ML20101S971
| ML20101S971 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/01/1985 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-372 OL-3, NUDOCS 8502050745 | |
| Download: ML20101S971 (15) | |
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LILCO, Februmry 1, 1985
,REATED CORRESPONW
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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I]EJ:
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~Before the Atomic Safety and Licensin~a: Board' N1 :50
.In the Matter of-
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LONG ISLAND LIGHTING COMPANY-
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Docket No. 50-322-OL-3
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(Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
LILCO'S OPPOSITION TO SUFFOLK COUNTY DISCOVERY REQUESTS CONCERNING USE OF NASSAU COLISEUM AS A RECEPTION CENTER, MOTION _FOR PROTECTIVE ORDER AND REQUEST FOR EXPEDITED BOARD RULING 4
LILCO received last night, without prior notice, a four-page letter from counsel for Suffolk County (Attachment 1),.containing-16-separately numbered discovery requests and attaching a notice t
of deposition for Elaine Robinson, LILCO's affiant in its January 11 motion to. reopen the record on use of the Nassau Coliseum as a-reception center.1/
Similar letters were sent by counsel for Suffolk County to the NRC Staff (Atta'h3eit 2) and FEMA (Attach-ment'3).2/
1/
For purposes of this paper, and'so as to avoid delay LILCO considers Suffolk County's letter, though not so labeled, as a-request for document produ'ction under S 2.741'.
7 l
- 2/
The -letter to FEMA counsel' recites his 'agreemerit to make i
FEMA personnel ~available'for deposition. lLILCO counsc.L under-l stands that'this " agreement" was obtained by telephone prior to FEMA ' counsel's receipt; of the letter ' and ~before FEMA ~ counsel l
was informed that Suffolk' County was' filing, in addition, i,
L document requests upon FEMA.
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l LILCO believes that these discovery requests fundamentally
. distort the limited reopening contemplated by the Board's January 28 Orde'r.
That Order permitted any party to produce its own response, in accordance with the Board's guidance, to LILCO's prima facia casefby. February 18 -- not to do so.only after obtain-
.ing extensive discovery.. The Order did not provide for any dis-covery on LILCO's' January 11 submissions, nor d'id Suffolk County ever1ask for such discovery in its January 18 response to LILCO's
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' January 11~ papers.2/
The Board's Order is consistent with other Commission. summary procedure, e.a.,
S 2.749 (no discovery-as of.
right in connection with summary disposition motions) and with otherfrecent usages in this proceeding (e.a., use of summary' pro-cedure on remand from ALAB-788)'.A/
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3/
.Suffolk County asked only for the opportunity toasubmit.
its own evidence and to cross-examine'LILCO's presentation.
Suffolk County and State of New York Opposition-to LILCO's i
Motion to Reopen the Record, January 18, 1985, at'49.
n 4/
In the. general safety phase of this case,.the Appeal Board remanded three-issues.to tha'Brenner. Licensing-Board in ALAB-788 (October 31, 1984).
That Board'followed a procedure'very 4
similar to that ordered by this' Board on January 28:
it or-i dered.the parties each to provide their-views'on the merits of each of these. issues, cn1 the basis of information available to l
them.
LILCO and the Staff provided pleadings.and affidavits; Suffolk County stated that iticould not comment substantively _
.without further time'and opportunity to review various docu-ments..On the basis of~those papers and one conference'of-counsel, the Board ultimately dismissed the.three remanded is-
. sues.
Memorandum and Order Ruling on. Remand Issues, LBP-84-53, November 30, 1984 (Docket 50-322-OL); Order Terminating Further a
~ Proceedings on Remand Issues, December-20,fl984 (Docket 50-322-OL).
