ML20210A836
| ML20210A836 | |
| 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-#187-2451 OL-3, NUDOCS 8702090025 | |
| Download: ML20210A836 (8) | |
Text
2, f6 /
au m ocar e,e..u m p ULCO, February 4,1987 e
L UNITED STATES OF AMERICA kac NUCLEAR REGULATORY COMMISSION
'87 FEB -6 A10:02 Before the Atomic Safety and Licensing Board p,
CE In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S SECOND 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 SS 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 that the evidence that may be presented on the adequacy of LILCO's proposed reception centers.
INSTRUCTIONS Please adhere to the Instructions and Definitions in LILCO's First Set of Inter-rogatories and Request for Production of Documents Regarding Reception Centers to t
Suffolk County and New York State, dated January 16,1987.
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Identification of Witnesses and Documents
- 13. Please answer Nos.1-8 of the First Set of Interrogatories dated January 16, 1987.
8702090025 870204 PDR ADOCK 05000322 Q
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i Factors Allered to Make the Reception Centers Unsuitable 14.
In your January 30,1987, Response to LILCO's First Set of Interrogatories you say (p. 5) that "( t]he number of persons who will arrive at LILCO's re-ception centers is much larger than those reception centers (and the facill-ties, resources, and personnel committed to them) can serve." What num-ber, in the Intervenors' view, is "the number of persons who will arrive at LILCO's reception cente.3"?
15.
What are the " facilities" and " resources" that you are referring to in the passage quoted above?
16.
Do the Intervenors claim that the number of people referred to in Interrog-atory 14 above must be monitored within about 12 hourc in order to comply with NRC regulations?
17.
Do the Intervenors claim that LILCO must be prepared to decontaminate the number of people asked for in Interrogatory 14 above within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to comply with NRC regulations?
18.
You say in your January 30 Response (p. 5) that "(t jraf fic congestion on the way to and in the vicinity of the facilities will render the reception centers ineffective." What studies or analyses support this statement?
Please provide copies.
19.
You say in your January 30 Response (p. 6) that LILCO's traffic manage-ment system, including the use of LILCO's Traffic Guides, is inadequate.
Precisely how is it inadequate? What would make it adequate?
20.
You say in your January 30 Response (p. 6) that "[t]ransportation and traf-fic problems will develop as a result of the reception centers' locations and their distance from the EPZ." Precisely what " problems" do you refer to?
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', 21. You say in your January 30 Response (p. 6) that LILCO's proposed moni-toring procedures are inadequate. Precisely how are they inadequate and why do they not, in your words, " provide reasonable assurance that all evacuees arriving at the reception centers to be monitored will be moni-tored, and that contaminated persons will be identified, in a timely man-ner"?
- 22. Is there any way in which LILCO's proposed monitoring procedures could made adequate in the Intervenors' view? If so, how?
q 23.
You say in your January 30 Response (p. 6) that " inadequate shelter" not only "affects the public health" but "under certain circumstances will ren-der LILCO's monitoring procedures ineffective." Precisely how does it af-feet the public' health, and what " circumstances" do you refer to? How will those " circumstances" render LILCO's monitoring procedures inef fective?
24.
In your January 30 Response (p. 6) you say that the reception centers and their "f acilities" and the " resources" provided by LILCO are physically inad-equate. What "facilitics" and " resources" are you referring to?
- 25. In your January 30 Response (p. 6) you say that the reception centers and their facilities and the resources provided by LILCO are physically inade-quate to provide "other necessary services" to evacuees. List all such "nec-essary services" to which you refer.
- 26. In your January 30 Responst, p. 6) you say that LILCO has provided inade-quate staff. What would make LILCO's staff adequate? How many people do the Intervenors believe should be provided for monitoring, decontamination, and other purposes?
- 27. In your January 30 Response in your Response 9(h) on page 6, what are the "other purposes" to which you refer?
- 28. In your January 30 Response you say that LILCO's proposal to transport all i
evacuees traveling on buses to the parking lot next to its Hicksville f acility i
renders that facility inadequate. Precisely how is it inadequate?
- 29. In your January 30 Response (p. 7) you say that the " proposal to send the evacuees to the LILCO parking lots can never be implemented in a way to protect the public health and safety." Why not?
- 30. In your January 30 Response (p. 7) you say that the " reception centers loca-tions will give rise to a larger evacuation shadow phenomenon, as well as inhibiting evacuation and the timely processing of the evacuees at the re-ception centers." Precisely how do the locations affect the so-called
" shadow phenomenon"?
i 31.
How will the alleged larger " shadow phenomenon" inhibit the timely pro-cessing of the evacuees?
32.
In your January 30 Response (p. 7) you say that the use of the reception centers threatens to contaminate water supplies. What studies or analyses support this statement? Please provide copies.
- 33. In your January 30 Response (p. 7) you say that " waste products from the decontamination procedures could pose additional environmental hazards."
What " waste products" do you refer to, and what additional" environmental 4
hazards" do you refer to?
l
- 34. In your January 30 Response (p. 7) you say that the " distance of the three f acilities from the EPZ will increase the adverse health effects of those ex-posed to radiation during an accident." Is the Intervenors' position that the distance of the LILCO f acilities from the EPZ is categorically too great as a matter of law? Or is your pcsition that they are too far because of par-i ticular conditions on Long Island? If the latter, what are those particular j
conditions?
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- 35. You say in your January 30 Response (p. 7) that "LILCO cannot lawfully use its facilities as relocation centers." Please state what laws intervenors claim would prevent LILCO from using its facilities as relocation centers.
- 36. At transcript page 16010 of the Shoreham emergency planning hearings FEMA witness Keller referred to a letter written by the Environmental Protection Agency to the State of New York addressing the release of con-taminated washwater to sewer systems. Mr. Keller believed this was in connection with the Nine Mile Point Station. Please provide a copy of the letter.
Other Nuc! car Power Plants 37.
For each of the other operating nuclear power plants in New York State, please state (a) the capacity of the relocation centers provided for an emergency at the plant to monitor people and vehicles for radioactive con-tamination within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and (b) their capacity to decontaminate people and vehicles, either within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or within such other times as you have information for.
38.
For each operating nuclear power plant in New York State other than Shoreham, are any of the relocation centers required to (a) have an SPDES permit or (b) have an environmentalimpact statement prepared under SEQRA or other state law?
39.
For each of the other operating nuclear power plants in New York State, has anyone addressed the question whether the use of the relocation cen-ters for monitoring and possible decontamination would violate local zoning laws or other state or local laws? !! anyone has addressed this question for any relocation center in New York State, please provide any documents ad-dressing the question. Please identify any people who have addressed or analyzed this question for relocation centers in New York State.
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- Respectfully submitted, f
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ames N. Christman Hunton & Williams 707 East Main Street j
P.O. Box 1535 i
Richmond, Virginia 23212 i
DATED: February 4,1987 l
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a LILCOo February 4,1987 y
CERTIFICATE OF SERVICE
'87 FEB -6 A10:02 In the Matter of
[0bn.',. 1 r J,u LONG ISLAND LIGHTING COMPANY W*
(Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's Second Set of Interrogatories and Re-quests 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, postage prepaid.
Morton B. Margulics, 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 Bethesia, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, D.C. 20555 Atomic Safety and Licensing BoaFd 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
o i 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., Rcom 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 liighway Riverhead, New York 11901 IIauppauge, 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 Wf~
ames N. Christman liunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 4,1987