ML20211D659
| ML20211D659 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/19/1987 |
| From: | Bachmann R, Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2560 OL-3, NUDOCS 8702240086 | |
| Download: ML20211D659 (7) | |
Text
WTED CORRES@N February 19, 1987 00CKETED
!$?iPC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 FEB 20 P3 :54 BEFORE THE ATOMIC SAFETY AND LICENSING BOARDh In the Matter of
)
)
LONG ISLAND LIGIITING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
NRC STAFF FIRST RET OF INTERROGATORIES AND REQUESTS TO PRODUCE OF SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON Pursuant to 10 C.F.R.
If 2.740, 2.740b and 2.741, and in I
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accordance with the Licensing Board's Orders of January 14, 1987 3_/ the NRC Staff hereby February 4, 1987 -
and February 9,
- 1987, serves upon Suffolk County, the State of New York and the Town of Southampton ("kntervenors") the Staff's First Set of Interrogatories and Requests to Produce.
Each interrogatory shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information available to the Intervenors, their
- officers, directors, members,
employees, advisors, representatives or counsel, based upon the personal knowledge of the person answering.
Intervenors are requested to produce each document identified in response to the subject 1/
" Order (Setting Discovery and Hearing Schedule)".
2_/
" Order (Ruling on Motions for Reconsideration on Scheduling)".
-3/
" Memorandum and Order (Ruling on LILCO's and Intervenors' ?.?otion for Reconsideration of Schedule)".
h Q T 8702240086 870219 PDR ADOCK 05000322 G
6,
interrogatories.
By such request for production of documents, the Staff seeks to inspect and copy pertinent documents which are in the possession, custody or control of Intervenors, their officers, directors, members, employees, advisors, representatives or counsel.
As used herein, the term " documents" shall -include any writings, drawings, graphs, charts, and schedules, however produced; photographs or other pictorial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
In addition, Intervenors are requested, pursuant to 10 C.F.R.
I 2.740(e), to supplement their responses as necessary with respect to the identity of each person expected to be called as an expert witness at the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance of such testimony.
INTERROGATORIES AND DOCUMENT REQUESTS Interrogatories 1 and 2 refer to the decision of the Appeal Board in ALAB-832, 23 NRC 135 (1986).
1.
At 23 NRC 162, n.105, the Appeal Board refers to six witnesses 4/ and their testimony previously proposed by Intervenors, but which was rejected by the Licensing Board.
Identify which of these witnesses are e::pected to testify during the reception center hearings, the subject matter on which he or she is expected to testify, and the substance of such testimony.
For each witness so identified, specify
-4/
Dr. James H.
- Johnson, Jr.,
Dr. Edward P.
Radford,
Richard Roberts, Charles E. lillduff, Langdon Marsh and Sarah J. Meyland.
See 23 NRC at 101, n.102.
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exactly how their testimony will differ from the testimony previously submitted.
2.
Identify any other person (s) whom Intervenors expect to call as a witness.
Set out the subject areas of their testimony.
State how this testimony relates to the five areas of inquiry referred to by the Appeal Board at 23 NRC 162, n.105, or to any other matter in controversy in this proceeding. For each witness:
a.
State the substance of his or her testimony, including the facts and opinions to which the witness is expected to testify; b.
Provide the basis for each such opinion; c.
Identify and provide all documents, including studies and analyses, upon which the witnesses intend to rely; d.
Identify all prior statements made by the witnesses in testimony or depositions, in this or other proceedings, which concern the subject matter of their testimony.
Interrogatories 3 and 4 relate to the decision of the Appeal Board in ALAB-855, 23 NRC (1986), (Slip Opinion; Tiecember 12, 1986).
3.
The Appeal Board has stated that LILCO has the duty to estimate and plan for the number of evacuees desiring monitoring but not sheltering. Slip op, at 17-18.
a.
What number of persons do Intervenors assert will desire monitoring but not sheltering?
How many persons do Intervenors assert LILCO must plan for in setting up monitoring facilities.
b.
