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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20150D4711988-07-0606 July 1988 Suffolk County Answers to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10.* W/Supporting Documentation & Certificate of Svc. Related Correspondence ML20150D5071988-07-0505 July 1988 State of Ny Response to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10 to Suffolk County,State of Ny & Town of Southampton.* W/Certificate of Svc.Related Correspondence ML20155C0791988-06-0707 June 1988 Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* Notices of Depositions & Certificate of Svc Encl.Related Correspondence ML20155C5671988-06-0303 June 1988 State of Ny Response to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl. Related Correspondence ML20151T6251988-04-22022 April 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Licensee.* W/Certificate of Svc. Related Correspondence ML20151T4391988-04-22022 April 1988 Govt Answer & Addl Objections to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Answers & Objections Listed.Notification to County Executive & Certificate of Svc Encl.Related Correspondence ML20151T5701988-04-22022 April 1988 Govt Answers to NRC Staff Interrogatories Re Contentions 1-2,4-8 & 10.* W/Certificate of Svc.Related Correspondence ML20151T8001988-04-20020 April 1988 Govts Objections to Lilco Second Set of Interrogatories Re Consumptions 1-2,4-8, & 10.* Certificate of Svc Encl.Related Correspondence ML20148S8381988-04-12012 April 1988 Suffolk County Fifth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20151F2041988-04-0909 April 1988 Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20151A0691988-04-0101 April 1988 Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20148L9181988-03-31031 March 1988 NRC Staff First Set of Interrogatories to Suffolk County,Ny State & Town of Southampton Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20150F8941988-03-30030 March 1988 Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc. Related Correspondence ML20148L9021988-03-28028 March 1988 Suffolk County Supplemental Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl. Related Correspondence ML20148K2151988-03-25025 March 1988 Lilco Responses & Objections to Suffolk County Third Set of Interrogatories & Requests for Production of Documents Re Emergency Broadcast Sys.* W/Supporting Documentation & Certificate of Svc.Related Correspondence ML20148K4421988-03-24024 March 1988 Lilco Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Suffolk County,State of Ny & Town of Southampton.* Certificate of Svc Encl.Related Correspondence ML20148K1771988-03-24024 March 1988 Lilco Second Set of Requests for Production of Documents Re Lilco Emergency Broadcast Sys to Suffolk County.* Util Makes No Admission or Representation About Proper Scope of Issues to Be Decided.W/Certificate of Svc.Related Correspondence ML20148K2201988-03-23023 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Realism.* W/Certificate of Svc.Related Correspondence ML20148K1571988-03-23023 March 1988 Suffolk County Response to Lilco First Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20148K3881988-03-23023 March 1988 Response of Suffolk County to Lilco 880311 Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl ML20150D1571988-03-18018 March 1988 Response of State of Ny to NRC Staff First Set of Interrogatories & Requests for Production of Documents Re Hosp Evcacuation Time Estimates.* Certificate of Svc Encl. Related Correspondence ML20150D0791988-03-16016 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to NRC Staff & Fema.* Certificate of Svc Encl.Related Correspondence ML20150D0121988-03-15015 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* Certificate of Svc Encl.Related Correspondence ML20150C6511988-03-15015 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Hosp Evacuation Time Estimates.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20150A8081988-03-11011 March 1988 Suffolk County Third Set of Interrogatories & Requests for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20150A9581988-03-11011 March 1988 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 ML20150A9421988-03-11011 March 1988 Lilco Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Related Documentation & Certificate of Svc Encl ML20150A9521988-03-11011 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Related Correspondence ML20150C9911988-03-11011 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Objections Stated. W/Certificate of Svc.Related Correspondence ML20150A8561988-03-10010 March 1988 Suffolk County Responses & Objections to Lilco First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20150A8431988-03-10010 March 1988 Suffolk County Responses & Objections to NRC Staff First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Related Correspondence ML20150A8881988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents.* Related Correspondence ML20150A9111988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents.* Util Objects to Interrogatory 1 as Vague,Overbroad & Unduly Burdensome.W/Certificate of Svc.Related Correspondence ML20150A9341988-03-0909 March 1988 Suffolk County Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl ML20150A9641988-03-0909 March 1988 Lilco First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* W/Certificate of Svc. Related Correspondence ML20150A9671988-03-0909 March 1988 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 ML20196H3941988-03-0707 March 1988 Lilco Second Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20196H4361988-03-0707 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8421988-03-0404 March 1988 Response of State of Ny to Lilco Second Set of Requests for Admissions Re Role Conflict of School Bus Drivers.* Lilco Second Set of Requests for Admissions Deemed Untimely. Certificate of Svc Encl.Related Correspondence ML17342B4211988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8061988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20147H8571988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H7901988-03-0303 March 1988 Suffolk County Second Supplemental Response to Lilco Second Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Lilco Interrogatories 28 & 29 Addressed.Related Correspondence ML20147H7991988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8121988-03-0303 March 1988 Suffolk County Fourth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20196G1121988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* Related Correspondence ML20196G1301988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Hosp Evacuation Issue.* Definitions & Instructions for Answering Interrogatories Encl.W/Certificate of Svc.Related Correspondence ML20196G1081988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8031988-02-29029 February 1988 Lilco Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20196G1371988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence 1988-07-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18
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LILCO, April 1,1988
. 59MED,9.M_W M M UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION UWC
'88 APR -4 P 5 :05 Before the Atomic Safety and Licensing Board QF5Ic~
OCCXE!M 7 ..A ,
,O in the Matter of ) W"
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power, Station ) (Best Efforts !ssue)
Unit 1)
LILCO'S SUPPLEMENTAL RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2,4-8. AND 10 TO LONG ISLAND LIGHTING COMPANY LILCO hereby supplements its response to Suffolk County's First Set of Interrogatories ,
and Requests for Production of Documents, dated March 15, 1988 and served on LILCO on March 16,1988.
I. GENERAL ANSWERS AND OBJECTIONS TO INTERROGATORIES, DEFINITIONS, AND INSTRUCTIONS LILCO gives the same general answers and makes the same general objections to Suffolk County's Interrogatories, Definitions, and Instructions that it made in response to Suffolk County's First Set of Interrogatories and Requests for Production of Documents. See LILCO's Responses and Objections to Suffolk County's First Set of Interrogatories and Re-quests for Production of Documents (Mar. 30,1988), at 1-2.
D. ANSWERS AND OBJECTIONS TO INTERROGATORIES Suffolk County Interrogatory No.1 Please identify, on a contention-by-contention basis, each witness LILCO expects to call to testify on Contentions 1 and 2 (directing traffic), Contention 4 (removing road obstruc-tions), Contention 5 (activating strens and broadcasting EBS messages), Contention 6 (making protective action decisions), Contention 7 (ingestion pathway), Contention 8 (recovery and re-entry), and Contention 10 (EPZ access control), as set forth in the Licensing Board's order ruling on LILCO's summary disposition motion on the legal authority / realism contentions.
Memorandum and Order (Ruling on LILCO's Motions for Summary Disposition of Contentions 1, 2, 4,5,6, 7, 8 and 10, and Board Guidance on Issues for Litigation) (Feb. 29, 1988). For each witness, other than experts, that LILCO expects to call, state on a contention-by-contention basis the subject matter on which he is expected to testify and the substance of the f acts to which he is expected to testify. For each witness that LILCO expects to call as an expert 8804060230 880401 PDR ADOCK 0500 2
}
(
witness, state on a contention-by-contention basis the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expected to testify, and the summary of the grounds for each such op!nion.
Response:In addition to LILCO's previously designated witnesses, LlLCO currently expects to call John A. Weismantle as one of its witneces during the realism remand proceeding. At present, LILCO expects that Mr. Weismantle will testify about how LILCO's plan and proce-dures accommodate State and County participation in a "best efforts" response to a Shoreham emergency with respect so Contentions 1-2, 4-8, 2nd 10. Mr. Weismantle will rely upon his experience and knowledge of emergency planning and upon Revision 9 of the LILCO Plan, including OPIP 3.1.1. The substance of the facts that he will testify about generally can be found in LILCO's realism summary disposition motions fHed March 20 and December 18, 1987.
