ML20213F445
| ML20213F445 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/10/1986 |
| From: | Zuegin L HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| References | |
| CON-#486-1462 OL-5, NUDOCS 8611140210 | |
| Download: ML20213F445 (32) | |
Text
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LILCO, November 10,1986
/ y,f 3-WELATED CURRE.5POJtDRM UNITED STATES OF AMERICA C OU' E NUCLEAR REGULATORY COMMISSION 2)"F g g 12 All 31 Before the Atomic Safety and Licensinst Board f0CF '" ' Mt f
In the Matter of
)
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)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK
}
COUNTY, NEW YORK STATE AND THE TOWN OF SOUTHAMPTON Long Island Lighting Company, by its counsel, propounds the following Interrogatories and Requests for Production of Documents to Suffolk County, New York State and the Town of Southampton ("Intervenor" or "the Intervenors"), pursuant to SS 2.740,2.740b, and 2.741 of the Nuclear Regulatory Commission's Rules of Practice.
In responding to these interrogatories and requests for production, Intervenors should follow the instructions and definitions contained in LILCO's First Set of Interrogatories to latervenors dated October 30,1986.
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Contention EX 16 1.
a.
How many of the bus companies or bus yards listed in Contention EX 16(K) do Intervenors contend would have had to have participated in the Exercise in order for the Exercise to have yielded " valid or meaningful results?"
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- 4 b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
2.
a.
How many buses from each bus company or bus yard that participated in the Exercise (see Contention EX 18(C)(i)) do Intervenors contend would have had to have been supplied in order to demonstrate that emergency response personnel were "f amiliar with their duties?"
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
3.
a.
How many of the ambulance companies listed in Contention EX 16(L) do Intervenors contend would have had to have participated in the Exercise in order for the Exercise to have yielded " valid or meaningful results?"
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
4.
a.
How many ambulances from each ambulance company that participated in the Exercise (see Contention EX 18(C)(ii)) do Intervenors contend would have had to have been supplied in order to demonstrate that emergency organization personnel were "f amiliar with their duties?"
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Contention EX 21 5.
Please state, for Contention EX 21 and each of its subparts, the basis on which Intervenors contend that the sample size evaluated by FEMA in the Exercise was insufficient to support the conclusions in the FEMA Report of April 17,1986.
6.
a.
Please identify for Contention EX 21 and each of its subparts the criteria used for determining the adequacy of sample size.
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the criteria identified in paragraph (a).
7.
a.
How many route alert drivers from how many staging areas do Intervenors 1
contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
8.
a.
How many bus drivers from how many staging areas do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
9.
a.
How many bus drivers from how many public, private, and parochial schools do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
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b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
- 10. a.
How many of the ambulette and ambulance drivers serving how many special facilities do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
l b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
- 11. a.
How many traffic guides do Intervenors contend would have had to have been 3
observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
- 12. a.
How many traffic impediments do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
- 13. a.
How many evacuee congregate care centers (see Contentions EX 15(I),22(K),
and 31) do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
I i
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Contention EX 22A
- 14. a.
Please state whether Intervenors contend based on the statement "Nassau County has expressly refused to agree to, or permit, the use of Nassau County facilities as part of, or to implement, the LILCO Plan" that in the event of an actual emergency at Shoreham, Nassau County would refuse to permit the use of the Nassau Coliseum (and/or any and au other Nassau County facilities or resources) by LERO for registration, monitoring, and decontamination of evacuees, or for any other emergency purpose during an actual emergency at Shoreham.
b.
Please state whether Intervenors contend based on the statement "Nassau County has expressly refused to agree to, or permit, the use of Nassau County facilities as part of, or to implement, the LILCO Plan" that Nassau County would refuse to permit use of the Nassau Coliseum (and/or any and all other Nassau County facilities or resources) by the American Red Cross for registration, monitcring, and decontamination of evacuees, or for any other emergency purpose during an actual emergency at Shoreham, c.
What is the basis for the answers to paragraphs (a) and (b)?
d.
Identify and provide a copy of each document upon which Intervenors intend to rely or which relates to the answer to paragraphs (a), (b) and (c).
- 15. a.
