ML20148L902
| ML20148L902 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/28/1988 |
| From: | Missal M KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#288-5980 OL-3, NUDOCS 8804050031 | |
| Download: ML20148L902 (7) | |
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I S9 M RELATED CORRESPONDENOt 00CMETED March 2895t1988 28 MM 30 P2:j2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Boarf[CK i I
BRANCH
)
In the Matter of
)
)
Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY
)
(Emergency Planning)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
=
.)
SUFFOLK COUNTY'S SUPPLEMENTAL ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LILCO'S EMERGENCY BROADCAST SYSTEM Suffolk County hereby supplements its responses to LILCO's First Set of Interrogatories and Requests for Production of Documents regarding LILCO's Emergency Broadcast System, dated February 24, 1988 ("First Request").
I.
GENERAL RESPONSE Suffolk County gives the same general responses and objections that it made in response to LILCO's First Request.
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o II.
SUPPLEMENTAL ANSWERS TO INTERROGATORIES AND DOCUMENT REOUESTS Identification of Witnesses LILCO Interrocatory No. 1
.l.
Please identify each witness Intervenors. expect to call to testify on any factors concerning EBS contentions.l.A, 1.B, l.C, and 2.A, admitted by the Board in its February 22, 1988 Order.
For each witness, other than experts, that Intervenors expect to call, state the subject matter on which he is expected to testify and the substance of the facts to which he is expected to testify.
For each witness that Intervenors expect to call as an expert witness, state the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expected to testify, and the summary of the grounds for each such opinion.
Answer.
On March 18, 1988, the County identified Charles G.
Perry, III as a potential witness in the remanded EBS proceeding.
Mr. Perry will likely testify concerning the coverage of LILCO's proposed EBS.
As Mr. Perry made clear during his deposition on March 23, 1988, he has only recently begun to study and analyze LILCO's EBS, including its coverage.
Therefore, at this time, Mr. Perry has not formed any specific opinions or conclusions concerning LILCO's EBS coverage.
I LILCO Interroaatory No. 2 l
2.
For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional qualifications.
I Answer.
A copy of Mr. Perry's resume was produced to LILCO l
on March 18, 1988, and again on March 25, 1988.
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4 LILCO Interroaatory No. 3 3.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on any matter concerning the adequacy and coverage capabilities of radio stations and, more specifically, the adequacy under NRC regulations of any EBS station or network intended to be used in the event of any nuclear or non-nuclear emergency to communicate emergency information to the public.
Answer.
Mr. Perry aas not appeared as a witness in any other proceeding on the subject topics.
LILCO Interrocatory No. 4 4.
Please provide a copy of any prefiled testimony listed in response to Interrogatory 3 above.
Answer.
Seg Answer to Interrogatory No. 3 above.
LILCO Interrocatory No. 5 5.
Please identify all articles, papers, and other documents authored or coauthored by each witness on the subject of the adequacy and coverage capabilities of radio stations and, more specifically, the adequacy under NRC regulations of any EBS station or network intended to be used in the event of any nuclear or non-nuclear emergency to communicate emergency information to the public.
l Answer.
Mr. Perry has authored no articles, papers or other documents on the issues relevant to this proceeding.
LILCO Interrocatory No. 6 i
i 6.
Please state whether each witness has prepared,.
l or has had prepared, any written studies, reports, analyses, or other documents with respect to any of the following:
(a)
The broadcast coverage area of any radio station (s);
j (b)
The effect of geography, transmitter i
location, and reception antenna location on i
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s the broadcast signal and coverage capability of any radio station (s); and (c)
The broadcast coverage capabilities required of any EBS radio station or system under NRC or FCC regulations.
Answer.
Mr. Perry has not prepared or had prepared any studies, reports, analyses or other dccuments on the issues relevant to this proceeding.
LILCO Interrocatory No. 7 7.
Unless the answer to Interrogatory 6 above is a simple negative, please identify and provide a copy of each document.
~
Answer.
See Answer to Interrogatory No. 6 above.
OBJECTIONS STATED BY COUNSEL All objections and assertions of privilege, or reference thereto, were stated by counsel.
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E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Hauppauge, New York 11788
~NJ LU Michael S. Sflie r Michael J. Missal KIRKPATRICK & LOCKRART 1800 M Street, N.W.
South Lobby - Ninth Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County March 28, 1988
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00LKETED I
March 28, 1988NPC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,88 MM 30 P2:12 Before the Atomic Safety and Licensina Boapd,gg g g g g gy 00CKEliNG A SrirvlCf.
BRANCH
~)
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'S SUPPLEMENTAL ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LILCO'S EMERGENCY BROADCAST SYSTEM have been served on the following this 28th day of March, 1988 by U.S. mail, first class, except as otherwise noted.
James P.
Gleason, Chairman Mr. Frederick J.
Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James P.
Gleason, Chairman William R. Cumming, Esq.
513 Gilmoure Drive Spence W.
Perry, Esq.
Silver Spring, Maryland 20901 Office of General Counsel Federal Emergency Management Agency Dr. Jerry R.
Kline 500 C Street, S.W.,
Room 840 Atomic Safety and Licensing Board Washington, D.C.
20472 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 W.
Taylor Reveley, III, Esq.
Hunton & Williams Fabian G. Palomino, Esq.
P.O.
Box 1535 Richard J.
Zahnleuter, Esq.
707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol Albany, New York 12224 1
b Joel Blau, Esq.
Anthony F.
Earley, Jr.,
Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq.
Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L.
F.
Britt Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S.
Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 Alfred L.
Nardelli, Esq.
Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 3-118 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq.
New York State Energy Office Edwin J.
Reis, Esq.
Agency Building 2 Office of the General Counsel Empire State Plaza U.S. Nuclear Regulatory Comm.
Albany, New York 12223 Washington, D.C.
20555 David A.
Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 a-Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 m
Michael J. Missal Ng KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 By Telecopy 4
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