ML20212K627
| ML20212K627 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/21/1987 |
| From: | Latham S, Mcmurray C, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#187-2301 OL-3, NUDOCS 8701290133 | |
| Download: ML20212K627 (8) | |
Text
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RELATED CORgEsrunDtitGk 00CKETED U3 tac l
January 21, 1987
'87 JAN 27 P2 :56 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
((C( ~.
- gu Before the Atomic Safety and Licensino Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LILCO REGARDING RECEPTION CENTER ISSUES Pursuant to 10 CFR SS 2.740(b) and 2.741, LILCO is requested by Suffolk County, the State of New York, and the Town of Southampton (the " Governments") to answer separately and fully, under oath, each of the interrogatories set forth below within fourteen (14) days after service hereof, and within thirty days to produce for inspection and copying, at the offices of Kirkpatrick & Lockhart, the documents specified below that are within the possession, custody, or control of LILCO.
DEFINITIONS AND INSTRUCTIONS FOR ANSWERS INTERROGATORIES AND DOCUMENT PRODUCTION The interrogatories and document requests which follow should be answered in accordance with the definitions and instructions set forth in Suffolk County's First Set of 8701290133 870121 PDR ADOCK 05000322
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Interrogatories and Request for Production of Documents to Long Island Lighting Company, dated October 10, 1986, which was served on LILCO in connection with the ongoing Shoreham Exercise proceeding (Docket No. 50-322-OL-5).
In addition, the term
" reception centers" refers to the Bellmore, Roslyn and Hicksville Operations Centers which are currently designated as reception centers under the LILCO Plan.
INTERROGATORIES AND DOCUMENT REOUESTS 1.
Identify each person whom LILCO expects to call as an expert or non-expert witness during the reception center hearings and state the subject matter on which each such witness is expected to testify.
For each expert witness identified, state the substance of the facts and opinions to which such witness is expected to testify, and a summary of the grounds for each such opinion.
2.
Provide an up-to-date resume for each witness identified in response to Interrogatory No.
1.
3.
Identify all studies, papers, articles, reports, books, and other such documents, published or unpublished, upon which each witness identified in response to Interrogatory No. 1 intends to rely in support of his or her testimony.
Provide a copy of all items identified in response to this interrogatory, except that those items readily available in the public domain need not be provided..__
4.
Identify by date, location and proceeding all prior testimony before any judicial, administrative, or legislative body, including deposition testimony, given by each of the witnesses identified in response to Interrogatory No. 1 concerning any aspect of emergency preparedness.
5.
Identify all articles, papers, and other documents authored or co-authored by each LILCO witness identified in response to Interrogatory No. 1 on the subject of reception centers, care of evacuees during emergencies, monitoring or decontamination of people or property, handling contaminated materials, traffic engineering or management, or the number of persons expected to arrive at LILCO's reception centers for monitoring.
Provide a copy of each document identified in response to this interrogatory.
6.
Identify all documents concerning the use of LILCO's Hicksville, Bellmore, and Roslyn Operations Centers as reception centers.
Provide a copy of each document identified in response to this interrogatory.
7.
Idr.ntify the number of evacuees which LILCO estimates will arrive at LILCO's reception centers for monitoring in the event of a radiological emergency at Shoreham and state whether LILCO's Plan or procedures reflect this estimate as a planning basis.
8.
Describe how the estimate provided in response to Interrogatory No. 7 was derived and state all facts and opinions on which the estimate is based... - -
J 9.
Identify each factor that LILCO claims makes its reception centers suitable to serve as reception centers for EPZ evacuees.
10.
Identify each factor which LILCO claims makes its Plan or procedures for operating the reception centers adequate.
11.
Identify all documents concerning LILCO's procedures for monitoring or decontaminating evacuees.
Provide a copy of each document identified in response to this interrogatory.
12.
Identify all communications between LILCO and any governmental bodies concerning LILCO's use of the Hicksville, Bellmore, and Roslyn Operations Centers as reception centers.
Provide all documents concerning such communications.
13.
Identify by date and location any drills or exercises held at LILCO's reception centers to determine their adequacy or the adequacy of-LILCO's procedures for monitoring and handling evacuees at the reception centers.
14.
Identify all communications between LILCO and the NRC or FEMA concerning the use of the Bellmore, Hicksville, and Roslyn Operations Centers as reception centers.
Provide all documents concerning such communications.
15.
Identify any documents concerning the management or treatment of vehicle traffic in and around the reception centers.
Provide all documents identified in response to this interrogatory..--.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 ku=
MErbert H. Brown Lawrence Coe Lanpher Christopher M. McMurray KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County L A /L k=
Fab'ian G.
Palomino
/
Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for Mario M. Cuomo, Governor of the State of New York Ste'phep'B. Lathad
/
Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton January 21, 1987 l
! (
l l
00tKETED vnm January 21, 1987
'87 JAN 27 P2 56 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION gFig'{
g
,m Before the Atomic Safety and Licensinc Board
)
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 hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LILCO REGARDING RECEPTION CENTER ISSUES have been served on the following this 21st day of January, 1987 by U.S. mail, first class, except as otherwise noted.
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.
20555 Suite 1020 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
Mr. Frederick J. Shon Anthony F. Earley, Jr., Esq.
Atomic. Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Ccmpany Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 Mr. William Rogers W. Taylor Reveley, III, Esq.
Clerk Hunton & Williams Suffolk County Legislature P.O. Box 1535 Suffolk County Legislature 707 East Main Street Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B..Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham 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 11787 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 1
Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 i
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 l
Martin Bradley Ashare, Esq.
Fabian G. Palomino, Esq.
i 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 Bernard M. Bordenick, 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 j
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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 m
istopher M. McMurray' s/
KIRKPATRICK & LOCKHART
/
1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891
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