What is the basis for Intervenors' statement that "the exercise scenario, and FEMA's conclusions on objectives EOC 16 and Field 9,17,19, and 21, are all
based upon an assumption that the Nassau Veterans Memorial Coliseum is available for use by LILCO and the American Red Cross as a Reception Center...?"
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer in paragraph (a).
Contention EX 36
- 16. a.
Does Contention EX 36 allege that protective action recommendations other than those made by LERO during the exercise would have resulted in greater dose savings to the general public?
b.
State the basis for Intervenors' answer to paragraph (a),
c.
Unless the answer to pragraph (a) is a simple negative, please state (1) the protective action recommendation or recommendations that Intervenors assert would have resq'.ted in greater dose savings and (2) the amount of dose savings assertedly rd'tized by Intervenors' alternative protective action recommendation or recommendations.
d.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a) through (c).
- 17. a.
Is it Intervenors' contention that, in light of the projected wind shif t, LERO personnel should have rescinded their recommendation to evacuate zones A-M, Q and R and instead recommended that people in those zones shelter?
b.
Is it Intervenors' contention that the change in protective action recommendations described in paragraph (a) would have produced greater dose l
l savings?
l 9
i 1
c.
Unless the answer to paragraph (b) is a simple negative, state the amount of dose savings.
d.
State the basis for the answers to paragraphs (a) through (c).
e.
Identify and provide a copy of each document upon which Intervenors rely or which provides support for the answers to paragraphs (a) through (c).
Contention EX 38
- 18. a.
Please state the time Intervenors believe the ENC should have been declared operational.
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 19. a.
Please state the time Intervenors believe the first press briefing should have been held, in order for it to have been deemed " timely" under the circumstances of the Exercise.
b.
State the bases for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 20. a.
Do Intervenors consider the asserted delay in activation of the ENC and holding of the first press briefing to reveal, by themselves, a fundamental flaw in the Shoreham Emergency Plan?
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraph (a).
l l
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- 21. a.
State the basis for the statement that "such a delay would result in substantial confusion, speculation, rumor generation, lack of confidence in LILCO's ability to deal with the emergency, and refusal to believe information, advice or instructions subsequently disseminated by LILCO personnel."
b.
Identify and provMe a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 22. a.
Do Intervenors contend that the absence of any reference in the 08:21 News Release No. I to the fact that a Site Area Emergency had been declared at 08:19 constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 23. a.
Do Intervenors contend that, if the Site Area Emergency had tieen declared at 08:21, some 30 seconds ahead of News Release No.1, the absence of any reference in the 08:21 News Release No. I to the fact that a Site Area Emergency had been declared constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan?
b.
State the basis for the answer to paragraph (a).
Identify and provide a copy of each document upon which Intervenors rely or c.
1 which provides support for the answers to paragraphs (a) and (b).
- 24. a.
Do Intervenors contend that the alleged delay between approval of the EBS message at 08:37 and issuance to the press of a news release containing the same information constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan?
I l
b.
State the basis for the answer to paragraph (a),
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 25. a.
Do Intervenors contend that the time interval between the LERO Director's determination to issue the information in News Release No. 2 and his approval of that release (08:37 to 09:00) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identity and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 26. a.
Do Intervenors contend that the interval between the LERO Director's approval of News Release No. 2 and its distribution to the press (09:00 to some unspecified time af ter 09:15) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 27. a.
What is the maximum length of time that Intervenors believe is acceptable between the LERO Director's determination to issue a press release and approval of that release?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 28. a.
What is the maximum length ctf time that Intervenors believe is acceptable between the LERO Director's approval of a press release and its distribution to the press?
i l
l l
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 29. a.
Identify each basis for the statement " insufficient copying capabilities at the ENC contributed to delays in the distribution of information.. to the media."
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 30. a.
Identify each instance in which the copying facilities at the ENC are alleged to have been insufficient and state the manner in which Intervenors believe LILCO could have avoided or corrected such insufficiencies.
b.
Identify and provide a copy of each document upon which Intervenors rely oi-i, which relates to the answer to paragraph (a).
31.
3.
Identify each map or display at the ENC which Intervenors allege was inadequate.
b.
For each map or display identified in paragraph (a), state the inadequacy.
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 32. a.
Identify each EBS message provided to the press which Intervenors assert contained extraneous information.
b.
