ML20150A808

Suffolk County Third Set of Interrogatories & Requests for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence

ML20150A808
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/11/1988
From:	Missal M KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
CON-#188-5837 OL-3, NUDOCS 8803160051
Download: ML20150A808 (11)

Text

,' 6937 PELATED CORRESF$ $ 6

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DOCKETED USNRC March 11, 1988 UNITED STATES OF AMERICA

'88 HM 14 M2:07 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board [0C hi k.

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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)

)

)

SUFFOLK COUNTY'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY REGARDING EMERGENCY BROADCAST SYSTEM Pursuant to 10 CFR SS 2.740b and 2.741, and in accordance with the Definitions and Instructions attached to Suffolk County's First Set of Interrogatories and Requests for Production of Documents, dated February 29, 1988, LILCO is requested by Suffolk County to answer separately and fully, under oath, each of the interrogatories set forth below, and to produce for inspection and copying, at the offices of Kirkpatrick & Lockhart, the documents specified below that are within the possession, custody, or control of LILCo.

INTERROGATORISS AND DOCUMENT REOUESTS 1.

The Cohen and Dippell Engineering Report concerning the field strength measurement survey of radio stations WEZN 8803160051 880311 PDR ADOCK 050DO322 G

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m (FM) and WPLR (FM), dated June 1987 (hereafter "June 1987 Engineering Report") indicates (at page 2) that a rectangular grid of approximately 3 kilometers was used in connection with the field strength measurement tests conducted by Cohen and Dippell.

(a) Why was a grid of approximately 3 kilometers used?

(b) Was any consideration given to using a different size grid?

(c) If so, specify precisely what consideration (s).

(d) If no consideration was given to using a different size grid, explain why this was the case.

2.

The June 1987 Engineering Report (at page 2) notes that 1980 U.S. census data were used to determine the minimum number of measurement locations.

(a) Why were 1980 U.S. census data used?

(b) Why was a 1988 census projection not used?

(c) Was consideration given to using any other census data, including projected population data?

(d) If so, what data?

If not, why not?

3.

The June 1987 Engineering Report (at page 3) states that, based upon a listening test conducted by Cohen and 7ippell, WPLR (FM) provides "a very good signal level throughout the measured area."

What qualitativt and quantitative criteria were used in determining that WPLR (FM) provides "a very good signal level?"

4.

The June 1987 Engineering Report (at page 3) notes that during the listening test, "nothing was heard that suggested any reception problems."

What level or amount of

i-interference would have constituted a "reception problem" for purposes of the Cohen and Dippell report?

5.

The June 1987 Engineering Report (at page 3) notes that field strength measurements were made with a receive antenna elevated 30 feet above ground level.

(a) Why was the receive antenna elevated to a 30 foot elevation?

(b) Was any consideration given to taking any measurements with the receive antenna elevated to a different height?

(c) If so, specify precisely what consideration (s).

(d) Would there have been any variation in the measurements if the receive antenna had been elevated 6 feet above ground level?

(e) If so, what would that variation have been?

6.

The June 1987 Engineering Report (at page 3) notes that field strength measurements were taken with a "horizontally polarized dipole receive antenna."

(a) Why was such an antenna used?

(b) Was any consideration given to using a vertically polarized antenna?

(c) If so, specify precisely what consideration (s)?

7.

What is the ratio of horizontal to vertical polarization from (a) WPLR (FM); (b) WRCN (FM); and (c) WLNG (FM)?

8.

Assuming that the instrumentation used to take the field strength measurements that were reported in the June 1987 Engineering Report was properly calibrated, what is the margin of error -- both in percentage and mV/m -- of the field strength measurements made on radio station WPLR7 Please provide a copy of the calibration report and any

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other documents relating to the June 4, 1986 calibration of the field strength meter referenced at pages 3-4 of the June 1987 Engineering Report.

9.

For every reading provided in the June 1987 Engineering Report, what is the uncertainty due to instrument, antenna and/or other inaccuracies?

10.

Were there any deviations from the FCC regulations contained in Title 47 of the Code of Federal Regulations with. respect to the procedures used in the June 1987 Engineering Report?

If so, please specify each and every such deviation.

11.

(a) With respect to Table VI of the June 1987 Engineering Report, why is the range of readings in the column entitled "Min / Max" 29.4 dBu for Point l?

(b) Identify every factor, reason or basis for such a range.

(c) Is this range possible elsewhere within the area measured by Cohen and Dippell?

12.

With respect to Table VII of the June 1987 Engineering Report, how was the elevation of each point determined?

13.

(a) Can field strength measurements of an FM signal vary depending upon when such measurements are made?

(b) Can such measurements vary during the day and night?

(c) Can such measurements vary during the different seasons of the year?

14.

(a) Can field strength measurements of an AM signal vary depending upon when such measurements are made?

(b) Can such measurements vary during the day and night?

(c) Can 4-

4 such measurements vary during the different seasons of the year?

15.

The Cohen and Dippell Engineering Report concerning the computed signal contours for radio stations WICC, WELI, WGLI, WRHD, WLIM, WLNG AM and FM, WPLR and WRCN, dated September, 1987 (hereafter "September 1987 Engineering Report") references "interference-free contours."

(a) Identify how the interference-free contour for daytime reception of each FM station in LILCO's EBS network would vary from the interference-free contour for nighttime reception.

(b) Identify how the interference-free contour for daytime reception of each AM station in LILCO's EBS network would vary from the interference-free contour for nighttime reception.