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.. 1 Secondly, even if this Board were to conclude that it had not i
I intended categorically to exclude discovery before February 18, 1985, the scope of Suffolk County's requests sweeps far beyond the Various designation'of the Nassau Coliseum as a reception center.
of the requests to LILCO involve, in whole or.in part, (1) discus-sions or. drafts underlying agreements or documents which speak for i
themselves (requests' 1, 2, 3, 9, 10,-15), (2) issues already liti-gated or outside the scope of contentions (e.a.,
requests 4, 5, 6, 7, 13, 14, 16)', and other issues of dubious relevance or material-ity.-
In addition, the requests purport to seek documents, and drafts of documents, not in LILCO's possession or control (i.e.,
documents and drafts from "any non-LILCO organization which may'be expected to respond to a radiological emergency at Shoreham").
Requests 2 and 3 to'the NRC Staff and FEMA are of a similarly sweeping nature.
Literal compliance with them would implicate issues far beyond the scope of this reopening, would be extra-ordinarily burdensome for LILCO, and command that which cannot be
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- produced, i.e., documents beyond LILCO's control.
The Board's prompt attention to this matter is necessary to avoid'any delay in this proceeding.- Suffolk County has requested depositions beginning next Wednesday, February 6.. Further, if the Board. permits-the requested discovery, LILCO will have to under-take to comply with it immediately in order to avoid imperiling the February 18 reply date.
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For the reasons stated above, LILCO believes the Board should it'is deny Suffolk County's requested discovery on the basis that forth in the not contemplated by the summary procedures set Board's - January-26 Order.
LILCO also requests that the Board rule on this issue as soon as possible,'by telephone today if possible.
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In the event the Board wishes to examine the discovery requests individually before ruling, LILCO requests either a telephone con-ference or live hearing at the earliest possible time, either this afternoon or Monday if possible.E/
Respectfully submitted, LONG ISLAND LIGHTING COMPANY-h 4
./,
~-s s Donald P.
Irwin James N. Christman Kathy E.B. McCleskey Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:
February 1, 1985 LILCO, by requesting a protective order, intends only to
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comply with the form of the. regulations and not to set off a
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new round of responsive pleadings.
Counsel for Suffolk County have been told by telephone to expect this response and have been served with it.by telecopier.
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(202) 452-7022 vIA TzLacOPY James N. Christman, Esq.
Rathy E. 3. McCloskey, Esq.
Runton & Williams 707 East Main street P.O. Box 1535 Richmond, Virginia 23212
Dear Jim and Kathy:
Pursuant to the Board's Memorandum and Order of January 28, 1985 requiring us to submit by February 18 testimony or affidavits on the issues raised by LILCO's Motion to Roopen the Record, we request that LILCO furnish the following information pertai as a relocation center as soon as possible, but not later than This will provide the minianum time necessary February 5, 1985.
to review the requested information prior to the deposition of Elaine D. Robinson, which we have noticed for Thursday, February 7, j
1985.
All documents relating to discussions or meetings 1
1.
between or among representatives of LILCO and the Hyatt Manage-ment Corporation of New York, Inc. concerning LILCO's proposed j
use of the Nassau Veterans Memorial Coliseum ("Nassau Coliseum"),
including, but not limited to, the discussions referenced in Ms.
10, 1985 Af fidavit (1 2) and any other dis-Robinson's January cussions, meetings, or correspondence relating to the letter from William J. Catacosinos to E. B. Sumerlin, Jr. dated
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September 25, 1984 (Robinson Affidavit, Attachment.1).
All documents relating to the Nassau County Executive's 2.
"advi(ca] (to) the General Manager of the Coliseum that he l
center in-approved the use of the Coliseum as a [ relocation]the event o i
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KIRXPATRICK & LOCKNART James N.-Christman, Esq.-
Kathy E. B. McCloskey,-Esq.
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Page Two
-January 31, 1985 including, but not limited to, cor-(Robinson Affidavit, 1 3),
respondence, or documents relating to discussions or meetings, between or among rspresentatives of LILCO and the carning LILCO's proposed luse of the Nassau Coliseum.