In addition, LILCO expects that Mr. Edward Leiberman, who has already been desig-nated as a witness, will also testify on Contention 10.
Suffolk County Interrogatory No._2 For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional qualifications.
Response: Mr. Weismantle's resume was provided to the Co'Jnty in connection with the j February 13 exercise proceeding held during the first half of 1987, and is a part of the record in that proceeding. LILCO provides with this response another copy of hit resume. A more up-to-date resume, if available, will be provided to the County before the end of the 30-day ,
production period.
Suffol.k County Interrogatory Non 3 l Please list any NRC, judicial, administrative, legislative, or other legal proceeding in l
which each witness has testified on any matter related in any way to the substance of the is- .
sues in Contentions 1-2,4-8, and 10. State on a contention-by-contention basis which conten-j tion the witness's testimony concerns. ,
l Response: Mr. Weismantle has testified in numerous LILCO proceedings all of which are well ,
i l
known to Suffolk County. Since all of his testimony has been in the Shoreha' proceeding, Suffolk County is capable of making its own determination about how it relates to the issues in l Contentions 1-2, 4-8, and 10.
i l
1
q Suffolk County Interrogatory No. 4 Please provide a copy of any profiled testimony listed in response to Interrogatory 3 above.
Rmponse: Suffolk County already has the testimony discussed in response to Interrogatory No.
3.
Suf tolk County Interrogatory No. 5 lilease identify all articles, papers, studies, reports, books and other such documents authored or prepared by each witness pertaining to the substance of the issues in Contentions 1-2, 4-8, and 10.
Response: LILCO is not aware of any such documents. If LILCO discovers any such docu-ments LILCO will produce them within the 30-day discovery period.
Suffolk County Interrogatory No. 6 Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses, or other documents with respect to the substance of the issues in Contentions 1-2, 4-8, and 10.
Response: See LILCO's response to Suffolk County Interrogatory No. 5 above.
Unless the answer to interrogatory 6 above is a simple negative, please identify each document in LILCO's response to these Interrogatories according to Definition J and provide a copy of each document.
Response: See LILCO's response to Suffolk County Interrogatory No. 5 above.
l l
Respectfully submitted.
l f ~~ ~ ~~
Jameb S. L an Mary Jo L g s i
l i llunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 l DATED: April 1,1988 1
Q
- PROFESSIONAL QUALIFICAT!ONS JOHN A. WEISMANTLE Vice President Engineering LONG ISLAND LIGHTING COMPANY My name is John A. Weismantle and my business address is Long Island Lighting Company (LILCO),1660 Walt Whitman Road. Melville New York 11747. I have been an employee of LILCO since 1965.
I was awarded my Bachelor of Arts degree with a Pre-Engineering major from Columbia College in New York City in 1963. I subsequently earned two degrees in Mechanical Engineering from Columbia School of Engineering in New York City - a Bachelor of Science degree in 1964 and a Master of Science degree in 1965. In 1970. I was again awarded a Master of Science degree, this time in Nuclear Engineering Sci-ence, from Long Island University in Brookville, New York. I also attended the Pubile Utilities Executive Program at the University of Michigan ..) 1979.
I was employed by LILCO in 1965 as an Assis* ant Engineer. In 1969 I was named Section Head in the Power and Instrumentation civ:.sion. I remained in this ca-pacity through 1973. In this position, I assumed a wide range of responsibilities related to new and existing steam plants, a new nuclear plant and gas tur0ines. These responsibilities included acting as Project Coordinator for Northport Units 3 and 4 (two 400 MW oil-fired units) and lead mechanical engineer for these units. I also served as lead mechanical engineer on balance of plant for the 320 MW Shoreham Nuclear Power Station as well as Project Engineer for Holbrook Power Station 1500 MW of gas tur-J bines).
