ML20062D522

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

ML20062D522
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/04/1982
From:	Sedky C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
ISSUANCES-OL, NUDOCS 8208060116
Download: ML20062D522 (16)

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UNITED STATES OF AfiERICA NUCLEAR REGULATORY COlitiISSION ,N M -4 90 n n

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.. , e Before the Atomic Safety and Licensing Board '-

In the liatter of

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) Docket No. 50-322 (OL) '

LONG ISLAND LIGHTING COMPANY ) (Emergency Planning) r..~~'

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(Shoreham Nucl. ear Power Station, )

Unit 1) )

RESPONSE OF SUFFOLK COUNTY TO LILCO'S SECOND REQUEST TO SUFFOLK COUNTY PRODUCTION OF E?iERGENCY PLANNING DOCUMENTS Pursuant to 10 C.F.R. S2.741(d), Suffolk County hereby responds to LILCO's second request to Suffolk County for production of emergency planning documents (the "second request") as follows:

A. Preliminary Statement In light of'the Board's July 20, 1982 ruling on LILCO's

!!otion to Compel Discovery on Emergency Planning, this Response is being filed out of time so that the spirit of the Board's July 20 ruling can be incorporated in this Response. This Response is being filed without prejudice to the County's motion for reconsideration or, in the alternative, for certification with respect to LILCO's first request for production of documents. The County continues to object to the production of any documents not related to the LILCO plan.

Accordingly, in the event that the County's motion for reconsideration or certification is granted, the County shall withhold all documents not already produced and not relating to YOh0$

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LILCO's plan which are otherwise encompassed within the First and Second Requests.

Since the Board's July 20th ruling, the County has sent instructions to its agencies and consultants to review their files for documents responsive to LILCO's First and Second Requests. The County expects responses from its agencies and consultants concerning documents to be produced within the periods set by the Board on July 20. In view of (a) the scope of LILCO's requests and (b) the ongoing nature of the work as to which documents are being sought by LILCO, it will not be possible to physically produce all the documents sought by LILCO within the time periods set by the Loard.

B. Document Requests Request No. 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 Response to Request No. 1.

Except for Messrs. Kanan, Polk, Jones and Cole, Suffolk County is unable to identify the individuals listed in Request No. 1. Suffolk County has surveyed its own officials and Messrs. Kanen, Polk, Jones and Cole and

will produce any testimony on emergency planning of the nature described in Request No. 1.

Request No. 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 Finalyson 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 Response to Request No. 2.

Except for Messrs. Kanen, Erikson, Herr, Jones, Zeigler, Finlayson, Budnitz, Radford, Polk and Cole, Suffolk County is unable to identify the individuals listed in Request No. 2. Suffolk County has surveyed its own officials, as well as Messrs. Kanen, Erikson, Herr, Jones, Zeigler, Finlayson, B.udnitz, Radford, Polk, and Cole and will

produce any documents pertaining to emergency planning of the nature described in Request No. 2.

Request No. 3.  ;

l 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, documents describing the methods used to conduct the surveys.

Response to Request No. 3.

A survey performed by Social Data Analysts has been furnished to LILCO. The County does not have in its possescion, custody or control any draft questions, draft results or documents describing the methods used to conduct the survey other than as may be contained in the survey itself. The County has requested Social Data Analysts to produce any documents other~than the survey itself.

Request No. 4.

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

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Response to Request No. 4.

The County has no documents within its possession, custody or control of the sort identified in Request No. 4. The County has requested Social Data Analysts to I produce any such documents.

Request No. 5. l The text of any public statements bearing on emer-gency planning made by any Suffolk County official during and up to two months prior to the telephone surveys by Social Data Analysts.

Response to Request No. 5.

The County does not have in its possession, custody or control any documents encompassed within Request No. 5.

Request No. 6.

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

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Response to Request No. 6.

The County does not have in its possession, custody or control any documents encompassed within Request No. 6.

Request No. 7.

All documents studying, analyzing, or otherwise per-taining to the results of the Social Data Analysts emer-gency planning surveys.

Response to Request No. 7.

The County does not have in its possession, custody or control any documents encompassed within Request No. 7.

At such time as the County's consultants furnish the County with any studies, analyses or any other information pertaining to the results of the survey, such documents shall be furnished to LILCO.

Request No. 8.

All documents studying, analyzing, or otherwise per-taining to the l' ocal conditions that might influence the Shoreham onsite emergency plan.

Response to Request No. 8.

Except for the survey referred to above, the County does not have in its possession, custody or control any documents encompassed within Request No. 8. At such time as the County's consultants furnish the County with any documents studying, analyzing or otherwise pertaining to local conditions that might influence the Shoreham onsite emergency plan, such documents shall be furnished to LILCO.

Request No. 9.

All documents analyzing, studying, or otherwise per-taining to procedures that might be used to notify those within the EPZ who are deaf or hard of hearing.

