ML20196H436
| ML20196H436 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/07/1988 |
| From: | Matchett S HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SUFFOLK COUNTY, NY |
| References | |
| CON-#188-5779 OL-3, NUDOCS 8803110036 | |
| Download: ML20196H436 (17) | |
Text
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00CKETE0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 MR -9 A10:23 Before the Atomic Safety and Licensing Board
{
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In the Matter of
)
)
LONG ISLAND LIGliTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station.
) (EBS)
Unit 1)
)
LILCO'S RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING EMERGENCY BROADCAST SYSTEM LILCO hereby responds to Suffolk County's First Set of Interrogatories and Re-quest for Production of Documents concerning EBS issues, dated February 2D,1988 and served on LILCO on March 1,1988.
I.
GENERAL ANSWERS AND OBJECTIONS TO IN TERROG ATORIES. DEFINITIONS AND INSTRUCTIONS A.
LILCO objects to all interrogatories, definitions and instructions insof ar as they require the disclosure of any information protected by the Jttorney-client privi-lege or work product doctrine.
B.
LILCO objects to all interrogatories to the extent they purport to require information outside the possession, custody or cor. trol of LILCO.
C.
LILCO objects to the inclusion of attorneys in the definition of "Ll'.CO" or "LILCO personnel" in paragraph 11 of Suffolk County's Definitions and Instructions be-cause their inclusion is clearly calculated to discover information protected by the attorney-client privilege and the work product doctrine.
I D.
LILCO objects on relevance gtrunch to allinterrogatories and requests that seek information that is outside the scope of the coverage issues raised in contentions 1.A.1.B.1.C, and 2.A, as limited by the Board in its February 24, 1988 Memorandum i
and Order.
LILCO objects to individual 7.nterrogatories on this ground where appropriate.
8803110036 880307 3
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2-II. ANSWERS AND OBJECTIONS TO INTERROGATORIES Suffolk County Interroratory No.1 Identify each person whom LILCO expects to call as an expert or non-expert witness during the EBS proceeding and the subject matter on which each witness will testify.
Response: LILCO identified two witnesses for the EBS proceeding on February 25, 1988, the first day of the discovery period,in a letter to Suffolk County counsel. Letter from LILCO counsel to Suffolk County counsel, February 25, 1988. The twc. witnesses are Douglas M. Crocker and Ralph E. Dippell, Jr. Mr. Crfscker will be the Company representative on the panel and will testify as necessary regarding i ev. 9's provisions concerning the Shoreham EBS, the agreements with the three new radio stations, etc.
Mr. Dippell will testify in support of Cohen and Dippell's conclusions regarding the cov-erage of LILCO's EBS.
LILCO may'name one additional witness to testify in this proceeding, and will notify Suffolk County promptly by telephone if it does so.
Suffolk County Interrogatory No. 2 For each expert witness identified in response to Interrogatory No.1, state the substance of the facts and opinions on which each expert is expected to testify and a summary of the grounds for each opinion.
Response: The substance of the facts and opinions on which Mr. Dippell will testify is contained in his affidavii which was attached to LILCO's Nov. 6 summary disposition motion.
Suffolk County Interraratory No. 3 Provide an up-to-date resume of 'ach witness identified in response to Interroga-tory No.1.
Response: 1.lLCO provided a resume for Nr. C ocker in connection with the school bus driver remand proceeding. A copy of Mr. Dippell's resume is being provided with these I
responses.
Suffolk County Interrogatory No. 4 For each witness identified in response to Interrogatory No.1, provide all studies, papers, articles, reports, books and other such documents, published or unpublished, authored or prepared by each such witness relating to the issues in this
3 proceeding including, but not limited to, emergency broadcast system, signal strength, signal strength measurements and technical requirements for EBS stations.
Response: For Mr. Crocker, there are no such documents. For Mr. Dippell, to the ex-tent his unpublist.W studies, papers, etc. are relevant to the narrow issues in this pro-ceeding and not privileged or proprietary, LILCO will provide copies of such documents as soon as possible, within the 15-day discovery period. LILCO will also provide a list of works published by each witness. LILCO objects to providing copies of published documents to which LILCO and Sulfolk County have equal access in the public record.