JOHN A. WEISMANTLE J Page As Section Head in the Power and Instrumentation Division, my special as-1 signments included acting as Chairman of the Engineering Productivity Task Force and
! a member of the Construction Manpower Task Force. In both of these positions the conclusions and recommendations ! proffered were accepted. .
'In 1974, I served as Licensing Engineer for the Jamesport Nuclear Power Station. This was a full-time ipecial assignment to d! rect completion of Stata Siting and NRC Construction Permit Applications wnich were behind schecule. I was respon-sible for direction and coordination of internal departments and numerous consultants.
In this capacity, I saw to it that the lost time was made up and that applicattuns were submitted by the original deadline.
From 1974 to 1975, I was the Manager of the System Planning Division. As
! manager of this division, I was responsible for generation, bulk transmission and interconnection planning. I had direct supervisory respont:ility over 12 graduate engi-i neers plus support personnel. l In 1975, I assumed the position of Project Manager for tha Jarnesport Nucle- ,
ar Power Station. I remained in this position until late 1976, assumlag responsibility for
- i two 1150 MW PWR nuclear units. At the time ! assumed this position, the project was l
< in the state and tederal licensing stage with preliminary engineering and construction planning proceeding. Eventually, a single 300 MW coal unit received a State Siting Cer-tificate.
From 1977 to 1978. I served as LILCO's first Research and Development Di-i rector. In addition to organizing a corporate Research and Development program, de- ,
veloping a five year plan, and establishing procedures, I represented LILCO on external l
research and cevelopment committees. One of my special adgnments involved acting 1
f
, +
a JOHN A. WEISMANTLE Page .
as Chairman of the LILCO Load Management Task Force, where my conclusions and recommendations were accepted.
From 1978 to 1981. I was Manager of LILCO's Planning Depariment. In this capacity, I was responsible for short term and long range planning of LILCO's electric facilittes and corporate r+. search and development function. The Planning Departmsnt comprises three divisions - System Planning (involving s'ab-transmission and inter-connections), Area Planning (involving sub-transmission and distribution), and Research and Development. I had direct supervisory responsibility over a staff of 30 graduate en-gineers plus support personnel. Furthermore I directed preparation of a wide ran2e of technical and economic reports in addition to serving as 5 member of the 1:!LCO ao hoc l task force on coal.
As Manager of the P!anning Department. I represen'.ed t.!LCO on the follow-ing incustry committees: the EEC System Planning Committa. ESEERCO Administra-tive Committee. NYPP Generation Planning Advisory Succommittee, and EPRI Ad-vanced Power Systems Task Forets (Chairman of Clean Gaseous Fuels Program
- Committeel.
In 1981. I was named Manager of the Power Engineering Department. In this j capacity. I was responsible for the Port Jeiterson Coal Conversion conceptual design.
cost estimate, and license applications, all of which is currently undergoing the state 11-l censing process. In addition. I was responsible for att major capital (above $25,000)im-l provement projects for existing fossil plants. Other esponsibilities included the fie.ds of gas system planning and engineering mechanical engtreering -- Shoreham support. ;
- and direct supervisory responsibility for a staff of over 35 graduate engineers plus sup-port personnel. I represented LILCO on the EE! Prime M6 vers Committee and the EPRI ,
Fossil Fue.' Power Task Force.
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. JOHN A. WEISMANTLE Page l In June 1982, I became responsible for the satisfactory implementation of
, the Shoreham onsite and local emergency plans. In carrying out this assignment, I re- ,
I ported to the Vice President of Engineering who has corporate lead responsibility for emergency preparedness, in September 1983 I became full-time manager of the Local Emergency Response Implementing Organization, a group of over 30 professionals plus i
support personnel.
