ML20207Q321
| ML20207Q321 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/16/1987 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2281 OL-3, NUDOCS 8701270162 | |
| Download: ML20207Q321 (11) | |
Text
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pc4 LILCO, January 16, 1987 DCOnRES g
00LKETED Ui!4PC UNITED STATES OF AMERICA.
NUCLEAR REGULATORY COMMISSION
'87 JAN 23 P1 26 Before the Atomic Safety and Licensing Board
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In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
) (Reopened Reception Center Issue)
Unit 1)
)
LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTERS TO SUFFOLK COUNTY AND NEW YORK STATE Long Island Lighting Company, by its counsel, propounds the following interroga-tories to Suffolk County and New York State ("Intervenor" or "the Intervenors"), pursu-ant to 55 2.740,2.740b, and 2.741 of the Nuclear Regulatory Commission's Rules of Practice. By propounding these interrogatories LILCO makes no admission or represen-tation about the proper scope of the issues to be decided or the evidence that may be presented on the adequacy of LILCO's proposed reception centers.
INSTRUCTIONS A.
Each interrogatory shall be answered separately and fully in writing under oath in accordance with S 2.740b of the NRC's Rules of Practice. To the extent that i
Intervenors do not have specific, complete, and accurate information with which to an-swer any interrogatory, Intervenors should so state, and the interrogatory should be an-swered to the extent information is available, identifying each person who is believed to have accurate information with respect thereto. Where exact information is not i
available, estimated information should be supplied; the answer should state that the in-formation is an estimate and the basis on which the estimate was made. Where app'ro-priate, the upper and lower boundaries of the estimate should be given.
1 G
iso 3
9 B.
Each interrogatory shall be deemed to be continuing, and Intervenors are requested seasonably to supplement' answers with additional facts, documents, informa-tion and names of witnesses which become known,in accordance with S 2.740(e)(1) and (2) of the NRC's Rules of Practice.
C.
The words "and" and "or" shall be construed either conjunctively or disjunc-tively so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
D.
Wherever appropriate, the singular form of a word shall be interpreted in the plural, and vice versa, so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
E.
Wherever appropriate, the masculine form of a word shall be interpreted as feminine, and vice versa, so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
F.
Please produce each document in the form and condition in which it exists on the date of service of this request, including all comments, notes, remarks, and other material that may have been added to the document af ter its initial preparation.
G.
If Intervenors object to or claim a privilege (attorney-client, work product, or other) with respect to any interrogatory or document request, in whole or in part, or seek to withhold documents or information because of the alleged proprietary nature of the data, please set forth all reasons and the underlying f actual 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 Intervenors should include with respect to any document: (1) author, addressor, addressee, recipients of in-dicated and " blind" copies together with their job titles; (2) date of preparation; (3) sub-ject matter; (4) purpose for which the document was prepared; (5) all persons to whom distributed, shown, or explained; (6) present custodian; (7) all persons believed to have a copy of the document; and (8) the nature of the privilege or objection asserted.
O
_.5(- -H.
For any document or part of a document that was at one time, but is no longer, in Intervenors' possession, custody, or control, or which is no longer in exis-tence, or which cannot be located or produced, identify the document, state where and how it passed out of existence or why it can no longer be located and the reasons there-for, and identify each person having knowledge concerning such disposition or loss and the contents of the document, and identify each document evidencing its prior exis-tence and/or any f act concerning its nonexistence or loss.
I.
When, in order to answer a question fully or accurately, it is necessary to distinguish between the responses of individual Intervenors or to identify individual In-tervenors, such distinctions or identifications should be made in the answer.
DEFINITIONS A.
" Person" means any individual, corporation, partnership, unincorporated as-sociation, joint venture, government or agency thereof, or other legal entity or form of organization or association.
B.
" Document" means the original and each copy, regardless of origin or loca-tion, of any written, typed, printed, recorded or graphic material, however produced or reproduced, or any tangible thing that in whole or in part illustrates or conveys infor-mation, including but not limited to papers, letters, notes, books, correspondence, memoranda, interoffice or intraoffice communications, corporate records, memoranda or minutes of meetings, or conversations whether personal or telephonic, cablegrams, mailgrams, telegrams, reports, summaries, surveys, analyses, studies, calculations, pro-jections, ledgers, journals and other formal or informal books of record or account, bul-l letins, notices, announcements, advertisements, catalogs, manuals, instructions, agree-ments, contracts and other legal documents, notebooks, clippings, vouchers, checks and draf ts, bills, receipts, invoices, calendars, appointment books, diaries, preliminary draf ts and working papers, drawings, sketches, graphs, charts, plans, specifications,
O'
~ Q blueprints, photographs, films, videotapes, tapes, recordings, computer-stored and computer-retrievable information, annotations or markings appearing on any document or thing, and all other writings and recordings of every description, however denominated, translated or described.
