ML20210A803
| ML20210A803 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/04/1987 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2450 OL-3, NUDOCS 8702090017 | |
| Download: ML20210A803 (29) | |
Text
.
g5O LILCO, February 4,1987 RELATED CGK%SVONDEngq DOMEIU N'T UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 FEB -6 A10:04 Before the Atomic Safety and Licensing Board jffb C -
0 n ;< :,
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
liLCO'S RESPONSES AND OBJECTIONS TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTER ISSUES DATED JANUARY 21,1987 LILC'O hereby responds to the "Suffolk County, State of New York and Town of Southampton's Interrogatories and Request for Production of Documents to LILCO Re-garding Reception Center Issues," dated January 21,1987.
I.
GENERAL ANSWERS AND OBJECTIONS TO ALL INTERROGATORIES, DEFINITIONS AND INSTRUCTIONS A.
All documents referenced in these answers which are not enclosed will be provided within the 30-day production period (that is, by February 20,1987) to the ex-tent LILCO does not object to their production. In some instances, LILCO may make the documents available for inspection at LILCO's place of business within the 30-day production period.
B.
LILCO continues to object to that portion of Suffolk County's definition V.(4) which seeks to include the " medical drill" held on February 9,1986 in the exercise litigation, though the objection is not relevant to these responses.
C.
LILCO continues to object to Paragraph L of Suffolk County's Definitions and Instructions on the ground that disclosure of such information would constitute an invasion of privacy of those individuals, which may subject them to harassment and intimidation.
)gh 8702090017 870204 PDR ADOCK 05000322 G
PDR l
D.
LILCO objects to the inclusion of attorneys in the definition of "LILCO or "LILCO personnel" in paragraph H 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.
E.
LILCO objects to all interrogatories, definitions and instructions insof ar as they require the disclosure of any information subject to the attorney-client privilege or work product doctrine.
F.
LILCO objects to allinterrogatories insofar as they purport to require in-formation outside the possession, custody or control of LILCO.
II.
ANSWERS AND OBJECTIONS TO INTERROGATORIES Intervenors' Interrogatory No.1 4
Identify each person whom LILCO expects to call as an expert or non-expert witness during the reception center hearings and state the subject matter on which each such witness is expected to testify. For each expert witness identified, state the substance of the facts and opinions to which such witness is expected to testify, and a summary of the grounds for each such opinion.
Response: As of this date, LILCO plans to present a panel of five expert witnesses:
Charles A. Daverio Dale E. Donaldson Edward B. Lieberman Roger E. Linnemann l
Richard J. Watts The following description of what these witnesses are expected to testify and l
l the bases for their testimony is accurate as of this date, but of course the testimony may be refined, modified, and supplemented as trial preparation continues.
Charles A. Daverlo - Mr. Daverio will describe the monitoring and decontamination procedures and testify that they are workable and that the equipment is available and the personnel adequate to implement them. He may also address the need for approvals under state environmental laws, based on his knowledge of the prac-tice at other nuclear plants. He may address the number of people likely to be monitored in an emergency.
i
Dale E. Donaldson - Mr. Donaldson may testify as to the adequacy of the proce-dures, equipment, and staffing for monitoring and decontamination. He may also testi-fy about the number of people likely to be monitored. Finally, he may be called upon to offer insight into the meaning of the guidance in NUREG-0654; these opinions will be based on his experience in the NRC, during which he participated in the draf ting of N UREG-0654.
Edward B. Lieberman - Mr. Lieberman will support LILCO's estimates of the number of vehicles that can be brought into the reception centers in about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and
. will testify that transportation and traffic problems would not make the reception cen-ters unsuitable. His opinions will be based on his own analysis, as described in KLD As-sociates, Inc., Capacity Analysis of Highways in the Vicinity of Reception Centers for Evacuees from within the Shoreham Station Emergency Planning Zone (September 26, 1986), and the 1985 Highway Capacity Manual, Special Report 209 by the Transporta-tion Research Board. (A copy of the Capacity Analysis document will be delivered to Suffolk County and New York State counsel on February 5,1987.)
Roger E. Linnemann - Dr. Linnemann is expected to testify about the medical aspects of radioactive contamination, particularly the expected public health and safe-ty impact of traveling to the reception centers. He will base his testimony on his expe-rience in radiological health and safety, as reflected in his resume.
Richard J. Watts - Mr. Watts is expected to describe how LILCO plans to moni-tor and, if necessary, decontaminate members of the public at the reception centers.
He is expected to testify about how washwater from the decontamination process would be contained; that the procedures, equipment, and staffing for monitoring and decontamination are adequate; that LILCO's proposal to transport evacuees traveling on buses to the Hicksville facility is workable; and that the proposal to send evacuees to LILCO parking lots could and would be implemented so as to protect the public health
4
. t and safety. He will base these opinions on his training as a health physicist and his ex-perience in developing the LILCO plan, as well as his experience working as a health physicist for other nuclear power plant licensees.
It is possible that additional witnesses will be designated, particularly if the In-tervenors raise issues that appear to call for additional witnesses. If so, LILCO will ad-vise the Intervenors.
Intervenors' Interrogatory No. 2 Provide an up-to-date resume for each witness identified in response to Interrog-atory No.1.
Response: Resumes for Messrs. Daverio, Lieberman, and Watts were provided on November 10,1986, in the -05 proceeding. Resumes for Mr. Donaldson and Dr.
Linnemann are enclosed. Mr. Donaldson is now Manager of Radiological Engineering Services at Hydro Nuclear Services rather than Director, Radiological Services Divi-sion, as shown on his resume, but his duties are substantially the same as before.
In addition to the " selected publications' listed on Mr. Lieberman's resume, Mr.