As a practical matter, LILCO has already provided to the Intervenors'(in attach-ments to LILCO's Nov. 6 summary disposition motion and in documents voluntarily pro-duced on March 1) all studies, reports, etc. prepared by Cohen and Dippell regarding the coverage of the stations in LILCO's EBS. LILCO objects to Interrogatory no. 4 to the extent it seeks all documents ever prepared by Mr. Dippell regarding "signal strength" or "signal strength measurements." Cohen and Dippell, P.C. and its predecessors have provided professional engineering services, including such signal strength studies, to the i
broadcasting industry for 50 years. Many such studies are confidential commercialin-formation which car. be produced only on the consent of the individual clients for whom they were prepared. Intervenors' request for all such studies is overly broad, unduly
)
burdensome, not relevant, and not reasonably calculated to ! cad to the discovery of ad-i missible evidence.
Suffolk County Interrogatory No. S Identify by date, location and proceeding, all prior testimony before any judicial, administrative, or legislative body, including deposition iestimony, concerning emer-gency preparedness, including emergency broadcast systems and the adequacy and cov-erage capabilities of radio stations, given by each of the witnesses identified in re-sponse to Interrogatory No,1.
i
?
Response: Mr. Crocker has previously testified as a witness only in the Shoreham re-i j
cept'on centers proceeding, which was held in July 1987, lie was deposed in coanection with that proceeding on June 22, 1987. Mr. Crocker has also been designated as a wit-ness in the school bus driver remand proceeding, and was depmed in connection with that proceeding on February 2,1988.
i I
..g.
Information concerning relevant testimony of Mr. Dippell is included in his resume.
Suffolk County Interrogatory No. 6 Provide copies of all correspondence or other communications between LILCO and the radio stations participating in LILCO's EBS. Such documents already provided to Suffolk County in connection with earlier Shoreham emergency planning proceedings need not be produced again, but merely identified.
REDonse: LILCO objects to Interrogatory no. 6 on the grounds that it seeks informa-tion that is not relevant to the subject matter of this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence. The only admitted issues in this proceeding concern the coverage of WPLR and the other EBS stations within the 10-mile EPZ. LILCO has already provided Suffolk County with all known documents concerning such coverage. Intervenors' requmt for "all correspondence or other com-munications" between LILCO and the radio stations is not likely to lead to the discovery of admissible evidence on the coverage issue.
Suffolk County Interrogatory No. 7 Provide copies of all correspondence to or from, and any other documents or in-formation sent by or on behalf of LILCO, to, or received from, FEMA and/or the NRC, or any other federal agency, federal personnel, or contractor thereof, relating to LILCO's EBS.
ResDonse: The only documents sent by LILCO to the NRC or FEMA or any other feder-al agency concerning the EBS are Rev. 9 to the LILCO Plan and the pleadings associ-ated with the EBS issue (LILCO's summary disposition motion, contention objections, e t c.). LILCO submitted Rev. 9 to the NRC on January 22, 1988. EBS-related pleadings were filed on and received from the NRC and FEMA in the normal course of litigation
.i on this issue,14, at the same time pleadings were flied on and received from the Inter-venors.
Suf folk County Interrogatory No. 8 Identify by date and description all drills, exercises, classroom training sessions, and all other training or instructional activities or documents relating to LILCO's EBS that have been held and/or are scheduled to be held.
Response; LILCO objects to Interrogatory no. 8 on the ground that it seeks information that is not relevant to the subject matter of this proceeding and is not reasonably cal-culated to lead to the discovery of admissible evidence. Information about drills, exer-cises, and EBS-related training is not relevant to the adequacy of the EBS stations' broadcast coverage within the 10-mile EPZ, which is the only issue raised by the admit-ted contentions. Nor is such informatior. likely to lead to the discovery of admissible evidence on the coverage questions.
Suffolk County Interrogatory No,9 For each activity identified in response to Interrogatory No. 8, provide all docu-ments concerning the activity.
Response: LILCO objections to this Interrogatory for the same reasons given in its re-sponse to Interrogatory no. 8.
Suffolk County Interrogatory No.10 Provide all documents, including but not limited to correspondence, the survey instrument and draf ts thereof, and all raw data relating to the telephone survey, as ref-erenced in LILCO's Motion, conducted by Campaign Research, Inc., of Westport, Con-necticut between September 30,1987 and October 4,1987.
Respons_ej The questions and numerical results of the survey, along with a one page re-port on the highlights of the survey and the methodology used, were attached to LILCO's November 6,1987 summary disposition motion as Att. 7. The survey is also de-scribed in the Johnson affidavit that is Attachment 10 to LILCO's summary disposition motion. A copy of the actual survey question form is provided with these responses.
LILCO will provide Suffolk County with copies of the completed survey forms (the "raw data"), if they are still in existence, as soon as possible.