For each EBS message identified in paragraph (a), identify the information which Intervenors believe to be extraneous.
c.
State the basis for the answers to paragraphs (a) and (b).
d.
State the basis for Intervenors' assertion that the presence of extraneous information in fact made each EBS message " unclear" and " confusing."
Identify and provide a copy of each document upon which Intervenors rely or e.
which relates to the answers to paragraphs (a) through (d).
- 33. a.
For each LERO Press Release listed in Contention EX 38(G) (iA, Nos. 3, 4, 5, 6, and 7), state whether Intervenors contend that the time interval between the ENC's receipt of each press release and the time each was posted was excessive.
b.
For each press release described in paragraph (a), state separately the basis for the answer to paragraph (a).
- 34. a.
State the maximum length of time between the ENC's receipt of a press release and the posting of that release which Intervenors believe is acceptable.
b.
State the basis for the answer to paragraph (a).
Identify and provide a copy of each document upon which Intervenors rely or c.
which relates to the answeru to paragraphs (a) and (b).
- 35. a.
Do Intervenors contend that the interval between the LERO Director's decision to recommend evacuation of the entire EPZ (11:46) and the alleged time at which the media were informed of the recommendation (12:47) was excessive?
b.
State the basis for the answer to paragraph (a).
Identify and provide a copy of each document upon which Intervenors rely or c.
which relates to the answers to paragraphs (a) and (b).
- 36. a.
Do the Intervenors contend that the interval between the 12:00 Noon EBS message containing the recommendation to evacuate the entire EPZ and the alleged time at which the media were informed of that recommendation (12:47) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 37. a.
State the maximum length of time between the LERO Director's decision to recommend a protective action and the time the media are informed of the recommendation which Intervenors believe is acceptable.
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
38, a.
Do Intervenors contend that the interval between the alleged time that LERO workers were instructed to ingest KI (09:45) and the alleged time the media were informed of that instruction (13:05) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 39. a.
State the maximum length of time between the instruction of LERO workers to ingest KI and the time the media are informed of that instruction that Intervenors believe is acceptabte.
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 40. a.
Do Intervenors contend that the general public should have been informed that LERO workers had been instructed to ingest KI?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervencrs rely or that relates to the answers to paragraphs (a) and (b).
- 41. a.
What is the basis for Intervenor's statement in Contention EX 38(I) that "such a delay and the attempt to conceal pertinent information about the life-threatening effects of the accident would result in further reductions in LILCO's credibility and refusals of the media and the public to obey LILCO's advice during a real emergency."
b.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answer to paragraph (a).
- 42. a.
Identify each specific instance in which LERO personnel were allegedly
" unable to respond satisfactorily or accurately to questions about evacuation" (see Contention EX 38(J)).
b.
State the criteria that Intervenors would use for judging whether the response was "satisf actory."
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
- 43. a.
Identify each specific instance in which ENC personnel were " unable to provide any information to the media... concerning traffic conditions, conditions or evacuation activity on the water portion of the EPZ, or protective actions for the correctional facility in the EPZ" (see Contention EX 38(J)).
b.
What is the basis for the answer to paragraph (a)?
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c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
- 44. a.
Identify each specific instance in which LERO personnel were allegedly
" unable to respond to questions about manpower at bridges and tunnels on evacuation routes, or the activities of the Nassau County Police" (see t
Contention EX 38(J)).
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
45, a.
What is the basis for Intervenors' statement that "LERO Public Information personnel were unable to contact Marketing Evaluations, Inc., in a timely manner?"
b.
What is the maximum acceptable period within which Intervenors contend that Marketing Evaluations, Inc. must be contacted in order for the contact to be " timely"?
c.
What is the basis for the answer to paragraph (b)?
d.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) through (c).
- 46. a.
Do Intervenors contend that the possession of allegedly inaccurate information about the traffic impediment by ENC personnel constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan, in light of the fact that (as the contention concedes) this information apparently was not disseminated to the public?
I
l b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
- 47. a.
Identify each specific instance in which LERO ENC personnel allegedly "were not able to respond to questions about the fuel truck impediment."
b.
Do Intervenors contend that the alleged inability described in paragraph (a) constituted or revealed, by itself, a fundamental flaw in the Shoreham Emergency Plan?
c.