Lieberman has written two papers that have not yet been published. Both were pres-ented at a Transportation Research Board meeting in January 1987. One is about an en-hancement of a freeway model dealing with traffic congestion, and the other deals with interactive computer graphics for use with a traffic model. LILCO will provide copies by February 20.
Intervenors' Interrogatory No. 3 Identify all studies, papers, articles, reports, books, and other such documents, published or unpublished, upon which each witness identified in response to Interrogato-ry No.1 intends to rely in support of his or her testimony. Provide a copy of all items identified in response to this interrogatory, except that those items readily available in the public domain need not be provided.
Response: At present the documents on which LILCO foresees that it may rely on in its testimony are the following:
6-1.
Figure 4.2.1 of the emergency plan (Rev. 8).
2.
OPIP 4.2.3 (Rev. 8) or portions thereof.
3.
Guidance memorandum on NUREG-0654/ FEMA-REP-1 Evaluation Criterion J.12, from Richard W. Krimm, dated December 24,1985, with attachments.
4.
KLD Associates, Inc., Capacity Analysis of Highways in the Vicinity of Re-ception Centers for Evacuees from within the Shoreham Station Emergency Planning Zone (September 26,1986).
5.
Letters of August 29,1983, and November 16,1983 from Donald B. Davidoff of New York State's Radiological Emergency Preparedness Group to George Brower, Director, Disaster / Emergency Preparedness.
6.
The information about locations of relocation centers attached to Stewart Glass's letter of February 12, 1985, to Michael S. Miller.
7.
Proposed draf ts of revisions to OPIP 3.9.2, 4.2.3, and/or 4.3.1 and proposed revisions of the relevant sections of the emergency plan.
8.
NUREG-0396 and NUREG-0654.
Inter'venors already have all these documents except no. 7. LILCO expects to provide draf t revisions of procedures and plan to Intervenors by February 20,1987.
Witnesses will also rely on the general body of literature in their fields and may also rely on the papers they have authored, as listed on their resumes. LILCO believes these papers are already available to Intervenors, except possibly for publication no. 30 on Dr. Linnemann's resume. LILCO expects to provide Intervenors a copy of that arti-cle by February 20,1987.
l Intervenors' Interrogatory No. 4 I
Identify by date, location and proceeding all prior testimony before any judicial, l
administrative, or legislative body, including deposition testimony, given by each of the I
witnesses identified in response to Interrogatory No.1 concerning any aspect of emer-gency preparedness.
I Response: Dr. Linnemann's prior testimony is listed on his resume, a copy of which is enclosed. Added to that list should be his testimony in the St. Lucie proceeding: Flor-Ida Power and Light Co. (St. Lucie Nuclear Power Project, Unit No. 2), Docket No. 50-389, in Stuart, Florida, in October 1974 and December 1976.
I
The locations of Dr. Linnemann's other testimony, to the best of his recollection, were Philadelphia (Limerick proceeding), Perryville, Ohio (Cleveland Electric Company proceeding), New York City (August 25,1982 deposition in Shoreham case), Fulton, Missouri (Callaway proceeding), Berwick, Pennsylvania (Susquehanna proceeding),
Granbury, Texas (Comanche Peak), Miami, Florida (Turkey Point), Anaheim, California (San Onofre), Hanover, Germany (Gorleben), Stony Brook, New York, (Shoreham 1971),
Prince Frederick, Maryland (Calvert Cliffs), and New London and Waterbury, Con-necticut (Millstone).
The third item of professional testimony on Dr. Linnemann's resume should refer to Duquesne Light Company instead of Pennsylvania Power Company. The testimony was presented, to the best of Dr. Linnemann's recollection, in the vicinity of the Bea-ver Valley nuclear plant.
Mr. Donaldson testified before the ASLB in the Three Mile Island restart pro-ceeding in approximately February or March 1980. He was deposed for an investigation of the NRC's response to the TMI accident by the NRC Office of the Executive Legal Director in about July 1980.
Information about the previous testimony of Messrs. Watts, Daverio, and Lieberman has already been provided to the Intervenors in the -05 proceeding; in addi-tion, those three people, as Intervenors know, were recently deposed in the -05 pro-ceeding.
Intervenors' Interrogatory No. 5 Identify all articles, papers, and other documents authored or co-authored by each LILCO witness identified in response to Interrogatory No.1 on the subject of re-ception centers, care of evacuees during emergencies, monitoring or decontamination i
of people or property, handling contaminated materials, traffic engineering or manage-l ment, or the number of persons expected to arrive at LILCO's reception centers for monitoring. Provide a copy of each document identified in response to this interrogato-ry.
i
Response: This information has already been provided in the -05 proceading for Messrs.
Watts, Daverio, and Lieberman. Dr. Linnemann's and Mr. Donaldson's publications are listed on their resumes. In addition, Mr. Donaldson contributed to a Temporary Instruc-tion document setting forth inspection techniques for the NRC's Emergency Prepared-ness Appraisal Program.
Of the publications listed on Dr. Linnemann's resume, nos. 3-6,9-11, and 14-30 address monitoring or decontamination or handling of contaminated materials or relat-ed matters. No. 30 addresses reception centers and care of evacuees during emergencies.
Richard Watts has written a progress report, in the summer of 1986, regarding the available monitoring instruments and their pros and cons. This will be provided to Intervenors by February 20,1987.
Intervenors' Interrogatory No. 6 Identify all documents concerning the use of LILCO's Hicksville, Bellmore, and Roslyn Operations Centers as reception centers. Provide a copy of each document identified in response to this interrogatory.
Response: Such documents are identified in response to Interrogatories 3,5, 8, and 15.