LILCO is withholding one document, an undated draf t of the survey question form with counsel's handwritten notes, based on the attorney-client privilege and work product doctrine.
Etifolk County Inte_rrogatory No.11 Identify all schools, hospitals, nursing homes, handicapped f acilities, large em-ployers or other organizations which have been or will be provided with tone alert ra-dios capable of being by activated (sic] WPLR's EBS signal.
Response: LILCO objects to Interrogatory no.11 on the ground that it seeks informa-tion that is not relevant to the subject matter of this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence. The only admitted issue in this proceeding is whether LILCO's EBS provides adequate coverage within the 10-mile EPZ. The tone alert radios are at issue only to the extent that Intervenors allqge that WPLR's EDS tone will not activate them. Moreover, the tone alert radios are activated by WPLR, and it is LILCO's position that WPLR provides full coverage of the entire 10-mile EPZ, including all f aellities within 10 miles that have been or will be provided with tone alert radios. The identity of each such facility is of no consequence to the cover-age issue, nor is it likely to lead to the discovery of admissible evidence on that issue.
In addition, as LILCO noted in its November 6 summary disposition motion, the tone alert radios are a backup or secondary means of notifying those f acilities that pos-sess themt in an emergency those facilities would also be notified by sirens and LERO phone calls. See LILCO's Summary Disposition Motion at 3.
The Board stated that it knew of "no requirement that special f acilities be alerted earlier than the general pub-lic in an emergency," and found that "the inclusion of the tone alert radio system in the Plan is simply a commendably prudent addition to the requirements." PID at 760. Thus, Intervenors' inquiry here into the identitles of f aellities with tone alert radios is irrele-vant not only for the reason given above, but for the additional reason that the Board has already held tone alert notification of special facilities not to be required by the ret,..a tions.
Suffolk County Interrogatory No.12 Provide a copy of all documents, including correspondence and draf ts, concern-ing the modification or replacement of any and all tone alert receivers that were set to be activated by WALK radio.
Response: LILCO has already provided (by Federal Express on March 1,1988) the Coun-ty with any documents that are responsive to this Interrogatory. LILCO will continue to search and will produce any additional responsive documents as soon as they are dis-l covered.
l l
Suffolk County Interrogatory No.13 Identify all persons who have evaluated, analyzed, or studied any of the radio stations comprising LILCO's EBS, in connection with such radio stations' participation in the EBS and explain the nature of such persons' activities in this regard.
Response: LILCO objects to this Interrogatory except to the extent it requests the identity of persons who have analyzed or studied the coverage capabilities of the EBS stations within the 10-mile EPZ. LILCO also objects to Interrogatory no.13 to the ex-tent it seeks to discover any role LILCO counsel may have played in analyzing the EBS stations' capabilities.
Within these confines, LILCO answers that the following persons evaluated the coverage of the Shoreham EBS stations: Ralpr. E. Dippeu, Jr., Robert W. Guill, and Sudhir K. Khanna, all of Cohen and Dippell, P.C. The nature of their participation and involvement is indicated in the engineering reports that have been provided to Interve-nors as part of LILCO's November 6,1987 summary disposition motion and in LILCO's voluntary production of documents on March 1,1988.
Suffolk County Interrogatory No.14 With respect to each person identified in response to Interrogatory 13, above, provide all documents prepared by, for, or under the supervision of such person relating to LILCO's EBS or the radio stations participating therein.
Response: LILCO already has provided the Intervenors with all of the engineering re-ports prepared by the Cohen and Dippell personnel identified in Interrogatory no.13.
LILCO will provide as soon as possible the detailed notes and other field data upon which the reports are based and which are not already included in the reports them-1 t
- selves, in addition, as mentioned in the June 1987 Engineering Report Re Field Strength Measurements Survey of WEZN and WPLR, Cohen and Dippell made audio tapes of the listening tests on WPLR. LILCO will produce copies of those tapes at Suffolk County's expense if the County notifies LILCO that it wants them. To the best of LILCO's knowledge, there are no other documents in existence that are reponsive to Interrogatory no.14.
e
Suffolk County Interraratory No.15 Provide all documents underlying, supporting, or relied upon in preparing the Cohen and Dippell reports attached to LILCO's motion for summary disposition on the EBS issues, including, but not limited to. notes, memoranda, field data, data compila-tions and draf ts of the reports.
Response: Beyond the documents mentioned in LILCO's response to the previous Inter-rogatory, there are no documents in existence that are responsive to Interrogatory no.
