ML20211F526

Lilco Responses & Objections to Intervenor Second Set of Interrogatories Dtd 870206.* W/Certificate of Svc.Related Correspondence

ML20211F526
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/20/1987
From:	Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF, SOUTH HAMPTON, NH, SUFFOLK COUNTY, NY
References
CON-#187-2565 OL-3, NUDOCS 8702250120
Download: ML20211F526 (11)

Text

s' J 2565 DE LILCO, February 20,1987 g

DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'87 FEB 24 P1 :12 y.[

Before the Atomic Safety and Licensing Board 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' SECOND SET OF INTERROGATORIES. DATED FEBRUARY 6.1987 LILCO hereby responds to "Suffolk County, State of New York and Town of Southampton's Second Set of Interrogatories and Requests for Production of Documents to LILCO," dated February 6,1987. The " General Answers and Objections" stated in LILCO's February 4,1987 response to the first set of interrogatories apply to this re-sponse as well.

I. ANSWERS AND OBJECTIONS TO INTERROGATORIES Intervenors' Interrogatory No.1 Are Red Cross personnel expected to perform any tasks or functions at the re-ception centers? Identify those tasks or functions. Provide a copy of all documents relating to such tasks or functions.

Response: LILCO objects to Interrogatories 1-3 on the ground that the participation of the Red Cross is outside the Board's jurisdiction and that therefore the interrogatories call for irrelevant information. Without waiving that objection, LILCO responds as fol-lows.

Red Cross personnel are not expected to perform any tasks or functions at re-ception centers. LILCO has no documents that the Intervenors do not already have.

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' Intervenors' Intertwatory No. 2 Identify those tasks or functions which Red (;ross personnel were expected to perform at the Nassau Coliseum, under previous versions of the Plan, but which Red Cross personnel will not be performing at the reception centers under Revision 8 of the Plan.

Response: Red Cross personnel were to assign congregate care centers to monitored evacuees.

Intervenors' Interrogatory No. 3 For each task or function identified in response to Interrogatory No. 2 state:

a. whether the task or function identified will be performed at all under the Plan:

b. If subpart(a) is answered in the affirmative, identify:

(1) the organization which will perform the task or function; (11) the location where the task or function will be performed; (111) the number of personnel assigned to that function per shif t:

(iv) the portions of the Plan,if any, where the identified task or function is explained; (v) all agreements between LILCO and any non-LILCO organizations to perform such tasks; l

(vi) all documents concerning the performance of each such task or function; Provide a copy of all documents identified in response to this interrogatory.

! Response: The assignment of evacuees to congregate care centers will be done by 46 I

LERO personnel at the three reception centers as detailed in OPIP 4.2.3 Sections 5.4.5 and 5.7.4 (Revision 8).

Intervenors'Interroratory No. 4 Provide copies of all zoning ilcenses, permits or other such documents issued by any local government concerning the permitted uses of LILCO's Bellmore, Hicksville and Roslyn Operations Centers.

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Response: LILCO objects to this request on the ground that it seeks information out-side the scope of the issues in this proceeding. Without waiving that objection, LILCO will provide the requested documents.

Intervenors' Interrogatory No. 5 Describe how evacuees with non-removable surface contamination or thyroid contamination will be handled, including:

a. Who will determine what hospitals they will go to;

b. On what basis will a hospital be selected;

c. How they will be transported to hospitals;

d. The amount of transportation available; and

e. How they will be segregated from non-contaminated individuals and prop-erty.

Response: Evacuees with non-removable contamination will be directed to proceed to hospitals. These hospitals will be determined by the Hospital Coordinator from the list of hospitals contained in OPIP 4.2.2 in accordance with the details of that procedure.

The evacuees will use their own transportation to get to the hospitals. The transporta-tion available will be approximately one car for every three evacuees. Since the evacuees have non-removable contamination, procedures to segregate them from non-i contaminated individuals and property are not necessary.

j Intervenors' Interrogatory No. 6 l

l For each reception center, identify the location and dimensions of the " con-trolled areas" referenced under OPIP 3.9.2, S 5.2.5.

Response: The locations for " controlled areas" for each reception center referenced under OPIP 3.9.2 Section 5.2.5 are itemized below:

! Hicksville Reception Center Decontamination trailers All areas identified as monitoring locations All areas identified ai contaminated vehicle locations Transportation garage

3 4

For location and dimensions of " controlled areas" at the Hicksville Reception Center, see OPIP 4.2.3 Att. 4. The scale for this diagram is approximately 1 inch = 386'.

i Bellmore Reception Center Decontamination trailer All areas identified as monitoring locations All areas identified as contaminated vehicle locations Transportation building For location and dimensions of " controlled areas" at the Bellmore Reception Center, i

j see OPIP 4.2.3 Att. 3. The scale for this diagram is approximately 1 inch = 124'.