Also, the following documents are in the custody of Jeff Sobotka at LERIO's headquar-ters at 140 Hoffman Lane, CentralIslip, New York 11722:
1.
Construction specifications and commercialinformation about the moni-toring/ decontamination trailers and 2.
Documents about storage tanks used to collect washwater.
Also, Brant Aidikoff has a file with reception center-related documents at LERIO head-quarters. Documents from this file will be produced for the Intervenors by February 20 to the extent the Intervenors do not already have them and they are not covered by j
attorney-client or work product privilege.
Intervenors'Interroratory No. 7 Identify the number of evacuees which LILCO estimates will arrive at LILCO's reception centers for monitoring in the event of a radiological emergency at Shoreham and state whether LILCO's Plan or procedures reflect this estimate as a planning basis.
Response: LILCO estimates that up to 20% of the population of the plume EPZ, or 32,000 people, might arrive at reception centers for monitoring. LILCO bases this esti-mate on FEMA guidance, namely the December 24,1985 guidance memorandum from Richard W. Krimm. It is possible that more people might need monitoring, depending on the nature of the accident.
LILCO is prepared to monitor more than 20% if necessary. LILCO's current esti-mate is that LERO can monitor 30-35% of the plume EPZ population (monitoring all passengers in cars)in about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, using a procedure that will be produced for Inter-venors, in draf t, by February 20,1987. By calling in additional resources from the Insti-tute of Nuclear Power Operations this figure could be bettered. By using the moni-toring method described in Revision 8 of the emergency plan the figure would be close to 100%.
Intervenors' Interrogatory No. 8 Describe how the estimate provided in response to Interrogatory No. 7 was de-rived and state all f acts and opinions on which the estimate is based.
Response: As stated above, the 20% estimate is based on FEMA guidance. The 30-35%
estimate is based on a summary of time trials for vehicle occupant monitoring, dated January 5,1987, and prepared by Richard Watts (copy provided to Suffolk County and New York State with these answers), and on the information in Revision 8 of the emer-gency plan and procedures. The 100% is based on a calculation using the information in Revision 8 of the plan and procedures.
Intervenors' Interrogatory No. 9 Identify each factor that LILCO claims makes its reception centers suitable to serve as reception centers for EPZ evacuees.
Response: The factors that make the three reception centers suitable are that they comply with NRC and FEMA regulations and guidelines. In particular:
a.
"A range of protective actions have been developed for the plume exposure pathway EPZ for... the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance are devel-oped and in place,..." as required by 10 C.F.R. S 50.47(b)(10)(1986).
b.
LILCO's plan includes " Relocation centers in host areas which are at least five miles, and preferably ten miles, beyond the boundaries of the plume exposure emergency planning zone," as suggested by NUREG-0654, Evalua-tion Criterion J.10.h.
c.
LILCO has described "the means for registering and demonitoring of evacuees at relocation centers in host areas" and "The personnel and equip-ment available (are] capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure EPZ arriving at reloca-tion centers," as suggested in NUREG-0654 Evaluation Criterion J.12.
d.
LILCO's plan includes provisions at relocation centers in the form of trained personnel and equipment to monitor a minimum of 20 percent of the estimated population to be evacuated, as suggested by the December 24,1986, guidance memorandum from Richard W. Krimm of FEMA.
2 As a more detailed list of f actors that make the reception centers suitable, LILCO submits that each of the nine issues that have been admitted for litigation should be answered in LILCO's favor:
1.
Transportation and traffic problems as a result of the reception centers' lo-i cation and their distance from the plume EPZ would not make the centers i
unsuitable.
2.
The reception centers' locations would not create problems in regard to the t
f evacuation " shadow phenomenon" such as to make the centers unsultable.
3.
The proposed use of the reception centers for reception center purposes would not require authorization under state environmental law (and in any event state environmentallaws would not interfere with the response to a real emergency).
4.
The effect of the use of the reception centers on the water supply would not make them unsuitable.
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5.
The distance of the reception centers from the plume EPZ would not in-crease exposure to radiation as to make the centers unsuitable.
6.
The evacuation routes to the three LILCO facilities proposed as reception centers are adequate, and the effects of traffic congestion on the way to and in the vicinity of the facilities and LILCO's proposal to employ traffic guides on Nassau County roadways would not render the facilities unsuitable.
7.
Staffing for the reception centers is adequate.
8.
LILCO's proposal to transport all evacuees traveling on buses to the parking lot next to its Hicksville facility, when that facility itself is also proposed by LILCO to be the LERO worker relocation center, does not render the centers unsuitable.
9.
The proposal to send evacuees to LILCO parking lots could and would be implemented in a way to protect the public health and safety; LILCO could and would perform radiological monitoring of the public in a suitable fashion.
If this interrogatory asks for more, for example, a complete list of every advan-tage that LILCO believes one or more of the three reception centers possess, LILCO objects on the grounds that it is burdensome and seeks irrelevant information.
Intervenors' Interrogatory No.10 Identify each factor which LILCO claims makes its Plan or procedures for op-erating the reception centers adequate.
Response: The factors that make the plan and procedures adequate are that the proce-dures and plan are implementable, the equipment necessary to implement them.is available, and it is reasonable to expect that the procedures would achieve the desired outcome, namely the monitoring of up to 20 percent of the EPZ population withh5 about i
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Moreover, as indicated above, the plan and procedures are capable of exceed-ing this performance by a substantial margin.
Intervenors' Interrogatory No.11 Identify all documents concerning LILCO's procedures for monitoring or decontaminating evacuees. Provide a copy of each document identified in response to this interrogatory.
I V
Response: Already identified in response to other interrogatories.
