ML20211A157
| ML20211A157 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/12/1987 |
| From: | Donegan K LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2509 OL-5, NUDOCS 8702190101 | |
| Download: ML20211A157 (6) | |
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LILCO, February 12, 1987
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UNITED STATES OF AMERICA C0CKETED NUCLEAR REGULATORY COMMISSION USWC
'87 FEB 17 P4 :53 Before the Atomic Safety and Licensing Board CFFF:
In the Matter of
)
DCC/ flin.,,
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)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station.
)
Unit 1)
)
LILCO'S SUPPLEMENTAL RESPONSE TO SUFFOLK COUNTY, STATE OF NEW YORK AND THE TOWN OF SOUTHAMPTON'S FIRST REQUEST FOR ADMISSIONS ANSWERS TO INTERROGATORIES Pursuant to S 2.740(e) of the NRC Rules of Practice, LILCO hereby supplements and corrects its responses to Suffolk County's First Request for Admissions, dated November 5,1986.
Suffolk County Admission No.1 That the U.S. Coast Guard did not participate in the Exercise, except as the re-cipient of telephone calls from LERO.
Response: In its November 17,1986 Admissions, LILCO stated: "LILCO admits that the U.S. Coast Guard participated in Exercise, and that the extent of that participation was the receipt of telephone calls from LERO, and denies any implication in the request that this participation was incomplete or insufficient."
LILCO retracts that admission and supplements and corrects Admission No.1 as follows: The U.S. Coast Guard participated in the Exercise in the following ways: (1) the Coast Guard received two phone calls from the LERO Evacuation Coordinator:(2) the Coast Guard telephoned the LERO Evacuation Coordinator six times to report on evacuation of the water portion of the Shoreham EPZ. In addition to these telephone 87021'70101 070212 PDR ADOCK 05000322 O
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. calls, at 11:27 a.m. the Coast Guard actually sent a boat into the water portion of the EPZ to perform the functions required under the LILCO Plan and reported to the Evac-uation Coordinator that the water evacuation was completed at 11:51 a.m.
Suffolk County Admission No.18 That, during the Exercise, U.S. Coast Guard personnel did not perform any public notification, protective action communication, waterborne traffic control, or access control functions on the water portion of the Shoreham EPZ.
Response: In its November 17,1986 Admissions, LILCO responded by admitting this re-quest. LILCO retracts that admission and supplements and corrects Admission No.18 as follows: Admitted, to the extent that public notification and protective action com-munication mean broadcasting over the marine band radio. Denied in all other re-spects. See LILCO's corrected response to Suffolk County Admission No.1.
Suffolk County Admission No.19 That, during the Exercise, U.S. Coast Guard personnel did not simulate or pre-tend to perform any public notification, protective action communication, waterborne traffic control, or access control functions on the water portion of the EPZ.
Response: In its November 17,1986 Admissions, LILCO responded by admitting this re-quest. LILCO retracts that admission and supplements and corrects Admission No.19 as follows: Admitted, to the extent that public notification and protective action com-munication mean broadcasting over the marine band radio. Denied in all other re-spects. See LILCO's corrected response to Suffolk County Admission No.1.
Suffolk County Admission No. 57 That, during the Exercise, LERO News Release No. I was not provided to the press by the ENC until 8:21 a.m.
Response: In its November 17,1986 Admissions LILCO stated: "LILCO admits that LERO News Release No. I was provided to the prets by the ENC at 8:21 a.m., and denies any implication in the request that this was not timely."
l
. LILCO retracts that admission and supplements and corrects Admission No. 57 as follows: LILCO is unable to admit or deny, from Exercise generated papers, that LERO News Release No. I was not provided to'the press by the ENC until 8:21 a.m. No record exists for determining the exact time LERO News Release No. I was provided to the press. The burden of establishing the approximate release time from existing documen-tation is the same for Intervenors as it would be for LILCO. The method of making the press releases available to the press and the persons responsible for dissemination of press releases are described in OPIP 3.8.1.
