ML20196G137
| ML20196G137 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/29/1988 |
| From: | Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#188-5739 OL-3, NUDOCS 8803070032 | |
| Download: ML20196G137 (17) | |
Text
MUD CORRE5myq 00ChCIED U%RC February 29, 1988 18 MM -3 P2:18 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION andLicensinaBoefihg4
((y*
3 Before the Atomic Safety cRANCH
)
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 FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE LONG ISLAND LIGHTING COMPANY REGARDING HOSPITAL EVACUATION Pursuant to 10 CFR SS 2.740b and 2.741, and in accordance with the Definitions and Instructions attached hereto as, LILCO is requested by Suffolk County to answer separately and fully, under oath, each of the interrogatories set forth below, and to produce for inspection and copying, at the offices of Kirkpatrick & Lockhart, the documents specified below that are within the possession, custody, or control of LILCO.
INTERROGATORIES AND DOCUMENT REOUESTS 1.
Identify each person whom LILCO expects to call as an expert or non-expert witness during the remanded proceeding on
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the hospital evacuation issue and state the subject matter on which each is expected to testify.
2.
For each expert witness identified in response to Interrogatory No.
1, state the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion.
3.
Provide an up-to-date resume for each witness identified in response to Interrogatory No. 1.
4.
For each witness identified in response to Interrogatory No. 1, provide all documents prepared by, for, or under the supervision of such witness relating in any way to evacuation time estimates for hospitals in and around the Shoreham EPZ.
5.
For each witness identified in response to Interrogatory No.
1, identify by date, location and proceeding, all prior testimony before any judicial, administrative, or legislative body, including deposition testimony, concerning emergency preparedness and, in particular, protective actions for special population groups such as hospital patients, nursing home residents, and other such individuals.
6.
Identify every company, organization, group, entity, institution, and individual, including those identified in Interrogatory 1, who participated in the preparation of the hospital evacuation time estimates set forth in Revision 9 of the LILCO Plan.
With respect to each organization or individual identified, explain the nature of that organization's or individual's participation in the preparation of the evacuation time estimates.
7.
Provide all documents underlying, supporting or relied upon in calculating the hospital evacuation time estimates set forth in Revision 9 of the LILCO Plan.
8.
Identify by date and description all drills, exercises, tabletop exercises, classroom training sessions, and all other training activities relating to LILCO's new hospital evacuation proposal that have been held or are scheduled to be held.
9.
For each activity identified in response to Interrogatory 7, provide all documents relating to the activity.
10.
What contacts has LILCO had with any hospital or l
medical association regarding LILCO's hospital evacuation proposal?
For each such contact, identify all hospital (s) or i
association (s) and person (s) involved, the date(s) of each i
l contact, the substance of any conversations, and produce copies l
l of any documents which relate in any way to such contacts.
11.
To the extent not stated in LILCO's December 18, 1987 Motion for Summary Disposition of the Hospital Evacuation Issue and pages IV-176 through 177 of Appendix A of the LILCO Plan, state all assumptions on which LILCO's hospital evacuation time l
l estimates are based.
12.
What event or occurrence is the starting point for the evacuation time estimate for each hospital?
What is the stopping point?
13.
.With respect to the evacuation time estimate for each hospital, what routes are evacuation vehicles (ambulances, ambulettes, etc.) assumed to take?
14.
With respect to the evacuation time estimate for each hospital, to what reception hospital or hospitals are the evacuating patients assumed to be taken and in what order?
To the extent that patients are assumed to be taken to more than one hospital, list the order in which the patients are taken to the receptic1 hospitals (starting with the first reception hospital that patients are taken to, then the second, etc.).
Identify how many patients are assumed to be taken to each such reception hospital.
15.
Do the hospital evacuation time estimates assume that all three hospitals evacuate concurrently?
If not, state how many of the hospitals are assumed to evacuate concurrently.
16.
Do the hospital evacuation time estimates assume multiple waves of evacuation vehicles -- i.e.,
multiple trips by the evacuation vehicles?
If so, how many?
In addition, state the routes which such vehicles are assumed to travel back to each evacuating hospital.
17.
Has LILCO, its experts or consultants analyzed or evaluated the sensitivity of any of the assumptions on which its hospital evacuation time estimates are based?
.f so, state the results of any such analyses or evaluations.
18.
Provide all documents relating to all of the studies or evaluations identified in response to Interrogatory 17...
f' 19.
Explain the bases for all assumptions set forth at pages IV-176 through 177 of Appendix A of the LILCO Plan.
20.
To the extent not covered by the above requests, provide all documents relating to LILCO's hospital evacuation time estimates.
21.
