ML20214Q738

Second Half of Response to Second Set of Interrogatories & Requests for Production of Documents.W/Certificate of Svc. Related Correspondence

ML20214Q738
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/29/1986
From:	Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTH HAMPTON, NH, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA
To:	LONG ISLAND LIGHTING CO.
Shared Package
ML20214Q678	List: ML20214Q676 ML20214Q738
References
OL-5, NUDOCS 8612050261
Download: ML20214Q738 (44)

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00LKETED USNRC November 29, 1986

'26 DEC -4 A11 :10 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFRC  : U . . 4'u 00CH Titm A 5 ~ N Before the Atomic Safety and Licensino Board I!N E"

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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) )

)

SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON RESPONSE TO LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON This is the second half of Suffolk County, State of New York and Town of Southampton Response to LILCO's Second Set of Inter-rogatories and Requests for Production of Documents to Suffolk County, New York State and Town of Southampton, the first half of which was filed November 26, 1986.

LILCO INTERROGATORY NO. 46

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?

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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).

Resoonse:

(a) The Governments have not yet made a final determination on this issue, but do~ contend that the referenced possession of.

inaccurate information supports Contention Ex 38's allegation that the Exercise demonstrated a fundamental flaw in the LILCO Plan in that LILCO was unable to provide timely, accurate, consistent and non-confusing information to the news media at the ENC, thus failing to implement Section 3.8B and OPIP 3.8.1 of the LILCO Plan. In addition, the facts set forth in subpart L of Contention Ex 38 together with the other exercise results set forth in all the subparts of that Contention, preclude a finding of reasonable assurance that adequate protective actions can and will be taken in the event of a Shoreham emergency.

(b) At this time, and to the knowledge of the Governments, the primary bases for the answer to (a) are the facts, Plan and FEMA Report references set out in Contention Ex 38, the documents generated during the Exercise by FEMA and LILCO, the ENC videotapes produced by LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research by those individuals may provide additional. bases for the referenced proposition.

(c) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in the answer to (b).

LILCO INTERROGATORY NO. 47

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).

Resconse:

(a) Since discovery is still in progress, the Governments are not at this time in a position to respond further than to refer to the logs generated during the Exercise by FEMA and LILCO personnel relating to ENC and Public Information personnel activ-ities, and the ENC videotapes. Discbveryandanalysismayyield additional data.

(b) The Governments have not yet made a final determination on this matter, but do contend that the referenced inability supports Contention Ex 38's allegation that the Exercise demon-strated a fundamental flaw in the LILCO Plan in that LILCO was unable to provide timely, accurate, consistent and non-confusing information to the news media at the ENC, thus failing to im-plement Section 3.8.B and OPIP 3.8.1 of the LILCO Plan. In addition, the facts set forth in subpart M of Contention Ex 38,

together with the other exercise results set forth in all the subparts of that Contention, preclude a finding of reasonable assurance that adequate protective actions can and will be taken in the event of a Shoreham accident.

(c) At this time, and to the knowledge of the Governments, the primary bases for the answer to (b) are the facts, Plan and FEMA Report references set out in Contention Ex 38,'the documents generated during the Exercise by FEMA and LILCO (particularly logs and messages relating to ENC and Public Information person-nel activities), the ENC videotapes, and the observations, know-ledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research may provide additional bases for the referenced proposition.

(d) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in the answer to (b) and (c).

LILCO INTERROGATORY NO. 48

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 that relates to the answers to paragraphs (a) through (c).

Response

(a) Since discovery is still in progress, the Governments are not yet in a position to respond further than to refer to the events set forth in the other subparts of Contention Ex 38, the logs and messages generated during the Exercise by FEMA and LILCO relating to ENC and Public Information personnel activities and the ENC videotapes. Discovery and analyses of discovery materials may yield additional data. ,

(b) The Governments have not yet made a final determination on this matter, but do contend that the referenced instances support Contention Ex 38's allegation that the Exercise demonstrated a fundamental flaw in the LILCO Plan in that LILCO was unable to provide timely, accurate, consistent and non-confusing information to the news media at the ENC, thus failing to implement Section 3.8B and OPIP 3.8.1 of the LILCO Plan. In addition, the instances set forth in subpart N of Contention Ex 38, together with the other Exercise results set forth in all the subparts of that Contention, preclude a finding of reasonable assurance that adequate protective actions can and will be taken in the event of a Shoreham accident.

