ML20148U545

NRC Staff Response to Suffolk County First Set of Interrogatories & Requests for Production of Documents Dated 880104.* W/Certificate of Svc.Related Correspondence

ML20148U545
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/22/1988
From:	Hogan R Office of Nuclear Reactor Regulation
To:	SUFFOLK COUNTY, NY
Shared Package
ML20148U456	List: ML20148U545
References
OL-3, NUDOCS 8802040053
Download: ML20148U545 (6)

Text

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Attachment A' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )

)

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) ) '

NRC STAFF RESPONSE TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS DATED JANUARY 4,1988 INTERROCATORIES AND DOCUMENT REQUESTS Interrogatory 1:

Identify each person whrn FBR and/or the WC Staf f e>pects to call as an expert or non-expert witness during the remand proceeding on Contention 25.C and state the subject matter on which each is eyected to testify.

Answer 1 ^

i The Staf f does not expect to call any witness during the renand proceeding m Contention 25.C.

Interrogatory 2:

Describe the mploynent history, educational background, emerience, and professiona l qual i ficat ions of each person identi fied in response to Interrogatory 1.

t Answer 2 See Response to interrogatory 1, above.

j 8802040053 890122 PDR ADOCK O WPDR 322 G

l

, Interrogatory 3:

Identi fy try date, Iocation ard proceedirg, alI prior testirrony before any judIcia1, achinistratIve, or iegisIatIve body, Including deposition testimony, ccocernirg emergency preparedness, Including the irrpiunentabilIty of erergency preparedness plans and, in particular, protective actions for school children, given by each of the persons identified in response to Interrogatory 1.

Answer 3 See Response to Interrogatory I, above.

Interrogatory 4:

Ident i fy al l MC Sta f f or FBM pe rsonne l , ard a l l trenbers o f the FB%

Reg iona l Assis tance Cmmi t t ee, including consultants thereto, who have reviewed or participated in any way in activities concerning LitID's schools evacuation preposal (includirg, wi thout l irni ta t ion, prepara t ion, review, negot iations or amroval of LitfD's proposal; preparation or review of the recruitment, cpalifications or training of LILCD mployees relied upon by LILCD to inplement its school evacuation proposal; or discussions concerning LILCD's schools evacuation proposal), ard with respect to each, describe such participation and activities.

Answer 4 The Staff has not received LI LCD's schools evacuation plan which is e@ected to be in supplanent 9 to the Emergency Plan. Therefore, no MC Staf f personnel have reviewed or participated in any activity concerning LILCD's schools evacuation plan.

Interrogatory 5 :

Ident i fy a l l MC Sta f f or FB% personne l , and a l l trmbers and Cha i rmen of the FB% Reg iona l Ass i s t ance Cctrmi t tee , including consultants thereto, who are expected to participate in the review of LlLCD's schools evacuation proposal, ard state when such review is to take place.

Answer 5 The Staf f cannot now identi fy who would review or when a review would take place of LILCD's schools evacuation plan until that plan is setrii t ted to the NC and/or FBR for review.

, Interrogatory 6:

Identify every agency, organizatlon, group, entity, instItutlon, and individual, other than those identi fied in Interrogatory 4, who participated in, reviewed, discussed, or received correspondence or doctments concerning LI LCD's schools evacuation proposal. With respect to each organization identified, identi fy the person or persons af filiated with that organization who are knowledgeable concerning that organization's participation or activitles, and describe such participaticn and actIvitles. WIth respect to individuals ident I fled, identify the organizatlon or entity which they represent or of which they are nu6ers, and describe their participation and activities. ~

Answer 6 The Staf f has no knowledge of any organiza' Ion which, or individual who, has participated in, reviewed, discussed or received correspondence concerning LILCD's schools evacuation plan.

Interrogatory 7:

Provide copies of all doctments, includir.g correspondence and draf ts:

(a) sent by or on behalf of the MC Staff or RAA to any person and relating to LILCD's schools evacuation proposal; and (b) received frcm any person concerning LILCD's schools evacuation proposal.