Identify the patient capacity of each reception hospital listed'in Attachment 5 to OPIP 3.6.5.
Respectfully submitted, E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 i
l Christoph'er 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
February 29, 1988.
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~
ATTACRMENT 1 1
DEFINITIONS AND INSTRUCTIONS FOR ANSWERING INTERROGATORIES AND DOCUMENT PRODUCTION REOUEST i
A.
Wherever appropriate, the singular form of a word shall l
be interpreted as plural and vice versa.
B.
"And" as well as "or" shall be construed either disjunctively or conjunctively as necessary to bring within the l
scope hereof any information (as defined herein) which might otherwise be construed to be outside the scope of these discovery requests.
C.
Wherever appropriate, the masculine form of a word shall be interpreted as feminine and vice versa.
D.
The term "person" includes any natural person, firm, partnership, medical institution or association, joint venture, corporation, and any foreign or domestic government organization (including military and civilian), or group of natural persons or such entities.
E.
The term "information" shall be expansively construed and shall include, but not be limited to, facts, data, theories, analyses, opinions, images, impressions, concepts and formulae.
F.
The term "document" means any tangible thing from or on which information can be stored, recorded, processed, trans-mitted, inscribed, or memorialized in any way by any means regardless of technology or form and including but not being lizited tot papers, books, accounts, newspaper and magazine articles, letters, photographs, objects, tangible things,
correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, drawings, blueprints, plans, specifications, manuals, procedures, transcripts, minutes, reports and recordings of telephone or other conversations, or of interviews, or of conferences, or of other meetings, occurrences, or transactions, affidavits, transcripts of depositions or hearings, statements, summaries, opinions, reports, tests, experiments, analyses, evaluations, contracts, agreements, ledgers, journals, books or records of account, receipts, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound recordings, computer printouts, data processing input and output, microfilms, all other records kept by electronic, photographic or mechanical means, and things similar to any of the foregoing.
Each copy of a document which contains any separate notations or writings thereon, and each draft of a document which differs in any way from the final version of the document, shall be deemed to be a separate document for purposes of these discovery requests.
(Versions of a document which differ in clearly non-substantive and unimportant ways from other versions of the document do not need to be considered a separate document.)
G.
The term "communication" includes every exchange of information by any means.
H.
The term "LILCO" or "LILCO personnel" means Long Island Lighting Company (including LERO), and any affiliate, agent, employee, consultant, contractor, technical advisor, representative (including, without limitation, attorneys and I
accountants and their respective agents and employees), or other person acting for or on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.
I.
The term "Shoreham" means the Shoreham Nuclear Power Station, Unit 1, any part thereof, or any structure, system, component, instrumentation, equipment, or materials included in, or intended to be included in, Shoreham.
J.
The term "contractor" means any person, not affiliated with LlLCO, who performed work concerning Shoreham, on behalf of LILCO and/or pursuant to a contract with LILCO.
The term "subcontractor" means any person, not affiliated with LILCO, who performed work of any kind concerning Shoreham, on behalf of a contractor with whom the person was not affiliated, and pursuant to a contract with such contractor.
A person, other than a contractor, who contracts with a subcontractor shall be deemed a subcontractor.
K.
The words "concerning," "concerns" or any other derivative thereof, include referring to, responding to, relating to, pertaining to, connected with, comprising, memorializing, commenting on, regarding, discussing, showing, describing, reflec2ing, analyzing, supporting, contradicting and constituting.
L.
Whenever in the interrogatories there is a request to identify a person that is a natural person, set forth:
l (1) his name; (2) his last known residential address; l
l (3) his last known business address; l._
+
(4) his last known employer; s
(5) his title or position; (6) his areas of responsibility; (7) his business, professional, or other relationship with LILCO; and (8) if any of the above information has changed subsequent to the time period referenced in a particular interrogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time referenced in the interrogatory.
M.
Whenever in the interrogatories there is a request to identify a person that is not a natural person, state:
(1) the full name of such person; (2) the nature or form of such person, if known:
(3) the address of its principal place of business or the principal place where such person is to be found; (4) whether LILCO has or has had any relationship or affiliation with such person, its affiliates or subsidiaries, and, if so, a description of such relationship; and (5) if any of the above information has changed subsequent to the time period referenced in a particular inte.rogatory, set forth in the answer, and label appropriately, current information as well as the information applicable to the time referenced in the interrogatory.
N.
Whenever in the interrogatories there is a request to identify or describe a document:
(1) set forth:
(a) the date of the document; (b) the type or nature of the document; (c) the length of the document; (d) the location of the document; (e) a brief description of the contents of the document; and (2) identify:
(a) the author, signatories and any other person who originated, prepared or participated in the preparation of the document; (b) all persons to whom the document was addressed and all persons to whom copies of the document were to be or have been sent; and (c) all persons whom LILCO knows or believes to have possession, custody or control of the document and of any copies thereof.
