ML20212K285
| ML20212K285 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/03/1987 |
| From: | Leugers M HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2690, CON-#187-2753 OL-3, NUDOCS 8703090264 | |
| Download: ML20212K285 (5) | |
Text
Q,,
20N LILCOJMCrsh 3,-1987 Q
W1EQ CORREStyNDENGF, l>
' UNITED STATES OF AMERICA E0WETEE-~
L^NRC' NUCLEAR REGULATORY COMMISSION
'87 - tiAR -5 P2 :08
-Before the Atomic Safety and Licensing Board
,h
~ l $f
~?
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTERS DIRECTED TO SUFFOLK COUNTY AND NEW YORK STATE Pursuant to 10 CFR SS 2.741, Long Island Lighting Company, by its counsel, hereby requests that Suffolk County and New York State produce the following docu -
ments specified below that are within the possession, custody, or control of Suffolk County and New York State. By requesting production of these documents, LILCO makes no admission or representation about the proper scope of the issues to be decided or 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 Suffolk County and New York State, dated January 16, 1987. In addition to the Defini-tions stated therein, please adhere to the following definitions in answering this Re-quest for Production of Documents:
Q.
" State Plan" means the New York State Radiological Emergency Response Plan, including all State-prepared annexes on appendices, or a county or any other basis, for individual nuclear power plants within New York State.
3 p0
g{
j-R.
" County Plan" means, to the extent not included in the State Plan, all spe-cific supplements or appendices to the State Plan prepared by the counties occupying the emergency planning zone around each nuclear power plant in New York State other than Shoreham.
S.
" Relocation center" means all facilities at any and all nuclear power plants in New York State other than Shoreham where evacuees and vehicles are monitored for radiological contamination and where such evacuees and vehicles are decontan inated.
Request for Production of Documents 1.
Identify and provide a current copy of all parts of the State Plar. and of each County Plan concerning the monitoring of evacuees and vehicles for radiological contamination, including for each relocation center, (1) monitoring procedures, (2) the number of monitoring teams for each relocation center, (3) the number of individuals on each team at each relocation center, (4) the number of individuals so assigned at each relocation center, (5) the specific types and quantities of radiological monitoring equip-ment at each relocation center,(6) the time it takes or is assumed to take a monitoring team to monitor individual evacuees and vehicles at each relocation center, (7) the 10-cation of each and every relocation center, and (8) the number of individuals and the number of vehicles that it is assumed will arrive at each relocation center as sta.ted in its planning basis.
2.
Please identify and provide a copy of any other document prepared by New York State or the counties occupying the emergency planning zones around each nucle-ar plant in New York other than Shoreham, not already identified in response to Re-quest No.1, concerning the monitoring of evacuees and vehicles for radiological con-tamlnation at each nuclear power plant in New York State other than Shoreham.
3.
Identify and provide a current copy of all parts of the State Plan and of each County Plan concerning decontamination of evacuees and vehicles, including (1)
fi g.
the facility or structure used to decontaminate evacuees and vehicles, (2) its name or
. Other identification, (3) a physical description, (4) its location, (5) the number of show-ers, sinks, and toilets at each such facility or structure, (5) the procedure for decontaminating evacuees and vehicles, and (6) the method of collecting and disposing contaminated water used in decontaminanting evacuees and vehicles.
4.
Please identify and provide a copy of any other document prepared by New York State or the counties occupying the emergency planning zones around each nucle-ar power plant in New York other than Shoreham, not already identified in response to Request No. 3, concerning the decontaminating of evacuees and vehicles for ra-diological contamination at each nuclear plant in New York State other than Shoreham.
Respectfully submitted, W.D
$138Y
~
1a rs Hunton & Williams 707 East Main Street P.O. Box 1535 Richmcnd, Virginia 23212 DATED: March 3,1987
N.
LILCO, March 3 ' 1987.
I:
D MCit t:
UWC CERTIFICATE OF SERVICE
'87 ffAR -5 P2:08
- .1 In the Matter of
~
LONG ISLAND LIGHTING COMPANY 1.. M r m w. y (Shoreham Nuclear Power Station. Unit 1)
' " y; g':%' ICE Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTERS DIRECTED TO SUFFOLK COUNTY AND NEW YORK STATE were served this date upon the following by Federal Express as indicated by one asterisk, or by first-class mall, postage prepaid.
Morton B. Margulles, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel i
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
- East-West Towers, Rm. 407 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD _20814 Richard G. Bachmann, Esq.
- George E. Johnson, Esq.
Dr. Jerry R. Kline U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 7735 Old Georgetown Road Board (to mallroom)
U.S. Nuclear Regulatory Commikion Bethesda, MD 20814 East-West Towers, Rm. 427 4350 East-West Hwy.
Herbert H. Brown, Esq.
- Bethesda, MD 20814 Lawrence Coe Lanpher, Esq.
Karla J. Letsche, Esq.
Mr. Frederick J. Shon Kirkpatrick & Lockhart Atomic Safety and Licensing South Lobby - 9th Floor Board-1800 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C. 20036-5891 East-West Towers, Rm. 430 4350 East-West Hwy.
Fabian G. Palomino, Esq.
- Bethesda, MD 20814 Richard J. Zahnteuter Esq.
Special Counsel to the Governor Secretary of the Commission Executive Chamber
. Attention Docketing and Service Room 229 Section State Capitol U.S. Nuclear Regulatory Commission Albany, New York 12224 1717 H Street, N.W.
Washington, D.C. 20555 Mary Gundrum, Esq.
Assistant Attorney General Atomic Safety and Licensing 120 Broadway
= Appeal Board Panel Third Floor, Room 3-116 U.S. Nuclear Regulatory Commission New York, New York 10271 Washington, D.C. 20555 n --- -.. - -.., _,. _._
c 4
} Ms. Nora Bredes Spence W. Perry, Esq.
- Executive Coordinator William R. Cumming, Esq.
Shoreham Opponents' Coalition Federal Emergency Management 195 East Main Street Agency Smithtown, New York 11787 500 C Street, S.W., Room 840 Washington, D.C. 20472 Gerald C. Crotty, Esq.
Counsel to the Governor Mr. Jay Dunkleberger Executive Chamber New York State Energy Office State Capitol Agency Building 2 Albany, New York 12224 Empire State Plaza Albany, New York 12223 Martin Bradley Ashare, Esq.
- Eugene R. Kelly, Esq.
Stephen B. Latham, Esq.
- Sulfolk County Attorney Twomey, Latham & Shea H. Lee Dennison Building 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11787 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockefctler Plaza Albany, New York 12223
/1AA/
2Ad L"a*y94#r*s *"/ /
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: March 3,1987