ML20077S712

Second Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl

ML20077S712
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	09/19/1983
From:	Monaghan J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SUFFOLK COUNTY, NY
References
ISSUANCES-OL-03, ISSUANCES-OL-3, NUDOCS 8309220185
Download: ML20077S712 (14)

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LILCO, September 19, 1983 00CNETED usuc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE 0F SECRETU '

00CET'tifi A SE9ni r.

im A NC;f Before the Atomic Safety and Licensing Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-03

) (Emergency Planning Proceeding)

(Shoreham Nuclear Power Station, )

Unit 1) )

LILCO INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO SUFFOLK COUNTY (SECOND SET) l As used in these interrogatories and requests for produc-i

tion, the term "Suffolk County" means Suffolk County, and any agent, employee, consultant, contractor, technical advisor, representative (including, without limitation, attorneys and f

l accountants and their respective agents and employees), or l .

l other person acting for or on behalf of Suffolk County, or at l

Suffolk County's direction and control, or in concert with l

Suffolk County or assisting Suffolk County.

Suffolk County is requested by LILCO, pursuant to 10 l C.F.R. 5 2.740b, to answer each of the following interrogato-ries within fourteen (14) days after service hereof, using the same instructions for answering interrogatories as are set forth on pages 1 through 11 of "Suffolk County Interrogatories to Long Island Lighting Company," dated August 19, 1983. To the extent that the following interrogatories requaat Dk hojK85 83o939 ._

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production of documents, responses to them are requested on tho same schedule as answers to interrogatories due to the close-ness of impending depositions and the fact that the need for these interrogatories did not become apparent until after l September 14, 1983.

, 5. With respect to Dr. Bruce Pigozzi:

a. Please state whether Dr. Pigozzi has prepared, or has had prepared, any written studies, reports, analyses or other documents for Suffolk County with respect to any of the following: (1) the proposition that "LILCO i time estimates are inaccurate, unreliable and, in

! fact, should be far longer" (see Answer to LILCO Re-quest 52(c) dated August 8, 1983); (2) traffic; (3) evacuation times.

l b. Unless the answer to part a. is a simple negative, j please identify each such document without regard to whether Suffolk County intends to assert a claim of privilege with respect to it, including date, title and addressee, if any.

c. Please provide a copy of each such document identified l

in part b. which can reasonably be copied and which has not already been provided to LILCO; LILCO agrees in advance to pay reasonable copying costs. For any I

document as to which Suffolk County asserts that

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0 copying is not feasible, please identify the location at which it may be inspected by LILCO.

d. Please describe any work already completed, or in progress, or now known to be conducted in the future

! in connection with this proceeding, by Dr. Pigozzi or under his supervision and direction and not already described in part b. hereof, and relating to any of l the following: (1) LILCO's evacuation plan, including, but not limited to, traffic time estimates; (2) estimation of time and other relevant aspects of evacuation of a lO-mile EPZ; (3) the PRC Voorhees eveucation time estimates and analysis for a 20-mile EPZ; (4) traffic; (5) evacuation times.

e. Please provide a copy of Dr. Pigozzi's most current j curriculum vitae or statement of professional qualifi-cations.

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f. Please list any NRC or other legal proceedings in which Dr. Pigozzi has testified on matters relating to traffic, evacuation time estimates, or emergency plan-ning, state the subject matter of his testimony, and its approximate date.

g. Please provide copies of any prefiled testimony by Dr.

Pigozzi in the proceedings listed in the response to item f.

h. Please identify all articles, papers or other docu-ments authored or co-authored by Dr. Pigozzi or the subjects of traffic, evacuation times, emergency plan-ning or the Shoreham power plant which have been published in the open literature.

i. Please also identify all such articles, papers and other documents not published in the open literature but circulated within the professional community.