(c) At this time, and to the knowledge of the Governments, the primary bases for the answer to (b) are the data, Plan and FEMA Report references set out in Contention Ex 38, the documents generated during the Exercise by FEMA and LILCO, including logs and messages relating to ENC and Public Information activities the ENC videotapes, and the observations, knowledge, training, l

experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention.

The results of discovery and analyses and research by those individuals may provide additional bases for the answer to (b).

(d) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in (a) and (c).

LILCO INTERROGATORY NO. 49

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?

b. What is the basis for the answer to paragraph (a)?

l c. What do Intervenors contend is the maximum l acceptable length of time between the receipt of a press release 2

and its submission to media monitoring personnel?

d. What is the basis for the answer to paragraph (c)?

4 e. Do Intervenors contend that these alleged delays I 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).

, Resoonser (a) The Governments have not yet made a final determination on this matter, but do contend that the referenced delays support i

Contention Ex 38's allegation that the Exercise demonstrated a fundamental flaw in the LILCO Plan in that LILCO was unable to i

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provide timely, accurate, consistent and non-confusing informa-tion to the news media at the ENC, thus failing to implement Section 3.8B of the LILCO Plan and OPIP 3.8.1.

(b) At this time, and to_the knowledge of the Governments, the primary bases for the answer to (a) are the data and Plan and FEMA Report references set out in Contention Ex 38, the documents generated during the Exercise by FEMA and LILCO, including logs and messages relating to ENC and Public Information activities, the ENC videotapes, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention.

The result; of discovery and analyses and research by those individuals may provide additional bases for the answer.

(c) The Governments have not yet made a final determination regarding this issue. In addition, the information sought is not relevant and the Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its ability to implement it. Egg also General Responses F and G.

(e) Egg answer to (a). In addition, the Governments con-tend that the delays set forth in subpart O of Contention Ex 38, together with the other exercise results set forth in all the subparts of that contention, preclude a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident.

(f) Egg answer to (b).

(g) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in (b).

LILCO INTERROGATORY NO. 50

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).

Resoonse:

(a) Since discovery is still in progress, the Governments are not yet in a position to respond to this question further than to note that in light of all the problems identified in the subparts of Contention Ex 38, there is no basis to believe such proposed " fixes" would have any substantial impact. At this time, and to the knowledge of the Governments, the primary bases for the referenced assertion are the data, Plan and FEMA Report references set out in Contention Ex 38, the documents generated during the Exercise by FEMA and LILCO, the ENC videotapes, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.

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(b) At this time, the Governments have identified no docu-ments as responsive to this request other than those' referenced in Contention Ex 38 subpart Q and the answer to-(a).

LILCO INTERROGATORY NO. 51

51. a. Do Intervenors contend in Contention EX 22(P) 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 con-cerning, 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 con-cerning "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."

Resoonse:

(a) The allegations contained in Contention 22 subpart F speak for themselves.

(b) Objection. Egg General Responses F and G. This in-terrogatory seeks irrelevant information. Furthermore, the Governments have no obligation to devise exercise scenarios, or to instruct LILCO on how to alter its exercise responses, or to correct deficiencies in its Plan or its implementation capabili-ties.

(c) At this time, the Governments are not in a position to respond to this question beyond referring to the survey research data, compiled by all the parties in connection with the litiga-

tion of Contentions 23 and 15 in 1983 and 1984, all of which is known to and in_the possession of, LILCO; and the Newsday survey conducted in 1986 and reported in Newsday September 21, 1986.

Discovery and additional research and analyses may provide additional data.

(d) Egg the Newsday survey referenced in (c); discovery and additional lresearch may provide additional data.

LILCO INTERROGATORY NO. 52

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 expected to testify and the substance of the facts to which he is expected to testify.

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 te 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.

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 rticles, 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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Response

(a) At the present time, Suffolk County tentatively identifies Suffolk County Police Department Lieutenant Streeter and Deputy Director Cosgrove, and Professor Charles Perrow, as individuals who are expected to testify regarding subpart F of Contention Ex 22.

(b) and (c) At this time, and to the knowledge of the Governments, the subject matter of the testimony will be facts and opinions relating to the allegations made in subpart F of Contention Ex 22, based on the observations, knowledge, training, experience and expertise of the individuals identified in (a).

The results of discovery and analyses and research may provide additional matters upon which testimony may be given.

(d) Such material previously has been produced.

(e) None.

(f) None.

LILCO INTERROGATORY NO. 53

53. a. Please state the information that Intervenors contend that EBS messages should have contained in order to prevent or limit the scope of the voluntary evacuation.

b. What is the basis for the answer to paragraph (a)?

