ML20211A532
| ML20211A532 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/13/1987 |
| From: | Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#187-2502 OL-3, NUDOCS 8702190187 | |
| Download: ML20211A532 (10) | |
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is 00CKETED February 13,Yh87 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFF J " S Before the Atomic Safety and Licensino Boa"r'd" '
)
In the Matter of
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LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
)
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SUPPLEMENTAL RESPONSE OF SUFFOLK COUNTY TO LILCO'S FIRST SET OF INTERROGATORIES i
AND REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTERS Pursuant to 10 C.F.R. S 2.740(e), Suffolk County, by its undersigned attorneys, hereby supplements its responses to LILCO's First Set of Interrogatories and Request for Production
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of Documents Regarding Reception Centers (January 16, 1987)
(" Discovery Requests"), subject to the' general and specific i
objections set forth in the Response of Suffolk County and State of New York to LILCO's First Set of Interrogatories and Request for Production of Documents Regarding Reception Centers (January 30, 1987).
'S 8702190187 G70213 PDR ADOCK 05000322
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SUPPLEMENTAL ANSWERS TO INTERROGATORIES AND REOUESTS FOR PRODUCTION OF DOCUMENTS Discovery Recuest'No. 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-Intervenors-expect to I
-l 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
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.such opinion.
Sunnlemental Response t'o Discovery Recuest No. 1:
Suffolk County supplements the Government's prior response to Discovery Request No. 1 by identifying the following witnesses and the subject matter on which they.are expected to testify:-
(a)
Stechen Cole, PhD., who will testify concerning the number of evacuees who will arrive at LILCO's reception center for monitoring; the consequences of that number of 1
evacuees converging on the reception centers; and the evacuation shadow phenomenon as it applies to the reception centers.
The grounds for Dr. Cole's testimony will include a recent survey conducted by Dr. Cole; other surveys and studies; and relevant literature.
Further analyses and the results of discovery may provide further grounds for his testimony.
(b)
Susan Saecert, PhD., who will testify concerning the number of evacuees who will arrive at LILCO's reception centers for monitoring; the behavior.that will result from the 4
inadequacy of LILCO's facilities; andLthe evacuation: shadow phenomenon as it relates.to the reception centers.
The grounds
.for Dr. Saegert's. testimony will.. include her review and analysis of the LILCO Plan; her research on the subject' areas; data from various. surveys and analyses; and relevant literature.
Further analyses and-research may-provide:further grounds for her.
testimony.-
(c)
David Harris, M.D., who will testify concerning.
the inadequacy.of facilities, personnel and resources available at the reception centers; the inadequacy of LILCO's monitoring and decontamination procedures; ina' equate staffing-at the d
reception centers; and the adverse public health effects resulting from the inadequacy of LILCO's reception centers, staffing and procedures.
The grounds for Dr. Harris' testimony will include his review of the LILCO Plan and his expertise in the field of public health.
Discovery may provide further grounds for his testimony.
(d)
Martin Maver, M.Dz, who will testify concerning the inadequacy of facilities, personnel and resources available at the reception centers; the inadequacy of LILCO's monitoring and decontamination procedures; inadequate staffing at the reception centers; and the adverse public health effects resulting from the inadequacy o'f the reception centers, staffing and procedures.
The grounds for Dr. Mayer's testimony will
o include his review-of the LILCO Plan and'his expertise ~in the field of public health.
Discovery may provide further1 grounds for his testimony.
4 (e).Greoorv'C. Minor, who will testify concerning the-inadequacy of LILCO's monitoring procedures and equipment.- The-4 grounds for Mr. Minor's testimony will include his~ review of LILCO's Plan and procedures, and information obtained during discovery.
Additional witnesses will be designated as they become available to the County.
Discoverv Recuest No. 2:
-For each witness, please provide a copy of his most current cirruculum vitae, resume, or statement of professional l
qualifications.
i Suoolemental Resoonse to Discovery Recuest No. 2:
Resumes for Drs. Cole, Saegert, Harris and Mayer and'Mr.
Minor have been provided to LILCO in connection with the ongoing OL-5 (Exercise) proceeding.
Discovery Recuest No. 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.
