ML20078E172
| ML20078E172 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/03/1983 |
| From: | Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| ISSUANCES-OL-03, ISSUANCES-OL-3, NUDOCS 8310050416 | |
| Download: ML20078E172 (31) | |
Text
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00CKETED USNRC UNITED STATES OF AMERICA '83 00T -4 A 0 :25 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-03
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUFFOLK COUNTY RESPONSES TO LILCO INTERROGATORIES AND REQUEST FOP PRODUCTION OF DOCUMENTS DATED AUGUST 25, 1983 AND SECOND SET DATED SEPTEMBER 19, 1983 Suffolk County hereby responds to the LILCO Interrogatories and Request for Production of Documc3.ts dated August 25, 1983 which were served on Suffolk County ,on September 19, 1983, and to LILCO Interrogatories and'HSquests for Production of Documents (Second Set) dated September 19, i 1983.
l Interrogatories and Recuest for Production of Documents, Dated August 25, 1983 Interrogatories 1 and 2:
- 1. State each exact portion of each request for admission not admitted;
- 2. With respect to each such unadmitted portion of each re-quest for admission referred to in the answer to interrogatory 1 above: (a) state the reason it is not admitted; (b) state the name of each expected witness.with respect to the area not 8310050416 831003 q PDR ADOCK 05000322 GD J G PDR
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admitted; (c) state the name of each person, not a witness, serving as a consultant on the area not admitted; (d) state the titles and authors of any studies completed to date by, for, or on behalf of Suffolk County respecting the area not admitted; (e) state the titles, subject matters and authors of any 4
studies by, for, or on behalf of Suffolk County presently in progress or specifically anticipated on the area not admitted; and (f) state the title and author of each other document i
i relied on or to be relied on by Suffolk County with respect to answers 2(a) through 2(f). If the answer includes a reference to any of Suffolk County's Revised Emergency Planning Conten-tions, please also answer questions 2(a) through 2(f) specifi-cally without reference to such Revised Contentions or state that no support for the answer exists apart from the literal text of such Revised Contentions.
j Response:
'Suffolk County either admitted or objected to each of the Re-
- quests for Admission. Accordingly, these Interrogatories are inapposite.
Interrogatories No. 3 and 4:
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- 3. Has Suffolk County performed or had performed, or is Suffolk County now performing or having performed, or is j . - . - - . . . - - . . . - - - . . . . . ~ . - _ . - . . - . , , _
, , . i Suffolk County relying or intending to rely on, an evacuation analysis, including but not limited to traffic analyses, using any of the following: (a) an approximately 10 mile EPZ, (b) any EPZ other than a 20 mile EPZ, (c) a 20 mile EPZ (other than the documents referred to in Requests for Admission 1 and 2)?
- 4. If the response to any of Interrogatory 3(a), (b) or (c) is anything other than a single negative, please state with respect to each such answer: (a) the nature of such analysis, (b) the author, title and date of any document containing such
- . analysis, (c) a summary of its conclusions.
Response
See the County's September 29, 1983 Pesponse to Requests for Admission 6, 7 and 8, and the Responses to Interrogatories ref-erenced therein. The County objects to these Interrogatories 3 and 4 on the grounds that they seek information protected by 5
the attorney work product doctrine and on the grounds set forth in the above-referenced, responses. See also letter, dated Sepuumber 29, 1983, from Karla J. Letsche to Donald P. Irwin.
The County further notes that its witnesses have been made I
available to answer LILCO's questions concerning relevant facts and their expert opinions.
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l Reouest'for Production:
Pursuant to 10 CFR S2.741, Suffolk County is requested to make
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-available for inspection and copying each study or other document identified in response to Interrogatories 2 and 4. It is requested that these documents be produced within the same i
time frame as the answers to Interrogatories 2 and 4.
j Response:
1 No documents, other than those already provided to LILCO, were
- identified in responses to Interrogatories 2 and 4.
Interrogatories and Requests for Production of Documents i
Directed to Suffolk County (Second Set) 4 i
j LILCO Request 5.a:
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! With respect to Dr. Bruce Pigozzi:
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Please state whether Dr. Pigozzi-has prepared, or has had prepared, any written studies, reports, analyses or other
{ documents for Suf folk County with respect to any 'of the follow-I i
- i. ing: (1) the proposition that "LILCO time estimates are inaccu-rate, unreliable and, in fact, should be far longer" (see i
! Answer to LILCO Request 52(c) dated August 8,-1983); (2) traf-l fic; (3) evacuation times.
