ML20148L918

NRC Staff First Set of Interrogatories to Suffolk County,Ny State & Town of Southampton Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence

ML20148L918
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/31/1988
From:	Matt Young NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-5975 OL-3, NUDOCS 8804050036
Download: ML20148L918 (5)

Text

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UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '88 APR -1 P3 :31 RCE G 51 Jt.iAr ,

in the Matter of ) OCKEliNu 4 %:n BPANCH P )

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

l Unit 1) )

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NRC STAFF FIRST SET OF INTERROGATORIES TO SUFFOLK COUNTY, NEW YORK STATE, AND THE TOWN OF SOUTHAMPTON REGARDING CONTENTIONS 1-2, 4-8 AND 10 h.

The NRC Staff, pursuant to 10 C.F.R. 55 2.740 and 2.740b, serves the following interrogatories to Suffolk County, New York State and the

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Town of Southampton ("Intervenors") to be answered in writing under f oath or affirmation within 14 days. Each Interrogatory shall be answered separately and fully and shall include all pertinent information available to

! Intervenors, their officers , directors, members, employees, advisors, representatives, or counsel, based upon the personal knowledge of the j

person answering.

In addition, intervenors are requested, pursuant to 10 C.F.R.

5 2.740(e), to supplement their responses as necessary with respect to the identity of each person expected to be called as an expert witness at hea ring , the subject matter on which the witness is expected to testify and the substance of that testimony.

ALL REALISM CONTENTIONS (CONTENTIONS 1-2, 4-8 AND 101

1. (a) Do you intend to call any witness on any of the Contentions 1, 2, 4, 5, 6, 7, 8, or 10?

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(b) If the answer to (a) is yes, which contentions?

l f (c) What is the substance of the testimony which will be presented i

on these contentions?

! (d) Do you know the identity of such witness?

(e) If the answer to (d) is yes, identify each witness by name and f

address and provide their professional credentials and resume, f *(f) What is the substance of the testimony of each witness?

(g) What is each witness' qualification to .estify?

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2. (a) Do you intend to subpoena any witnesses?

) (b) What persons do you intend to subpoen:?

(c) What subjects do you intend to ask them about?

(d) What information do you intend to elicit by such examination?

3. (a) What documents do you intend to subpoena for the "reallsm" g

hearings?

f (b) Through which witness will you introduce such documents?

4. (a) Do you contend that LILCO's emergency plan supplemented by a best effort response by the affected governments will not meet the adequacy standards with respect to each matter at issue?

See Memorandum and Order, February 29, 1988, at 3-4.

(b) Specify each and every manner in which you maintain that LI LCO's emergency plan supplemented by a "best effort" a response by affected governments does not meet the adequacy i standards with respect to each matter at issue.

l (c) Specify each and every way in which the matter (s) identified in I

i (b), above, prevents a reasonable assurance finding from being made.

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} 5. Do you intend to present "a positive case" at hearing in response to a prima facie case presentation by LILCO on the contentions? See Memorandum and Order, February 29,1988, at 3-4.

6. Identify all persons who participated in, or substantially contributed I

[ to, the preparation of the responses to these Interrogatories.

Respectfully submitted, o

Mit i . Young Cou I for NRC Staff j Dated at Rockville, Maryland i this 31st of March 1988 h

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0 UNITED STATES OF AMERICA DOLKEiED NUCLEAR REGULATORY COMMISSION N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 118 APR -1 P3:31 0FHCE o' Nth r 00CKETm3 4 ney!a, in the Matter of )

SRANCH

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-O L-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF FIRST SET OF INTERROGATORIES TO SUFFOLK COUNTY, NEW YORK STATE, AND THE TOWN OF SOUTHAMPTON REGARDING CONTENTIONS 1-2, 4-8 AND 10"

. In the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an

asterisk, through deposit in the Nuclear Regulatory Commission's internal

( mail system or, as indicated by double asterisks, express mall, this 31st day of March 1988.

James P. Gleason, Chairman

• Joel Blau, Esq.

I Administrative Judge Director, Utility intervention Atomic Safety and Licensing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue

Washington, DC 20555 Albany, NY 12210 Jerry R. Kline* Fabian C. Palomino, Esq.**

Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 Frederick J. Shon* Jonathan D. Feinberg, Esq.

s Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, DC 20555 Albany, NY 12223

} Philip McIntire W. Taylor Reveley lil, Esq.

! Federal Emergency Management Donald P. Irwin, Esq.**

l Agency Hunton 6 Williams i 26 Federal Plaza 707 East Main Street

} Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212 i

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Douglas J. Hynes, Councilman Dr. W. Reed Johnson Town Board of Oyster Bay 115 Falcon Drive, Colthurst Charlottesville VA 22901 i Town Hall

( Oyster Bay, New York 11771 l

Stephen B. Latham, Esq.** Herbert H. Brown, Esq.

}

Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.**

Attorneys at Law Karla J. Letsche, Esq.

l Kirkpatrick & Lockhart

{* 33 West Second Street Riverhead, NY 11901 South Lobby - 9th Floor 1800 M Street, NW

! Washington, DC 20036-5891 l

Atomic Safety and Licensing Board Panel

• r U.S. Ifuclear Regulatory Commission Jay Dunkleberger i Washington, DC 20555 New York State Energy i Office

! Atomic Safety and Licensing Agency Building 2 i Appeal Board Panel

• Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 l Washington, DC 20555 d Spence W. Perry, Esq.

Martin Bradley Ashare, Esq. General Counsel l Federal Emergency Management

! Suffolk County Attorney i H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW l Hauppauge, NY 11788 Washington, DC 20472 i

Anthony F. Earley, Jr. Dr. Monroe Schneider

! General Counsel North Shore Committee

! Long Island Lighting Company P.O. Box 231 i 175 East Old County Road Wading River, NY 11792

) Hicksville, NY 11801 Ms. Nora Bredes Dr. Robert Hoffman Shoreham Opponents Coalition Long Island Coalition for Safe 195 East Main Street Living Smithtown, NY 11787 i P.O. Box 1355 Massapequa, NY 11758 William R. Cumming, Esq.

! Office of General Counsel i Alfred L. Nardelli, Esq. Federal Emergency Management New York State Department of Law Agency l 500 C Street, SW l

120 Broadway

, Room 3-118 Washington, DC 20472 1 Docketing and Service Section* Barbara Newman Office of the Secretary Director, Environmental Health U.S. Nuclear Regulatory Commission Coalition for Safe Living Washington, DC 20555 Rox 944 Huntington, New York 11743 Mit21 A

• F CounN. for (oung NRC Staff

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