ML20151F204

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

ML20151F204
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/09/1988
From:	Ross R KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-6041 OL-3, NUDOCS 8804180125
Download: ML20151F204 (7)

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ECLATED CORRESPONDENg Aor 01DVIEQ988 var ex UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.E0 MH 13 P3 M6 Before the Atomic Safety and Licensina Board GFFICE OF Ell,F LIM 00CKElit:0 4 SLWid; BRANOi

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In the Matter of )

} Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY ) (Emergency Planning)

)

(Shoreham Nuclear Power )

Station, Unit 1) )

)

SUFFOLK COUNTY'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2, 4-8 AND 10 TO THE LONG ISLAND LIGHTING COMPANY Pursuant to 10 CFR SS 2.740, 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 Regarding Contentions 1-2, 4-8 and 10 to Long Island Lighting Company (March 15, 1988), Suffolk County, by its counsel, propounds the following interrogatories and requests for documents to the Long Island Lighting Company ("LILCO").

I INTERROGATORIES AND DOCUMENT REQUESTS

1. Does LILCO intend to pursue its "immateriality" theory with respect to Contentions 1 and 2 in the CLI-86-13 remand proceedings?

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2. Unless the answer to Interrogatory 1 is negative, identify all witnesses who will testify on that issue, and for each such witness, identify the facts and opinions to which the witness will testify.

3. Identify all modifications to LILCO's traffic analysis which were incorporated into the revised evacuation time estimates of Revision 5 of the LILCO Plan ("Rev. 5"), including but not limited to, changes in methodology and in assumptions.

4. Explain why EPZ Zone Q was reanalyzed to produce the revised evacuation time estimates in Rev. 5. Were any other subzones of the EPZ reanalyzed? If so, identify them and the results of the reanalysis of the additional subzones.

5. Identify and explain all factors which contributed to a reduction reflected in Rev. 5 of LILCO's uncontrolled evacuation time estimates.

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6. Was traffic in Zone F reassigned in the revised traffic analysis reflected in Rev. 5. If so, explain how such traffic l

l was reassigned, the assumptions underlying the reassignment, the routes to which such traffic was reassigned, and the number of i vehicles reassigned.

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7. Identify and explain the criteria used to select additional roads in Zone Q for the assignment of evacuating traffic.

8. Identify all assumptions regarding the capacities of the additional roads referred to in Interrogatory 7 above.

9. Explain the basis for adding 1310 additional cars to the network in Zone Q for the Rev. 5 evacuation time estimate analysis.

10. Explain the basis for the Rev. 5 assumption that approximately 300 cars from Zone Q will evacuate by local road-ways not represented as links in the evacuation network. Egg Affidavit of Edward B. Lieberman 1 5 (Dec. 14, 1987) (attached to LILCO's Motion for Summary Disposition on Contentions 1, 2 and 9

-- Immateriality (Dec. 18, 1987)) ("Lieberman Affidavit").

11. Provide all documents, including computer inputs and outputs, concerning the revised Rev. 5 evacuation time estimates.

12. Explain why the Rev. 5 time estimates are more sensitive to non-compliance with assigned routing than previous estimates. Identify and explain all factors which contributed to the increased sensitivity of the Rev. 5 time estimates to noncompliance with assigned routing.

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13. Explain specifically how the reassignment of traffic from two subzones in Zone F had the effect of decreasing the uncontrolled evacuation time estimate. Egg Lieberman Affidavit 1 7.

Respectfully submitted, E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 La. v Lawrence Coe Lanpher 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 l Aoril 9, 1988 l

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cDU.ETED Adi[1 9, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *26ONE ge p 3 'A6 Before the Atomic Safety and Licensino Boardu da%EC

$0dNI*U SEPviCL 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 SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2, 4-8 AND 10 TO THE LONG ISLAND LIGHTING COMPANY have been served on the following this 9th day of April, 1988 by U.S. mail, first class, except as otherwise indicated.

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 Agenc!

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 W. Taylor Reveley, III, Esq.*

Hunton & Williams Fabian G. Palomino, Esq. P.O. Box 1535 Richard J. Zahnleuter, Esq.* 707 East Hain Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol Albany, New York 12224

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B Joel Blau, Esq. Anthony F. Earley, Jr., Esq.

Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Compar.y 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 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 Comm.

195 East Main Street 1717 H Street, N.W.

Smithtown, New York 11787 Washington, D.C. 20555 Alfred L. Nardelli, Esq. Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-118 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 Mr. Jay Dunkleburger Richard G. Bachmann, Esq.

New York State Energy Office Edwin J. Reis, Esq.

Agency Building 2 Office of the General Counsel Empire State Plaza U.S. Nuclear Regulatory Comm.

Albany, New York 12223 Washington, D.C. 20555 David A. Brownlee, Esq. Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W. 43rd Street New York, New York 10036 l

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I Douglas J. Hynes si 8.lman Adjudicatory File Town Board of OyL r my Atomic Safety and Licensine Town Hall Board Panel Dockat Oyster Bay,-New Yor.. 11771 U.S. Nuclear Regulatory C mis. 7n Washington, D.C 20555 c e_ ~

fistopMer M'. McMurray KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C. 20036-5891

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