C.
" Communication" includes every exchange of information by any means including but not limited to personal or telephonic.
4 D.
"LILCO" or "LILCO personnel" means Long Island Lighting Company and any affiliate, agent, employee, consultant, contractor, technical advisor, representa-tive, or other person acting for on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.
i E.
"Shoreham" means the Shoreham Nuclear Power Station, Unit 1, any part ther30f, or any structure, system, component, instrumentation, equipment, or materials included in, or intended to be included in, Shoreham.
F.
"Intervenors" means Suffolk County, New York State, and the Town of Southampton, or any of them, or any agency thereof and any agent, employee, consul-tant, contractor, technical advisor, representative or other person acting for or on be-half of them, or at their direction and control, or in concert with or assisting them.
G.
" Contractor" means any person, not affiliated with Intervenors, who per-i i
formed work concerning Shoreham on behalf of Intervenors and/or pursuant to a con-tract with Intervenors or sub-contractors who performed work on behalf of a contrac-tor with whom the person was not affiliated and pursuant to a contract with such contractor. A person other than a contractor, who contracts with the sub-contractor, i
shall be deemed a sub-contractor.
H.
" Concerns," "concerning," or any other derivative thereof, includes refer-ring to, responding to, relating to, pertaining to, in connection with, comprising, memoralizing, commenting on, regarding, discussing, showing, describing, reflecting, analyzing, supporting, contradicting, and constituting.
7 I.
" Identify" when used in reference to a natural person means to set forth the following:
1.
his name; 2.
his last known residential address; 3.
his last known business address; 4.
his last employer;.
5.
his title or position; 6.
his area of responsibility; 7.
his business, professional, or other relationship with Intervenors; and 8.
If any of the above information is changed subsequent to the time period referenced in a particular interrogatory, set forth in the an-swer, and label appropriately, current information as well as the in-formation applicable to the time period referenced in the interroga-tory.
J.
" Identify" when used in reference to a corporation or other entity that is not a natural person shall mean to set forth the following:
1.
the full name of such person, including its legal name and any as-sumed or trade names under which it transacts or has transacted business; 2.
the nature or form of such a person, if known; 3.
the address of its principal place of business or the principal place where such person is to be found; a
4.
whether Intervenors have or have had any relationship or affiliation i
with such person, its affiliates or subsidiaries, and, if so, a descrip-l tion of such relationship; and f
5.
if any of the above information has changed su'mequent to the time period referenced in a particular interrogatory, set forth in the an-swer, and label appropriately, current information as well as the in-formation applicable to the time referenced in the interrogatory.
i K.
" Identify" when used in reference to a document shall mean to set forth the following:
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O 7 _
1.
Its title; 2.
Its subject matter; 3.
Its date:
4.
Its author; 5.
Its addressee; 6.
Its file designation or other identifying designation; and 7.
Its present location and present custodian.
L.
" Identify" with respect to a contact or communication shall mean to set
- forth the following:
1.
the date of the communication; 2.
the place of the making and place of receipt of the communication; 3.
the type and means of communication; i
4.
the substance of the communication 5.
each person making a communication, and his location at the time the communication was made:
4 6.
each person to whom the communication was made, and his location l
at the time the communication was made; 1
7.
all other persons present during, participating in or, receiving the communication and the location of each such person at the time; 8.
each document concerning such communication; and S.
each document upon which the communication is based or which is referred to in the communication.
M. " Analysis" means rescarch, investigation, audit, inspection, review, evalua-tion, testing, monitoring, or any other method or form of examining data and/or forming conclusions or recommendations.
N.
"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, 4
consultant, contractor, technical advisor, employee, or representative of the NRC.
2
-7 O.
" FEMA" means the Federal Emergency Management Agency and its staff, any division or section or region thereof, any staff member thereof, or any agent, con-sultant, contractor, technical advisor, employee, or representative of FEMA.
P.
" Reception Centers" means the three reception centers that are presently designated in the LILCO offsite plan, Revision 8, namely LILCO's Hicksville, Bellmore, and Roslyn Operations Centers.
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Identification of Witnesses 1.