- 15. See LILCO's Response to Interrogatory no.14.
Suffolk County Interrogatory No.16 Identify all persons who participated in preparing the Cohen and Dippell reports and explain the nature of their participation.
Response: See LILCO's Response to Interrogatory no.13.
Suffolk County Interrogatory No.17 Describe in detail any portions of the EPZ that are not covered by an AM signal, including but not ilmited to, the "portion of the EPZ that might remain uncovered by a nighttime AM signal" as referenced in LILCO's Motion. Describe also in detail any por-tions of the EPZ that are not covered by an FM signal. Provide all documents, including correspondence and draf ts, relating to any portions of the EPZ identified above.
Response: There are no portions of the EPZ that are not covered by an FM signal.
There are no portions of the EPZ that are not covered by an AM signal during the day.
LILCO has made no detailed analysis concerning which,if any, areas of the EPZ are not covered by an AM signal at night, and thus cannot "describe in detall" any such areas.
LILCO notes only that the signal contours of the EBS stations are presented in the Sep-tember 1987 Cohen and Dippell report (Att. 6 to LILCO's summary disposition motion),
and that signal contours are conservative representations of coverage, meaning that most stations can actually be heard far beyond what the signal contours indicate.
Suffolk County Interrogatory No.18 (a) Describe in detail LILCO's "requirements" for testing WPLR-FM's "signal" as referenced in the letter confirming WPLR's willingness to participate in LILCOs EBS i
dated July 27,1987, and included as Attachment I to LILCO's Motion.
(b) Has LILCO furnished WPLR-FM, or any other person, with such require-I ments?
Provide a copy of all documents, including all correspondence and draf ts, relating to such requirements, i
Response: LILCO objects to Interrogatory no.18 because it seeks information that is not relevant to the subject matter of this proceeding and is not reasonably calculated to lead to the discovery of admissible evidence. The only admitted issues concern the ade-quacy of the EBS network's broadcast coverage within the 10-mile EPZ. The admitted contentions say nothing about signal testing or the requirements that such tests must satisfy. They go only to coverage. Thus, Interrogatory no.18 goes beyond the scope of the admitted contentions and is irrelevant to the coverage issue.
Without waiving this objection, LILCO states that the only "requirements" re-ferred to are that WPLR make a reasonable effort to participate in LERO drills (in ad-dition to the regular weekly EBS tests) when asked to do so by LILCO.
Suffolk County Interrogatory No.19 Describe in detail any test of, or attempt to activate or implement LILCO's EBS plan, in whole or in part, and equipment related thereto. Provide a copy of all docu-ments relating to any such activities.
Response: LILCO objects to interrogatory no.19 for the same reason it objected to in-terrogatory no.18, Lg, it is irrelevant to the narrow coverage issues raised in the ad-mitted contentions. To the extent Interrogatory no.19 seeks information concerning drills and exercises involving the EBS, LILCO objects for the same reasons it objected to Interrogatory no. 8.
I Notwithstanding and without waiving these objections, LILCO answers that one test of WPLR's signal is mentioned in LILCO's summary dispositbn motion (at page 9) and in the Crocker affidavit attached thereto (paragraph 6). A memorandum concern-ing this test, prepared by one of LILCO's onsite personnel, is enclosed with these re-sponses, in addition. LILCO responds that WPLR conducts weekly tests of its EBS sig-nal. During one such test, on January 21. WPLR's EBS test signal activated a tone alert receiver (like the ones in place at the other EBS stations) at Mr. Crocker's desk in the LILCO training center in Central Islip, New York. Mr. Crocker clearly heard the tone and EBS test message. Mr. Crocker's contemporaneous memorandum concerning the I
test is enclosed with these responses. During the EDS test on March 4, personnel from 4
l
station WGLI reported to LILCO that WPLR's EBS tone activated WGLl's EDS equip-ment, and the test message was clearly heard. Mr. Crocker's contemporaneous memo-randum memorializing this occurrence is also enclosed with these responses.
Suffolk County Interrogatory No. 20 LILCO states in its Motion that "... LILCO has provided or is providing each station with whatever additional equipment it needs to participate." Describe what ad-ditional equipment is required or necessary. Has such additional equipment been pro-vided to each station in LILCO's EBS plan? Provide all documents relating to the provi-sion of such additional equipment.
