ML20150A958

Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* W/Certificate of Svc. Related Correspondence

ML20150A958
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/11/1988
From:	Matchett S HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SUFFOLK COUNTY, NY
Shared Package
ML20150A953	List: ML20150A952 ML20150A958
References
OL-3, NUDOCS 8803160105
Download: ML20150A958 (4)

Text

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LILCO, March 11,1988

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[EW.ED RRR@MDg 00tMETED UNITED STATES OF AMERICA UN NUCLEAR REGULATORY COMMISSION g 14 NO 51

.g Fy}-hCHYhNC; Before the Atomic Safety and Licensing Board BRAN In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station,

) (EBS)

Unit 1)

)

LILCO'S SUPPLEMENTAL RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DO('UMElT_S REGARDING EMERGENCY BROADCAST SYSTEM LILCO hereby supplements its responset to Suffolk County's First Set of Interrogatories t-and Request for Production of Documents concerning EBS issues, dated February 29,1988 and served on LILCO on March 1,1988.

L GENERAL ANSWERS AND OBJECTIONS TO INTERROGATORIES. DEFINITIONS AND INSTRUMENTS LILCO gives the same general answers and makes the sawl general objections to Suffolk County's Interrogatories, Definitions, and Instructions that it made in response to Suffolk County's First Set of Interrogatories and Request fo? Production of Documents con-i cerning EBS issues, dated February 29,1988, i

II.

SUP?LEMENTAL ANSWERS TO INTERROGATORIES l

t Suffo5c County Interrogatory No.1 E

Identify each person whom LILCO expects to call as an expert or non-expert witness ci8*

during the EBS proceeding and the subject matter on which each witness will testif y.

88 ed Response: In addition to the two other witnesses identified by LILCO in this proceeding, og 38 LILCO identified its third witness during the deposition of Doug Crocker on March 8,1988, and no in a letter to Suffolk County later that same day. Letter from LILCO counsel to Suffolk Coun-ty counsel, March 8,1988. The witnes.:i is William G. Johnson. Mr. Johnson will testif y in sup-port of his survey of radio ownership within the Shorcham EPZ conducted in the Fall of 1987, and the conclusions drawn from that survey. A report on the survey was attached to LILCO's No.cmb:r 6 summary disposition motion.

Suffolk County Interrogatory No. 2 For ech expert witness identified in response to Interrogatory No.1, state the sub-stance of tbm uts and opinions on which each expert is expected to testify and a summary of the grounds for each opinion.

Rmponse The substance of the facts and opinions on which Mr. Johnson will testify is contained in his affidavit which was attached to LILCO's Nov. 6 summary disposition motion.

Suffolk County Interrogatory No. 3 Provide an up-to-date resume of each witness identified in response to Interrogatory No.1.

Rmponse: A copy of Mr. Johnson's resume will be provided as scon as possible.

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Suffolk County Interrogatory No. 4

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s For each witness identified in response to Interrogatory No.1, provide all studips, pa-pers, articles, reports, books and other such documents, published or unpublished, authored ors prepared by each such witness relating to the issues in this proceeding including, but not limit-ed to, emergency broadcast system, signal strength, signalstrength measurements and teohnb cal requirements and technical requirements for EBS stations.

Rmponse: Mr. ' Johnson has prepared no documents that are responsive to this interrogatory a,......, i. r.

.. m n,*.c iio u.i>

other than thesurvey documents aboutyhich he wille testify.4 e -

Suffolk County Interrogatory No. 5 Identify by date, location and proceeding, all prior testimony before any judicial, ad-ministrative, or legislative body, including deposition testimony, concerning emergency pre-paredness, including emergency broadcast systems and the adequacy and coverage capabilities of radio stations, given by each of the witnesses identified in response to Interrogatory 1.

Rmponse: Mr. Johnson previously testified as a witness in the Shoreham proceeding on the is-sues of role conflict and shsdow phenomenon, on December 6 and 12,1983. He was deposed in connection with that proceeding on September 15, 1983.

Respectfully submitted,

~

Scott D. Matchett

'6CodLt/

Counsel for Long Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: March 11,1988

aDh LILCO, March 11,1988 00CKETED USNRC o

1B twt 14 N050 CERTIFICATE OF SERVICE 0FFICE OF HailAr*

In the Matter of 00CKElmG A SEkv!Cf.

BRANCH LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's Responses and Objections to Suffolk County's Second Set of Interrogatories and Request for Production of Documents Re-garding Emergency Broadcast System and LILCO's Supplemental Responses and Objec-tions to Suf folk County's First Set of Interrogatories and Request for Production of Documents Regarding Emergency Broadcast System were served this date upon the fol-lowing by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.

James P. Gleason, Chairman "

Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline "

Charles A. Barth, Esq. "

Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board One White Flint North U.S. Nuclear Regulatory Comraission 11555 Rockville Pike East-West Towers, Rm. 427 Rockville, MD 20852 4350 East-West Hwy.

Bethesda, MD 20814 Herbert H. Brown, Esq.

• Lawrence Coe Lanpher, Esq.

Mr. Frederick J. Shon **

Karla J. Letsche, Esq.

Atomic Safety and Licensing Kirkpatrick & Lockhart Board South Lobby - 9th Floor U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

East-West Towers, Rm. 430 Washington, D.C. 20036-5891 4350 East-West Hwy.

Bethesda, MD 20814 Fabian G. Palomino, Esq.

• Richard J. Zahnleuter, Esq.

Secretary of the Commission Special Counsel to the Governor Attention Docketing and Service Executive Chamber Section Room 229 U.S. Nuclear Regulatory Commission State Capitol 1717 H Street, N.W.

Albany, New York 12224 Washington, D.C. 20555 Alf red L. Nardelli, Esq.

Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel 120 Broadway U.S. Nuclear Regulatory Commission Room 3-118 Washington, D.C. 20555 New York, New York 10271

Spence W. Perry, Esq. **

Jonathan D. Feinberg, Esq.

William R. Cumming Esq.

New York State Department of Federal Emergency Management Public Service, Staff Counsel Agency Tbme Rockefeller Plaza 500 C Street, S.W., Room 840 Albany, New York 12223 War.hington, D.C. 20472 Ms. Nora Bredes Mr. Jay Dunkleberger Executive Coordinator New York State Energy Office Shoreham Opponents' Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, New York 11787 Albany, New York 12223 Evan A. Davis, Esq.

Stephen B. Latham, Esq. **

Counsel to the Governor Twomey, Latham & Shea Executive Chamber 33 West Second Street State Capitol P.O. Box 298 Albany, New York 12224 Riverhead, New York 11901 E. Thomas Boyle, Esq.

Mr. Philip McIntire Suffolk County Attorney Federal Emergency Management Building 158 North County Complex Agency Veterans Memorial Highway 26 Federal Plaza Hauppauge, New York 11788 New York, New York 10278 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Wading River, NY 11792 i

fM Scott D. MatcKett Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 l

DATED: March 11,1988 i

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