ML20054H265 (8)

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t UNITED STATES OF A!1 ERICA .

NUCLEAR REGULATORY cot!!!ISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

i i In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

) (Emergency Planning (Shoreham Nuclear Power ) Proceedings)

Station, Unit 1) )

)

SUFFOLK COUNTY'S SECOND REQUEST TO LONG ISLAND LIGHTING COliPANY FOR PRODUCTION OF EMERGENCY PLANNING DOCUMENTS Pursuant to C.F.R. 52.741, and the Licensing Board's Order, dated April 20, 1982, LILCO is requested by Suffolk County to produce at the Shoreham Nuclear Power Plant (or another agreed upon location) each of the documents set forth below, within thirty (30) days after service hereof. These document requests pertain to the emergency planning and pre-paredness issues under consideration by the Licensing Board and to whether emergency planning and preparedness for the Shoreham facility complies with 10 C.F.R. S50.47(b) and 10 C.F.R. Part 50, Appendix E.

DEFINITIONS AND INSTRUCTIONS The definitions and instructions applicable to this request are identical to those contained in "Suffolk County's j First Request For Production of Emergency Planning Documents To Long Island Lighting Company" dated May 11, 1982. To i

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• e the extent that LILCO may have already provided to Suffolk County any of the documents sought herein in response to a previous discovery request, LILCO should identify such documents by titler date and subject matter and state when -

such documents were produced.

DOCUMENTS REQUESTED

1. Any testimony on emergency planning given by any of LILCO's consultants, officials, employees, or representatives, or by any persons LILCO intends to present as witnesses on its behalf regarding the emergency planning issues to be r .

litigated pursuant to the Board's April 20, 1982 Order, whether such testimony was before an administrative, legislative or judicial body.

2. All documents discussing, analyzing or concerning the Federal assistance LILCO intends to request and/or utilize in the event of a radiological emergency and the resources it intends to supply to make available to support the Federal response.

3. All documents discussing, analyzing or concerning LILCO's ability to augment its radiological emergency response personnel within thirty minutes of declaration of an emergency at the Shoreham site, including any documents analyzing, discussing or concerning whether LILCO's ability to augment its radiological emergency response personnel within thirty minutes meets the requirements of NUREG 0654.

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4. All documents analyzing, discussing or concerning the adequacy of commercial telephone lines to communicate from the Shoreham site or LILCO's emergency response facilities with hospitals, the Coast Guard, the U.S. Department of Energy --

or other off-site agencies in the event of a radiological emergency.

5. All documents discussing, analyzing or concerning the time required to activate the EOF and make it fully operational following the declaration of an emergency.

6. All agreements with any person or organization to supply seismic offsite information to LILCO's emergency response facilities.

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7. All documents or additions to the plans providing the l

contents of initial and followup messages to offsite authorities.

8. All documents concerning LILCO's plans and schedules for drills and exercises to be conducted in the next seven years including details of the specific areas and emergency planning concerns that each such exercise or drill will address.

9. All documents concerning, discussing or analyzing LILCO's possible use of a mobile radiological laboratory for accident assessment and monitoring.

10. All documents identifying or concerning the instruments to be relied upon for emergency classification including, but not restricted to:

a. All documents explaining how such instruments will be used in classifying emergencies;

b. The parameters of the information that will be displayed for each such instrument.

11. All documents identifying or concerning the type and ,

capability of all process and radiological instruments, as -

well as all monitoring systems, required for initiating emer-gency measures and conducting assessments.

12. All documents concerning, discussing or analyzing the interim and permanent Safety Parameter Display Systems including:

a. All parameters to be displayed;

b. The methods used for data verification;

c. The ability of the interim and permanent SPDS to provide trending capabilities;

d. All documents discussing, analyzing or concerning the effects of failure to provide an interim SPDS display in the TSC or EOF;

e. All documents assessing or discussing the ability of the interim or permanent SPDS to operate during or following an

accident, including an earthquake;

) f. All documents reflecting incorporation of human factors principles into the design of the interim and permanent I

SPDS.

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13. All documents discussing, analyzing or concerning 4

4 incorporation of human factors principles into LILCO's develop-ment of its emergency plan and procedures and the instrumenta-tion, control and equipment required for their implementation. -

14. All documents discussing, analyzing or concerning the i

capacity and capability of Central Suffolk Hospital to treat and/or decontaminate injured and contaminated persons.

15. In reply to LILCO's Response of June 14, 1982, to request i

number 65 in Suffolk County's first request for emergency planning documents, Suffolk County is narrowing its request for contracts or agreements to the following:

a. All contracts or agreements concerning review, evaluation or assessment of LILCO's radiological emergency response plan by any person or organization, including the plan's compliance with applicable NRC and I

FE?IA regulations.

b. All documents and correspondence written, developed or created by such person or organization as a result of conducting i such a review, evaluation or assessment.

16. All correspondence with the NRC regard'ing LILCO's radiological emergency plan and LILCO's planning efforts.

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Respectfully submitted, DAVID J. GILMARTIN Suffolk County Attorney PATRICIA A. DEMPSEY Assistant Suffolk County

_. Attorney --

Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 Herbert H/ Brown Lawrence Coe Lanpher Christopher M. McMurray KIRKPATRICK, LOCKHART,;21LL, CHRISTOPHER & PHILLIPS 1900 M Street, NW, Suite 800 Washington, DC 20036 (202) 452-7000

, Attorneys for suffolk County

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

_. ) __

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (O.L.)

(Shoreham Nuclear Power Station, ) (Emergency Planning Proceedings)

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County's "Second Request for Long Island Lighting Company for Production of Emergency Planning Documents," dated June 18, 1982 were served to the following on June 18, 1982 by U.S. Mail, first class, except as otherwise noted:

Lawrence Brenner, Esq. Ralph Shapiro, Esq.

Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Howard L. Blau, Esq.

Dr. James L. Carpenter 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission *W. Taylor Reveley III, Esq.

Washington, D.C. 20555 Hunton & Williams P.O. Box 1535 707 East Main St.

Mr. Peter A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C. 20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Poad Mineola, New York 11501 Stephen B. Latham, Esq.

Twomey, La tham & Shea Mr. Brian McCaffrey Attorneys at Law Long Island Lighting Company P.O. Box 398 175 East Old Country Poad 33 West Second Street Hicksville, New York 11801 Riverhead, New York 11901

• By Federal Express

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Marc W. Goldsmith Mr. Jeff Smith Energy Fesearch Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue ~

The Governor Nelson ~A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David H. Gilmartin, Esq. County Executive / Legislative Suffolk County Attorney Building County Executive / Legislative Bldg. Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Fegulatory Commission New York State Department of Washington, D.C. 20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Ndclear Regulatory Bernard M. Bordenick, Esq. Commission David A. Repka, Esq. Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Matthew J. Kelly, Esq.

Staff Counsel, New York State Public Service Comm.

3 Rockefeller Plaza Albany, New York 12223 p

Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: 1900 M Street, N.W., 8th Floor' June 18, 1982 Washington, D.C. 20036