ML20213A040
| ML20213A040 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/28/1987 |
| From: | Latham S, Mcmurray C, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Federal Emergency Management Agency, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#187-2371 OL-3, NUDOCS 8702030069 | |
| Download: ML20213A040 (8) | |
Text
,
15 b? ?/
,<tuu eu cuatseuavem 00LKETED us1RC January 28, 1987
'87 JAN 30 P2 :09 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cn,t '
COCf Before the Atomic Safety and Licensina Board i
)
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 SOUTRAMPTON'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO FEMA AND THE NRC STAFF Pursuant ;o 10 CFR SS 2.740(b), 2.741 and 2.744, Suffolk County, the State of New York and the Town of Southampton (the
" Governments") hereby request PEMA and the NRC Staff to answer separately and fully, under oath, each of the interrogatories set forth below, and 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 FEMA, or the NRC Staff, or both.
l 5035 8702030069 870128 PDR ADOCK 05000322 G
DEFINITIONS AND INSTRUCTIONS FOR ANSWERING INTERROGATORIES AND DOCUMENT REOUESTS In responding to the interrogatories and document requests below, FEMA and the NRC Staff shall follow the definitions and instructions set forth in Suffolk County's First Request for Production of Documents to the NRC Staff and FEMA (Oct. 10, 1986), and Suffolk County' First Set of Interrogatories to the NRC Staff and FEMA (Oct. 15, 1986), both of which were served on FEMA and the NRC Staff in connection with the Shoreham Exercise litigation (Docket No. 50-322-OL-5).
In addition, the term
" reception centers" refers to LILCO's Bellmore, Roslyn and Hicksville Operations Centers which are currently designated as reception centers under the LILCO Plan.
The term "LILCO Plan",
unless otherwise stated, refers to Revisions 6, 7 and 8 of the LILCO Plan.
INTERROGATORIES AND DOCUMENT REOUESTS 1.
Identify each person whom FEMA or the NRC Staff expects to call as an expert or non-expert witness during the reception center hearings and state the subject matter and the facts 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 FEMA or NRC Staff 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.
4 -_.
7.
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.
8.
Identify all documents concerning LILCO's procedures for monitoring or decontaminating evacuees as set forth in the LILCO Plan.
Provide a copy of each document identified in response to this interrogatory.
9.
Identify all documents concerning the LILCO Plan's compliance with NUREG 0654 II.J.12 or with FEMA or NRC guidance memoranda, or other such documents, regarding reception centers or the care, monitoring or decontamination of evacuees.
Provide copies of all documents identified pursuant to the interrogatory.
10.
Identify all documents concerning FEMA's review of the LILCO Plan.
Provide copies of all documents identified in response to this interrogatory.
11.
Identify all documents concerning the Regional Assistance Committee's (the "RAC's") review of the LILCO Plan.
Provide copies of all documents identified in response to this interrogatory.
12.
Identify each RAC member and all other individuals, including all FEMA contractors, who reviewed the LILCO Plan's compliance with NUREG 0654 II.J.12 or with FEMA or NRC guidance memoranda, or other such documents, concerning reception centers or the care, monitoring or decontamination of evacuees. _ ~.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 A
m CKwrence/Coe Canphdr Karla J.
Letsche Christopher M. McMurray KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County 6 /LJL Fabian 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
- ==
St6pfien g.~ "Gtham
/
Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton January 28, 1987 "
k 00t r' E T E
- : W M-January 28, 1987
'87 Jm 30 P2 :09 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION GFF:t t DOCKE M 4 "i 7 Before the Atomic Safety and Licensino Board D'
)
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 FEMA AND THE NRC STAFF have been served on the following this 28th day of January 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 BY TELECOPY
Mr. Frederick J. Shon Anthony F.
Earley, Jr., Esq.
Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company 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. Peter Cohalan New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 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 Martin Bradley Ashare, Esq.
Fabian G.
Palomino, Esq.
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 BY TFLECOPY I
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 ristopfher M. McMurray KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 l
l
..