Answer 7 The Staf f has no doctments concerning LILID's proposed schools evacuation plan except "LILID's Motion for Surrmary Disposition of Contention 25.C (Role Conflict of School Bus Drivers)," dated October 22, 1987 and doctnents fonmily served to the parties in this proceeding. (As conterplated by the discovery rules, correspondence to and frcm the FFC covering licensing activities are to be found in the MIC doctrent rocm. tb separate ident i fica t ion is recul red. )

i

, 4

. Interroga_ tory 8:

Provide copies of all correspondence to or from, and any other doctrents or information sent by or on behalf of the MC Staff or FEA%, to, or received frm1, LILCD, or any federal agency. federal personnel, or contractor thereof, concerning LilID's schools evacuation proposal .

Answer 8 See response to interrogatory PAnber 7 above.

Interrogatory 9:

i-Provide copies of any docments of any kind relating to LILCO's schools evacuation proposal and not previously produced, incitxfirsj, by way of exanple only, draf ts, notes, and correspondence, whether produced or ger.erated by the MC Staf f, FEhW, LILCD, LBO, or others.

Answer 9 '

See response to Interrogatory Ntnber 7 above. ,

These NRC Staff responses to Suffolk's Interrogatories have been made by me, Rosemary T. Hogan. I am employed by the NRC in its ,

L Emergency Preparedness Branch of the Office of Nuclear Reactor Regulation. In the performance of my dutles I am responsible for monitoring the LILCO amergency plan and its review insofar as the NRC Staff is involved. I hereby affirm, subject to the penalty of perjury, that the foregoing responses are true and correct to the best of my '-

knowledge and beilef.  !

bhw bu Rosemapp T. Hogan l

January g 1988 l

i i

CXKETEP

'JS NK UNITED STATES OF A7.'EP.lCA NUCLEAR REGULATORY COMMISSION g gq gg BEFORE THE ATOMIC SAFETY AND LICENSING @OARD Sicht IA,a uvut orG A SERVICE ORANCH in the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-32 2-O L-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

CERTIFICATE OF SERVICE i hereby certify that copies of "NRC STAFF RESPONSE TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR j PRODUCTION OF DOCUMENTS DATED JANUARY 4, 1988" in the j ebove-captioned proceeding have been served on the following by deposit in the United States mall, first class or, as indicated by an asterisk,  ;

through deposit in the Nuclear Regulatory Commission's internal mall system, this 22nd day of January 1988.

James P. Gleason, Chairman

• Joel Blau, Esq.

Administrative Judge  !'

4 Director, Utility Intervention Atomic Safety and Licensing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue i Washington, DC 20555 Albany, NY 12210  :

Jerry R. Kline* Fabian C. Palomino, Esq.

Administrative Judge Special Ccunsel to the Covernor 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.

i Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service 1 2 U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, DC 20555 Albany, NY 12223

, Philip McIntire W. Taylor Reveley ill, Esq.

Federal Emergency Management Donald P. Irwin, Esq.

. Agency Hunton f, Williams 26 Federal Pfara 707 East Main Street i Room 1349 P.O. Box 1535 i New York, NY 10278 Ricirond, VA 23212  :

Douglas J. Hynes, Councilman '

Town Board of Oyster Bay l Town Hall Oyster Bay, New York 11771 l

1 ,

i

. I Stephen R. Latham, Esq. Herbert H. Brown, Esq.

Twomey, Lathbm & Shea Lawrence Coe Lanpher, Esq.

. Attor'ocys at Law Karla J. Letsche, Esq.

33 West Second Street Kirkpatrick & Lockhart Riverhead, NY 1i901 South Lobby - 9th Floor 1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel

• U.S. Nuclear Regulatory Cotamission Jay Dunkleberger

%ashington, DC ?0555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panu!* Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.

Martin Bradley Ashare, Esq. General Counsel Suffolk County Attorney Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street. SW Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq.

North Shore Committce Attorney General of the State P.O. Box 231 of New York Wading River, NY 11792 Attn: Peter Blenstock, Esq.

Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center 195 East Main Street Room 46-14 Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr. William R. Cumming, Esq.

General Counsel Office of General Counsel Long Island Lighting Company Federal Emergency Management 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW Washington, DC 20472 Dr. Robert Hoffman Long Island Coalition for Safe Docketing and Service Section*

Living Office of the Secretary P.O. Box 135$ U.S. Nuclear Regulatory Commission Massapequa, NY 11758 Washington, DC 70555 Alfred L. Nardelli, Esq. Barbara Newman New York State Department of Law Director, Environmental Health 120 Broadway Coalition for Safe Living Room 3-118 Box 944 New York, NY 10271 Huntington, New York 11743 b Y ad Charles A. Barth Counsel for NPC St6ff