From 1983 to 1985 I was the Manager for the Local Emergency Response Or-ganization (LERO). I directed the development and impMmentation of a unique off-site s
' nuclear emergency plan which relles entirely on utility workers, private companies and ,
volunteer organizations. An approved off-site plan is the final Fequirement for a full power license for Shoreham. My responsibilities included development and mainte-nance of the plan, preparation and administration of a training program for 2200 ,
workers, estab!!shing several emergency f acilities and direc*ing all preparations for a I federally graded exercise held in February,1956. I made prnentations to senior man-agement and the Board of Directors, presented tastimony en more than 50 Lees in a protracted and bitterly contested licenslag hearing, ad advanced LILCO's position at debates and before the media.
- From 1984 to 1985 I was the Manager of the F?cilities Planning Department.
In March,1934 LlLCO reorgani?ed and I was appointed to fill th!.s position in addition to i continuing as Manager of LERO. I reported to the Vice President of Corporate Phn-l l ning, and directed over 25 engineers with the responsibility for planning LILCO's elec- ,
tric f acilities and ccrporate R ,k P program, from 1985 to the present ' have been Vice Presidera of Engineering, In l
November of 1985 I was elected to this position. I report to the senior V!ce President l
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4 JOHN A. WEISSIANTLE
! Page :
of Enginecting and Operations, five departments report to me: Power Engineering, l
Electrical Engineering, Environmental Engineerir.g. Engineering Design and Stapping, and Engineering Analyst 4. These departments contain over 200 personnel, Sly responsibilities include al.1 engineering and design fc.t' improvements to LILCO's fossii j ' generating stations. We are also responsible for engineering and design of balance of plant impiovements at the 300 A!W Shnrenam Nuchar Power Piant. Engineering also
- provides operating support for our entire electric system, in connection with my professional experience and qualifications, I have prepared and presented testimony on a vide range of technica12md econorth issues at I numerous proceedings. Includidg the 1979 State Energy 5f aster Plan hearings, in elec-l tric rate cases finvolving corporate capital oudget and Research and Development pro-
, grams), and in hearing ::efore tne State 51 ting Board, the Suelest Regulatory Comin!s-
) ston, State Legislative Commissions (in*,'olving cogen ration and researen and i
j development), and the federal Energy Reguutory Commiss:.n.
l ! have ceen a '!cer. sed Protessional Engineer in tr.e state of New York s;nce l 1970, Sly profes5 tonal affiliatices include membertW in the American Soc!ety of .\te-chsnical Engineers ( ASNtSh at?.3 past memnership on :ne Power Test Code Committee --
t Condensers and Feecwrer Featers, and (no Executive Committee, Long Island Section.
i am also a past memter of EE! Prime Slovers and System Plann:ng Committees. EPR!
fossd Perwer Plant and Advacced Fossil Power Systems Task Force, and several NYPP ano ESEERCO Committees.
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4 LILCO, April 1,1988 toutlic um
'88 H -4 PS :05 CERTIFICATF OF SERVICE
- g. ,
00CMitar,A nuwu' 3RANN in the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's Supplemental Responses and Objections to Suffolk County's First Set o' Interrogatories and Requests for Production of Docu-ments Regardirq Contentions 1-2,4-8, and 10 to Long Island Lighting Company were served this date upon the following t;y Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.
James P. Gleason, Chairman " Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and I,1 censing 513 Gilmoure Drive Board Panel Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline "
- Atomic Safety and Licensing Richard G. Bachmann, Esq. "
Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy. Rockville,, MD 20852 Bethesda, MD 20814 Herbert H. Brown, Esq. "
! Mr. Frederick J. Shon " Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
i Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.
4350 East-West Hwy. Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq. "
l Secretary of the Commission Richard J. Zahnicuter, Esq.
Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.C. Nuclear Regulatory Commission Room 229 1717 H Street, N.W. State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing Alfred L. Nardelli, Esq.
- Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission 120 Broadway
, Washington, D.C. 20555 Room 3-118 i New York, New York 10271 I
4 Spens W. Perry, Esq. ** Ms. Nora Bredes William R. Cumming, Esq. Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.
Stephen B. Latham, Esq. ** Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee i
Federal Emergency Management P.O. Box 231 l Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel
, Three Rockefeller Plaza
! Albany, New York 12223 s _
l Ma Jo_ p;rs Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: April 1,1988 l
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