Intervenors' Interroratory No.12 Identify all communications between LILCO and any governmental bodies con-cerning LILCO's use of the Hicksville, Bellmore, and Roslyn Operations Centers as re-ception centers. Provide all documents concerning such communications.
Response: Letters from the Towns of Hempstead and North Hempstead are already in the possession of the Intervenors;likewise a letter of January 8,1987, from the Roslyn Water District Board of Commissioners. All correspondence with FEMA and the NRC, namely Revision 8 of the emergency plan and its cover letter, is also in the Intervenors' hands.
LILCO objects to the disclosure of oral communications with individual govern-ment officials or employees on the ground that disclosure might subject the individuals to harassment and intimidation and have a chilling effeet on routine communications LILCO may need to make to ensure the safety of Shoreham or to conduct its 0:dinary business operations on Long Island. Disclosure would also interfere with LILCO's First Amendment rights to freedom of speech and to petition its government for redress of grievances.
I Intervenors' Interrogatory No.13 Identify by date and location any drills or exercises held at LILCO's reception centers to determine their adequacy or the adequacy of LILCO's procedures for moni-I toring and handling evacuees at the reception centers.
Response: None.
l Intervenors' Interrogatory No.14 Identify all communications between LILCO and the NRC or FEMA concerning the use of the Bellmore, Hicksville, and Roslyn Operations Centers as reception cen-ters. Provide all documents concerning such communications.
Response: Revision 8 of the emergency plan and the cover letter thereto. See the ob-jection in the response to Interrogatory No.13 above.
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Intervenors' Interrogatory No.15 Identify any documents concerning the management or treatment of vehicle traffic in and around the reception centers. Provide all documents identified in re-sponse to this interrogatory.
Response: The principal document is " Capacity Analysis of Highways in the Vicinity of Reception Centers for Evacuees from within the Shoreham Station Emergency Planning Zone," by KLD Associates, Inc., dated September 26,1986.
The following documents are in the custody of Edward Lieberman at KLD Associ-ates, Inc.:
1.
Correspondence between KLD and ATI,15 Park Row, New York City, the company that collected traffic data for the KLD study identified above.
2.
Documents containing information on traffic signal timing and sketches of key intersections and places on streets leading to the three reception cen-ters.
3.
Computer print-outs (perhaps 100 pages) showing traffic counts.
4.
Memorandum from Jeff Sobotka of LERIO containing information about the flow of traffic within each reception center, including sketches for each reception center.
5.
Hand calculations of traffic volumes (perhaps 300 pages).
)
These documents will be made available to Intervenors by February 20,1987.
III.
PRIVILEGED DOCUMENTS The following documents are privileged under both the attorney-client privilege and the work product doctrine:
1.
Memorandum of January 16,1987 from LILCO counsel (James N.
Christman) to LILCO emergency planning personnel and lawyers (Robinson, Daverio, Crocker, Aidikoff, McCaffrey, Weismantle, Irwin, and McCleskey) regarding preparation for hearing, witness identification, and issues for hearing.
2.
Draf t of LILCO's testimony questions on reception centers, dated January 23,1987, prepared by counsel (Christman) af ter consultation with witness-M.
]
3.
Memorandum of December 17,1986 by members of LILCO Legal Depart-ment (Anthony F. Earley, Jr., and Warren S. Arthur) to Ira L. Freilicher, a LILCO vice president, about legalissues regarding the reception centers.
i a
4.
Memorandum of January 26,1987, from LILCO's General Counsel (Anthony F. Earley, Jr.) to LILCO's Chairman of the Board regarding LILCO's re-sponse to inquiries regarding the three reception centers.
The following documents are privileged under the work product doctrine:
5.
Report prepared by Richard Watts for Douglas Crocker, dated September 16,1986, on capacities of relocation centers for plants other than Shoreham.
6.
Memorandum of November 10,1986, from Brant Aidikoff to legal counsel (Lee Zeugin) regarding monitoring capacities for plants other than Shoreham.
7.
Undated memorandum by Brant Aldikoff on revised reception center plan-ning basis, prepared for meeting with counsel. Copies in custody of Brant Aldikoff, Charles Daverlo, Douglas Crocker, Richard Watts, and Lee Zeugin.
IV.
OBJECTIONS STATED BY COUNSEL All objections and references to objections are stated by counsel.
Respectf ully submitted, h.
' James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 4,1987
VERIFICATION Charles A. Daverio, being first duly sworn on oath, deposes and says:
that he is currently the Assistant Department Manager, Nuclear Operation 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 knowledge and with which he has been provided, he is informed and believes the matters stated therein to be true, and on these grounds alleges that the matters stated therein are true and there-fore verifies the foregoing on behalf of Long Island Lighting Company.
/Ac-ttA-Charles A. Daverio State of New York)
SS:
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/a Notary Public in and for the jur'isd Daverio, whose).ction aforesaid, eby certify that Charles A.
name a signed,po e foregoing Answers to Inter-rogatories, dated smo 1, 987, has personally sworn before me that the statements thegein are true to the best of his knowl-edge and belief, r
3 /
i Notary Fublic
/
My Commission expires:
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kLf2ABF1.9 A BRICOT Notary Pubhe, Seite of fM v YOA' Ho. 33ALC"'73 Que ihn in it O C '*.[/, j L
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LILCO, February 4,1987 DOCKETED US M CERTIFICATE OF SERVICE
'87 FEB -6 A10:05 UD In the Matter of i.
LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's Responses and Objections to Intervenors' First Set of Interrogatories and Request for Production of Documents Regarding Recep-tion Center Issues Dated January 21,1987 were served this date upon the following by telecopier as indicated by one asterisk, by Federal Express as indicated by two aster-isks, or by first-class mail, postage 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 j
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 l
Bethesda, MD 20814 South Lobby - 9th Floor 1800 M Street, N.W.