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Response
.Yes; see response to LILCO Request 5.b.
- LILCO Request 5.b
i Unless the answer to part a. is a simple negative, please iden-4 f tify each such document without regard to whether Suffolk Coun-1 i ty intends to assert a claim of privilege with respect to it, .
including date, title and addressee, if any.
Response: [
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- Dr. Pigozzi has not prepared any formal " studies" or " reports" that are responsive to this request. All the documents respon-2 sive to LILCO Request 5.a. were prepared by Dr. Pigozzi at the request of counsel for the County in preparation for litigation and thus they are protected from discovery under the attorney i
work product doctrine. They consist of four letters from Dr.
Pigozzi to Christopher M. McMurray, dated July 26, and August l
1, 17 and 19, 1983 (with enclosures) all regarding Dr. ;
3 Pigozzi's review of Appendix A, some notes reflecting Dr.
i j Pigozzi's review of Appendix A, and a letter te Karla J.
J Letsche dated July 13, 1983 regarding discovery requests.
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,o .i LILCO Reauest 5.c:
i Ple'ase provide a copy of each such document identified in part
- b. which can reasonably be copied and which has not already been provided to LILCO; LILCO agrees in advance to pay reason-able copying costs. For any document as to which Suffolk Coun-ty asserts that copying is not feasible, please identify the ,
location at which it may be inspected by LILCO.
Response
See response to LILCO Request 5.b.
LILCO Recuest 5.d:
Please describe any work alr?ady completed, or in progress, or now known to be conducted in the future in connection with this J
proceeding, by Dr. Pigozzi or under his supervision and direc-tion 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) es-
-timation of time and other relevant aspects of evacuation of a l
10-mile EPZ; (3) the PRC Voorhees evacuation time estimates and l
analysis for a 20-mile EPZ; (4) traffic; (5) evacuation times.
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< Response:
Dr. Pigozzi is performing work, at the request of the County's attorneys, in connection with the preparation of testimony and other litigation preparation. A description of such work is protected by the attorney work product doctrine. Dr. Pigozzi .l will be available at his deposition to answer questions con-cerning relevant facts and his expert opinions.
LILCO Request 5.e:
Please provide a copy of Dr. Pigozzi's most current curriculum vitae or statement of professional qualifications.
Response
l A copy of Dr. Pigozzi's vitae was provided to counsel for LILCO on September 21, 1983. .
LILCO Request 5.f:
t Please list any NRC or other legal proceedings in which Dr.
Pigozzi has testified on matters relating to traffic, evacua-
- tion time estimates, or emergency planning, state the subject matter of his testimony, and its approximate date.
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Response
Dr. Pigozzi testified before the Indiana Public Service Commission in 1976 regarding the development and implementation of the Indiana State Rail Plan.
LILCO Request 5.g:
Please provide copies of any prefiled testimony by Dr. Pigozzi in the proceedings listed in the response to item f.
Response: ,
There was no prefiled testimony in the identified proceeding.
LILCO Request 5.h:
Please identiff all articles, papers, or other documents authored or co-authored by Dr. Pigozzi on the subjects of traf-fic, evacuation times, emergency planning or the Shoreham power plant which have been published in the open literature.
Response
Dr. Pigozzi has authored or co-authored the following materials relating to transportation systems modelling:
Indiana State Rail Plan: Methodology Review. monograph sub-mitted to the Public Service Commission of Indiana, May 24, l
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1976. Later published as Research Paper Number 2 in the " Rail Planning and Policy Series" of the Center for Urban and Region-al Analysis, Indiana University, Bloomington, Indiana; series
! editor, william R. Black.
! Indiana State Rail Plan: FinallPhase 2, a release to the public and the Federal Railroad Administration of the Public Service
- Commission of Indiana, January 1976. Co-author and Director of
- State Rail Planning.
Indiana State Rail Plan Preliminary Phase 2, (Volumes I and i
II), a release of the State Rail Planning Staff of the Public Service Commission of Indiana, October 1975. Co-author and As-
!~ sistant Director of State Rail Planning Staff.
Indiana State Rail Plan Phase 1, a submission to the Federal Railroad Administration by the Public Service Commission of the State of Indiana, January 1975. Contributor and Assistant 1 Director of the State Rail Planning Staff.