Suffolk County Admission No. 73 That, during the Exercise, no mention was made by LERO to the media that a Site Area Emergency had been declared, that a minor release of radiation had occurred, or that dairy animals should be placed on stored feed until af ter 9:15 a.m.
Response: In its November 17, 1986 Admissions, LILCO responded by admitting this re-quest. LILCO retracts that admission and supplements and corrects Admission No. 73 as follows: LILCO admits that the media was not informed that dairy animals should be placed on stored feed until af ter 9:15 a.m. LILCO denies the request in all other re-spects.
Suffolk County Admission No. 84 That during press conference during the Exercise, LERO personnel were unable to provide any information to the media concerning conditions or activity on the water portion of the EPZ.
Response: In its November 17,1986 Admissions LILCO responded as follows: " Denied.
No information was requested by the press concerning the water portion of the EPZ."
LILCO retracts that admission and supplements and corrects Admission No. 84 by stating: Denied. In response to questions about activity on the water portion of the EPZ, the LERO spokesperson explained the functions that are performed by the U.S.
Coast Guard in accordance with the LERO Plan.
.) Suffolk County Artmissinn No.105 That, although during the Exercise a simulated rumor message inquiring whether the cooling towers on the Shoreham plant had blown up was given to the Riverhead Callboard operator at 1:30 p.m., a response was not relayed to the caller until 2:48 p.m.
Rmponse: In its November 17,1986 Admissions LILCO stated: "LILCO admits that the message described in request No.101 was received at 1:30 p.m. and a response relayed at 2:48 p.m., and denies any implication in the request that this response was untime-ly."
LILCO retracts that admission and supplements and corrects Admission No.105
~
as follows: Denied. The message described in request No.105 was received at 1:35 p.m. and a response was relayed to the caller at 1:53 p.m. LILCO denies any implica-tion in the request that this response was untimely.
Respectfully submitted,
(
Kar'en L. Donegan U
Counsel for Long Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 12,1987 I
l-LILCO, February 12, 1987 myn CERTIFICATE OF SERVICE
'87 FE817 P4 :53 In the Matter of LONG ISLAND LIGHTING COMPANY 6H u (Shoreham Nuclear Power Station, Unit 1)
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Docket No. 50-322-OL-5 I hereby certify that copies of LILCO'S SUPPLEMENTAL RESPONSE TO SUFFOLK COUNTY, STATE OF NEW YORK AND THE TOWN OF SOUTHAMPTON'S FIRST REQUEST FOR ADMISSIONS were served this date upon the following by Federal Express as indicated by an asterisk, or by first-class mail, postage prepaid.
John H. Frye, III, Chairman
- Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers 4'350 East-West Hwy.
Oreste Russ Pirfo. Esq.
- Bethesda, MD 20814 Edwin J. Reis. Esq.
U.S. Nuclear Regulatory Commission Dr. Oscar H. Paris
- 7735 Old Georgetown Road A'tomic Safety and Licensing (to mallroom)
Board Bethesda, MD 20814 U.S. Nuclear Regulatory Commission East-West Towers Herbert H. Brown, Esq.
- 4350 East-West Hwy.
Lawrence Coe Lanpher, Esq.
Bethesda, MD 20814 Karla J. Letsche, Esq.
Kirkpatrick & Lockhart Mr. Frederick J. Shon
- South Lobby - 9th Floor Atomic Safety and Licensing 1800 M Street, N.W.
Board Washington, D.C. 20036-5891 U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 Fabian G. Palomino, Esq.
- 4350 East-West Hwy.
Richard J. Zahnleuter, Esq.
Bethesda, MD 20814 Special Counsel to the Governor Executive Chamber Secretary of the Commission Room 229 Attention Docketing and Service State Capitol Section Albany, New York 12224 U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Mary Gundrum. Esq.
Washington, D.C. 20555 Assistant Attorney General 120 Broadway Atomic Safety and Licensing Third Floor, Room 3-116 Appeal Board Panel New York, New York 10271 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
1
' 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.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 Ka'ren L. Donegan Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 12, 1987