Secretary of the Commission Washington, D.C. 20036-5891 i
Attention Docketing and Service Section Fabian G. Palomino, Esq.
- l U.S. Nuclear Regulatory Commission Richard J. Zahnleuter, Esq.
j 1717 H Street, N.W.
Special Counsel to the Governor Washington, D.C. 20555 Executive Chamber Room 229 State Capitol Albany, New York 12224 1
, ~, -. - - -... - - - - - -
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 Bradley 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,0. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278
.dr b.
gJamesi dtEr,1an Hunton & Williams 707 East Main Struet P.O. Box 1535 Richmond, Virginia 23212 DATED: February 4,1987
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I January 5, 1987 cc. B.Aidekoff D.Dre1 Lorn To: D.Crocher From:
R. Watts
//dr
Subject:
Summary of Time Trials for Vehicle Occupant Monitoring This enemo cummarizes the time measurrmonts per t' armed today to determino how long it would require to monitor al l venicle occupants, cons 3dering different vehicle designn. Time trials were per f ormed on the following vehicles:
a.
1996 Chrysler LeBaron (4-docr) b.
1985 Suuuru GL 4WD (2-door) c.
1905 Dodge Caravan (2-door, with zi dinq cide door )
IB16L 1:
Vkhiclo type:
Suburu, 2-dece Pacsenger Arrangement: 1 person in front, 1 pee r.on direct l y in back Areas Manitored:
Both feet, both k r. e e s., both hands r
Activi ti es Tiined:
Monitor 1ng only Tctal Times 1:15 (Monitor A) 1:16 (same repeated by Monitor B) 18166 2:
l Vehicle type:
Suburu, 2-door Passenger Arrangement: 1 person in front, 1 per son directly in back l
Areas Monitored:
Both feet, both hande sweep of shoulders, neck, head l
Activities Timed:
Monitoring only Total Time:
1:00 (Monitor A) 1:09 (samn repaated by Mnnitor B) l
a IBldb 2:
Vehicle type:
Dodge Caravan, 2-door w/ cliding door Passenger Arrangement: 1 passenger in front, 1 person in second back seat (driver si ds:-), 2 people in third back seat.
Areas Moni tcred:
Both fact, both hands sweep of shoulders, neck, head Activities Timed:
Monitoring only Total Ti me -
' 12 (Moni tor A,
all 4 riderne 1:36 (Monitor A, 3 back riders onJV) 1:34 (Monitor A, 3 back rider; cn ] v,
uting ruler ta sar..ulEtd HP 260) 18166 4:
Yehicle type:
Chrysler L e E'ac t r.,
.:-do, r Pacsenger Ari :4n:;;ee.c n t : 1 parson in front. I per t o.
d;.ect:y in back Areas Manitored:
fictn t eet, both t i.e.n d e 2.wc ep ni shoulders, neck, nead Attivitiec Ttmad:
Vehicle pul1e up to cnt:e. ap:n Jcor,
perform monitoring in car, cicca door, car pullu away Totn1 Time:
1: 22 (Monitor A) 18186 5:
Vohicle type:
Suburu, 2-door Passenger Arrangement: 1 person in front, 1 person directly in back Areas Monitored:
Both feet, both hands, sweep of shoulders, n ec t;, head Activities Timed:
Vehicle pulls up to cone, open door, have 2 people step out of one T.ide.
monitor 2 people, 2 people get back in, close door, car pulls away Total Times 1:29 (Monitor A)
k.
, se r
yo.uyouvn v t A At:,
ROCER E.
LINNEMANN, M.D.
PRESIDENT RADIATION MANAGENENT CONSULTANTS ASSOCI ATE PROFESSOR OF CL.INICAL RADIOltCY I;N1 n..MSITY GF PENNSYLVANIA SCHCOL OF MEDICINE
['
t CURRIcut.UM_ VI_TAJ June 9.
1986_
Ro,G,Jg., E.
LINNgpfNN.' N.D.
Home Addr,gn:
517 S. Providence Road Wallingford, PA 19086 Off<ce Add s :
RadiaLion Management Consultant.s 5301 Tacony Streal - Box D's Philadelphia, PA 19117
_D,e_t e e t S l e t_h,:
Januaty 17, 1931 Place of Etief h:
St. Cloud, MinncGota usu.g ior.:
19a7 university of Minnesota, Minneapolis, 1*J ;
B.A.
(Cum Laude) 19h ?niversity
<>f Minnesota, Minneapolis, M.*J,
B.C.,
M.D.
l '* M. - 1M!
k Iter Reed Arrt:y Mcspital, ushington.
0.C.; LNThPZHIP th2 19t 's Walter Reed Army Hospital, Washington, D.C.; RE::IDKhCY (Radiology) 19 t> 3 1965 03 Department. of Agelculture draduate School (Evening). Washington, D.C.,
Russian Language Professional Exeriwpfa:
1986 - present President, Nadiation Menagement Consultants i
1969 - 1956 Pres"ident/ Chief Executive Officer, Radiallon Manag. amen t. Corpora t ion 19/a. pecaent Clinical Associale Prof essor at Radiology.
Univeruity of Pennsylvania School of Medicine 1911 - present Viciting Aavoci,ete Professor, Clinical Radiology.
Nort.hwest++rn Univeesit.y Medical School 1969 - 1914 Assi8 tant Professor, Cilnical Radiology.