Resoonse:

(a) The Governments do not believe LILCO is capable of preventing or effectively limiting voluntary evacuation in the event of a Shoreham accident. In addition, the Governments note

that they have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities. Egg General Responses F and G.

(b) Egg Contention Ex 22, subpart F, the first sentence of Contention Ex 44, and the response to Interrogatory No. 51.

LILCO INTERROGATORY NO. 54

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)?

Response

(a) The Governments do not believe LILCO is capable of preventing or effectively limiting voluntary evacuation in the event of a Shoreham accident. In addition, the Governments note that they have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities. Egg General Responses F and G.

(b) Egg Contention Ex 22, subpart F, the first sentence of Contention Ex 44, and the response to Interrogatory No. 51.

LILCO INTERROGATORY NO. 55

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)?

c. List all activities undertaken or simulated by LERO players on which such 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)?

Resoonse:

(a) The Governments do not believe LILCO is capable of preventing or limiting voluntary evacuation from a Shoreham acci-dent, or of changing the perceptions of Long Island residents concerning an accident at Shoreham. In addition, the Governments have no obligation to instruct LILCO on how to correct deficien-cies in its own Plan or implementation capabilities. Sgg General Responses F and G.

(b) At this time, and to the knowledge of the Governments, the primary bases for the answer to (a) are the facts and data set out in Contentions Ex 22 subpart F, Ex 38, Ex 39, and the first sentence of Contention Ex 44, the materials generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individu-als the Governments have or intend to identify to testify re-garding Contention Ex 22 subpart F. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition. Egg also the response to Interrogatory No. 51.

(c) Egg full text of Contention Ex 44 and other contentions referenced therein.  !

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(d) At this time, and to the knowledge of the Governments, the primary bases for the answer to (c) are the data and facts set out in Contention Ex 44 and contentions referenced therein, the materials generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding Contention Ex 22 subpart F. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced answers.

(e) Egg Contention Ex 44 and other contentions referenced therein.

(f) Egg response to (d).

LILCO INTERROGATORY NO. 56

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)?

c. Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).

Resoonse:

(a) The Governments have not yet made a final determination regarding this issue, bg1 ggg cenerally, the survey results referenced in the response to Interrogatory 51(c).

(b) Egg the response to Interrogatory 51(c).

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(c) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in response to (a) and (b).

LILCO INTERROGATORY NO. 57

57. a. Identify the specific harmful effects, if any, that Intervenors claim would be caused by each of the examples listed in subparts (i) to (v) of Contention EX 39(A).

b. State whether Intervenors contend that any or all of subparts (i) 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 which relates to the answers to paragraphs (a) through (c).

Resoonse:

(a) The Governments contend that each referenced example supports the allegation in Contention Ex 39 (that the Exercise revealed a fundamental flaw in the LILCO Plan in that LILCO is incapable of dealing with rumors or responding to inquiries from the public as required by the regulations and the LILCO Plan),

because LILCO personnel were unable to dispel rumors, correct misinformation, provide necessary and accurate information to the public in a timely manner, or provide consistent, coordinated and non-conflicting information to the public.

(b) Egg response to (a).

I (c) At this time, and to the knowledge of the Governments, the primary bases for the answer are the facts, data, Plan and FEMA Report references set out in Contention Ex 39, the materials generated during the Exercice by FEMA and LILCO, and the l

observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced answer.

(d) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in the answer to (c). ,

LILCO INTERROGATORY NO. 58

58. a. State for each of the subparts,(i) through (xiii) 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)?

J 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 (i) to (xiii) of Contention EX 39(B) for which the response time is deemed excessive, identify the specific harm that would have4been caused by such delay. ,

f. What is the basis for the answer to paragraph'~(e)?

g. Do Intervenors contend that any or all of the, incidents in subparts (i)' to (xiii) of Contention EX 39(B) constituted or revealed, by themselves, fundamental flaws in the.

Shoreham Emergency Plan?

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observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced answer.

(d) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in the answer to (c).

LILCO INTERROGATORY NO. 58

58. a. State for each of the subparts (i) through (xiii) of Contention EX 39(B) whether Intervenors contend that the interval between rumor call-in and the response was excessive. j i

b. What is the basis for the answers to paragraph )

(a)?

c. What do Intervenors contend is the maximum I

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 (i) to (xiii) 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.

f. What is the basis for the answer to paragraph (e)?

g. Do Intervenors contend that any or all of the incidents in subparts (i) to (xiii) of Contention EX 39(B) constituted or revealed,'by themselves, fundamental flaws in the Shoreham Emergency Plan?