All documents relating to discussions or meetings b'e' tween f
'the American Red' Cross, including, but not limited t 3.
(1 4) and any.
cussions referenced in'Ms. Robinson's Affidavit other-correspondence, discussions, or meetings relating to the to Frank matters' referred to in the letter from Matthew C. Cordaro(Robinson Affid M. Rasbury dated October 23, 1984
- 3).
All documents relating to the ordinary business use ofs the Nassau Coliseum and its availability for use by L 4.
Shoreham.
Copies of a calendar and description of events scheduled and/or held at the Nassau Coliseum during the past five years.
5.
5
-A calendar and description of events scheduled for 198,
6.
and 1986.
A copy of the agreement or contract form generally used by Hyatt Management Corporation in permitting the use of the 7.
l Nassau Coliseum.
All documents relating to the physical layout of and facilities available in the Nassau Coliseum, including, but not 8.
limited to, information about the number, size, dimensions, and l-locations of lockers / dressing rooms,.. toilet and shower facilities, i
sinks, storage areas, common areas, telephones, and food prepara-tion areas.
All documents relating to the Nassau County Exec 9.
f an to the fullest in making the' Coliseum available in the event o "assur(ance).
(Robinson Affidavit, 1 7), including, but not-limited to, correspondence, or documents rela accident at Shoreham" fficials the Nassau. County Executive and/or other Nassau-County o i
or-agencies concerning LILCO's proposed use of the Nassau' Col seum l
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l KDUCPATRICK 6. LOCKHART James N. Christman, Esq.
Kathy E. B. McCloskey, Esq.
Page Three January 31, 1985 All correspondence of any kind relating to LILCO's pro-posed use of the Nassau Coliseum as a relocation center, including,
.10.
but not limited to, all drafts of the September 25, October 1, October 23, and December 31, 1984 letters attached to the Robinson Affidavit-(Attachments 1, 2, 3 and 6, respectively).
All documents relating to the informa' tion in the Robinson Affidavit regarding the time required to clear the Coliseum and 11.
-its parking lot should.am accident at Shoreham occur while a " sport-ing or entertainment event" were-in progress at the Coliseumincluding, but (Robinson Affidavit, t 7),
circumstances surrounding and assumptions underlying such informa-tion.
4 All documents, including, but not limited to, any survey, 12.
report or study, which relate to the parking lot capacity of the Nassau Coliseum, and access to and from the' Coliseum from the EPZ, (for example, from west of the EPZ to the areas outside the EPZand the roadways and streets surrounding and adjacent Coliseum),
to the Coliseum.
All documents relating to LILCO's proposal to direct 13.
evacuees from the Nassau Coliseum to so-called " congregate care (where evacuees would be housed), including, but not centers" limited to, the distances and locations of such congregate care l
centers from the Nassau Coliseum, proposed travel routes, and l
proposed method (s) of transporting evacuees.
l All documents relating to the time and types and I
14.
numbers of personnel necessary to monitor and decontaminate all l
evacuees at one facility or at the Nassau Coliseum.
All documents and correspondence of any kind between or 15.
among representatives of LILCO and the~NRC Staff and/or FEMA concerning LILCO's proposed use of the Nassau Coliseum.
All documents relating to the health effects to EPZ 16.
evacuees or to the population of Nassau County or other areas outside the EPZ that could result from LILCO's proposal to use the Nassau Coliseum as a relocation center.
Please construe the term " document" as used-in this request.
to include, but not be limited to, all drafts or final copies of correspondence, comments, reports, notes, minutes, or l
memoranda, Please also construe the term'" document" to include,
-summaries.
KRKPNI1 TICK 6s. LOCKHART James N. Christman, Esq.
Kathy x. 3. McCloskey, Esq.
Page Four January 31, 1985 but not be limited to, documents in the possession or control of LILCO, LERO, LERIO, any representative (including, without limita-or other tion, attorneys and their respective agents and employees) person acting for or on behalf of LILCO, LEDO, or LERIO or at their direction, including, without limitation, any non-LILCO organiza-tion which shy be expected to respond to a radiological emergency at shoreham.