University of Pennsylvani. School of Medicine 1968 - 19h9 Nuclear Medicine Consultant, Philadelphia Elecleic Company
6 Professional troorlence (Con't.):
Jan - AuEust 1968 AssistanL Professor, Radiology, University of Minnesota school of Medicine (investi-gated use of radioisotopes in kidney function evaluation) 1957 - 1968 Medical officer in United States Army...
1965 - 1968 Commanding Officer. Nuclear Medicine Research Detachment, Europe; Radiological Health Con-sultant, US Army-Europe (responsible for plans, procedures and training of military hospitals and personnel in the evaluation, evacuation and treatment of radiation casualties).
In January, 1966 sent to Palcmares, Spain for evaluation of medical and environmental as-pects of the mid-air collision involving nuclear weapons) 1961 1962 Research Associale. Department of Radiobiology.
Walter Reed Army Institute of Reccarch, Washington, D.C.
(investigated use of anti-radiation drugs in treatment of cancer) 1957 - 1961 General Medical Officer. Europe Languages:
German, Russian Professional Appointments:
1982 -
American Medical Association Council on Scientific Af, fairs Subcommittee on the Manage-ment of Radiation Accident Victims 1979 - present Health ghy1(cs Society standards Committee 1978 - 1981 General Dynamics Elec_tric Boat Division Radiological Health Consultant 1978 - 1980 Edison Electric _ Igstitute Utility Radiation Standards Genup 1973 - present University of Pennsyly.ejle Nadiation Safety Committee 1973 - 1983 The Atomic Ir,dustrial Forum, Ing. Pubile Affairs & Information Committen
i 1970 The American Nuclear Society Subcommittee for Writing Emergency Procedures Standards 1969 ggy,WL Energy Cggualssion ad hoc Committee on Medical Aspects of Radiation Accidents 1966 - present American College 2[ EAdIOIORY * -
1966 - present Commission on Radiological Units Standards and Protection 1969 - 1980 Committee on Radiation Exposure of Women 1969 - 1983 Committee on Radiological Aspects of Olsaster Planning 1967 - 1978 International Affairs Committee
, Specialty Certification:
1964 Certified by American Board of Radiology 1972 Cert ified by American Board of Nuclear Medicine Licensure commonwealth of Pennsylvania, Illinois and Minnesota National Societies:
American college of Radiology I
American Pubile Health Associatlon American Medical Association Society of Nuclear Medicine Pennsylvanla Medical society Radiological Society of North America, Inc.
American Institute of Physicists /American Association of Physicists in Medicine American college of Nuclear Physicians The New York Academy of Sciences Awards & Hon __o_r_s_:
l i
Association of Medicine & Security, Madrid, Spain (1978) l University of Minnesota Radiological Research Scholar (National i
Research Council)
United States Army Legion of Merit Listed in Who's Who in Frontier Science and Technology
J s
Presentations:
1983 DWK (see 1978) Munich. Germany - Appeared before as international expert 1983 DWK (see 1978) Hanover Germany - Presented seminar
" Medical Significance of Radiation Exposure" at University of Regensburg for medical and chemistry grad students 1982 Health Physics Society (Annual Meeting. Las Vegas.
Nevada) - Presented keynote speech " Medical & Public Health Consequences of an Off-Site Release of Radiation from Nuclear Power facility" 1980 Korea Woman's Association (Seoul. Korea) -
~
Presented paper. " Energy:
The Basis for Health in Developing and Developed Countries", at International Symposium on the Expulsion of Environmental Pollution 1980
<orean Association for Radiation Protection (Seoul, Korea) - Presented seminar on emergency management of radistion injuries 1980 Min 2 m of Healtj (Madrid, Spain) - Presented paper,
" Definitive Trealment of Radiation Injuries", at First Oe.minar on Assistance to Those Wounded by Radioactive Elenwnts and Ion! Zing Radiations 1979 Reinisch Westfalisches Elekrizitatswerk (Essen.
Gormany) - Presented paper. " Energy: The Basis for Health in Developing and Developed Countriec". at The Seventh Energy Workshop 1978 lhe Swedish State P_ower Boagd (Vallingby. Sweden)
Presented seminar, " Management and Trealment of Radiation Injuries", and conducted radiation emergency j
medical exercise al the Ringhauls Nuclear Power PlanL 1978 Deutsche Gesellschaf t [ug Wiederauf arbeitun_a (Hanover.
Germany)
Appeared before the Prime Minister and Parli.
ament of Lower Saxony as an International expert to testify on the safety of a reprocessing plant at Corleben. Carmony 1978 International A_tomle E,neyg Ag nn (Vienna, Austria) g Pecaentation at Symposium on Late Effects of Ionizing Radiation 7
. _. _ _ _ - - ~
_~ -.
[-
,t, i
Presentations (Continued):
1978 Assoelecion de Medicina y Seggeldad eS tl Trabajo de Uqese para la Industria E[getrica (Madrid, Spain) -
~'
Presented one-day seminar entitled, " Primary Manage ment of Radiation Injury" 1977 International d(omi_c Energy Agency (Vienna, Austria).
Presented paper, " Emergency Medical Assistance Programs for Nuclear Power Reactors", at Symposium on Handling of Radiation Accidents 1967 University of freiburg Institute of Radiobiology (Freiburg, Cormany) - Presented seminar on diagnosis and treatment of radiation injurier Publications:
1.
Linnemann, Roger E.
" Berlin: The Ycung Old City" Senior Citizen (September 1901).
2.
f.innemann, Roger E.
"This Way to Berlin",
pir American 8 n,adictine Soview:
14 No. 4 (December 1963; t
3 1.tnnemanu. Ro6er E.
"The Acute Radiation Syndrome and its Tmpact on the Chain of Evacuation" Medical 8alletin, ti.S. Army hurope.