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- i 4 h. What is the basis for the answer to paragraph-(h)?

Response

i (a) Yes.  ;

(b) At this time, the primary bases for the answer are common sense, the data set out in Contention Ex-39, and the  ;

observations, knowledge,' training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding Contention Ex 39. The results of discovery and i

< analyses and research by those individuals may provide additional bases for the referenced answer.

(c) The Governments have not yet made a final determination i regarding this issue. In addition, the Governments are under no i

} obligation to instruct LILCO on how to correct deficiencies in l its Plan or implementation capabilities. Egg General Responses F and G.

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(d) Not applicable.

(e) The Governments contend that each referenced example supports.the allegation in Contention Ex 39 (that the Exercise I revealed a fundamental flaw in the LILCO Plan in-that LILCO is incapable of dealing with rumors or responding to inquiries from the public as required by the regulations-and the LILCO Plan),

because LILCO personnel were unable to dispel rumors, correct misinformation, provide necessary and accurate information to the public in a timely manner, or provide consistent, coordinated and non-conflicting information to the public.

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(f) At this time, and to the knowledge of the Governments, the primary bases for the answer are the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding Contention Ex 39. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.

(g) Egg answer to (e).

(h) Egg answer to (f).

LILCO INTERROGATORY NO. 59

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 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 (vii) 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)?

Resoonse:

(a) Common sense and the facts set forth in subpart C of Contention Ex 39.

(b) Common sense and the facts set forth in subpart C of Contention Ex 39.

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l (c) Common sense and the facts set forth in subpart C of Contention Ex 39.

(d) Common sense and the facts set forth in subpart C of Contention Ex 39.

(e) Common sense and the facts set forth in subpart C of Contention Ex 39. The results of discovery and ongoing analyses and research by the individuals the Governments have or intend to identify to testify concerning Contention Ex 39 may provide additional bases for the referenced answers.

(f) The Governments contend that each referenced example supports the allegation in Contention Ex 39 (that the Exercise revealed a fundamental flaw in the LILCO Plan in that LILCO is incapable of dealing with rumors or responding to inquiries from the public as required by the regulations and the LILCO Plan),

because LILCO personnel were unable to dispel rumors, correct I misinformation, provide necessary and accurate information to the-public in a timely manner, or provide consistent, coordinated and non-conflicting information to the public.

(g) At this time, and to the knowledge of the Governments, the primary bases for the answer.are the data and facts set out-in Contention Ex 39, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, -

experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention.

The results of discovery and analyses and research by those individuals may provide additional bases for the referenced answer.

LILCO INTERROGATORY NO. 60

60. a. Please state the bases, other than those expressly detailed in the Contention, for Intervenors' statement that "the (LILCO) Plan fails to provide any traffic assistance or guidance for evacuees until long after they are likely to be on the roads attempting to evacuate."

b. Have Intervenors attempted to quantify the difference in tima 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?

Response

(a) The bases are as stated in Contention Ex 40, and Contention Ex 22 subpart F, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research by those individuals may provide additional bases for the refer-enced statement. Egg also the materials identified in response n

to Interrogatory No. Sl(c).

(b) Egg Contention Ex 40.

(c) Sag answer to (b).

LILCO INTERROGATORY NO. 61 l l

61. a. Please state the basis for Intervenors' statement in Contention EX 40(B) that "the LILCO Plan, as demonstrated during the Exercise, fails to provide any evacuation assistance, or other ' guidance' necessary to ensure that evacuees follow the 1

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prescribed routes which form the bases of the evacuation' time estimates used during the Exercise, until long after 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 para-graph (a).

Resoonse:

(a) At this time r and to the knowledge of the Governments, the primary bases for the contention are the data, facts, and Plan references set out in Contentions Ex 40 and Ex 22 subpart F, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding those Contentions. The results of '

discovery and ongoing analyses and research by those individuals may provide additional bases for the referenced proposition. Egg also the response to Interrogatory No. Sl(c).

(b) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced

in (a).

! LILCO INTERROGATORY NO. 62

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

" false?"

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).

ResDonse:

(a) As stated in Contention Ex 40, when the EBS evacuation advisories were supposedly " aired," Traffic Guides were not at their posts or in a position to provide the " guidance" or assis-tance represented as being available in the EBS broadcasts.

(b) The Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities. Egg General Responses F and G.