) U.S.R.A. Segments in Indiana: State Analysis and l Recommendations, (Volumes 3 and 4), a submission to the United States Railway Association, January 1975. Contributor and As-sistant Director of the Governor's Rail Study Technical Staff.
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1 In addition,.Dr. Pigozzi has presented the following papers: i
" Application of the URBAN SYSTEMS PODEL to the proposed Grand Rapids Beltway" (with R. Collard). East Lakes Division of the
. Association of American Geographers Annual Meeting, Kalamazoo, t
Michigan; November 1982.
"The 1973 Ballroad Transportation Act and Its Effect on Indiana", invited paper to the Conference of the Indiana Area Development Council, Ball State University, Muncie, Indiana, T
May 1976. .
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" Changing Service Levels as an Alternative to Rail Line Aban-1 donment: The Case of On-Branch Costs", (with W. R. Black) pre-sentation to the West Lakes Division of the Association of
! American Geographers, Carbondale, Illinois, November 1975.
LILCO Request 5.i:
1 Please also identify all such articles, papers and other 4
1 documents not published in the open literature but circulated 1
i within the professional community.
i Response:
i j There are no such documents.
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l LILCO Request 6.a:
With respect to Dr. David M. Harris:
- a. Please state whether Dr. Harris has prepared, or has had prepared, any written reports, studies, analyses or other documents for Suffolk County with respect to any of the following: (1) the proposition that "the time necessary, i
following mobilization, to accomplish the proposed evacua-tion of special facilities will be too long to provide 4 adequate protection from health-threatening radiation doses" (SC Revised Contention 72.A); (2) the proposit!on .
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 re-lated services; (4) relocation centers.
Response
Yes; see response to LILCO Request 6.b.
LILCO Request 6.b:
i Unless the answer to part a. is a simple negative, please iden-( tify each such document without regard to whether Suffolk Coun-ty intends to assert a claim of privilege with respect to it, including date, title and addressee, if any.
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Response
A report commenting on the LILCO Transition Plan, prepared by Robert J. Sheppard in response to the request of the County's attorneys, dated August 26, 1983, and letters to Christopher M.
McMurray from Oliver Schepers dated September 27 and 28, 1983, concerning discovery documents, are responsive to this request, but are protected from discovery under the attorney work product doctrine. In addition, the following documents are re-sponsive to this request:
- 1. " Comments on the LILCO Emergency Plan for Shoreham."
LILCO has received a copy of this document.
- 2. Memorandum to Martin Mayer from William Larkin regarding evacuation, dated August 29, 1983. A copy of this document is an attachment to document 1 above, already received by LILCO.
- 3. A document prepared prior to Dr. Harris' appearance before Governor Cuomo's Shoreham Commission, which was not in fact presented to the Commission. A copy of this document is enclosed.
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.o .i LILCO Request 6.c:
Please provide a copy of each such document identified in part
- b. which can reasonably be copied and has not already been pro-vided to LILCO; LILCO agrees in advance to pay reasonable copy-ing costs. For any document as to which Suffolk County asserts that copying is not feasible, please identif- ; the location at which it can be inspected by LILCO.
I Response:
See response to LILCO Request 6.b.
LILCO Request 6.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 under his supervision and direc-tion and not already 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 j, 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
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Response
Work performed or to be performed by Dr. Harris or under his direction on the referenced subjects has been and will be at the request of the County's attorneys in connection with the preparation of testimony or other preparation for this proceed-ing. A description of such work is pretected under the attorney work product doctrine. Dr. Harris will be available at his deposition to answer questions concerning his expert opinions and relevant facts.
LILCO Recuest 6.e:
- Please identify each person who conducted interviews or other-wise collected information for a report entitled " Comments on the LILCO Emergency Plan for Shoreham," presented by Dr. Harris to the Cuomo Commission on September 14, 1983.
Response
l' Martin Mayer, M.D., M.P.H., William Larkin, and Robert J..Shep-pard collected information pursuant to the request of Suffolk County's attorneys for " Comments on the LILCO Emergency Plan for Shoreham."
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LILCO Recuest 6.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 para-graph e.
Response
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Handwritten notes made in preparation of " Comments on the LILCO Emergency Plan for Shoreham," are protected from discovery under the attorney work product doctrine. A letter dated August 25, 1983 from Martin Mayer, M.D., M.P.H. to Janine Hold-er, M.D., with enclosure, is provided.