Roslyn Reception Center Decontamination trailer

All areas identified as monitored locations All areas identified as contaminated vehicle locations '

j Storage building For the location and dimensions of " controlled areas" at the Roslyn Reception Center, ,

see OPIP 4.2.3 Att. 5. The scale for this diagram is approximately 1 inch = 155'.

Intervenors' Interrogatory No. 7 Identify and describo each measure LILCO will take to ensure that contaminated liquid waste at the reception centers does not enter a surface water source. Identify all documents concerning efforts to ensure that contaminated liquid wastes at the recep-tion centers do not enter a surface water source, and provide copies of such documents.

Response: LILCO will contain all reception center decontamination waste water in j collapsible storage containers that will be set up at the time of an emergency. Docu-l ments concerning these containers are being provided, i

Intervenors'Internaratory No. 8 For each reception center, identify the location and dimensions of the " con-i trolled area" referenced in OPIP 3.9.2, S 5.6.7.

Response: " Controlled areas" referenced under OPIP 3.9.2 Section 5.6.7 will be desig-nated, cordoned off, and posted in decontamination areas of all general population re-l ception centers on an "as needed" basis.

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i Intervenors'Interroratory No. 9 Identify how long it will take to follow the procedures outlined in OPIP 3.9.2, 5 5.6.7 through 5 5.6.12. Describe the basis for such an estimate. Identify any docu-ments which relate to the estimate, and provide copies of those documents.

Response: LILCO objects to Interrogatories 9,11,14.c, and 15 on the ground that they seek information irrelevant to the issues in this proceeding. Without waiving that ob-i jection, LILCO answers as follows.

t LILCO cannot estimate the amount of time that it would take to implement steps 5.6.6 through 5.6.12 of OPIP 3.9.2 without knowing details of the postulated lev-els, locations, and types of contamination. However, because of the easily removable nature of contamination and the fact that almost all contamination is likely to be on outer clothing, few evacuees will require the shower described in the procedures. For those that do require this procedure, it is estimated for planning purposes that evacuees -

4 will take approximately 15 minutes in the shower. ,

Intervenors' Interrogatory Nor10 For each reception center, identify the location and dimensions of the " con-trolled area" referenced in OPIP 3.9.2,5 5.7.6.

Respong: LILCO objects to this question as seeking irrelevant information outside the scope of the proceeding. " Controlled areas" referenced in OPIP 3.9.2 Section 5.7.6 l apply to the Emergency Worker Decontamination Facility in Brentwood, not to the gen-eral population reception centers.

i i Intervenors'Interroratory No.11 3

Identify how long it will take to perform the procedures described in OPIP 3.9.2, S 5.8.7. Describe the basis for such an estimate. Identify any documents which relate to the estimate, and provide copies of those documents.

Response: LILCO cannot estimate the amount of time it will take to implement Sec-tion 5.8.7 of OPIP 3.9.2 without knowing details of the postulated levels, location, and types of contamination.

S Intervenors'Interroratory No.12 For each reception center, identify the location and dimensions of the " con-trolled area" referenced in OPIP 3.9.2, S 5.10.8.

Response: " Controlled areas" referenced under OPIP 3.9.2 Section 5.10.8 will be desig-nated, cordoned off, and posted on an "as needed" basis.

Intervenors' Interrogatory No.13 Identify the length of time required to accomplish the following steps set forth in the flow diagram at Figure 1 of OPIP 3.9.2 (page 25 of 49):

a. Use count meter to check for contamination of clothes and entire body;

b. Use count rate meter to check for contamination of skin under clothing;

c. Perform a thyroid scan.

For each time estimate, describe the basis for the estimate, identify the documents which relate to the estimate, and provide copies of the documents so identified.

Response: The estimated times are as follows:

Item a - 90 seconds Item b - 90 seconds Item c - 5 seconds for adults 30 seconds for children These estimates are based upon experience gained during drills and routine monitoring practices observed in the nuclear power industry.

Intervenors' Interrogatory No.14 Identify the length of time required to accomplish the following steps set forth in the flow diagram at Figure 2 of OPIP 3.9.2 (page 26 of 49):

a. monitor exterior of vehicle;

b. monitor interior of vehicle;

c. wash vehicle.

For each time estimate, describe the basis for the estimate, identify the documents which relate to the estimate, and provide copies of the documents so identified.

O

Response

a. Approximately 15 seconds b,c. It is not possible to provide a time estimate for the reason stated in re-sponse to Interrogatory No.11.