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Suoolemental Response to Discovery Reauest No. 3
'All of'the above witnesses have! testified at various times
'in proceedin~s regarding emergency planning.for Shoreham. 'LILCO g
is aware of those proceedings.
To the extent the above witnesses have testified in other proceedings on the issues set forth in
- Discovery Request No. 3, Suffolk County is in the process of obtaining such information and will provide it when obtained.
Discoverv Recuest No.'4:
Please provide a copy of any pre-filed-testimony listed in response to Interrogatory 3 above.
4 Sucolemental Response to Discovery Reauest No. 4:
Egg the County's Supplemental Response to Discovery Request No. 3.
Suffolk County will not provide the testimony of the above witnesses in Shoreham proceedingsLor any other proceeding where the requested testimony is publicly available and thus accessible to LILCO without undue burden.
If the County determines that responsive testimony exists to.which LILCO does j
not have access, it will respond further at that time.
l Discovery Recuest No. 5:
1 Please identify all articles, papers, and other. documents by or co-authored by each witness on the subject of the care of evacuees from, or other victims'of, large-scale disasters or emergencies. -
Sucolemental Response to Discovery Recuest No. 5:
The County is in the process of obtaining the requested-information, which will be provided when acquired.
Discoverv Recuest No. 6:
Please sta.te 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.
Sunclemental Response to Discovery Recuest No. 6:
Suffolk County is in the process of obtaining this information and will respond further when the information is acquired.
Discovery Recuest No. 7:
Unless the answer to interrogatory 6 above is a simple negative, please identify and provide a copy of.each document.
Sucolemental Response to Discovery Recuest No. 7:
See Supplemental Response to Discovery Request No. 6.. _ - -
O e
Respectfully submitted, Martin Bradley Ashare' Suffolk-County Attorney Building 158 North County Complex Veterans Memorial Highway-Hauppauge, New York-11778 k-CNristoph'er M. McMurray
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David T. Case
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KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington,_D.C.
20036-5891
-Attorneys _for Suffolk County
4 1T,y987 February UNITED STATES OF AMERICA
'87 FEB 17 P3 :39 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina B6ard r-D a n T.
- r c ;':F.
D ~ ' 1,
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I
l l
l I hereby certify that copies of SUPPLEMENTAL RESPONSE OF SUFFOLK COUNTY TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTERS have bee;.
served on the following this 13th day of February by U.S. mail, first class, except as otherwise noted.
'j Morton B. Margulies, Esq., Chairman Joel Blau, Esq.
Atomic Safety and Licensing Board Director, Utility Intervention U.S. Nuclear Regulatory Commission N.Y. Consumer Protection Board Washington, D.C.
2055C Suice 102C Albany, New York 12210 Dr. Jerry R.
Kline William R. Cumming, Esq.
Atomic Safety and Licensing Board Spence W.
Perry, 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
w Mr.. Frederick'J. Shon:
Anthony F.
Earley, Jr., Esq..
Atomic! Safety and Licensing Board:
General' Counsel.
M
-U.S.
Nuclear.-Regulatory Commission.
Long> Island Lighting CompanyJ Washington,7 D.C.
20555
_175: East-Old Country Road:
Hicksville, New' York 11801 Elisabeth Taibbi W.' Taylor-Reveley,III,fEsq.*L Clerk; Hunton & Williams Suffolk County _ Legislature P.O.-Box 1535' Suffolk County Legislature 707cEast Main' Street.
Office Building Richmond,. Virginia 23212
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Veterans Memorial Highway-Hauppauge, New York 11788 Mr. L..F.-Britt
. Stephen ~B.
Latham, Esq.
Long Island-Lighting Company:
Twomeyi-Latham & Shea-Shorehain 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 11*,37
- Washington, D.C.
20555 Mary M. Gundrum, Esq.
Hon. Michael LoGrande New York State Department of Law Suffolk County' Executive 120 Broadway, 3rd Floor H. Lee Dennison Building-Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe-Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York' 11792 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
-Mr. Jay Dunkleburger Richard G. Bachmann, Esq.
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency Building 2 Washington, D.C.
20555 Empire State Plaza Albany, New York 12223 i
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t David A.
Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Ball, New York 11771 Via Federal Express ristopKer M. McMurray
)
KIRKPATRICK & LOCKHART
/
1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
~ 20036-5891 l
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