ML20212N618

NRC Second Supplemental Response to Intervenors First Set of Interrogatories & Request for Production of Documents to FEMA & Nrc.* Affidavit & Certificate of Svc Encl.Related Correspondence

ML20212N618
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/06/1987
From:	Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY
References
CON-#187-2769 OL-3, NUDOCS 8703130098
Download: ML20212N618 (8)

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RELATED COMMLSPONDtNGA .

@. March 6, ~1987 DSCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . ._,

T1 tuR 11 Pl2q2 DEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECf ETAFY 00CKETINfi & SEPVifE.

BRANC!!

In the Matter of )

)

LONG ISLAND LIGIITING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO FEMA AND 'THE NRC STAFF The NRC Staff hereby1 supplements its previous responses, dated -

February 17, 1987 - and March 2,1987, to "Suffolk County, State of New York and Town of Southampton's First Set of Interrogatories and Request ' for ' Production of Documents to FEMA and the NRC Staff" 4

(" Discovery Request").

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I. RESPONSES TO INTERROGATORIES INTERROGATORY NO.1 i Lewis G. Hulman has been _ designated by the Staff to testify on the matters set forth in the Staff's response to Interrogatory No.1 of NRC Staff Supplemental Response to Intervenors' First Set of Interrogatories and Request for Production of Documents to FEMA and the NRC Staff, 4

dated March 2,1987.

Mr. Hulman replaces Mr. Soffer as a witness in this matter., and will be made available for deposition in piece of Mr. Soffer at the time and place - previously arranged for deposition of Messrs. I;antor and Soffer.

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_g-D INTERROGATORY NO. 2

- Mr. Hulman's resume is attached to this response.

'INTERRCGATORY NO 3 Documents . which Mr. Hulman has identified to date as documents upon which he intends to rely are:

(1) Technical Guidance for Siting . Criteria Development, .

NUREG/CR-2239, SAND 81-1549, December 1982 (2) Demographic Statistics Pertaining to Nuclear Power Reactor Sites, NUREG-0348, October 1979.

(3) Calculations referenced in Testimony of Fred C. Finlayson and Edward P.

Radford, insofar as relevant, in this proceeding, Wednesday, July 11, 1984, pp.12317, et seq.

(4) Shoreham, DES, FES, and SER (5) Review and Evaluation of the Indian Point Probabilistic Safety Study, NUREG

/CR-2934, S AND82-2929, December 1982 (6) Reassessment of the Technical Bases for Estimating Source Terms, NUREG-0956 (Draft), July 1985

-(7) Sandia Report: Estimates of the Financial Consequences of Nuclear Power Reactor Accidents, David R. Strip ,

NUREG/CR-2723, SAND 82-1110, September 1982 (8) FES Related to the Operation of Limerick i Generating Station, Units 1 and 2, NUREG-0974, April 1984 (9) NUREG-0654-REP-1, Rev.1 (10) Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of 1

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7-Light Water . Nuclear Power Plants, NUREG-0396, EPA 520/1-78-016, December 1978-INTERROGATORY NO. 4 Mr. Hulman testified in the Limerick,' Midland, and Byron

. proceedings on matters related .to accident analyses, accident risks, and accident consequences.

INTERROGATORY NO. 5 Mr. Hulman has not authored any documents within the scope of this interrogatory.

II. RESPONSES TO DOCUf.!ENT REQUESTS All documents identified in answers to the above interrogatories are available in the NRC Public Document Room.

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l Res cetfully submitted, 3 v [

rg , ohnson Counsel fo NRC Staff l Dated at Bethesda, f.faryland this 6th day of March,1987 l

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matt'er of )

)

LONG -ISLAND LIGHTING COMPANY ') Dcchet No.1 50-322-OL-3

) (Emergency Planning)

(Shoreham . Nuclear Power Station, )

Udt 1) )

AFFIDAVIT OF LEWIS G. HULMAN I, Lewis G. Hulman , being duly sworn, do depose and state the following:

, 1. I am the Chief of the Plant Systems Branch , Divisien of Boiling Water Reactors, in the Office of Nuclear Reactor Regulation ,

1 U.S. Nuclear Regulatory Commission. A copy of my professional qualifications g attached to my affidavit.

2. I have provided supplemental answers to Interrogatories 1 through 5 contained in "Suffolk County, State of New York and Town of i Southampton's First Set of Interrogatories and Request for Production of o Documents to FEMA and the NBC Staff," filed .Tanuary 28, 1987.