Please provide a copy of any and all documents referencing such variances.

16.

Identify any changes or modifications made to the FCC data used to compute the interference-free contours included in the September 1987 Engineering Report.

Please provide a copy of any and all documents referencing in any way such changes or modifications.

17.

Identify all FM stations that cover any part of the EPZ at nighttime, and designate the specific parts of the EPZ that are covered.

Identify all AM stations that cover any part of the EPZ at nighttime, and designate the specific parts of the EPZ that are covered.

Please provide a copy of any documents relating to such FM and/or AM coverage.

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18.

Please provide a copy of any maps of the EPZ that show only the interference-free contours of AM stations'in LILCO's EBS network.

19.

(a) Did any person, including but not limited to Cohen and Dippell, recalculate the signal contours depicted in the September 1987 Engineering Report that, according to the Affidavit of Ralph E. Dippell, Jr. (Attachment 9 to LILCO's Nov. 6 Summary Disposition Motion), were generated from FCC-recognized signal strengths in the radio stations' license files?

(b) If so, please specifically identify what recalculations were made.

(c) Please provide a copy of any documents referencing such recalculations.

20.

(a) How far beyond the signal contours depicted in the September 1987 Engineering Report does LILCO expect the AM radio stations in the EBS network to be heard?

(b) How far beyond the signal contours depicted in the September 1987 Engineering Report does LILCO expect the FM stations in the EBS network to be heard?

(c) Please specify the basis for LILCO's opinion regarding this interrogatory.

21.

Identify any studies, analyses and/or tests that have been performed or conducted with respect to whether the tone j

i alert receivers provided the radio stations in LILCO's EBS network can, in fact, be activated by WPLR's signal.

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provide a copy of any and all documents concerning su.h studies, analyses and/or tests.

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22.

Identify any studies, analyses and/or tests that have been performed or conducted with respect to whether the tone alert radios provided by LILCO to schools, hospitals, special facilities, large employers, and others can, in fact, be activated by WPLR's signal.

Please provide a copy of any and all documents concerning such studies, analyses and/or tests.

23.

What is the minimum signal strength necessary to trigger and/or activate the tone alert receivers provided the radio stations in LILCO's EBS network?

24.

(a) Identify any studied, tests and/or analyses of LILCO's EBS network that were contemplated.

(b) Identify any studies, tests and/or analyses of LILCO's EBS network that were started or initiated, but not completed or finalized.

25.

(a) With respect to Figures 1 and 2 of the September 1987 Engineering Report, what, if any, assumptions were made concerning the ground conductivity of Long Islar.u?

(b) What, if any, assumptions were made concerning the conductivity of Long Island Sound?

26.

Identify the back-up or alternative power source for each of the radio stations included in LILCO's EBS network.

Please provide a copy of any and all documents referencing or mentioning in any way such back-up or alternative power sources.

27.

Do all radio stations in LILCO's EBS network have a person capable of operating the station on the premises of the b'

station at all times?

Identify any stations that do not,

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and for each-such station identify the times when there is not a person on the premises capable of operating the station.

Respectfully submitted, E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 m

Michael S."Miller ~

Michael J. Missal KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C.

20036-5891 Attorneys for Suffolk County EWRM%SPONDENQ3 00LMETE0 March 11, 1988%E UNITED STATES OF AMERICA g MR j4 Pl2:07 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Boardfrict g g;g w, 00CMEONG & SEkvici; 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 THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY REGARDING EMERGENCY BROADCAST SYSTEM have been served on the following this lith 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

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s Fabian G. Palomino, Esq.

W. Taylor Reveley, III, Esq.*

Richard J. Zahnleuter, Esq.

Hunton & Williams Special Counsel to the Governor P.O. Box 1535 Executive Chamber, Rs. 229 707 East Main Street State Capitol Richmond, Virginia 23212 Albany, New York 12224 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 County Road Riverhead, New York 11901 Wading River, New York 11792 Docketing and Service Section Office of the Secretary U.S. 'fuclear Regulatory Commission Ms. Nora Bredes 1717 H Street, N.W.

Executive Director Washington, D.C.

20555 Shoreham Opponents Coalition 195 East Main Street Hon. Patrick G. Halpin Smithtown, New York 11787 Suffolk County Executive H. Lee Dennison Building Alfred L. Nardelli, Esq.

Veterans Memorial Highway New York State Deparment of Law Hauppauge, New York 11788 120 Broadway, 3rd Floor Room 3-118 Dr. Monroe Schneider New York, New York 10271 North Shore Committee P.O. Box 231 MHB Technical Associates Wading River, New York 11792 1723 Hamilton Avenue Suite K George E. Johnson, Esq.

San Jose, California 95125 Edwin J. Reis, Esq.

Office of the General Counsel Mr. Jay Dunkleburger U.S. Nuclear Regulatory Comm.

New York State Energy Office Washington, D.C.

20555 Agency Building 2 Empire State Plaza Mr. Stuart Diamond Albany, New York 12223 Business /Fipancial NEW YORK TIMES 229 W.

43rd Street New York, New York 10036

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David A. Brownlee, Esq.

Kirkpatrick.& Lockhart 1500 Oliver Building Pittsburgh, Pennsylvania 15222 1

Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall t-Oyster Bay, New York 11771 F

Michael J. Missal LOCKHART (

KIRKPATRICK &

1800 M Street, N.W.

i South Lobby - 9th Floor Washington, D.C.

20036-5891 i

i By Telecopy t

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