??, No. 17 (Dececher 1965).
4 Linnemann, Roger E. and Robert T. Wangemann.
" Medical Support of Nuclear Weapons Accidents".
Medical Bulletin, pd A_fjn1 Europe (November 1967).
5.
Linnemann, Roger E. and O. MesserschmidL.
"Erholungsvor5aenge bei Grosstleren nach Ganzkoerperbestrahlung", :dem 6, Jahebuch von der vereinigunt Duetscher Strahlenschutznerite (1968).
6.
Linnemann, Roger E.
" Command Radlation Guidance". Militger Modicine:
33, pp. 771-716 (September 1968).
7 Loken. Meric K., Linnemann, Roger E. and George S. Kush.
"8 val-uation of Renal Function Using a Scintillation Camera and Computer".
R_adjglogy:
93,, No. 1, pp. 85 94 (July 1969).
l 8.
Linnemann, Roger E., Loken, Merle K. and Colin Markland.
I puteri7.cd Compartmental Renograms to Study Kidney Function".
"Com-Journal of Uro(ggy: 103, pp. 533 537 (May 1970).
I 9.
Linnemann, Roger E. and J.W. Thiessen.
" Regional Approach to the Management of Radiation Accidents" Pup,{,ic He a lt h A s R,qc l a t i on :
Jou rn a,1, o_f { h_e A.!!te rley.,g 61, No. 6, pp. 1229 1235 (June 1911).
l I
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L I
1 e
Publications (Continued):
10.
Linnemenn, Roger E.
and Robert N.
Holmes.
" Nuclear Accidents and Their Management".
Emergency Medical Caro, pp. 281-292, Spitzer, Stanley and Wilbur W. Oaks (eds.) New York: Brune and St.retton, Inc. (1971).
11.
Linnemann, Roger E.,
Nasmussen, N.C. and F.K. PILLman.
Nuclear Ene tLY -
Issues and Answers. Atomic Industrial Forum, Inc. in cooperation with Pennsylvania Power & Light Company (April 1973).
12.
Linnemann. Roger E.
" Accentuate the positive" Telal:
10, No. 4
- p. 13 (July / August 1974).
13.
Linnemann, Roger K.
" Accentuate the Positive".
Conr,ressional Record:
109, pp. 4964-4967.
Washington, D.C.
tinited Status of Ameraca Proceedings and Debates af the 93rd Congress, Second Session (July 23, 1974).
14 Linnemann. Roger N.
tnd J.W. Thiesson.
Editorial "Tn Defanse of Radiation and Cells" The New York Times (May 23, 1974).
15.
L i n n em a r.n. Roger E.
- uelaar Radi_ation and Health. Sprin6Ville, NY, Nuclear Fuel Services, Inc. (September 23, 1974).
16.
Linnomaqn, Roger E.
Editorial, "In Defense of Nuclear l'cwwr Plants", Tpg Philadelphia Inquirer, p.
IIA (March 6, 19/S).
17 Linnemann, Roger E.
" Nuclear Power Plants Fose Minimal Health Risks", Perspective. News Bureau of the University of Pennsyl-vania, Philadelphia, PA (February 1975).
18.
Linnemann, Noge E.
" Medical Aspects of Power Generatlon".
Impulse. Massachusetts:
Electrical Council of New England (June 1975).
19.
Linnemann, Roger E.
"Bu6s in the Nuclear Fuel Cycle" Egechtum
- p. $9, Gadi Kaplan (ed.)
Piscataway, NJ: The InsLilute of Elec-trical and Electronic Engineers, Inc. (September 1975).
20.
I,innemann, Roger E.
and Fred A. Mettler, Jr.
"Emcegency Medical Assistance Programa for Nuclear Power Reactors".
International Atomic Energy Agency Symposium on the Handling ni Hadintion Acci dents, IAEA-SM-215/22, Vienna, Austria (1977).
21.
Linnemann, Roger E.
"Why ALARA?" Transactions of 1979 American Nuclear Socicly Conference, Atlanta, GA (June 3-7, 1979), Vo.
32 TANS AD 37 1 837 ISSN 0003-018x (1979).
22.
Linnemann, Roger E.,
Hackbarth, C.J.
and Ray Crandall.
"Thu Contaminated and Injured Patient".
Proceedings of Twenty Fourth Annual Meeting of the Health Physics Society, Philadelphia, PA l
(July n.13, 1979).
l
6 23.
Linnemann, Roger E.
"The Three Mile Island Incident in 1979: The utility Response". The Medkal, Bash f,og Ra_d.,{ation Acciden( Pre-ggtedness, K.F. Hubner and S.A. Fry (eds.), Elsevior/ North-ifolland, pp. 501-509 (1980).
24.
Linnemann, Roger E.
" Initial Management of Radiation Lujuries".
J,ournal g[ Eadiation Protection, 1, No.
1, pp. 11-25 (December 1980).
25.
Linnemann, Roger E., Kim, Stephen M. and Frazier L. Bronson.
"Three Mile Island: Medical and Public Health Aspects of a Radiation Accident".
Jo u r n a ( o,[ Ra d i a,t ip n P ro,t,e c t i o n, Q.
i No. 1, pp. 45 52 (Octobce 1981).
26.
Linnemann. No5er E.
" Facilities for llandling the Contaminated Patient". Radiation Accident Preparedness: Modical and Man 3-aerial Asp _q_Qs, 3clence-Thru Media Company: New York ('t937).
27.
Ltnnemann, RoAer E.
"A Systens Approach to the laitial Management af Radiation injuries" hste.m: Approach to t'mer m cy Medical.
Care, Appleton.Centory-Crofts:
New York (1983).
28.
1.innemann. Hosce E.