Response: LILCO objects to this Interrogatory on the ground that it seeks information that is not relevant to the subject matter of this proceeding and is not reasonably cal-culated to lead to the discovery of admissible evidence. The admitted contentions ad-cress only the adequacy of the EBS stations' signal coverage within the EPZ. Nowhere do the contentions mention the adequacy of EBS equipment or backup generating equip-ment provided to each station. Thus, Interrogatory no. 20 goes beyond the language of the admitted contentions and is not relevant to the admitted issues.
Notwithstanding and without waiving this objection. LILCO notes that Interve-nors already know what equipment has been provided to the participating stations. The equipment provided to WPLR is described in LILCO's summary disposition motion (at pages S-9) and is listed in detail in Attachment 4 to the motion. The equipment provid-ed to the other EBS stations is also described in the motion (at page 9); this equipment consists of a single-frequency broadcast receiver set to WPLR-FM's frequency, and an EBS tone-activated switch. Motion at 9.
All such equipment has been provided to WPLR and eight of the nine other EBS stations; the remaining station will receive its EBS equipment within the next few days.
Suffolk County Interrogatory No. 21 Identify all persons who have analyzed the type and directional orientation of antennas on Long Island for LILCO or on LILCO's behalf and state the conclusions of each such person. Provide all documents created by, for or under the supervision of such persons regarding such analyses.
Response: LILCO has not performed a detalled analysis on the directional orientation of antennas on Long bland.
Suffolk County Interrogatory No. 22 Provide a copy of all documents, including correspondence and draf ts, concern-ing any request of any person, including FEMA, to review LILCO's EBS proposal as well as the response to such request.
Response: LILCO objects to Interrogatory no. 22 on the ground that it seeks informa-tion that is not relevant to the EBS coverage issum ano is not reasonably calculated to lead to the discovery of admissible evidence on those issues. The identity of persons who may have asked to review the EBS plan is not likely to lead to the discovery of ad-missible evidence concerning the adequacy of broadcast coverage within the 10-mile EPZ.
Nothwithstanding and without waiving this objection, LILCO answers that the only responsive document that it is aware of is LILCO's cover !ctter accompanying LILCO's transmittal of Rev. 9 to the NRC. That letter, dated January 22,1988, was served on all parties by the NRC's docketing branch. The transmittal of Rev. 9, and the corresponding request by LILCO for the NRC to seek FEMA review of Rev. 9, were also mentioned in a January 27,1988 letter from LILCO counsel to the NRCt that letter was also copied to counsel for the other parties.
Suffolk County Interrogatory No. 23 llow will LILCO's EBS operate, as stated in LILCO's Motion, in "combination with the existing State EBS?" Provide a copy of all documents including correspondence and draf ts, concerning such combination.
Response: LILCO objects to Interrogatory no. 23 on the ground that it seeks informa-tion that is not relevant to the EBS coverage issues and is not reasonably calculated to lead to the discovery of admissible evidence on these issues. The only issues raised by the contentions admitted for litigation in the Board's February 24 Memorandum and Order concern the coverage of LILCO's EBS stations within the 10-mile EPZ. The ad-mitted contentions say nothing about the State EBS or how LILCO's EBS will operate in combination with it. Thus, Interrogatory no. 23 is outside the scope of the admitted contentions and is not likely to produce admissible evidence on the admitted conten-tions.
Notwithstanding and without waiving this objection, LILCO notes that the proce-dures for incorporating the State EBS into an emergency response are contained in OPIP 3.8.2 5 5.1.4 (Rev. 9), which LILCO distributed to the Intervenors on January 22, 1988.
Suffolk County Interrogatory No. 24 Identify all persons who participated in the draf ting, designing, preparing, re-viewing, revising, negotiating, or finalizing of LILCO's EBS plan.
Response: LILCO objects to Interrogatory no. 24 because it is irrelevant to the admit-ted coverage issues and is not reasonably calculated to lead to the discovery of admissi-ble evidence on the coverage issues. Moreover, LILCO objects to this Interrogatory to the extent it purports to include counsel for LILCO who may have participated in ac-tivities concerning the Shoreham EBS.
Without waiving these objections, LILCO lists below the persons primarily in-volved in the listed activities, and the general role or function each performed:
Ira L. Freilicher Policymaking; negotiation Douglas M. Crocker Policymaking; negotiation; procedure review John A. Weismantle Policymaking; negotiation; procedure review Charles A. Daverlo Policymaking; negotiation; procedure review Brant Aldikoff Procedure draf ting and developments Vicki Palmiotto Procedure review Ralph E. Dippell, Jr.
Participation in coverage studies Robert W. Guill Participation in coverage studies Sudhir K. Khanna Participation in coverage studies
Suffolk County Interrogatory No. 25 Provide all documents concerning the draf ting, designing, preparing, reviewing, revising, negotiating or finalizing of LILCO's EBS proposal.