Counsel for New York State has authorised me to inform you that the State joins in this request.
Sincerely, k.
Michael 5. Miller cc Fabian Palomino, Esq.
Bernard M. Bordenick, Esq.
j Stewart M. Glass, Esq.
James B. Dougherty, Esq.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CONNISSION Before the Atomic Safety and Licensing Board
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In the Matter of
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p 14NG ISLAND LIGETING COMPANY f
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(Shoreham Nuclear Power Station,
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f Unit 1)
NOTICE OF DEPOSITION _
PLEASE TAKE NOTICE that Suffolk County and New York State, by counsel, pursuant to 10 CFR 2.740a of the Nuolear Regulatory Commission's Rules of Practice, will take the deposition upon oral examination of Elaine D. Robinson on the subject of LILCO s proposed use of the Nassau Veterans Memorial Coliseum as a such deposition will be taken before a notary relocation center.
l public, or before some other authorized official, at the M. Lee Dennison Building, 8th Floor, Veterans Memorial Highway, Hauppauge, 11788, on the 7th day of February, 1985, at 10:30 a.m.
New York and thereafter until the deposition is completed.
DATED:
January 31, 1985 KIRKPATRICK & LOC 1GGutT By Richael s. Miller Attorneys for Suffolk County 1900 M Street, N.W., Suite 800 Washington, D.C 20036 (202) 452-7022 A984sf L
Palomino, Esq.
Fabian G.
Special Counsel to the Governor of the State of New York
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MTTMAGl. PA 19333 m muse venutsasser omuman (202) 452-7022 VIA TELECOPY Bernard M. Bordenick, Esq.
U.S. Nuclear Regulatory l
Cossaission j
Washington, D.C.
20555 l
Dear Bernie:
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l Pursuant to our telephone conversation earlier today, this j will confirm, with respect to the Board's_ Memorandum and Order of January 28, 1985 granting LILCO's Motion to Reopen the Record'
(" order"), that, at this time, the NRC Staff does not intend to cross-examine LILCo's witness "on the substance of'the designa-tion of the Nassau Vaterans Memorial Coliseum as a relocation center.
." order, at 9.
Nor does the Staff presently intend "to submit direct testimony or other evidence on the merits of LILCO's designation of the Coliseum as a relocation center.
i-Id.
You have advised, however, that FEMA may submit testimony L
6r other evidence on the issues raised by the Board's Order.lf As you know, the Board's Order requires the parties to sub-mit any testimony or affidavits on the issues raised by LILCo's Motion to Roopen the Record by February 18.
In light of the schedule set by the Board, we request that the NRC Staff furnish the following information pertaining to LILCO's proposed use of the Nassau Veterans Memorial Coliseum as a relocation center as soon as possible, but not later than February 5, 1985.
We also request that you immediately inform us if the Staff later decides either to oceduct cross-examination of LILCo's witness or to sub-mit testimony or other evidence on~the issues regarding LILCO's proposal to use the Nassau Coliseum as a relocation center.
If Following our telephone conversation, I was advised by i
Stewart Glass that, at this time, FEMA does intend to submit direct testimony or evidence in the form of affidavits on the LILCO relocation center issues.
Apparently, such testimony or affidavits will be submitted by the same witnesses FEMA has used on other emergency planning issues, i.e., Messrs.
McIntire, Kowieski, Keller and Baldwin.
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KRKPATRICK &, LOCKHART Bernard M. Bordenick, Esq.
Page Two
' January 31, 1985 1.
All documents and correspondence of any kind between or among representatives of the NRC Staff and LILCO and/or FEMA concerning LILCO's proposed use of the Nassau Coliseum.
2.