"Resdiat. ion Injuries" Current. E.v e rre nc y Thernpy.
Editors;
. Richard Edlich and Dani.:1 Spyper; and Asp-n Publication by A;p*>n Uystems Corporaticn. korkville. PD (198'2).
/9.
Linnenann. Noger E.
" National Emergency Medical Assistance Program for Commercial Nuclear Power Plants".
Presented al. the Ucpt ember L986 American Nuclear Society Topical Meeting on "kadiologicsl Accidunt s:
Perspectives and Emergency preparedness".
30.
f.innemann, Roger E.
" Soviet Medical Response to Chernnbyl." Submitted for publication by the Journal of.the American Medical Association (JAMA). January, 1987.
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'd PROVRSSIONAr, TESTIMONY 1984 Limerick Nuclear Generating Statlon Emergency Planning Hearings 1985 Cleveland Electric llluminating Company Emergency Planning Hearings In progress John Benek vs. Pennsylvania Power Company et al.
- 99 of 1977 Eminent Domain 198a Long Island Lighting Company Emergency Planning Hearings for the Shoreham Nuclear Power St.ation L983 Union Electric Company Emergency Planning / Licensing Hearings for Callaway Nuclear Pcwer Plant 1983 Pennsylvania Power & Light Company Susquehanna Steam Electric Operating License Hearing,s L982 Texts Utilitics Generating Company Empfgency Planning
!! earings f or the Comanche Peak St eam Electric Station 1981 riorida Powcr & Light Company Turkey Point Steam Generator Repair Hearings 1981 Southern California Edison Company Emergency Planning Hearings for the San Onofre Nuclear Generating Station 1919 Corlehen Nuclear Fuels Reprocessing Plant Hearings before the Prime Minister and Parliament of Lower Sarony. Hanover, Germany 1919 Florida Power & Light Company Turkey Point Nuclear Station Operating License Hearings i
1971 Long Island Lighting Company Shoreham Nuclear Power Station Operating 1.lcense Hearings 1970
(
Baltimore Gas & Hlectric Company CalverL Cliffs Nuclear Power Plant Operating License Hoarings 1970 Northeast Util*,t les Service Company Millstone Nuclear Power Station Operating License Hearings
~
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o DALE E. DONALDSON Director, Radiological Services Division EDUCATION B.S., Ohio State University SU_MMARY OF EXPERIENCE Mr. Donaldson is an expert in the planning, scheduling, implementation.
and evaluation of emergency preparedness and radiation protection pro-grams for nuclear facilities.
Mr. Donaldson gained invaluable experience as a member of the NRC investigation team for the accident at Three Mlle Island.
He was also involved with nuclear incident assessment and control and radiation protection activities while working for the U.S.
Army and Nuclear Regulatory Commission.
His most recent work has involved the evaluation,
- planning, scheduling, and related management of the imple-mentation of the Health Physics Program at the Limerick Cenerating Station and Shoreham Station in preparation for licensing.
1985 - Present
- Director, Radiological Services Division, Hydro Nuclear Services.
Provides overall Divisional executive management, L
direction and coordination for all professional consulting aspects of HNS operations.
Responsible for all routine and special RSD projects, regulatory affairs, project plancing and development, quality control of RSD operations and executive liaison functions both internally within HNS and with respect to client executive management.
1982 - 1985 Senior Radiological Engineer and Director of East Coast operation, Radiological Services Division, Hydro Nuclear Services.
Provided senior level consultir.g services in the areas of Health Physics, Radioactive Waste Management, Reactor Chemistry, and Emergency Preparedness.
Performed program evaluation and provides management services to power reactors relative to the scheduling, and implementation of these programs, planning, Senior Engineer, Engineering Services
- Division, TERA Corporation.
Provided professional consulting services in all phases of Radiation Protection and Emergency Prepared-ness.
1975 - 1982 Health Physicist, U.S.
Nuclear Regulatory Commission, Region i
Office of Inspection and Enforcement.
Was responsible for inspecting emergency planning, radiation protection and environmental monitoring programs at nuclear power reactors, nuclear fuel facilities and test and research reactors; developing and maintaining a 1
61014-RSD1
DALE E. DONALDSON Page 2 Regional incident Response Plan; serving as co-chairman of three Federal Regional Advisory Committees and the Federal Field Assistance Cadre for assistance to states in radiological emergency response planning; member of the NRC Office of Inspection and Enforcement investigation Team for the accident at Three Mile Island; contributing author of NUREG-0654 and the NRC health physics and emergency preparedness appraisal programs; member of a Nuclear Regulatory Commission Health Physics Appraisal Team, and Team Leader of a Nuclear Regulatory Commis-slon Emergency Preparedness Appraisal Team.
1909 - 1975 Chemical, Biological and Radiological Officer, U.S.
Army.
Various titles with Supervisory responsibility and in-structor duties involving:
Radiation safety,
nuclear accident / incident assessment and control; civil.
and military emergency preparedness; nuclear weapons effects:
project management for the research, development, test and evaluation of radiological items of equipment and radiological safety policies and procedures.
PUBLICATIONS i
NRC_ _ _ Health Physics Appraisal Prog ram, U.S.
Nuclear Regulatory Com-mission, May 1980.
Investigation into the March 28, 1979 T_hree Mile Island Accident by Office of Inspection and Enforcement _,
N U R EG-0600, U.S.
Nuclear Regulatory Commission, August 1979.
Criteria for Preparation and Evaluation of Radiological Emergency Response l
Plans and Preparedness in 5upport of Nuclear Power Plan ts,
U.5.
Nuclear Regulatory Commission and Federal Emergency Management Agency, January 1980.
l l
e 61014-RSD1