What is the basis for the answer to paragraph (b)?
d.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) through (c).
- 48. a.
Identify each instance Other than the two examples given in subpart N, in which LERO personnel allegedly " misstated facts and provided inaccurate information".
b.
Do Intervenors contend that the two examples cited, along with any other such instances identified, constitute or reveal, by themselves, a fundamental flaw in the Shoreham Plan?
c.
What is the basis for the answer to paragraph (b)?
d.
Identify and provide a copy of each document upon which Intervenors rely or I
that relates to the answers to paragraphs (a) through (c).
- 49. a.
Do Intervenors contend that the interval between receipt of Press Releases 4 and 5 at the ENC (at 08:45 and 09:05, respectively) and their submission to Media Monitoring personnel (at 09:31) was excessive?
i b.
What is the basis for the answer to paragraph (a)?
- c. -What do Intervenors contend is the maximum acceptable length of time between the receipt of a press release and its submission to media monitoring personnel?
d.
What is the basis for the answer to paragraph (c)?
e.
Do Intervenors contend that these alleged delays in giving Press Releases 4 and 5 to Media Monitoring personnel constituted or revealed, by themselves, fundamental flaws in the Shoreham Plan?
f.
What is the basis for the answer to paragraph (e)?
g.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) through (f).
- 50. a.
State the basis for Intervenors' assertion that LILCO's proposal to expedite dissemination of information by substituting summary information for press releases and transmitting it by computer to the ENC, by adding an extra LERO spokesperson at the ENC, and by replacing of copying machines "would (not] resolve the deficiencies revealed during the exercise?"
b.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answer to paragraph (a).
- 51. a.
Do Intervenors contend in Contention EX 22(F) that exercise players should not have assumed that members of the public would follow LERO's protective action recommendations?
b.
Describe precisely how the scenario should have been written, and how exercise responses should have been altered, in order to take into account any assumption other than that protective action recommendations would be followed?
c.
Identify and provide a copy of any document concerning, constituting, reflecting, or relating to the " survey research data" referred to by Intervenors on page 71 of their contentions.
d.
Identify and provide a copy of any document concerning "public response to the nuclear accident at Chernobyl" which Intervenors believe supports their position and on which Intervenors base their assertion that voluntary evacuation "would in fact occur."
52 a.
Please identify each witness Intervenors expect to call on Contention EX 22(F).
b.
For each person other than experts state the subject matter on which each is 4
expected to testify and the substance of the facts to which he is expected to testify.
1 c.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify, and a summary of the grounds for each such opinion.
d.
For each witness, provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
4 e.
List any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning "public response to the nuclear accident at Chernobyl."
f.
Please identify all articles, papers, or other documents authored or co-authored by each witness on the subject of "public response to the nuclear accident at Chernobyl," which have either been published in the open literature or, if not published in the open literature, circulated within the professional community.
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- 53. a.
Please state the information that Intervenors contend that EBS messages should liave contained in order to prevent or limit the scope of the voluntary evacuation.
b.
What is the basis for the answer to paragraph (a)?
- 54. a.
Please state the information that Intervenors contend press advisories should have contained in order to prevent or limit the scope of such voluntary evacuation.
b.
What is the basis for the answer to paragraph (a)?
55 a.
Identify specifically the ways in which LERO should have responded differently in order to limit the contribution to such voluntary evacuation of the " pre-existing perceptions and fears of Long Island residents concerning nuclear accidents."
b.
What is the basis for the answer to paragraph (a)?
List all activities undertaken or simulated by LERO players on which such c.
voluntary evacuation would have had a " substantial impact."
d.
What is the basis for the answer to paragraph (c)?
e.
Describe how LERO players' ability to perform the activities listed in paragraph (c) would have been affected or prevented by voluntary evacuation.
f.
What is the basis to the answer to paragraph (e)?
- 56. a.
State the size of the evacuation shadow (the scope of voluntary evacuation) that Intervenors contend LERO should have assumed in responding to scenario events during the Exercise.
b.
What is the basis for the answer to paragraph (a)?
f c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Contention EX 39
- 57. a.
Identify the specific harmful effects, if any, that Intervenors claim would be caused by each of the examples listed in subparts (1) to (v) of Contention EX 39(A).
b.
