ML20054J128

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

ML20054J128
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/22/1982
From:	Reveley W HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SUFFOLK COUNTY, NY
References
ISSUANCES-OL, NUDOCS 8206280161
Download: ML20054J128 (11)

Text

a LILCO, Junn-22, 1982 0 ., . " ~n '. A.

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,  : a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 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 SECOND REQUEST TC SUFFOLK COUNTY FOR PRODUCTION OF EMERGENCY PLANNING DOCUMENTS The Long Island Lighting Company (LILCO) hereby requests Suffolk County to produce at LILCO's offices in Hicksville or at another mutually agreed-upon location eac's of the documents set forth below, within thirty (30) days after service of this request, in accordance with 10 C.F.R. 5 2.741. These document requests pertain to the emergency planning and preparedness issues under consideration by the Atomic Safety and Licensing i Board in the Shoreham operating license proceeding.

DEFINITIONS A. " County" means the government organization of Suffolk County and any officer, official, employee, representative, l

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consultant, agent, contractor, subcontractor, technical advisor, attorney, or other person acting for or on behalf of the County or at the County's direction, or in concert with the County or assisting the County.

B. " Person" means any natural person, firm, partnership, educational institution, joint venture, corporation, and any domestic government organization, or group of natural persons or such entities.

C. " Document" means any handwritten, typewritten, printed or recorded graphic matter however produced or reproduced, whether or not in the possession, custody or control of the County and whether or not claimed to be privileged against discovery on any ground, including but not limited to reports, records, lists, memoranda, correspondence, telegrams, schedules, photographs, sound recordings, ledgers, books of account, catalogues, checks, check stubs, brochures and written statements of any person.

If the County considers any document called for in this request to be privileged from production, the County must include in its response to this request a list of documents withheld from production, identifying each document by date, addressee (s), author, title and subject matter. In addition,

the County should identify those persons who have seen the document or who were sont copies, and state the ground (s) upon which each such document is considered privileged.

If any document called for in this request has been destroyed, the County must include in its response to this request a description of the documents destroyed, identifying each document by date, addressee (s), author, title, and subject matter. In addition, the County should state the date of destruction, the identity of the person or persons who destroyed the document, and the reason the document was destroyed.

D. The words " pertaining to" include referring to, responding to, relating to, connected with, concerning, comprising, memorializing, commenting on, regarding, discussing, showing, describing, reflecting, analyzing, supporting, contradicting and constituting.

DOCUMENT REQUESTS

1. All testimony on emergency planning given by any of Suffolk County's consultants, officials, employees, or representatives in any proceeding, be it administrative, legislative, or judicial. Such consultants include, but are not limited to, the following:

Stan Fabic W. Kulash Howard Lambert P. Polk .

Social Data Analysts B. Ogden Future Resources W. Harold Associates, Inc. S. Seeburger W. Hansen E. Plank D. Schoppert Frank Jones A. Kanen Dr. Stephen Cole R. Tanczos Peter Davis R. Aschettino S. T. Wray, Jr.

R. Sumner A. H. Bogen H. E. Lambert

2. All documents, articles, papers, or other publications pertaining to emergency planning, authored or co-authored by any of Suffolk County's consultants, officials, employees, or representatives, including but not limited to these consultants:

PRC-Voorhees Dr. Walter C. Farrell, Jr.

Prof. Philip B. Herr Dr. David Stevenson Dr. Kai T. Erikson Dr. Fred Finlayson Dr. James H. Johnson Dr. Robert J. Budnitz Dr. Donald J. Ziegler Dr. Edward P. Radford Stan Fabic W. Kulash Howard Lambert P. Polk Social Data Analysts B. Ogden Future Resources W. Harold Associates, Inc. S. Seeburger W. Hansen E. Plank D. Schoppert Frank Jones A. Kanen Dr. Stephen Cole R. Tanczos Peter Davis R. Aschettino S. T. Wray, Jr.

R. Sumner A. H. Bogen H. E. Lambert

3. All documents pertaining to Social Data Analysts' telephone surveys of Nassau and Suffolk County

residents regarding emergency planning, including but not limited to draft and final survey questions, draft and final results of the surveys, and documents describing the methods used to conduct the surveys.

4. All documents relied upon by Social Data Analysts in preparing the survey questions used in any surveys regarding emergency planning.

5. The text of any public statements bearing on emergency planning made by any Suffolk County official during and up to two months prior to the telephone surveys by Social Data Analysts.