(c) The documents and messages generated by FEMA and LILCO during the Exercise. Discovery and analyses may provide additional bases.

LILCO INTERROGATORY NO. 63

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."

b. Identify and produce a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).

Response

(a) At this time, and to the knowledge of the Governments, the primary bases for the referenced statement are the facts and documents set out in Contention Ex 40, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individu-als the Governments have or intend to identify to testify re-

1 garding that Contention. The results of discovery and analyses

~

' and research by those individuals may provide additional. bases ,

i for the referenced prop'osition.

i (b) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced 4 in (a).

. LILCO INTERROGATORY NO. 64

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).

Response

(a) The bases are as stated in Contention Ex 41, the f

documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention. The results of discovery and analyses and research by those individuals may provide additional bases for the re,ferenced proposition.

(b) At this time, the Governments'have identified'no docu-ments as-responsive to this request other than those referenced in (a).

LILCO INTERROGATORY NO. 65-

65. a. Please state the bases for Intervenors' statemeat in Contention EX 41 that "LILCO's proposal for removal of.

impediments to evacuation is inherently unworkable."

i l

1

b. Identify and produce a-copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).

ResDonse:

(a) The bases are stated in Contention Ex 41. At this time, and to the knowledge of the governmental entities, the primary bases for the Contention are as stated in the contention, and the observations, knowledge, training, experience, and expertise of those individuals the Governments presently are securing to testify regarding this Contention. The results of discovery and ongoing analyses and research by those individuals may provide additional bases for the referenced proposition.

(b) Egg response to Interrogatory 64(a) and (b).

LILCO INTERROGATORY NO. 66

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 para-graph (a).

ResDonse:

(a) The bases are as stated in Contention Ex 41, the data, Plan and FEMA Report references set out in that Contention, and the documents generated during the Exercise by FEMA and LILCO.

The results of discovery, and analyses and research by the individuals identified by the Governments to testify regarding this issue, may provide additional bases for the referenced statement.

25 -

(b)- At this time, the Governments have identified no docu-ments as responsive to this request other than those' referenced in (a).

LILCO INTERROGATORY NO. 67

67. a. With respect to LERO's response to the gravel truck impediment (see Contention EX 41 (B)(iii)(a)), what-are Intervenors' bases, other than the FEMA report, for their.conclu- 6 sions 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."

b. Identify and produce a copy of_each document upon which Intervenors rely or which relates to the answer to para-graph (a).

Resoonse:

(a) The bases for the referenced statements are the data set out in Contention Ex 41, the documents generated during the ,

Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that contention. The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.

(b) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in (a).

LILCO-INTERROGATORY NO. 68

68. With respect to LILCO's proposed remedy fcr 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."

Resoonse:

The bases are as stated in Contention Ex 41 and all its subparts, the data, Plan and FEMA Report references set out in that Contention, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention.

The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.

LILCO INTERROGATORY NO. 69

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).

Response

(a) Assuming the individuals are in special facilities because they have special needs and/or require special care',

transportation, equipment, treatment, and the like, yes.

1 (b) As LILCO itself has acknowledged by its Plan provisions (agg Contention Ex 47), special facility residents require specialized transportation and reception center facilities.

1

Registering, monitoring, and decontaminating non-ambulatory, or elderly, or handicapped, or ill individuals requires additional time and care than is required to perform the same procedures on healthy, ambulatory individuals.

(c) At this time, the bases for the answers are common sense, LILCO's Plan, and the facts stated in the answers to (a) i and (b). The results of discovery and analyses and research may provide additional bases for the referenced answers.

I (d) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in (b).

LILCO INTERROGATORY NO. 70

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)?

c. Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).

Resoonse:

(a) Contention Ex 47 speaks for itself. The Governments have no obligation to instruct LILCO on how to design an exercise or implement its Plan. Egg General Responses F and G.

(b) Not applicable.

(c) Not applicable.

LILCO INTERROGATORY NO. 71

71. a. State the basis for Intervenors' assertion that LILCO's oroposal "to send only one monitor to each special facility 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).

Resoonse:

(a) and (b) At this time, the primary bases for the refer-enced statement are common sense, and the facts, data and Plan references set out in Contention Ex 47. The results of discovery and analyses and research may provide additional bases.

(c) The Governments have not yet made a final determination regarding this issue, and have no obligation to instruct LILCO on how to correct deficiencies in its Plan or in its implementation capabilities. Eeg General Responses F and G.

(d) See answers to (a) through (c).

(e) At this time, the-Governments have identified no docu-ments as responsive to this request other than those referenced in (a).