3. The responses referred to above are true and correct "to the best of my personal knowledge and belief.

O Oudo ,

• A von Lewis G. Ilulman N Subscribed and sworn to before me this 6th day of March,1W

% )- .' YSA&Wu Notary' Public My commission expires: '7///9d

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LEWIS G. HULMAN PROFESSIONAL QUALIFICATIONS I am the Chief of the Plant Systems Branch, Division of Boiling Water i Reactors, in the Office of Nuclear Reactor Regulation. I was formerly the Chief of the Accident Analysis Branch, Chief of Systems Interaction

~ Branch and Chief of the Hydrology-Meteorology Branch, also both in the Office of Nuclear Reactor Regulation.

My formal education consists of study in Engineering at the University of Iowa where I received a BS in 1958, and an MS in Engineering Mechanics and Hydraulics in 1967. In addition, I have taken postgraduate courses at ' the University of Nebraska, MIT, Colorado State University, and the University of California, and numerous management, technical and computer utilization courses sponsored by the government.

My employment with NRC (formerly AI:C) dates from February 1971 with both the Office of Nuclear Reactor Regulation and the former Office of Reactor Safeguards, and for consultation on the siting of materials-utilization facilities. I have been responsible for the assessment of the potential for accidents resulting from natural phenomena, accident analysess, system performance under accident conditions, the generation and transport of fission and activation products within and outside nuclear power plants,- fire protection, health physics, plant systems, and the radiological consequences of accidental releases.

A scheduled reorganization of NRC has identified me as Chief of the

• Severe Accident Issues Branch in the Office of Research. This reorgani-zation is scheduled for implementation on April 12, 1987. My responsi-bilities under this reorganization will include resolution of severe accident issues , assessment of severe accident phenomenology, implementation of the Commission's Severe Accident Policy, accident consequences and source terms and analysis techniques, Safety Goal evaluation and l implementations, the development knd implementation of containment performance design objections, accident management analysis , and the agency technical focal point on emergency preparedness and siting I

rulemakings.

From November, 1985 until the reorganization, I have been Chief of

l. the Plant Systems Branch, Division of Boiling Water Reactor Licensing, MRR. In this position I have been responsible for review of plant systems and environmental assessments. Included in the scope of l

responsibilities has been activities associated with fire protection, contain-

ment and penetration leak testing, feedwater systems, radwaste j

occupational and offsite exposures, fuel handling, flood protection, water l supply adequacy, accident analyses, generators, turbines, water i chemistry and environmental assessments of licensee proposalsc T have also been a participant in a staff initiative to identify potential i

improvements in boiling water reactor containments to improve their ability to mitigate the consequences of severe accidents.

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l From ' December, 1981 through November 1, 1985 I supervised the preparation of all the accident sections for draft and final Environmental, Impact Statements, Safety Evaluation Reports; and participated in the 1 staff's ' evaluation of Zion, Indian Point and Limerick and GESSAR standard plant design PR A's. In addition, I participate:d in the ..

development of the technical bases for safety guides, and standards, and ,

in research assessments.

From lifarch 1980 through mid-April 1981 I was employed in private' industry as a Vice President with ' Tetra Tech, Inc. in Pasadena, L California. During this period I was responsible for busineri development, and for managing several contracts involving various engineering studies. including several contracts " for government and industry. Of note were studies of a nuclear power plant in Yugoslavia for the International Atomic ; Energy A gency, risk and risk aversion studies in the Dominican RepuMic, is refinery intako desfrn in Indonesia, and Hurricane risk assessments in Texas, North Carol! Iia, Florida, and

New Jersey. ,

From 1968 to 1971, I wcs a ' hydraulic Engineer with the Corps of Engineers' Hydrologic Engineering Center in Davis, California, where I worked as a consultant for 1most Corps' offices, participated 'zy an instructor in training courses, aind conducted research.