LILCO Request 6.q:
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Please provide copies of Dr. Harris' most current curriculum I vitae or statement of professional qualifications.
Response
A copy'of Dr. Harris' vitae is enclosed.
LILCO Request 6.h:
Please list any NRC or other legal proceedings in which Dr.
Harris has testified on matters within the scope of the
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expected subject matter of his testimony in this proceeding, state the subject matter of his testimony, and its approximate date.
Response
In addition to Dr. Harris' appearance to answer questions by the'Cuomo Commission, Dr. Harris testified before the Suf folk County Legislature in January, 1982. LILCO has received a copy of that testimony.
LILCO Recuest 6.i:
Please provide copies of any prefiled testimony by Dr. Harris t
in the proceedings listed in the response to item h.
Response
See response to LILCO Request 6.h. Only " Comments on the LILCO Emergency Plan for Shoreham" was submitted by Dr. Harris to the Cuomo Commission.
. LILCO Reauest 6.j: '
F l' Please identify all articles, papers or other documents authored or co-authored by Dr. Harris on matters relating to medical or public health aspects of emergency planning or evac-uation, which have been published in the open literature.
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Response
1 There are no documents of the type described other than items 1 and 3 identified in response to LILCO Request 6.b. and Dr.
Harris' testimony before the Suffolk County legislature.
LILCO Request 6.k:
i i Please also identify all such articles, papers and other documents not published in the open literature but circulated j within the professional community.
i l Response l
j See response to Request 6.j.
n I LILCO Request 7.a:
e i With respect to Commissioner Donald Dilworth: please state I
j whether Commissioner Dilworth has prepared any written studies,
! reports, analyses or other documents for Suffolk County with i
respect to any of the following: (1) command and control; (2) emergency planning; (3) role conflict; (4) traffic; (5) mobili-i zation.
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i Response-Yes; see response to'7.b.
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LILCO Recuest 7.b:
Unless the answer to part a. is a simple negative, please iden-tify each such document without regard to whether Suffolk Coun- l ty intends to assert a claim of privilege with respect to it, including date, title and addressee, if any.
Response
Commissioner Dilworth participated in the preparation of the "Suffolk County Police Department's Presentation to the Legis-lature of Suffolk County on the November 1982 Draft Suffolk County Radiological Emergency Response Plan," dated January 26, 1983. Commissioner Dilworth also has presented the following testimony:
- 1. Testimony of Donald J. Dilworth, Commissioner of the Suffolk County Police Department Before the Subcommittee on Energy, Conservation and Power of the Committee on En-ergy and Commerce, United States House of Pepresentatives.
I June 8, 1983.
- 2. Testimony of Suffolk County Police Department, Presented by Commissioner Donald J. Dilworth, Before the Suffolk County Legislature. January 26,.1983.
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- 3. Testimony before the Cuomo Commission, June 28, 1983.
In addition, correspondence involving Commissioner Dilworth that was provided to LILCO in response to Phase I discovery re-quests may be responsive to LILCO Pequests 7.a. and 7.b.
LILCO Recuest 7.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 LILCC; LILCO agrees in advance to pay reasonable copying costs. For any document as to which Suffolk County asserts that copying is not feasible, please identify the loca-tion at which it may be inspected by LILCO.
Response
Enclosed is a summary of Commissioner Dilworth's June 28, 1983 testimony before the Cuomo Commission. Copies of the other re-quested documents either are publicly available or have already been provided to LILCO.
LILCO Request 7.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 l
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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) es-timation of time and other relevant aspects of evacuation of a 10-mile EPZ; (3) the PRC Voorhees evacuation time estimates and analysis for a 20-mile EPZ; (4) command and control; (5) emer-gency planning; (6) role conflict; (7) mobilization.
Response
Any such work by Commissioner Dilworth, other than his prepara-tion of the testimony described in 7.b. above, has been or will be performed at the request of the County's attorneys in prepa-ration for litigation. A description of,such work is protected by the attorney work product doctrine. Commissioner Dilworth has been made available to answer questions concerning his expert opinions and relevant facts.
LILCO Request 7.e:
Please provide a copy of Commissioner Dilworth's most current curriculum vitae or statement of professional qualifications.
Response
A copy of Commissioner Dilworth's resume has been provided to LILCO.
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LILCO Request 7.f:
Please list any NRC or other legal proceedings in which Commissioner Dilworth has testified on matters within his professional expertise and relevant to emergency planning, state the subject matter of his testimony, and its approximate date.