Stato whether Intervenors contend that any or all of subparts (1) to (v) constituted or revealed, by themselves, fundamental flaws in the Shoreham Emergency Plan.
c.
What is the basis for the answers to paragraphs (a) and (b)?
d.
Identify and provide a copy of each document upon which Intervenors rely or 4
i which relates to the answers to paragraphs (a) through (c).
- 58. a.
State for each of the ' subparts (1) through (xili) of Contention EX 39(B) whether Intervenors contend that the interval between rumor call-in and the response was excessive.
b.
What is the basis for the answers to paragraph (a)?
c.
What do Intervenors contend is the maximum acceptable interval between rumor call-in and response that would permit a finding that the response was
" prompt"?
d.
What is the basis for the answer to paragraph (c)?
e.
For each instance described in subparts (1) to (xill) of Contention EX 39(B) for which the response time is deemed excessive, identify the specific harm that would have been caused by such delay.
l
f.
What is the basis for the answer to paragraph (e)?
g.
Do Intervenors contend that any or all of the incidents in subparts (1) to (xill) of Contention EX 39(B) constituted or revealed, by themselves, fundamental flaws in the Shoreham Emergency Plan?
h.
What is the basis for the answer to paragraph (h)?
- 59. a.
Identify the criteria used by Intervenors to determine that LILCO rumor responses were " inappropriate."
b.
Identify the criteria used by Intervenors to determine that LILCO rumor responses were " misleading."
c.
Identify the criteria used by Intervenors to determine that LILCO rumor l
1 responses were " grossly improper."
d.
Identify the criteria used by Intervenors to determine that LILCO rumor responses were in " extremely poor judgment."
e.
What is the basis for the answers to paragraphs (a) through (d)?
f.
Do Intervenors contend that any or all of the allegedly inaccurate or improper responses in subparts (i) to (vil) of Contention EX 39(C) constituted or revealed, by themselves, fundamental flaws in the Shoreham Plan.
g.
What is the basis for the answer to paragraph (f)?
Contention EX 40 60, a.
Please state the bases, other than those expressly detailed in the contention, for Intervenors' statement that "the [LILCO] Plan falls to provide any traffic assistance or guidance for evacuees until long af ter they are likely to be on the roads attempting to evacuate."
b.
IIave Intervenors attempted to quantify the difference in time between when the Plan provides traffic assistance and when evacuees will be "on the roads attempting to evacuate?"
c.
If the answer to paragraph (b) is affirmative, what is the time differential and how is that differential calculated?
- 61. a.
Please state the basis for Intervenors' statement in Contention EX 40(B) that "the LILCO Plan, as demonstrated during the Exercise, falls to provide any evacuation assistance, or other ' guidance' necessary to ensure that evacuees follow the prescribed routes which form the bases of the evacuation time estimates used during the Exercise, until long af ter evacuees would be on the road attempting to evacuate."
b.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
j
- 62. a.
With respect to the EBS evacuation advisories (see Contention EX 40(C)),
what is the Intervenors' basis for the statement that the information contained in those advisories was "f alse"?
b.
What do Intervenors contend the messages should have said?
c.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 63. a.
Please state the basis for Intervenors' statement in Contention EX 40(E) that the dispatching of traffic guides to traffic control posts within the 2-mile zone upon the issuance of an evacuation order "would not correct or even substantially lessen the defect inherent in the LILCO Plan."
l
b.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
Contention EX 41
- 64. a.
Please state the bases for Intervenors' statement in Contention EX 41 that "LILCO's inability to deal with such impediments will cause delay in the implementation of protective actions and preclude LILCO from managing an orderly evacuation of the EPZ."
b.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
65 a.
Please state the bases for Intervenors' statement in Contention EX 41 that "LILCO's proposal for removal of impediments to evacuation is inherently unworkable."
I b.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 66. a.
With respect to the mobilization of LERO road crews (see Contention EX 41(A)), what is the basis for Intervenors' statement that " subsequent to being dispatched, it took substantial time before crews were in position to drive to an identified impediment in the field and attempt to remove it."
b.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
67 a.
With respect to LERO's response to the gravel truck impediment (see Contention EX 41(B)(lii)(a)), what are Intervenors' bases, other than the FEMA report, for their conclusions that the equipment sent to remove the gravel impediment was inadequate and that the time needed to clear that impediment would have been "30 minutes or more."
i
b.
Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 68. With respect to LILCO's proposed remedy for the impediment problems (see Contention EX 41(E)), what is the basis for Intervenors' statement that "even assuming (a Traffic Engineer) could provide such ' assistance,' it would have no impact on the basic structural flaws in the Plan and demonstrated incapacities of LERO personnel described in this contention."
Contention EX 47
- 69. a.
State whether~ the equipment, time, and procedures required to register, monitor, and decontaminate evacuees from special facilities are different from the equipment, time, and procedures required to perform those functions for other evacuees.
b.
Identify the manner in which necessary equipment, time, and procedures for special facilities described in answer to paragraph (a) differ.
c.
What is the basis for the answer to paragraphs (a) and (b)?
d.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) through (c).
- 70. a.
Do Intervenors contend that, in order to test adequately its capability to register and monitor special facility evacuees, LERO was required to actually send appropriate personnel to special facility reception centers and have them simulate registration and monitoring procedures there?
b.
What is the basis for the answer to paragraph (a)?
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k
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 71. a.
State the basis for Intervenors' assertion that LILCO's proposal"to send only one monitor to each special f acility reception center... is unworkable."
b.
State the basis for Intervenors' assertion that one person could not
" adequately or effectively perform the necessary monitoring, recordkeeping, and related activities" at special facility reception centers.
c.
What is the number of persons that Intervenors contend would be required in order to " adequately" and " effectively" register and monitor evacuees at a special facility reception center?
d.
What is the basis for the answers to paragraphs (a) through (c)?
e.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) through (d).
72, a.
State the basis for Intervenors' assertion that inclement weather would prevent the monitoring of evacuees as they leave their buses, ambulances, or ambulettes, b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 73. a.
State the special requirements, if any, that Intervenors contend must exist at unloading points at special facility reception centers in order to permit monitoring of evacuees as they leave their buses, ambulances, or ambulettes, b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of eacn document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
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- 74. a.
State the basis for Intervenors' assertion that evacuees could not be " subjected c
1 to waits in buses or ambulances" in order to be monitored and registered at reception centers for special f acilities.
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 75. a.
Identify any special training or equipment which Intervenors contend that bus t
drivers must be given to enable them to keep monitoring records.
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
76, a.
State whether Intervenors contend that bus drivers are inherently incapable of keeping monitoring records.
b.
What is the basis for the answer to paragraph (a)?
4 l
c.
Identify and provide a copy of each document upon which Intervenors rely or f
which relates to the answers to paragraphs (a) and (b).
77, a.
State the basis for Intervenors' assertion that it is " impractical to expect a
]
bus driver to be able to perform such a function."
l b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
- 78. a.
State whether Intervenors contend that evacuees from special facilities cannot be decontaminated at reception centers for the general population.
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
i l
- 79. a.
State whether Intervenors contend that school children evacuees must be monitored (and registered and, if necessary, decontaminated) at the special reception centers to which they might be evacuated in an emergency, instead of at the three regular reception centers.
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each d)cument upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 80. a.
Do Intervenors contend that the referenced provision in the Plan, OPIP 4.3.1, S 5.1.5 (Rev. 8) ('.'It is unnecessary to include reception locations for evacuating schools if the parents are going to be picking up the children") is wrong or " inadequate"?
b.
What is the basis for the answer to paragraph (a)?
Contention EX 49
- 81. a.
State whether Intervenors contend that personnel from INPO, DOE, and other power plants actually had to participate in the Exercise by going to the Reception Center and simulating monitoring procedures, in order to test adequately LILCO's alternative evacuee monitoring plan.
i b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
82, a.
State the number of persons who would seek monitoring at the reception center.
4 l
i l
b.
What is the basis for the answer to paragraph (a)?
- 83. a.
Specify the number of persons whom Intervenors contend are likely to engage in voluntary evacuation under conditions such as those that occurred during the Exercise.
b.
What is the basis for the answer to paragraph (a)?
Contention EX 50
- 84. a.
Identify all events that occurred during the Exercise which Intervenors would classify as " unanticipated and unrehearsed situations?"
b.