.All documents relating to the use or proposed use by any licensee, including LILCO, of a relocation center (or other-facility at which all evacuess would be monitored and, if.necessary, decontaminated in the event of a radiological accident) which is 40 or more miles from the licensee's nuclear power plant.
3.
All documenus relating to the health effects to EPZ evacuees or to the population of Nassau County or other areas outside the EPZ that could result from LILCO's proposal to use the Nassau Coliseum'as a relocation center.
Please construe the term " document" as used in this request to include, but not be limited to, all drafts or final copies of memoranda, correspondence, comments, reports, notes, minutes or summaries.
Please also construe the term " document" to include, but not be limited to, documents in the possession or control of the NRC Staff, any representative (including, without limitation, attorneys and their respective agents and employees) or other person acting for or on behalf of the NRC Staff, or at its j
direction or control.
Counsel for New York State has authorized me to inform you l
that the State joins in this request.
i j
Sincerely, j
Michael S. Miller cca Fabian Palomino, Esq.
James N. Christman, Esq.
Kathy E. B. McCloskey, Esq.
Stewart M. Glass, Esq.
James B. Dougherty, Esq.
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ATTACHMENT 3 KIRKPATRICK & LOCKHART too M mast. N.W.
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VIA TELECOPY 4
Stewart M. Glass, Esq.
Regional Counsel j
Federal Emergency Management Agency 26 Federal Plaza, Room 1349 New York, New York 10278
Dear Stewart:
l
. Pursuant to our telephone conversation earlier today, this will confirm, with respect to the Board's Memorandum and order of January 28, 1985 granting LILCO's Motion to Roopen the Record
(" Order"), that, at this time, although FEMA has some questions to ask of LILCO regarding LILCO's reliance on the Nassau County 4
Red Cross, it is unclear whether FEMA will seek to cross-examine LILCO's witness "on the substance of the designation of the Nassau Veterans Memorial Coliseum as a relocation center.
order, at 9.
You indicated, however, that FEMA does intend "to submit direct testimony-or other evidence on the merits of LILCO's designation of the Coliseum as a relocation center.
Id.
In this regard, you advised that such testimony or other avl"dence l
in the form of affidavits would be submitted on FEMA's behalf by the same witnesses FEMA has used on other emergency planning t
i
- issues, i.e., Messrs. McIntire, Kowieski, Keller and Baldwin.
l I advised you that we would want to depose these witnesses as l
- soon as possible.
l' As you know, the Board's order requires the parties to submit any testimony or affidavits on the issues raised by LILCO's Motion to Roopen the Record by February 18.
In light of'the schedule set by the Board, we request that FEMA furnish the following information pertaining to LILCO's proposed use of-the Nassau Veterans Memorial Coliseum as a relocation center as soon as possible, but not later than February 5, 1985.
We also request that you inform us promptly of the availability of the FEMA witnesses.
We are hopeful that their deposition can be scheduled next week, either for the day before or after the deposition of LILCO's witness Elaine D. Robinson, which we have noticed for
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a KRKPATRICK &. LOCKHART Stewart M. Glass, Esq.
Page Two L
January 31, 1985 f
i Thursday, February 7.
In this regard, you have just advised me that Wednesday, February 6 appears to be available as a date for deposing FEMA's witnesses, and have promised to get back to me tomorrow to confirm this.
Perhaps at that time we can discuss your suggestions that the depositions of Ms. Robinson and FEMA's i
witnesses be scheduled for the same' day and held at your offices l
in New York City.
1.
All documents and correspondence of any kind between or among representatives of FEMA and the NRC Staff and/or LILCO concerning LILCO's proposed use of the Nassau Coliseum.
i i
2.
All documents relating'to the use or proposed use by any licensee, including LILCo, of a relocation center (or other facility at which all evacuees would be monitored and, if necessary, decontaminated in the event of a radiological accident) which is
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40 or more miles from the licensee's nuclear power plant.
j 3.