Intervenors' Interrogatory No.15 Identify the length of time required to accomplish the following steps set forth in the flow diagram of Figure 3 of OPIP 3.9.2 (page 27 of 49):

a. monitor item;

b. wash item.

For each item estimate, describe the basis for the estimate, identify the documents which relate to the estimate, and provide copies of the documents so identified.

Response: It is not possible to provide the time estimate requested without knowing details of the item being decontaminated and the locations, type, and level of contami-nation postulated.

Intervenors' Interrogatory No.16 Describe the basis for the estimate in OPIP 4.2.3, 5 5.2.6 that members of the public will arrive "approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> af ter the evacuation recommendation." Iden-tify all documents concerning that estimate and produce the documents so identified.

Response: LILCO objects to this Interrogatory as seeking information outside the scope of this proceeding and therefore irrelevant. Without waiving that objection, LILCO an-swers as follows. The estimate of evacuation travel time from the western boundary of the SNPS EPZ to the three reception centers at Hicksville, Roslyn and Bellmore is cal-culated as follows:

1. Assume that all highways will be congested

2. Estimate mean speed along the long-haul routes as follows:

a. Estimate mean densit'y as 100 vpml, reflecting LOS F operations

b. Estimate capacity as 1800 vphl

c. Apply equation of state: V = Q/R Thus, V - 1800/100 = 18 mph

= .

I

3. Distance from western boundary of EPZ to reception centers is approxi-mately 30 miles.

4. Travel time is 30/18 = 1.67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br />

' 5. Elapsed time from the order to evacuate to the time that the first evacuees reach the western boundary of the EPZ in significant volume is about 20-30 minutes.

6. Total elapsed time from the order to evacuate until the arrival of evacuees at the reception centers is the same as items 4 and 5, or about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Intervenors' Interrogatory No.17 4

Identify a 1 structures at each reception center which may be used for care, sheltering, monitoring or decontamination of evacuees. Produce all blueprints or other schematic diagrams of every structure so identified.

_R_esponse: All f acilities and locations which may be potentially used are shown in the facility diagrams attached to OPIP 4.2.3.

Intervenors' Interrogatory No.18 For each reception center, provide copies of all surveys, diagrams, plats, maps or similar documents illustrating, reflecting or describing the property on which the re-ception center is located.

Response: Provided in response to Interrogatory No. 6 of the First Set of Interrogato-ries dated January 21,1987.

Intervenors' Interrogatory No.19

Describe what will be done to dispose of the water used to decontaminate indi-viduals and vehicles.

Response: Provided in response to Interrogatory No. 6 of the First Set of Interrogato-I ries dated January 21,1987.

Intervenors' Interrogatory No. 20 Identify all equipment to be used in monitoring evacuees and vehicles. Produce all documents pertaining to such equipment, including specifications.

Response: All equipment to be used is detailed in OPIP 3.9.2. Copies of the specifications for the HP-210,260 probes, and RM14 are being provided.

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t Intervenors' Interrogatory No. 21 Identify the number of medical doctors LILCO has assigned to each reception center and describe their role at the reception center.

Response: LILCO objects to this Interrogatory as seeking information irrelevant to the issues in this proceeding. Without waiving that objection, LILCO answers as follows.

No medical doctors are assigned to the reception centers.

OBJECTIONS STATED BY COUNSEL All objections and references to objections are stated by counsel.

[. />rt w James N. Chris' man Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 20,1987 t

Y g LILCO, February 20,1987 DXy'Eq.cit E

'87 FEB 24 P1 :13 CERTIFICATE OF SERVICE YOC l' ' , .. + r 0td in the Matter of sio nca 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' Second Set of Interrogatories, Dated February 6,1987 we!'e 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. Margulies, 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, Rm. 407 -

4350 East-West Hwy. Richard G. Bachmann, Esq.

• Bethesda, MD 20814 George E. Johnson, Esq.

U.S. Nuclear Regulatory Commission

. Dr. Jerry R. Kline 7735 Old Georgetown Road Atomic Safety and Licensing (to mailroom)

Board Bethesda, MD 20814 j U.S. Nuclear Regulatory Commission 1 East-West Towers, Rm. 427 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. NucMar Regulatory Commission 1717 H Street, N.W. Mary Gundrum, Esq.

Washington, D.C. 20555 Assistant Attorney General 120 Broadway '

i Atomic Safety and Licensing Third Floor, Room 3-116 i

Appeal Board Panel New York, New York 10271 U.S. Nuclear Regulatory Commission e 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 M

James N. Chriftman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 20,1987 i

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