For each event listed in paragraph (a), identify whether Intervenors contend LERO personnel failed to respond " properly, appropriately, or effectively" to that event.
c.
Identify and provide a copy of each docuntent which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
85, a.
Identify all events that occurred during the Exercise which Intervenors contend " demonstrated that LILCO's training program has been ineffective in instructing LERO personnel to follow and implement the LILCO Plan and Procedures."
b.
Identify all events tha't occurred during the Exercise which Intervenors contend " demonstrated that LILCO's training program has been ineffective... In imparting basic knowledge and information essential to the ability to implement such procedures."
c.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) through (c).
- 86. a.
Identify all events that occurred during the Exercise in which Intervenors contend that information was communicated between or among LERO personnel?
b.
Identify all events that occurred during the Exercise which Intervenors rely for the statement that "the exercise demonstrated that the LILCO training program has not successfully or effectively trained - LERO personnel to communicate."
c.
For each event listed in paragraphs (a) and (b), identify whether Intervenors contend that LERO personnel f ailed to communicate "necessary and sufficient data and information."
d.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) through (c).
- 87. a.
Identify all events that occurred during the Exercise which Intervenors would classify as requiring LERO personnel to " follow directions given by supervisors."
b.
For each event listed in paragraph (a), identify whether Intervenors contend that LERO personnel failed to carry out those directions properly.
c.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
88 a.
Identify all events that occurred during the Exercise which Intervenors would classify as requiring LERO personnel to " exercise independent judgment or good judgment, or to use common sense."
i b.
For each event listed in paragraph (a), identify whether Intervenors contend i
that LERO personnel failed to exercise independent judgment, good judgment j
or common sense.
i
. 4 c.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 89. a.
Identify all events that occurred during the Exercise which Intervenors would classify as requiring LERO personnel to " deal with the media or otherwise provide timely, accurate, consistent and non-conflicting information to the public, through the media."
b.
For each event listed in paragraph (a), identify whether Intervenors contend that LERO personnel failed to provide timely, accurate, consistent or non-conflicting information.
c.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 90. a.
Identify all events that occurred during the Exercise which Intervenors contend demonstrate that "LILCO has failed to provide training to persons and organizations relied upon for the implementation of the Plan other than those employed by LILCO."
b.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
- 91. a.
Identify all events that occurred during the Exercise which Intervenors contend tested the training of LERO workers in the areas of " dosimetry, exposure control, KI, understanding of radiation terminology, and related areas?"
b.
For each event listed in paragraph (a), identify whether Intervenors contend that LERO personnel improperly understood that information and how the LERO worker's knowledge was inadequate.
. 4 c.
Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Respectfully submitted, M
DonEld P. Ir$ (/
Lee B. Zeugin Jessine A. Monaghan Scott D. Matchett Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 10,1986 1
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LILCO, November 10,1986 ALLAlLU taunnu:,yunygngg 00LKEILE UWC CERTIFICATE OF SERVICE 86 NOV 12 M151 In the Matter of LONG ISLAND LIGHTING COMPANY CFFILE u-
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(Shoreham Nuclear Power Station, Unit 1) 00CKEig'g,,#I Docket No. 50-322-OL-5 I hereby certify that copies of LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND THE TOWN OF SOUTHAMPTON were served this date upon the fol-lowing by Federal Express as indicated by an asterisk, or by first-class mail, postage prepaid.
John H. Frye, III, 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 4350 East-West Hwy.
Bernard M. Bordenick, Esq.
Bethesda, MD 20814 Oreste Russ Pirfo, Esq.
Edwin J. Reis, Esq.
Dr. Oscar H. Paris U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 7735 Old Georgetown Road Board (to mailroom)
U.S. Nuclear Regulatory Commission Bethesda, MD 20814 East-West Towers 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 Eighth Floor Board 1900 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C. 20036 East-West Towers, Rm. 430 4350 East-West Hwy.
Fabian G. Palomino, Esq.
- Bethesda, MD 20814 Richard J. Zahnleuter, Esq.
Special Counsel to the Governor Secretary of the Commission Executive Chamber l
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 Panet Third Floor, Room 3-116 U.S. Nuclear Regulatory Commission New York, New York 10271 Washington, D.C. 20555 i
- o 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 L"eckB. Zeu
(/
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 10,1986