ML20150A843

Suffolk County Responses & Objections to NRC Staff First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Related Correspondence

ML20150A843
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/10/1988
From:	Ross R KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20150A846	List: ML20150A843 ML20150A856
References
CON-#188-5842 OL-3, NUDOCS 8803160067
Download: ML20150A843 (3)

Text

-

7 .

8 $ fj/l' 000KETED V5HRC EMDMRegc3 .g g g gg):39 March 10, 1988 crn:t . : '00CKCi M j l;':y1 r b ... .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board

)

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 RESPONSES AND OBJECTIONS TO THE NRC STAFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING HOSPITAL EVACUATION On February 29, 1988, the NRC Staff filed its First Set of Interrogatories and Requests to Produce to Suffolk County, State of New York and Town of Southampton Concerning Hospital Evacuation

("First Request"). Pursuant to 10 CFR S 2.740b, Suffolk County (the "County") hereby responds to the NRC Staff's First Request.

ANSWERS TO INTERROGATORIES AND DOCUMENT REOUESTS Staff Interrocatory 1

1. With regard to hospital evacuation time estimates, identify the person (s) whom Intervenors expect to call as a witness. For each witness:

a. State the substance of his or her testimony, including the facts and opinions to which the witness is expected to testify; 8303160067 080310 PDR ADOCK 05000322 g PDR

()bb )

l

b. Provide the basis for each such opinion; ,

c. Identify and provide all documents, including ,

studies and analyses, upon which.the witnesses intend to rely;

d. Identify all prior statements made by the witnesses in testimony or depositions, in this or other proceedings which concern the subject matter of their testimony.

i Answer. At this time, the County has not identified any [

witnesses. ,

I i

Staff Interrocatory 2

2. For each witness identified in response to Interrogatory 1, provide a statement of the witness' educational and i professional background, with specific reference to his or her qualifications to give the particular testimony.  !

I Answer. 111 Answer to Interrogatory 1. r i

I f

?

(

t i

f I

l 2- l i

4

(

t Respectfully submitted, E. Thomas Boyle Suffolk County Attorney  ;

Building 158 North County Complex Veterans Memorial Highway l Hauppauge, New York 11788 t

}i gM ]_ _

Christopher M. McMurray Ronald R. Ross KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C. 20036-5891 Attorneys for Suffolk County ,

t March 10, 1988 I

I I

i i  !

f i

l f

t i

1 I

- - _ _ _ , _ . __.