LILCO INTERROGATORY NO. 72

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).

Resoonse:

~

(a) At this time, the primary bases *for the referenced statement are common sense, and the other bases set forth in Contention Ex 47, subpart B. The results of discovery and analyses and research may provide additional bases, f (b) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in (a).

LILCO INTERROGATORY NO. 73

73. State the special requirements, if any, that Intervenor 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 each document upon which Intervenors rely or which relates to the nswers to paragraphs (a) and (b).

Response

(a) The Governments have not yet made a final determination regarding this issue, but refer to subpart B of Contention _Ex 47.

In addition, the Governments note that they have no obligation to instruct LILCO on how to correct deficiencies in its Plan or implementation capabilities. See General Responses F and G.

(b) Egg answer to (a).

(c) Egg answer to (a).

LILCO INTERROGATORY NO. 74

74. a. State the basis for Intervenors' assertion that I evacuees could not be " subjected to waits in buses or ambulances" in order to be monitored and registered at reception centers for i

special facilities, l

\ i

1

b. Identify and-provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).

Response

(a) At-this time, and to the knowledge of the Governments, the primary basis for the referenced statement is~ common sense.

Egg also the answer to Interrogatory 69. The results of dis-covery and analyses and research may provide additional bases for the referenced proposition.

t (b) At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced '

in the answer to Interrogatory 69.

LILCO INTERROGATORY NO. 75 ,

75. a. Identify any special training _or equipment which '

Intervenors contend that bus 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).

Response

(a) The Governments have-no obligation to instruct LILCO on how to correct deficiencies in its Plan. Sag General-Responses F and G.

(b) Not applicable.

(c) Not applicable.

l LILCO INTERROGATORY NO. 76 l I

76. a. State whether Intervenors contend that bus drivers are inherently incapable of keeping monitoring records.

l l

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- 31'-

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).

Resoonse:

(a) This question is ambiguous and cannot be answered.

J Contention Ex 47 subpart C speaks for itself; the Governments note that the references therein to " bus drivers" are to the "LERO bus drivers" raised as such under the LILCO Plan.

(b) Not applicable. Egg-answer to (a).

(c) Not applicable. Egg answer.to (a).

LILCO INTERROGATORY NO. 77

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."

b. Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).

Response

f (a) Egg answer to Interrogatory No. 76.

I (b) Egg answer to Interrogatory No. 76. .

LILCO INTERROGATORY NO. 78

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 i which Intervenors rely or which relates to the answers to paragraphs (a) and (b).

4 i

f r - , , - - , n . .n,, , , --.,r--,- , ,,--.. .-. - - . . . . , - , _ . , , -e , --, e-.

Resoonse:

(a) The Plan at issue in this proceeding is LILCO's, which recognizes the need for special reception centers for special facility residents. Egg answer to Interrogatory No. 69, and Plan references in Contention Ex 47. Speculation about other proposals is irrelevant.

(b) Not applicable.

(c) Not applicable.

LILCO INTERROGATORY NO. 79

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 document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).

Response

(a) The Plan at issue.in this proceeding is LILCO's, which recognizes the need for special reception centers for school children (although, as yet, LILCO has failed to identify any).

Egg LILCO Plan App. A at II-20; OPIP 3.6.5. Speculation about other proposals is irrelevant.

(b) Not applicable. I l

(c) Not applicable. I LILCO' INTERROGATORY NO. 80

80. a. Do Intervenors contend that the reference 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?"

l l

.. , , .- 1

. b.

What is the basis for the answer to paragraph (a)?

Response

(a)

The reference in Contention 47 subpart E is to Revision 7 of the LILCO Plan. That subpart speaks for itself.

The Governments contend, as stated in Contention Ex 47, that the Revision 7 proposals, including the provision for school children referenced in subpart E, fail to correct the deficiencies revealed during the Exercise and set forth in the remainder of Contention Ex 47.

(b) Egg answer to (a).

LILCO INTERROGATORY NO.__81

81. a.

from INPO, DOE, State whether Intervenors contend that personnel and other power plants actually had to partici-pate in the Exercise by going to the Reception Center and simu-lating monitoring procedures, alternative evacuee monitoring plan.in order to test adequately LILCO's b.

What is the basis for the answer to paragraph (a)?

c.

which(a) graphs Intervenors and (b). rely or which relates to the answers to paraId -

Response:_

(a) The allegations in Contention Ex 49, including subpart B, speak for themselves.