6. All correspondence between the County and Social Data Analysts regarding the emergency planning surveys.

7. All documents studying, analyzing, or otherwise pertaining to the results of the Social Data Analysts i emergency planning surveys.

l 8. All documents studying, analyzing, or otherwise pertaining to the local conditions that might

influence the Shoreham onsite emergency plan.

l l 9. All documents analyzing, studying, or otherwise i

pertaining to procedures that might be used to notify those within the EPZ who are deaf or hard of hearing.

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10. All documents analyzing, studying or otherwise pertaining to the traffic or radiological conditions that might exist during a radiological emergency.

11. All documents analyzing, studying, or otherwise pertaining to the various protective actions available for the plume exposure pathway EPZ during emergency conditions, and the bases for choosing one of those actions.

12. All evacuation time estimate studies for Long Island prepared by the County, its employees, or its consultants.

13. All documents analyzing, studying, or otherwise pertaining to evacuation time estimate studies for.

Long Island.

14. All analyses, studies, or surveys regarding the voluntary evacuation or other actions by people outside the EPZ.

15. All documents analyzing, studying or otherwise pertaining to analyses, studies, or surveys regarding the voluntary evacuation or other actions by people outside the EPZ.

16. All documents identifying, analyzing, studying, or otherwise pertaining to protective actions for persons for whom the full range of protective actions may not be available.

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17. All documents addressing, analyzing, studying, surveying, or otherwise pertaining to the possibility that LILCO and non-LILCO personnel expected to report to the site for emergency duty would fall to report (or to report in a timely manner) because of conflicting family or other duties that would arise in the event of a radiological emergency.

18. All documents analyzing, studying, or otherwise pertaining to public education programs to inform the population potentially affected by a radiological emergency of the initial and subsequent actions to be taken in the event of a radiological emergency.

19. All documents regarding the particular social and psychological profile of Suffolk County's residents and the probable response of particular groups, such as the economically disadvantaged, to various educational programs.

20. All documents analyzing, studying, or otherwise concerning a PRA consequence analysis applicable to Shoreham.

21. All documents detailing, analyzing, studying, or otherwise pertaining to the methods for prompt notification of any boats within the EPZ.

22. All documents pertaining to or analyzing the relative merits of various means of providing public information to ensure preparedness to respond to a radiological emergency.

23. All documents analyzing, studying, or otherwise pertaining to the most effective method to inform the transient or permanent population or both within Suffolk County of the protective actions to be taken in the event of a radiological emergency at Shoreham.

24. All documents studying, analyzing, or otherwise concerning possible obstacles, such as impassible roadways due to evacuation or adverse environmental conditions, that might prevent field monitoring teams from reaching the offsite monitors.

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25. All documents pertaining to consequence analysis studies that reflect the potential consequences of a serious radiological emergency at Shoreham.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

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W/ Tay or Reveley, James N. Christman III ff Kathy E. B. McCleskey Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED- June 22, 1982 t

.,- LILCO, June 22, 1982 I

l 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 SECOND REQUEST TO SUFFOLK COUNTY FOR PRODUCTION OF EMERGENCY PLANNING DOCUMENTS were served upon the following by first-class mail, q postage prepaid, by Federal Express (as indicated by an asterisk), or by hand (indicated by two asterisks), on June 22, 1982:

Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal 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 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 David 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.

U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 Secretary of the Commission U.S. Nuclear Regulatory Commiscion Washington, D.C. 20555

Herbert H. Brown, Esq.** Howard L. Blau, Esq.

Lawrence Coe Lanpher, Esq. 217 Newbridge Road Karla J. Letsche, Esq. Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Matthew J. Kelly, Esq.

8th Floor State of New York 1900 M Street, N.W. Department of Pubic Service Washington, D.C. 20036 Three Empire State Plaza Albany New York 12223 Mr. Mark W. Goldsmith Mr. Jay Dunkleberger Energy Research Group New York State Energy Office 400-1 Totten Pond Road Agency Building 2 Waltham, Massachusetts 02154 Empire State Plaza Albany, New York 12223 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 Stephen B. Latham, Esq.*

Twomey, Latham & Shea 33 West Second Street P.O. Box 398 Riverhead, New York 11901 Ralph Shapiro, Esq.*

Cammer and Shapiro, P.C.

9 East 40th Street New York, New York 10016

[d h v E 8.RL? W Kakhy f. B. McCleskey Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 22, 1982 l

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