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! Response:
Commissioner Dilworth has given no testimony of the type de-scribed other than that identified in response to LILCO Request 7.b.
j -LILCO Request 7.g:
1 Please provide copies of any prefiled testimony by Cormissioner Dilworth not already provided to LILCO in the proceedings 1 ' listed in the response to item f.
Response
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.See response to LILCO Request 7.c.
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LILCO Recuest 7.h:
Please identify all articles, papers or other documents and 3
' authored or co-authored by Commissioner Dilworth which have l c
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(1) LILCO's evacuation plan, including, but not limited to, traffic time estimates; (2) estimation of time and other rele-vant 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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Response
There are no documents of the type described other than those identified in response to LILCO Request 7.b.
LILCO Reauest 7.i:
Please also identify all such articles, papers and other documents not published in the open literature bitt 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 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.
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Response
There are no documents of the type described other than those identified in response to LILCO Request 7.b.
.. .a LILCO Fequest 8.a:
1 With respect to Mr. Gregory Minor: 1 Please state whether Mr. Minor has prepared any written studies, reports, analyses or other documents, for Suffolk County with respect to any of the following: (1) sheltering; (2) radiclogical monitoring; (3) consequence analysis.
Response
Yes.
LILCO Pequest 8.b:
Unless the answer to part a. is a simple negative, please iden-tify each such document without regard to whether Suffolk Coun-ty intends to assert a claim of privilege with respect to it, including date, title and addressee, if any.
Response
Mr. Minor has not prepared any written " studies" or " reports" that are responsive to this request. However, the following i
documents which are protected from discovery under the attorney work product doctrine, may be responsive to this request:
- 1. Letter dated August 10, 1983 from Mr. Minor to Karla J.
Letsche regarding review of Final vs. Preliminary Shoreham PRA, with enclosure. l
- 2. Letter dated August 16, 1983 from Mr. Minor to Karla 7.
Letsche regarding Review of Shoreham PRA, with enclosure.
- 3. Letter dated July 22, 1983 from Mr. Minor to John E.
Birkenheier regarding responses to informal discovery re-quests, with enclosures.
- 4. List of discovery items prepared by Mr. Minor.for Lawrence Coe Lanpher on or about July 13, 1983.
- 5. Letter dated September 15, 1983 from Mr. Minor to Karla J.
Letsche and Fred C. Finlayson regarding proposed testimo-ny, with enclosure.
LILCO Recuest 8.c:
Please provide a copy of each such document identified in part
- b. which can reasonably be copied and has not.been already pro-
- ided to LILCO, LILCO agrees in advance to pay reasonable copy-i ing costs. For any document as to which Suffolk County asserts that. copying is not feasible, please identify the location at which it may be inspected by LILCO.
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.. .e Response: l l
See response to LILCO Request 8.b.
LILCO Request 8.d: l 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) she'ltering ; (2) radiological moni-toring; (3) consequence analysis.
Response
Work performed or to be performed by Mr. Minor on the refer-enced subjects has been and will be at the request of the Coun-ty's attorneys in connection with the preparation of testimony or other preparation for this proceeding. A description of such work is protected under the attorney work product doc-trine. Mr. Minor will be available to answer questions at his deposition concerning his expert opinions and relevant facts.
ll l LILCO Request 8.e: ,
Please provide a copy of Mr. Minor's most current curriculum vitae or statement of professional qualifications.
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Response
A copy has been provided to LILCO.
LILCO Pecuest 8.f:
Please list any NBC or other legal proceedings in which Mr.
Minor has testified on any of the following: (1) sheltering; (2) radiological monitoring; or (3) consequence analysis; and state the subject matter of such testimony, and the approximate
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Response
See Items 8, 25, 28, and 34 on Mr. Minor's resume. The testi-mony identified in Item 8 dealt with the risks associated with nuclear power plants. In addition, Mr. Minor was deposed dur-ing Shoreham Phase I discovery (August 18, 1982) concerning ra-diation monitoring, and filed Testimony on behalf of Suffolk County dated October 12, 1982, regarding Contentions EP 10B, 10C and 14 (Radiation Monitoring and Dose Assessment).
LILCO Request 8.g:
If l Please provide copies of any prefiled testimony by Mr. Minor in the proceedings listed in the response to item f.
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Response
A copy of Mr. Minor's Diablo Canyon testimony is enclosed.
