ML20150A967

State of Ny First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* W/Certificate of Svc.Related Correspondence

ML20150A967
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/09/1988
From:	Zahnleuter R NEW YORK, STATE OF
To:	Atomic Safety and Licensing Board Panel
References
CON-#188-5841 OL-3, NUDOCS 8803160108
Download: ML20150A967 (6)

Text

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000KETED March 9, 1988 USNRC 5 liar 14 All:p UNITED STATES OF AMERICA OFFICE OT 3'WTu,cp NUCLEAR REGULATORY COMMISSION v

DOCKEilNG A g;,y BRANCi Before the Atomic Safety and Licensina Board In the Matter of

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IDNG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station,

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Unit 1)

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i STATE OF NEW YORK'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF REGARDING THE HOSPITAL EVACUATION ISSUE In accordance with the Board's "Memorandum and order (Ruling on LILCO's Motion for Summary Disposition of the Hospital Evacuation Issue)", dated February 24, 1988, and pursuant to 10 CFR Sections 2.720(h) (2) (ii), 2,740, 2.740b, 2.741, and 2.744, the State of New York asks the NRC Staff to answer the interrogatories and to respond to the document requests set forth below.

Please answer all interrogatories separately, fully and under oath, and please produce the requested documents at the offices of the Special Counsel to the Governor, Capitol, Room 229, Albany, New York.

The definitions and instructions for this set of 8803160108 880309 PDR ADOCK 05000322 G

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interrogatories and document request are the same as the ones attached to "Suffolk County's First Set of Interrogatories and Request for Production of Documents to the NRC Staff Regarding the Hospital Evacuation Issue," dated March 1, 1988.

Interroaatories and Document Requests 1.

The NRC Staff states on page 14 of "NRC Staff Response to LILCO's Motion for Summary Disposition of the Hospital Evacuation Issue," dated January 15, 1988, that "The Urbanik Affidavit demonstrates that the Staff has reviewed Applicant's estimates, and that the estimates were calculated oronerly and in accordancwe with the guidance in NUREG -

0654."

(Emphasis added)

Similarly, Dr. Urbanik states in paragraph 14 of his affidavit, which is an attachment to the pleading referenced above, that "The hospital evacuation time estimates were calculated in accordance with the guidance provided in NUREG 0654, and are suitable for inclusion in the Plan for use by decision makers in making protective action recommendations."

(Emphasis added)

Elaborate on these statements by answering the following:

a) Identify precisely what LILCO hospital evacuation time estimate calculations Dr. Urbanik had available to him on or before the date when he subscribed to his affidavit (January 11, 1988).

Who provided such calculations to the NRC Staff or Dr. Urbanik, and when were they provided?

b) Give 2 precise examples of LILCO hospital evacuation time estimate calculations that Dr. Urbanik believed were "proper" on or before the date when he subscribed to his affidavit (January 11, 1988).

c) State the precise basis for the NRC Staff's statement that "the estimates were calculated properly."

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d) Provide a copy of all documents used in preparing the answers'to these interrogatories.

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uMnAD Richard J.Qab(11duter Fabian G. Palomino Special Counsel to the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 Attorneys for Mario M.

Cuomo, Governor, and the State of New York t

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@EE8EghIED C s 'tva 14 mt :i6 DATE:. March 4, 1988-0FFICE OF EEGUAN 00CKElgGgEPvlCf.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station

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Unit 1)

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CERTIFICATE OF SERVICE I hereby certify that copies of the "State of New York's First Set of Interrogatories and Request for Production of Documents to the NRC Staff Regarding the Hospital Evacuation Issue," have been served on the following this 9th day of March 1988 by U.S. Mail, first class, except as noted by asterisks.

Mr. Frederick J.

Shon Spence W.

Perry, Esq.

Atomic Safety and Licensing Board William R. Cumming, Esq.

U.S. Nuclear Regulatory Commission Office of General Counsel, Washington, D.C.

20555 Federal Emergency Management Agenc 500 C Street, S.W.,

Room 840 Washington, D.C.

20472 Dr. Jerry R.

Kline Mr. James P. Gleason, Chairman 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

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4 Anthony F.

Earley, Jr., Esq.

Joel Blau, Esq.

General Counsel Director, Utility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi Mr. Donald P.

Irwin Clerk Hunton & Williams Suffolk County Legislature 707 East Main Street Suffolk County Legislature P.O.

Box 1535 Office Building Richmond, Virginia 23212 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 Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Commission 195 East Main Street 1717 H Street, N.W.

Smithtown, New York 11787 Washington, D.C.

20555 Adrian Johnson, Esq.

Hon. Patrick G.

Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.

Lee Dennison Building Room 3-16 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O.

Box 231 San Jose, California 95125 Wading River, New York 11792 E. Thomas Boyle Lawrence Coe Lanpher, Esq.

Suffolk County Attorney Kirpatrick & Lockhart Building 158 North County Complex 1800 M Street, N.W.

Veterans Memorial Highway South Lobby - Ninth Floor Hauppauge, New York 11788 Washington, D.C.

20036 Mr. Jay Dunkleburger Richard Bachman**

New York Sttte Energy Office U.S. Nuclear Regulatory Conmission Agency Building #2

-Washington, D.

C.

20555 Empire State Plaza Albany, New York 12223

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Mr. James P. Gleason Douglas J. Hynes Chairman Town Board of Oyster Bay Atomic Safety and Licensing Board Town Hall 513 Gilmoure Drive Oyster 3ay, New York 11771 Silver Spring, MD 20901 David A.

Brownlee, Esq.

Mr. Philip McIntrie Kirkpatrick & Lockhart FEMA l'aO', Oliver Building 26 Federal Plaza Pitcsburgh, Pennsylvania 15222 New York, New York 10278 Mr. Stuart Diamond Business / Financial NEW YORK TIMES 229 W.

43rd Street New York, New York 10036 7m

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[ ichard Defg116 uter,

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Deputy Special Counsel to the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 (518) 474-1273 By Telecopier By Federal Express l

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