6. With respect to Dr. David M. Harris:

a. Please state whether Dr. Harris has prepared, or has had prepared, any written r0 ports, studies, analyses or other documents for Suffolk County with respect to any of the following: (1) the proposition that "the time necessary, following mobilization, to accomplish the proposed evacuation of special facilities will be l

too long to provide adequate protection from health-threatening radiation doses" (SC Revised Contention 72.A); (2) the proposition that "the LILCO Plan cannot be implemented in a timely manner and therefore will not provide adequate protection to handicapped persons in the EPZ" (SC Revised Contention 73); (3) evacuation of persons with special needs and related services; (4) relocation centers.

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b. Unless the answer to part a. is a simple negative, please identify each such document without regard to whether suffolk County intends to assert a claim of privilege with respect to it, including date, title and addressee, if any.

c. Please provide a copy of each such document identified in part b. which can reasonably be copied and has not already been provided to LILCO; LILCO agrees in ad-vance to pay reasonable copying costs. For any docu-ment as to which Suffolk County asserts that copying is not feasible, please identify the location at which it can be inspected by LILCO.

d. Please describe any work already completed, or in progress, or now known to be conducted in the future in connection with this proceeding, by Dr. Harris or l

l under his supervision and direction and not already 1

described in part b hereof, and relating to any of the following: (1) the time necessary, following mo-bilization, to accomplish evacuation of hospitals, nursing homes, and other special facilities; (2) the relationship between the timeliness of evacuation plan implementation and provision of protection to handicapped persons or of persons in hospitals, nursing homes and other special facilities; (3)

LILCO's provisions for evacuation of hospitals,

nursing homes and other special facilities; (4) evacuation of persons with special needs and related services; (5) relocation centers.

e. Please identify each person who conducted interviews or otherwise collected information for a report enti-tied " Comments on the LILCO Emergency Plan for Shoreham," presented by Dr. Harris to the Cuomo Com-mission on September 14, 1983.

f. Please provide copies of each set of interview notes or other documents compiled by the persons who conducted interviews in the process of preparation of the report referred to in paragraph e.

g. Please provide copies of Dr. Harris' most current cur-riculum vitae or statement of professional qualifica-tions.

h. Please list any NRC or other legal proceedings in which Dr. Harris has testified on matters within the scope of the expected subject matter of his testimony in this proceeding, state the subject matter of his testimony, and its approximate date.

1. Please provide copies of any prefiled testimony by Dr.

Harris in the proceedings listed in the response to item h.

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j. Please identify all articles, papers or other docu-ments authored or co-authored by Dr. Harris on matters relating to medical or public health aspects of ener-gency planning or evacuation, which have been published in the open literature.

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k. Please also identify all such articles, papers and other documents not published in the open literature but circulated within the professional community.

7. With respect to Commissioner Donald Dilworth:

a. Please state whether Commissioner Dilworth has pre-pared any written studies, reports, analyses or other documents for Suffolk County with respect to any of the following: (1) command and control; (2) emergency planning; (3) role conflict; (4) traffic; (5) mobili-zation.

b. Unless the answer to part a. is a simple negative, please identify each such document without regard to whether Suffolk County intends to assert a claim of privilege with respect to it, including date, title

! and addressee, if any.

l c. Please provide a copy of each such document identified 1

in part b. which can reasonably be copied and has not l

t been already provided to LILC0; LILCO agrees in l

advance to pay reasonable copying costs. For any document as to which Suffolk County asserts that copy-ing is not feasible, please identify the location at which it may be inspected by LILCO.

d. Please describe any work already completed, or in progress, or now known to be conducted in the future in connection with this proceeding, by Commissioner Dilworth or under his supervision and direction and not already described in part b. hereof, and relating to any of the following: (1) LILCO's evacuation plan, including, but not limited to, traffic time estimates; (2) estimation of time and other relevant aspects of evacuation of a 10-mile EPZ; (3) the PRC Voorhees evaucation time estimates and analysis for a 20-mile l EPZ; (4) command and control; (5) emergency planning; (6) role conflict; (7) mobilization.

l e. Please provide a copy of Commissioner Dilworth's most L

current curriculum vitae or statement of professional l qualifications.

l l f. Please list any NRC or other legal proceedings in which Commissioner Dilworth has testified on matters within his professional expertise and relevant to l

emergency planning, state the subject matter of his testimony, and its approximate date.