The exercise provides no basis to find that proposals to telephone INPO, other power plants, and other entities to obtain additional personnel could be implemented, or that they would result in an ability to perform, in a timely manner, necessary monitoring of the number of evacuees antici-pated to report to the reception center.

The Governments are not l

I l

_ _ _ _ - _ ' - ~ ' -' '

obligated to instruct LILCO on how to structure an Exercise, or how to correct deficiencies in its Plan or implmentation capa-bilities.

(b) Not applicable.

(c) Not applicable.

LILCO INTERROGATORY NO. 82

82. a. State the number of persons who would seek monitoring at the reception center.

b. What is the basis for the answer to paragraph (a)?

Resoonse:

(a) For the reasons set forth in Contention Ex 22 subpart F, and as stated in subpart C of Contention Ex 49, the Govern-ments contend that substantially more people than the number expressly advised by LILCO to report for monitoring would do so in the event of a Shoreham accident. As noted in Contention Ex 49, during the Exercise LILCO actually " advised" over 100,000 ,

evacuees to report to the Nassau Coliseum for monitoring and, if necessary, decontamination.

(b) At this time, the primary bases for the answer are the data set out and referenced in Contentions Ex 22 subpart F, Ex 49, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding Contention Ex 49. The results of discovery and analyses and research by those individuals may pro-vide additional bases. Sgg also the responses to Interrogatory ,

Nos. 51-56.

LILCO INTERROGATORY NO. 83

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)?

Resoonse:

(a) Egg responses to Interrogatory Nos. 51-56.

(b) Egg responses to Interrogatory Nos. 51-56.

LILCO INTERROGATORY NO. 84

84. a. Identify all events that occurred during the 1 Exercise which Intervenors would classify as " unanticipated and unrehearsed situations?" l

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 document which !

Intervenors rely or which relates to the answers to paragraphs I (a) and (b). l Response: 1 l

(a) Examples are identified in Subpart A of Contention Ex 50 and the contentions and FEMA comments identified therein.

The results of discovery and analysis and research may provide additional examples.

(b) Egg answer to (a) and the allegations in the conten-tions and FEMA comments referenced in subpart A of Contention Ex 50.

(c) At this time, the Governments have identified no documents as responsive to this request other than the facts, data, Plan and FEMA Report references set forth in subpart A of-

Contention Ex 50, and documents and materials. generated during the Exercise by FEMA and LILCO. The results of discovery and analysis and research may provide additional documents.

~

LILCO INTERROGATORY NO. 85

~

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."

i

b. Identify all events that 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 4

such procedures."

i

c. Identify and provide a copy of each document which

] Intervenors rely or which relates to the answers to paragraphs (a) through (c).

Response

(a) and (b) Examples are identified in subpart B of Con-tention Ex 50, and the contentions and FEMA comments identified therein. The results of discovery and analysis and research may provide additional examples.

I (c) At this time, the Governments have identified no i

documents as responsive to this request other than the facts, I

data, Plan and FEMA Report references set forth in subpart B of Contention Ex 50, and documents and materials generated during i

the Exercise by FEMA and LILCO. The results of discovery and I

analysis and research may provide additional documents.

l LILCO INTERROGATORY NO. 86 1

86. a. Identify all events that occurred during the Exercise in which Intervenors contend that information was communicated between or among LERO personnel?

f I

l

-, _ ,, ., .i.,-,.1, , . . . . _ , , - , - _ _ , _ , - - - , , . ___. ___ . - - - - , . - , _ . . . - - , -

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 failed 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).

Response

(a) The Governments note that LILCO is in the best position to know what exercise events involved the communication of information between or among LERO personnel. Egg subpart C of Contention Ex 50 and the events identified therein, for examples identified to date by the Governments. The results of discovery and analysis and research may provide additional examples.

(b) Egg subpart C of Contention Ex 50 and the events identified therein for examples identified to date by the Governments. The results of discovery and analysis and research may provide additional examples.

(c) Egg the allegations and comments in the Contentions and FEMA comments referenced in subpart C of Contention Ex 50.

(d) At this time, the Governments have identified no documents as responsive to this request other than the facts, data, Plan and FEMA Report references set forth in subpart C of ,

Contention Ex 50, and documents and materials generated during the Exercise by FEMA and LILCO. The results of discovery and analysis and research may provide additional documents.

LILCO INTERROGATORY NO. 87

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).

Response

(a) Egg subpart D of Contention Ex 50 and the events identified therein for examples identified to date by the Governments. The results of discovery and analysis and research may provide additional examples.