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Response to Request No. 9.

The County does not have in its possession, custody or control any documents encompassed within Request No. 9.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 10.

All documents analysing, studying or otherwise per-taining to the traffic or radiological conditions that might exist during a radiological emergency.

Response to Request No. 10.

Except for the survey referred to above, the County does not have in its possession, custody or control any documents encompassed within Request No. 10. At such tire as the County's consultants furnish the County with any such documents, those documents shall be furnished' to LILCO.

Request No. 11.

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

Response to Request No. 11.

The County does not have in its possession, custody or

control any documents encompassed with Request No. 11 At such time as the County's consultants furnish the l County with any such documents, those documents shall be furnished to LILCO.

Request No. 12.

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

l Response to Request No. 12.

The County does not have in its possession, custody or control any documents encompassed with Request No. 12.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

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1 l Request No. 13.

All documents analyzing, studying, or otherwise per- i taining to evacuation time estimate studies for Long Island.

l Response to Request No. 13.

The County does not have in its possession, custody or control any documents encompassed with Request No. 13.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

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Request No. 14.

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

Response to Request No. 14.

The County does not have in its possession, custody or control any documents encompassed with Request No. 14.

At such time as the County's consultants furnish the l l County with any such documents, those documents shall be furnished to LILCO.

Request No. 15.

All documents analyzing, studying or otherwise per-

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

Response to Request No. 15.

The County does not have in its possession, custody or control any documents encompassed with Request No. 15.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 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.

Response to Request No. 16.

The County does not have in its possession, custody or control any documents encompassed with Request No. 16.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 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 fail to report (or to report in a timely manner) because of conflicting family or other duties that would arise in the event of a radio-logical emergency.

Response to Request No. 17.

The County does not have in its possession, custody or control any documents encompassed with Request No. 17.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

, Request No. 18.

All documents analyzing, studying, or otherwise per-taining to public education programs to inform the popula-tion potentially affected by a radiological emergency of the initial and subsequent actions to be taken in the event of a radiological emergency.

1 Response to Request No. 18.

The County does not have in its possession, custody or control any documents encompassed with Request No. 18.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 19.

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

Response to Request No. 19.

The County does not have in its possession, custody or control any documents encompassed with Request No. 19.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 20.

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

Response to Request No. 20.

The County does not have in its possession, custody or control any documents encompassed with Request No. 20.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 21.

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

Response to Request No. 21.

The County does not have in its possession, custody or control any documents encompassed with Request No. 21.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 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.

Response to Request No. 22.

The County does not have in its possession, custody or control any documents encompassed with Request No. 22.

At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Request No. 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.

Response to Request No. 23.

.The County does not have in its possession, custody or control any documents encompassed. with Request No. 23.

. At. such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCo.

Request No. 24.

All documents studying, analyzing, or otherwise con-cerning possible obstacles, such as impassible roadways due to evacuation or adverse environmental conditions, that

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might prevent field monitoring teams from reaching the off-site monitors.

Request No. 25.

All document pertaining to consequence analysis studies that reflect the potential consequences of a serious radio-logical emergency at Shoreham.

Response to Request No. 25.

The County does not have in its possession, custody or control any documents encompassed with Request No. 25. At such time as the County's consultants furnish the County with any such documents, those documents shall be furnished to LILCO.

Respectfully submitted, David J. Gilmartin Suffolk County Attorney Patricia A. Dempsey Assistant Suffolk County Attorney H. Lee Dennison Building Veterans Memorial Highway Hauppauge, New York 11788

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HerTert H. / Brown

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Cherif Sedky

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Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County Dated: August , 1982 Washington, D.C.

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

) 1 In the Matter of ) '

)

LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (0.L.)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Response of Suffolk County to LILCO's Second Request to Suffolk County Production of Emergency Planning Documents" was sent on August 4, 1982 by first class mail, except where otherwise noted; to the follow-ing:

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 N'ew 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

• Richmend, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washir.gton, 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 Road Mineola, New York 11501 Stephen B. Latham, Esq.

Twomey, Latham & Shea l

Mr. Brian McCaffrey Attorneys at Law Long Island Lighting Company P.O. Box 398 175 East Old Country Road 33 West Second Street Hicksville; New York 11801 Riverhead, New York 11901

• By Hand

l Marc W. Goldsmith Mr. Jeff Smith Energy Research 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 Regulatory 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. Nuclear 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 Stuart Diamond State Public Service Comm.

Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223 Long Island; New York 11747 l

Cherif Sedky; Esq.

Kirkpatrick, Lockhart, Johnson & Hutchison 1500 Oliver Building Pittsburgh, Pennsylvania 15222

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Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL, g / CHRISTOPHER & PHILLIPS DATE: //ftfe d Y, /ffdL 1900 M Street, N.W., 8th Floor Washington, D.C. 20036

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