g. Please provide copies of any prefiled testimony by Commissioner Dilworth not already provided to LILCO in the proceedings listed in the response to item f.

h. Please identify all articles, papers or other docu-ments and authored or co-authored by Commissioner Dilworth which have been published in the ,open litera-ture on any of the following: (1) LILCO's evacuation plan, including, but not limited to, traffic time es-timates; (2) estimation of time and other relevant as-pects of evacuation of a 10-mile EPZ; (3) the PRC Voorhees evacuation time estimates and analysis of a 20-mile EPZ; (4) mobilization.

i. Please also identify all such articles, papers and other documents not published in the open literature but circulated within the professional community on any of the following: (1) LILCO's evacuation plan, including, but not limited to, traffic time estimates; (2) estimation of time and other relevant aspects of evacuation of a 10-mile EPZ; (3) the PRC Voorhees evacuation time estimates and analysis of a 20-mile EPZ; (4) mobilization.

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8. With respect to Mr. Gregory Minor:

a. Please state whether Dr. Minor has prepared any writ-ten studies, reports, analyses or other documents for Suffolk County with respect to any of the following:

(1) sheltering; (2) radiological monitoring; (3) con-sequence analysis.

b. Unless the answer to part a. is a simple negative, please identify each such document without regard to whether Suffolk County intends to assert a claim of privilege with respect to it, including date, title and addressee, if any.

c. Please provide a copy of each such document identified in part b. which can reasonably be copied and has not been already provided to LILCO; LILCO agrees in ad-vance to pay reasonable copying costs. For any docu-ment as to which Suffolk County asserts that copying is not feasible, please identify the location at which it may be inspected by LILCO.

d. Please describe any work already completed, or in progress, or now'known to be conducted in the future in connection with this proceeding, by Mr. Minor or under his supervision and direction and not already described in part b. hereof, and relating to any of the following: (1) sheltering; (2) radiological monitoring; (3) consequence analysis.

e. Please provide a copy of Mr. Minor's most current cur-riculum vitae or statement of professional qualifica-tions.

f. Please list any NRC or other legal proceedings in which Mr. Minor has testified on any of the following:

(1) sheltering; (2) radiological monitoring; or (3) consequence analyses; and state the subject matter of such testimony, and the approximate date.

g. Please provide cepies of any prefiled testimony by Mr.

Minor in the proceedings listed in the response to item f.

h. Please identify all articles, papers or other docu-l ments authored or co-authored by Mr. Minor which have l

l been published in the open literature on any of the following: (1) sheltering; (2) radiological monitoring; (3) consequence analyses.

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1. Please identify all articles, papers and other docu-ments authored or co-authored by Mr. Minor and not i

published in the open literature but circulated within the professional community on any of the following:

(1) sheltering; (2) radiological monitoring; (3) con-sequence analyses.

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9. Please identify any persons who have contacted the nation-al headquarters of the American Red Cross on behalf of Suffolk County with respect to emergency planning at Shoreham since July 1, 1983. Please also state the date of any such visit, its purpose, the subject-matter area discussed and the name or names of persons met with. Please also identify any documents provided to, or received from the Red Cross, regardless of whether a claim of privilege is intended to be asserted with respect to such document or documents.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY 0l}$fW Y. W onald P. Irwin /

Jessine A. Monagh d Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: September 19, 1983

LILCO, September 19, 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 certify that a copy of LILCO INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO SUFFOLK COUNTY (SECOND SET) was served this date upon the following by first-class mail, postage prepaid, or by

hand (as indicated by an asterisk), or by Federal Express (as indicated by two asterisks).

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. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, D.C. 20555 l

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 Board Commission U.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom)

East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.

j. Bethesda, MD 20814 l

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I Eleanor L. Frucci, Esq.* Stewart M. Glass, Esq.**

Attorney 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 New 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 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 Totten Pond Road Three Empire State Plaza Waltham, 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 Euilding 2 Empire State Plaza Ms. Nora Bredes Albany, New York 12223 Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street Smithtown, New York 11787 NN .

'JessineA.Monag%n Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: September 19, 1983