All documents relating to the health effects to EPZ evacuees or to the population of Nassau County or other areas outside the EPS that could result from LILCO's proposal to use l
the Nassau Coliseum as a relocation center.
Please construe the term " document" as used in this request to include, but not be limited to, all drafts or final copies of memoranda, correspondence, comments, reports, notes, minutes, or summaries.
Please also construe the term " document" to include, I
but not be limited to, documents in the possession or control of i
FEMA, any representative (including, without limitation, attorneys i
and their respective agents and employees) or other person acting j
for or on behalf of FEMA, or at its direction or control.
Counsel for New York State has authorized me to inform you j
that the State joins in this request.
j Sincerely, Michael S. Miller cc:
Fabian Palomino, Esq.
James N. Christman, Esq.
Kathy E. B. McCloskey, Esq.
Bernard M. Bordenick, Esq.
James B. Dougherty, Esq.
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d LILCO, February 1, 1985 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
(Emergency Planning Proceeding)
Docket No. 50-322-OL-3 I certify that copies of LILCO's OPPOSITION TO SUFFOLK COUNTY DISCOVERY REQUESTS CONCERNING USE OF NASSAU COLISEUM AS A RECEPTION CENTER, MOTION FOR PROTECTIVE ORDER AND REQUEST FOR EXPEDITED BOARD RULING were served this date upon the following by first-class mail, postage prepaid, or (as indicated by an asterisk) by hand or telecopier, or (as indicated by two aster-isks) by Federal Express.
Secretary of the Commission James A. Laurenson, Chairman
- U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Washington, D.C.
20555 Board 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 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.*
Oreste Russ'Pirfo, 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.
Bethesda, MD 20814 Stewart M. Glass,'Esq.**
Regional Counsel Federal Emergency Management Donna Duer, Esq.*
Law Clerk Agency Atomic' Safety and Licensing 26 Federal Plaza, Room 1349
= Board Panel New York,-New York 10278 U.JS. Nuclear Regulatory Commission Stephen B. Latham, Esq.**
East-West Tower, North Tower John F. Shea, Esq.
4350 East-West Highway Twomey, Latham & Shea Bethesda, MD 20814 33 West Second Street P.O. Box 398 Riverhead, NY 11901 l
l 1
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4.
Fabian G. Palomino, Esq.**
Ralph Shapiro, Esq.**
Special Counsel-to the Cammer & Shapiro P.C.
' Governor 9 East 40th Stre Executive Chamber.
New York,.New Yor,.
10016 Room 229 State Capitol James B. Dougherty, Esq.**
Albany, New York 12224 3045 Porter Street Washington, D.C.
20008 -
Herbert H. Brown, Esq.*
Lawrence Coe Lanpher, Esq.-
Jonathan D.
Feinberg, Esq.
Christopher M. McMurray, Esq.
New York State Public Service Kirkpatrick & Lockhart Commission, Staff Counsel 8th Floor 3 Rockefeller Plaza 1900 M Street, N.W.
Albany, New York 12223 Washington, D.C.
20036 Spence W.
Perry, Esq.*
MHB Technical Associates Associate General Counsel 1723 Hamilton Avenue Federal Emergency Management Suite K Agency
~
San Jose, California 95125 500 C Street, S.W.,
Rm. 840 Washington, D.C.
'20472 Mr. Jay Dunkleberger New York State Energy Ms. Nora Bredes Office Executive Coordinator Agency Builcing 2 Shoreham Opponents' Coalition 4
Empire State Plaza 195 East Main Street Albany, New York 12223 Smithtown, New York 11787 Gerald C. Crotty, Esq.
Martin Bradley Ashare, Esq.
Counsel to the Governor Suffolk County Attorney Executive Chamber H.
Lee Dennison' Building State Capitol Veterans Memorial Highway 1
Albany, New York 12224 Hauppauge, New York 11788 i
~
Donald P.
Irwin Hunton & Williams I
707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED:
February 1, 1985 1
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