To the extent that Intervenors do not intend to provide testimony on this issue, state the basis for any general disagreement
1 s.
Intervenors may have with the number of persons estimated by LILCO.
Specifically, state whether Intervenors agree or disagree with the answers given by LILCO in its February 4, 1987 responses -
to Intervenors' Interrogatories 7 and 8.
If Intervenors disagree, provide the basis for the disagreement and identify and provide all documents, studies and analyses relied upon, including any generated by Intervenors.
4.
With respect to Interrogatory 3, identify the person (s)
Intervenors expect to call as a witness on this issue, and provide the information for each such person in accordance with the format given in Interrogatory 2.
5.
For each witness identified in response to Interrogatories 1, 2 and 4 provide a statement of the witness' educational and professional background, with specific reference to their qualifications to give their particular testimony.
6.
In LILCO's February 4,1987 responses (noted in Interrogatory 3), a copy of KLD Associates, Inc., Capacity Analysis 6/ was provided to Intervenors.
With respect to the Capacity Analysis in particular, and to the traffic issue in general (as set forth by the Licensing Board in its December 11, 1986 Memorandum and Order (Rulings on LILCO Motion to Reopen Record and Remand of Coliseum Issue), Slip Op. at 18.), identify
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5/
"LILCO's Responses and Objections to Intervenors' First Set of
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Interrogatories and Recyest for Production of Decuments Regarding Reception Center Issues Dated January 21, 1987".
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" Capacity Analysis of Highways in the Vicinity of Reception Centers for Evacuees from within the Shoreham Station Emergency Planning Zone" dated September 26, 1986.
4.
expected Intervenora' witnesses and provide information in accordance with the format in Interrogatorv 2, above.
Respectfully submitted, Richard G. Bachmann Cou sel for NRC Staff rge
. Jo son Counsel for RC Staff Dated at Bethesda, Maryland this 19th day of February,1987
1 CMl[iL:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 FEB 20 P3 54 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOpRD b.7 In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No.
50-322-OL-03
)
50-322-OL-05 (Shoreham Nuclear Power Station,
)
Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF FIRST SET OF INTERROGA-TORIES AND REQUESTS TO PRODUCE OF SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTIIAMPTON" in the above-captioned proceeding
- have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatorv Commission's internal mail system, this 19th day of February,1987.
Morton B. Margulf'es, Chairman
- Joel Blau, Esq.
Administrative Judge Director, Utility Intervention Atomic Safety and Licensing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 Jerry R. Kline*
Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 Frederick J. Shon*
Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Fmpire State Plaza Washington, DC 20555 Albany, NY 122?3 Philip FicIntire W. Taylor Reveley III, Esq.
Federal Emergency Management Donald P. Irwin, Esq.
Agency Hunton & Filliams 26 Fe&ral Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212
o 2-i Stephen B. Latham, Esq.
Herbert H. Brown, Esq.
Twomey, Latham a Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick & Lockhart Riverhead, NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel
- U.S. Nuclear Regulatory Commission Jay Dunkleberger Washingtcn, DC 20555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel
- Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.
Martin Bradley Ashare, Esq.
General Counsel Suffolk County Attorney Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq.
Horth Shore Committee Attorney General of the State P.O., Box 231 of New York Wading River, NY 11792 Attn: Peter Bienstock, Esq.
Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center 195 East Main Street Room 46-14 Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr.
William R. Cumming, Esq.
General Counsel Office of General Counsel Long Island Lighting Company Federal Emergency Management 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW l
Washington, DC 20472 Dr. Robert Hoffman Long Island Coalition for Safe Docketing and Service Section*
Living Office of the Secretary P.O. Box 1355 U.S. Nuclear Regulatory Commission Massapequa, NY 11758 Washington, DC 20555 i
l Wry M. Gundrum, Esq.
New York State Department of Law Douglas J. Hynes, Councilman 120 Broadway Town Poard of Oyster Bay l
3rd Floor, Room 3-116 Town Hall New York, NY 10271 Oyster Day, New York 11771
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