LILCO has copies of the Shoreham testimony. There was no prefiled testimony in the Canadian proceeding.
LILCO Request 8.h:
Please identify all articles, papers or other documents authored or co-authored by Mr. Minor which have been published
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in the open literature on any of the following: (1) shel--
tering; (2) radiological monitoring; (3) consequence analyses.
Response
See Item 9 on Mr. Minor's resume.
LILCO Request 8.i:
Please identify all articles, papers and other documents authored or co-authored by Mr. Minor and not published in the open literature but circulated within the professional communi-ty on any of the following: (1) sheltering; (2) radiological monitoring; (3) consequence,dnalyses.
Response
See Items 10 and 19 on Mr. Minor's resume. In addition, Mr.
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.. *e Minor participated in the preparation of " Summary of Emergency Response Planning Criteria for United States Regional and Local Authorities Near Nuclear Electric Generating Stations," by PHB Technical Associates, February 1982, prepared for Amici della Terra, Rome, Italy.
LILCO Request 9 Please identify any persons who have contacted the national 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.
R,esponse:
Claib Cook, of Kirkpatrick, Lockhart, Hill, Christopher &
Phillips contacted Roy Popkin of the American Red Cross on
. lI August 17, 1983. John E. Birkenheier and Laura Hudgins, both with Kirkpatrick, Lockhart, Hill, Christopher & Phillips, met t
! on August 24 and 19, 1983, respectively, with Roy Popkin of the l
American Red Cross. Red Cross emergency procedures and l l
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.. v .o emergency planning for Shoreham were discussed. The following documents have been received from the Red Cross:
- 1. Disaster Services Regulations and Procedures: ARC 3027, May 1980; ARC 3002 (Rev. Mar. 1982); ARC 3003 (Rev. Feb.
1979, July 1979 Prtg.)
- 2. Preliminary Draft of Mass Care Preparedness and Operations Manual, with cover letter dated August 15, 1983, from Dan Prewitt to Member, National Mass Care Workgroup. ,.
Respectfully submitted, Dated: October 3, 1982 David J. Gilmartin Washington, D.C. Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 az i KarJa J. Letsch Johh J. Birke ier KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County
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.c d *o UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION
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In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County Responses to LILCO Interrogatories and Request for Production of Documents Dated August 25, 1983 and Second Set dated September 19, 1983 have been sent to the following this 3rd day of October, 1983 by U.S. mail, first class, except as otherwise noted:
James A. Laurenson, Chairman Ralph Shapiro, Esq.
Atomic Safety and Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D. C. 20555 New York, New York 10016
! Dr. Jerry R. Kline *W. Taylor Reveley, III, Esq.
i Atomic Safety and Licensing Board Hunton & Williams U.S. Nuclear Regulatory Commission P. O. Box 1535 Washington, D. C. 20555 707 East Main Street Richmond, Virginia 23212 Mr. Frederick J. Shon Atomic Safety and Licensing Board Stephen B. Latham, Esq.
U.S. Nuclear Regulatory Commission Twomey, Latham & Shea Washington, D. C. 20555 33 West Second Street Riverhead, New York 11901 David J. Gilmartin, Esq.
Suffolk County Attorney Docketing & Service Section H. Lee Dennison Building Office of the Secretary G Veterans Memorial Highway U.S. Nuclear Regulatory Comm.
Hauppauge, New York 11788 Washington, D. C.20555 i
Bernard M.-Bordenick, Esq. Eleanor L. Frucci, Esq.
l David A. Repka, Esq. Atomic Safety and Licensing l U.S. Nuclear Regulatory Commission Board Panel l Washington, D. C. 20555 U.S. Nuclear Regulatory Comm.
L Washington, D. C. 20555
- By Federal Express
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o 6o Nora Bredes Stewart M. Glass, Esq.
Executive Director Regional Counsel Shoreham Opponents Coalition Federal Emergency Management 195 East Main Street Agency Smithtown, New York 11787 26 Federal Plaza, Foom 1349 New York, New York 10278 MHB Technical Associates 1723 Hamilton Avenue James B. Dougherty, Esq.
Suite K 3045 Porter Street, N. W.
San Jose, California 95125 Washington, D. C. 20008 l
1 ,
Katla 4. Letsche KIRKPATRICK, LOCK RT, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N. W., Suite 800 Washington, D.C. 20036 DATED: October 3, 1983 d
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