Response: LILCO objects to Interrogatory no. 25 on relevance grounds, except to the extent it seeks documents concerning the coverage issues raised in the admitted con-tentions.
Documents concerning "the draf ting, designing, preparing, reviewing, revising, negotiating, or finalizing of LILCO's EDS proposal" are not relevant, except to the extent they address the adequacy of the EBS stations' broadcast coverage within the 10-mile EPZ.
Without waiving this objection, LILCO states that, to the best of its knowledge, there are no responsive documents in addition to those provided with the Nov. 6 sum-mary disposition motion, LILCO's voluntary production of documents on March 1, and those referred to in connection with Interrogatory nos. 12,14,15, and 18. LILCO will continue to search for relevant documents and will promptly produce any that are found.
Suffolk County interrogatory No. 26 One of the Cohen and Dippell reports contains information pertaining to WEZN, which is not a participating station in LILCO's EBS. Why was this study of WEZN con-ducted? Why is WEZN not included in LILCO's EBS? Provide all documents concerning whether or not to include WEZN in the EBS.
l Response: LILCO objects to Interrogatory no. 26 on the grounch that it is not relevant to the admitted issues and is not reasonably calculated to lead to admissible evidence on the admitted issus. All that is at issue in this proceeding is the adequacy of broadcast coverage within the EPZ of the stations in the Shoreham EBS. As the Interrogatory ex-pressly states, "WEZN is not a participating station in LILCO's EBS." Therefore, Inter-rogatory no. 26 is not relevant. Moreover, the Board ruled in its February 24 Memoran-dum and Order that evidence concerning WALK radio, the former lead EBS station, is irrelevant and will not be heard. A fortiori, evidence concerning WEZN, a station that I
is not participating in the EBS and never ha_s participated in the EBS, is totally irrele-l vant to the issues open to litigation in this proceeding.
l l
Sulfolk County Interroratory No. 27 Provide copies of any documents relating to LILCO's EBS plan that were not pre-vlously produced or called for by the above.
Response: To the best of LILCO's knowledge, there are no other relevant documents relating to the coverage of the Shoreham EBS that were not already produced by LILCO or called for by Interrogatories 1-26.
Objections Stated by Counsel All objections and references to objections were stated by courtsel.
Respectfully submitted,
'~p)
Scott D! Match'ett
(
Counsel for Long Island Lighting Compa liunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: March 7,1988
LILCO, March 7,1988 00(,htiED usNRC
'88 g.-9 N0:23 CERTIFICATE OF SERVICE In the Matter of f0C' 1f LONG ISLAND LIGHTING COMPANY SaANCH (Shorcham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 Ihereby certify that copies of LILCO'S RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRO-DUCTION OF DOCUMENTS REGARDING EMERGENCY BROADCAST SYSTEM were served this date upon the following by telecopier as indicated by one asterisk, by Feder-al 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 Fanel 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 Commission 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 Alfred 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
[
r Spence W. Perry, Esq. **
Jonathan D. Ft!!nberg, Esq.
William R. Cumming, Esq.
New York State Department of Federal Emergency Management Public Service, Staff Counsel Agency Three Rockefeller Plaza 500 C Street. S.W., Room 840 Albany, New York 12223 Washington, 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
/14/
Ma Jo rs Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: March 7,1988 i
G VERIFICATION Douglas M. Crocker, being first duly sworn on oath, deposes and says:
that he is currently the Manager, Nuclear Emergency Preparedness, Nuclear Operations Support Department for Long Island Lighting Company; that he has personal knowledge of a portion of the subject matter of this litigation; that responsible corporate employees have provided him with additional facts necessary to provide the information contained in the foregoing Answers to Interrogatories; that he has read the answers, and knows the contents thereof; and that based upon such information of which he has personal knovicdge and with which he has been provided, he is informed and believes the matters stated therein to be true, and on these grounds allegss that the matters stated therein are true and therefore verifies the forgoing on behalf of Long Island Lighting Company.
/
' Douglas M.
Crocker State of New York SS:
/0 I,
NMbe a Notary Public in and for the ju id ceion afor y ld, hereby certify that Douglas M.
Crock hose name is sj.gned to the foregoing Answers to Inter atories, dated 97/M 2 /PJP,1988, has personally sworn before me that the statedents therein are true to the best of his knowledge and belief.
/m.~,
i M
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.ioAN M. WmotN
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