Please identify each witness Intervenors expect to call to testify on factors that might make the Reception Centers unsuitable to serve as reception centers for EPZ evacuees. For each witness, other than experts, that In-tervenors expect to call, state the subject matter on which he is expected to testify and the substance of the facts to which he is expected to testify.
For each witness that Intervenors expect to call as an expert witness, state 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 opinion.
2.
For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional qualifications.
3.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on any matter concerning the care of evacuees from or other victims of large-scale disasters or emergencies.
4.
Please provide a copy of any prefiled testimony listed in response to Inter-rogatory 3 above.
~.
4 T ' 5.
Please identify all articles, papers, and other documents authored or co-authored by each witness on the subject of the care of evacuees from, or other victims of, large-scale disasters or emergencies.
6.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses, or other documents with respect to any of the following:
(a)
Care of evacuees from, or other victims of, large-scale disasters or emergencies.
(b)
Monitoring of people or vehicles for radiological contamination.
(c)
Decontaminating people who have been contaminated by radioactive materials.
(d)
Handling or disposal of radioactive waste or of things contaminated by radioactive materials.
7.
Unless the answer to Interrogatory 6 above is a simple negative, please identify and provide a copy of each document.
Identification of Other Documents 8.
Please identify and provide a copy of any document not already identified in response to Interrogatory 7 above on which Intervenors intend to rely in support of their position on the suitability of LILCO's Reception Centers.
Alleged Deficiencies in LILCO's Reception Centers or the Plan for Using Them 9.
Please list each and every factor that Intervenors claim might make the Reception Centers unsuitable to serve as reception centers for EPZ evacuees.
4 A \\
10.
To the extent not covered by the answer to Interrogatory 9 above, please list every respect in which Intervenors claim that LILCO's plan or proce-dures for operating the Reception Centers are inadequate.
l 11.
Please provide an up-to-date list of all relocation centers (including recep-tion centers, congregate care centers, and facilities combining both func-tion-) designated under emergency plans for nuclear power plants in New York State other than Shoreham.
12.
For each relocation center listed in response to Interrogatory 11 above,
, tate why that relocation center is acceptable to New York State in con-trast to LILCO's Reception Centers, which are not acceptable to the State.
Distinguish the other New York relocation centers from LILCO's Reception Centers with respect to each factor listed in response to Interrogatory 9 above.
.O W James N. Chfistman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 16,1987
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LILCO, January 16,1987 I
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'87 JAN 23 P1 :26 CERTIFICATE OF SERVICE Off:n e. :Pvmt
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50CKf Ti401 In the Matter of gu gn LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Reception Centers to Suffolk County and New York State were served this date upon the following by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, post-age prepaid.
Morton B. Margulies, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers, Rm. 407 4350 East-West Hwy.
Atomic Safety and Licensing Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, D.C. 20555 Atomic Safety and Licensing Board Bernard M. Bordenick, Esq.
U.S. Nuclear Regulatory Commission Oreste Russ Pirfo, Esq.
East-West Towers, Rm. 427 Edwin J. Reis, Esq.
4350 East-West Hwy.
U.S. Nuclear Regulatory Commission Bethesda, MD 20814 7735 Old Georgetown Road (to mailroom)
Mr. Frederick J. Shon Bethesda, MD 20814 Atomic Safety and Licensing Board Herbert H. Brown, Esq.
- U.S. Nuclear Regulatory Commission Lawrence Coe Lanpher, Esq.
East-West Towers, Rm. 430 Karla J. Letsche, Esq.
4350 East-West Hwy.
Kirkpatrick & Lockhart Bethesda, MD 20814 South Lobby - 9th Floor 1800 M Street, N.W.
Secretary of the Commission Washington, D.C. 20036-5891 Attention Docketing and Service Section Fabian G. Palomino, Esq.
- U.S. Nuclear Regulatory Commission Richard J. Zahnleuter, Esq.
1717 H Street, N.W.
Special Counsel to the Governor Washington, D.C. 20555 Executive Chamber Room 229 State Capitol Albany, New York 12224
j Mary Gundrum, Esq.
Jonathan D. Feinberg, Esq.
Assistant Attorney General New York State Department of 120 Broadway Public Service, Staff Counsel Third Floor, Room 3-116 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 Spence 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 Gerald C. Crotty, 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 Martin Bradle Ashare, Esq.
Stephen B. Latham, Esq.
Eugene R. Kelly, Esq.
Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 ew^^ -
?7' ames N. Christinan Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 16,1987 i
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