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From 1963 to 1968, I .was a Nupervisory IIydraulic Endneer with the

Philadelphia District, Coirps of Engineers. As Assistant - Chief of the Hydrology Branch, I wsn responsible for design espects of multi-purpose

. dams, navigation projects, coastal engineering de relopment and special studies on modeling of dams, inlets, water supply, and shoaling, . salt u water intrusion, andtthe effects '6f dredging.

From 1958 to 1963, ~ I ..was a Ilydraulic Enginar with the Omaha Dietrict of the Corps of Engineers. I was responsible for the hydraulic design of flood control channels, hydraulic design of structures for large dams and several flood control projects. I also received training in, probabilistic . -

i assessments, hydrologic engineering, structural engineering, sedimentation, river training studies and design , and water resource project formulation.

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I I have published in journals or periodicals of the American Society of Civil Engineers, the American Water Works Association, the Journal of Marine Geodesy, the National Society of Professional Engineers , the 1 American Gecphysical Union , Physics Magazine, the American . Nuclear l Society and in internal technical papers and semirar proceedings of tho l Corps of Engineers, the AEC, and the NRC.

i I am a registered Professional Engineer in the States of Nebraska and /

California. I am a member .of the American Society of Civil Engineers, i the American Meteorological Society, and the American Gecphysical Union.

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, . UNITED STATES OF AMERICA 00LMETED z/ NUCLEAR REGULATORY COMMISSION USNRC lf "

' BFFCBE THE ATOP'M SAFETY AND LICENSING BOED HAR 11 Pl2:12 e

OFFICE OF SECEETAnY

-In the Matter of- ) SOCKETING & SEltvicf.

2

. ) .

BRANCH A LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

^ ,(Shorchum Nuclear Power Station, )

Unit 1) )

3.

CERTIFICATE OF SERVICE

'I' ilereby certify that coIies S of "NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND

-PUQUEST FOR PRODUCTION OF DOCUMENTS TO- FEMA AND THE NRC -

STAFF" 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 Regulatory Commission's internal mail system this 6th day of March 1987:

.Morton B. Margulies, Chairman * - Joel Blau, Esq.

pdministrative Judge . Director, Utility Intervention

- ntomic Safety and Licensing Board Suite ~1020 U.S.- Nuclear Regulatory Commission- 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 X . Jerry R. Kline* Fabian G. Palomino, Esq.

Administrative Judge Special Counsel to the Governor

' Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear P.egulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 I .'

t

. Frederick J. .Shon* Jonathan D. Feinberg, Esq.

Administrative Judge New York. State Department of a Atomic Saf'ety and Licensing Board Public Service

.U.S. Nuclear Regulatory Commission Three Empire State Plana Weahington, DC 20555 Albany, NY 12223 Philip ftcIntire W. Taylor Reveley III, Esq.

Federal Emergency Management Donald P. Irwin, Esq.

Agency - Hunton a Williams

. 126 Federal Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY' 10278 Richmond, VA 23212" Douglas J. Hynes. Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 i

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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 4 South Lobby .- 9th Floor 4 > 1800 M Streeti NW Atomic Safety and Licensing h

• Washington , ' DC 20036-5891 Board Panel * / 3 ,

s U.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, 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 Ifighway 500 C Street, SW l Hauppauge, NY ' 11788 Washington, DC 20472 i

Dr. ' Monroe .3chneider , Robert Abrams, Esq.

North 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

i Anthony F. Earley, Jr. William R. Cumming Esq.

General Counsel Office of General Counsel Long Island Lighting Company Federal Emergency Management i 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW Washington, DC 20472 Dr. Robert Hoffman s 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 <

Mary M. Gundrum, Esq. Barbara Newman New York State Department of Law Director, Environmental Health 120 Broadway Coalition for Safe Living 3rd Floor, Room 3-116 Box 944

New York, NY 10271 Huntington, New York 11743

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<Ccorge E.' Jolynson Counsel for)1RC Staff

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