O.
Whenever in the interrogatories there is a request to identify a communication:
(1) state:
(a) the date of the communication; (b) the place of the making and place of receipt of the communication;.
(c) the type and means of communication; (d) the substance of the communication; and (2) identify:
(a) each person making the communication, and his location at the time the communication was made; (b) each person to whom the communication was made, and his location at the time the communication was made; (c) all other persons present during, partici-pating in, or receiving the communication and the location of each such person at the time; j
(d) each document concerning such communication; and (e) each document upon which the communication is based or which is referred to in the communication.
1 P.
With respect to each interrogatory answer, identify each document which forms a basis for the answer given, is relied upon or which was reviewed, in whole or in part, in preparing the answer. or which in any way corroborates or concerns the answer given.
A document to be so identified may be produced in lieu of the elements of such identification.
In such case, however, please identify the document in the answer to the interrogatory in sufficient detail so that Suffolk County can readily locate the document among all documents produced by LILCO.
l O.
Where exact information cannot be furnished, estimated information should be supplied to the extent possible.
Where estimated information is used, the answer should so state and should indicate the basis upon which the estimate was made.
If l
possible, the upper and lower boundaries of the estimate should be given.
R.
If LILCO objects to or claims a privilege (attorney-client, work product, or other) with respect to any interrogatory or document request, in whole or in part, or seeks to withhold documents or information because of the alleged proprietary nature of the data, set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the Licensing Board to determine the validity of the objection or claim of privilege.
This description by LILCO should include with respect to any document:
the author, addressor, addressee, recipients of indicated and "blind" copies, date of preparation, subject matter, purpose for which it was prepared, number of pages, attachments or appendices, all persons to whom distributed, shown or explained, present custodian, all persons believed to have a copy of the document, and the nature of the privilege or objection asserted.
S.
If any document called for herein has been destroyed, that document is to be identified as in Instruction "R" above.
LILCO also is requested to state the date of destruction, place and manner of destruction, persons authorizing destruction and person destroying the document. _ _ _ _
T.
Information furnished in answer to an interrogatory may be furnished by reference to the answer provided for another interrogatory, provided the other referenced answer fully responds to each request for information contained in the interrogatory.
Separate answers should be provided for each interrogatory and each subpart chereof, unless a complete answer to each interrogatory may best be presented through combining answers.
The County is interested in this regard in receiving the relevant data requested and any means of providing such data which is less time-consuming for the responder but which is nevertheless complete will satisfy the intent of this discovery request.
U.
Each interrogatory and document request shall be construed to impose upon LILCO the continuing obligation to supplement answers and document production whenever required by the NRC's Rules of Practice.
V.
As used herein:
(1)
"Analysis" means research, investigation, audit, inspection, review, evaluation, testing, monitoring, or any other method or form of examining data and/or forming conclusions or recommendations.
(2)
"NRC" or "NRC Staff" means the Nuclear Regulatory Commission and its staff, any division or section or region thereof, any staff member thereof, or any agent, consultant, contractor, technical advisor, employee, or representative (including but not limited to attorneys and accountants and their employees and agents) of the NRC.
(3)
"FEMA" means the Federal Emergency Management Agency and its staff, any division or section or region thereof, any staff member thereof, or any agent, consultant, contractor, technical advisor, employee, or representative (including but not limited to attorneys and accountants and their employees and agents) of FEMA.
(4)
References to LILCO's "hospital evacuation proposal" are to the proposal first put forth by LILCO on December 18, 19871/ as further detailed by Revision 9 to the LILCO Plan.
W.
If LILCO is unable to answer any interrogatory or portion thereof, identify the person whom LILCO believes has the knowledge or information which the interrogatory addresses.
1/
Egg LILCO's Motion for Summary Disposition of the Hospital Evacuation Issue (Dec. 18, 1987). L
000KETED February 29, SYkb UNITED STATES OF AMERICA 18 ME -3 P2 :19 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Boat 9f f!CE U SECM.lAr?
00CKEimG A SEnv4CL GRANCH
)
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 FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE LONG ISLAND LIGHTING COMPANY REGARDING HOSPITAL EVACUATION have been served on the following this 29th day of February, 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 Agency 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 Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol Albany, New York 12224 Joel Blau, Esq.
Anthony F.
Earley, Jr., Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company 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 3-116 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 George E. Johnson, 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 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York '11771 ng s
Ronald R. Ross KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 2
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