ML20207C112
| ML20207C112 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/19/1986 |
| From: | Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#486-1983 OL-5, NUDOCS 8612300053 | |
| Download: ML20207C112 (9) | |
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DOCKEIED U5NRC December 19E1988 23 P4 56 UNITED STATES OF AMERICA CFF F NUCLEAR REGULATORY COMMISSION I'07 Before the Atomic Safety and Licensina Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(S.oreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON SECOND SET OF INTERROGATORIES TO LILCO Suffolk County, State of New York, and Town of Southampton
(" Governments"), by their counsel, propound the following Interrogatories and Requests for Production of Documents to Long Island Lighting Company ("LILCO"), pursuant to SS 2.740, 2.740b, and 2.741 of the Nuclear Regulatory Commission's Rules of Prac-tice.
In responding to these interrogatories and requests for production, LILCO should follow the instructions and definitions contained in Suffolk County's First Set of Interrogatories and Request for Production of Documents to Long Island Lighting Company dated October 10, 1986.
8612300053 861219 PDR ADOCK 05000322 5
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. By propounding Interrogatory No. 1 below, the Governments do not waive their position, as stated in State of New York's Response to LILCO's First Set of Interrogatories, dated November 19, 1986, State of New York's Opposition to LILCO's Motion to Compel, dated December 4, 1986, and Suffolk County's Opposition to LILCO's Motion to Compel, dated December 4, 1986, that infor-mation about exercises other than the February 13 Shoreham Exercise is not relevant to the admitted contentions in this proceeding.
And, if the Governments' position is upheld by the ASLB in rulings on LILCO's Motion to Compel, the Governments will withdraw Interrogatory No. 1.
However, in light of the December 19 cutoff for non-deposition discovery, and in order to protect their rights should LILCO's Motion be granted, the Governments must propound this Interrogatory now.
INTERROGATORIES 1.
Identify each non-Shoreham exercise upon which LILCO intends to rely in support of its position on admitted Exercise contentions, and with respect to each such exercise identify the followings a.
Date of the exercise; b.
Plant (s) or facility (ies) to which the exercise related; c.
Location (s) of facilities identified in response to (b);
l d.
Participants in the exercise; 1
1 f
c.
f e.
Contentions.as to which LILCO intends to rely upon the exercise to support its position; f.
All facts about, or data relating to, the exercise upon which LILCO intends to rely; 9
Documents, concerning the exercise, upon which LILCO intends to rely; h.
Any other documents concerning the exercise known to LILCO, whether LILCO intends to rely upon them or not.
2.
Identify the times at which each of the following LERO News Releases were made available to the press during the February 13 Exercise and for each state how it was made available and by whom a.
LERO News Release #1; b.
LERO News Release #2; c.
LERO News Release 83; d.
LERO News Release #4; e.
LERO News Release #5; f.
LERO News Release #6; g.
LERO News Release #7; h.
LERO News Release #8; i.
LERO News Release 59.
3.
Identify the times at which each of the following LILCO News Releases were made available to the press and for each state how it was made available and by whom:
. a.
LILCO News Release #1; b.
LILCO News Release #2; c.
LILCO News Release #3; d.
LILCO News Release #4; e.
LILCO News Release #5; f.
LILCO News Release #6; g.
LILCO News Release #7; h.
LILCO News Release 48; i.
LILCO News Release #9; j.
LILCO News Release #10; k.
LILCO News Release #11; 1.
LILCO News Release #12; m.
LILCO News Release #13; n.
LILCO News Release #14; o.
LILCO News Release #15; p.
LILCO News Release #16; q.
LILCO News Release #17; r.
LILCO News Release #18; s.
LILCO News Release #19.
4.
Identify all hospitals, special facilities, adult or nursing hcmes (other than the Central Suffolk Hospital, the Oak Hollow Nursing Center and Crest Hall Health Related Facility and the Riverhead Nursing Home and Health Related Facility),
t i
. if any, which actually participated in the Exercise, or were consulted or contacted by LERO personnel during the Exer-cise.
5.
With respect to each hospital, facility, or home identified in response to Interrogatory No. 4 above, identify who made the contact or consultation, and the nature and substance of the contact or consultation.
6.
State how many route alert drivers were dispatched during the Exercise to notify the ambulatory deaf.
7.
State when, if ever, during the Exercise, LERO or LILCO personnel at the ENC informed the media that LERO workers had been instructed to ingest KI (potassium iodide), and if the media was so informed, identify who did so and by what 1
means.
8.
State how many road crew members had reported to the Patchogue Staging Area as of 10:20 a.m. on the day of the Exercise.
. - ~.
S 9.
Identify the time (s) during the Exercise when LERO bus drivers were dispatched from:
a) the Patchogue Staging Area; and b) the Riverhead Staging Area, to pick up their buses from bus company yards and, thereafter, to proceed to their assigned bus transfer points.
10.
State, as of the time of the Exercise, how many school bus drivers had been trained in potassium iodide policy or use and describe the training.
11.
State, as of the time of the Exercise, how many school bus drivers had been supplied with dosimetry equipment.
12.
State the precise text of each EBS message aa " issued" during the Exercise.1 Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex i
Veterans Memorial Highway Hauppauge, New York 11788
/
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K(rl4 J. Letschf u Susan M. Casey' KIRKPATRICK & LOCKHART South Lobby - 9th Floor 1800 M Street, N.W.
Washington, D.C. 20036-9581 Attorneys for Suffolk County 1
The Governments have received the messages as drafted and marked up during the Exercise.
However, many of the markups and deletions are unclear, thus necessitating this Interrogatory.
. t Fabian G. Paloihino Richard J. Zahnleuter Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for Mario Cuomo, Governor of the State of New York Step 3 B.
Latham bh
/W (Twom<p,Latham&Shea
/
.y P.O. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton December 19, 1986 1
l
DCULIEi
' nl Decemby lag g8s4 :56 UNITED STATES OF AMERICA C F F i '..,
ar,
NUCLEAR REGULATORY COMMISSION 00CM i
.vn Before the Atomic Safety and Licensina Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON SECOND SET OF INTERROGATORIES TO LILCO have been served on the following this 19th day of December, 1986 by U.S. mail, first class, except as otherwise noted.
John H. Frye, III, Chairman Dr. Oscar H. Paris 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 Mr. Frederick J. Shon Spence W. Perry, Esq.
Atomic Safety and Licensing Board William R. Cumming, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W.,
Room 840 Washington, D.C.
20472 l
f f
Anthony F. Earley, Jr., Esq.
Bernard M. Bordenick, Esq.
General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 Mr. William Rogers W. Taylor Reveley, III, Esq.*
Clerk Hunton & Williams Suffolk County Legislature P.O. Box 1535 Suffolk County Legislature 707 East Main Street Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 MHB Technical Associates Hon. Peter Cohalan 1723 Hamilton Avenue Suffolk County Executive Suite K H. Lee Dennison Building San Jose, California 95125 Veterans Memorial Highway Hauppauge, New York 11788 Martin Bradley Ashare, Esq.
Fabian G. Palomino, Esq.
Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 David A. Brownlee, Esq.
Mr. Philip McIntire Kirkpatrick & Lockhart Federal Emergency Management 1500 Oliver Building Agency Pittsburgh, Pennsylvania 15222 26 Federal Plaza New York, New York 10278 dd Oa By Federal Express Karl a J. Letse.
KIRNPATRICK &
OCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891