(b) Egg the allegations and comments in the Contentions and FEMA' comments referenced in subpart D of Contention Ex 50.

(c) uAt this time, the Governments have identified no documents as responsive to this request other than the facts, data, Plan and FEMA Report-references set forth in subpart D of Contention Ex 50, and documents and materials generated during the Exercise by FEMA and LILCO. The results of'iscovery d and analysis and research may provide additional documents.

LILCO INTERROGATORY NO. 88

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."

b. For each event listed in paragraph (a), identify-whether Intervenors contend that LERO personnel failed to exercise independent judgment, good judgment or common sense.

c. Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).

Resoonse:

(a) Egg subpart E of Contention Ex 50 and the events

' identified therein for examples identified to date by the Governments. The results of discovery and analysis and research may provide additional examples.

(b) Egg the allegations and comments in the Contentions and FEMA comments referenced in subpart E of Contention Ex 50.

(c) At this time, the Governments have identified no documents as responsive to this request other than the facts, data, Plan and FEMA Report references set forth in subpart E of Contention Ex 50, and documents and materials generated during-the Exercise by FEMA and LILCO. The results of discovery and analysis and research may provide additional documents.

LILCO INTERROGATORY NO. 89

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).

Response

(a) Egg subpart F of Contention Ex 50 and the events identified therein for examples identified _to date by the Governments. The results of discovery and analysis and research may provide additional examples.

(b) Egg the allegations and comments in the Contentions and FEMA comments referenced in subpart.F of_ Contention Ex 50.

(c) At this time, the Governments have identified no documents as responsive to this request other than the facts, data, Plan and FEMA Report references set forth in subpart F of Contention Ex 50, and documents and materials generated during the Exercise by FEMA and LILCO. The results of discovery and analysis and research may provide additional documents.

LILCO INTERROGATORY NO. 90 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).

Resoonse:

(a) Egg subpart G of Contention Ex 50 and the events identified therein for examples identified to date by the Governments. The results of discovery and analysis and research may provide additional examples.

O l

(b) At this time, the Governments have i'dentified no documents as responsive to this request other than the facts, data, Plan and FEMA Report references set forth in subpart G of Contention Ex 50, and documents and materials generated during the Exercise by FEMA and LILCO. The results of discovery and analysis and research may provide additional documents.

LILCO INTERROGATORY NO. 91

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.

c. Identify and provide a copy of each document which Intervenors rely or which relates to the answers to paragraphs (a) and (b).

Resoonse:

(a) Sgg subpart H of Contention Ex 50 and the events identified therein for examples identified to date by the Governments. The results of discovery and analysis and research n.ay provide additional examples.

(b) Egg the allegations and comments in the Contentions and FEMA comments referenced in subpart H of Contention Ex 50.

(c) At this time, the Governments have identified no documents as responsive to this request other than the facts, data, Plan and FEMA Report references set forth in subpart H of l

1 l

l i

Contention Ex 50, and documents and materials generated during the Exercise by FEMA and LILCO. The results of discovery and analysis and research may provide additional documents.

Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788

-G h tt l LaGrepce Coe LanpMr Karla J. Letschd P. Matthew Sutko Kirkpatrick & Lockhart 1900 M Street, N.W.

Washington, D.C. 20036 Attorneys for Suffolk County

, bd A v V44 -

' 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, p4ernor of the State of New York

/ m ') .,

-l '

- b.)( Y ' j Stepp n B. Latham~

Twoey, Latham & Shea P.O. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton l

l

6-p.ALLD CURntsPU{ tdt.ftOf, O ,

00LKETEP November 29, 198BDEC UNITED STATES OF AMERICA. e 1E EC -4 A11 :10 NUCLEAR REGULATORY COMMISSION ,

GFFICE ui H -t u r Before the Atomic Safety and Licensino Board 00CKlillo t MPviu. l RRANCs ,

I

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'In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5

) (EP Exercise) ,

(Shoreham Nuclear Power Station, ) l Unit 1) )

) i l

CERTIFICATE OF SERVICE

- I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON RESPONSE TO LILCO'S'SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON, responding to Interrogatories 46-91, have been served on the following this 29th day of November by U.S. mail, first' class, except as otherwise noted.

l

. John H. Frye, III, Chairman Dr. Oscar H. Paris (

Atomic Safety and Licensing Board Atomic Safety and Licensing Board j U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission-Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon Spence W. Perry, Esq.

Atomic Safety and Licensing Board William R. Cumming, Esq. 1 U.S. Nuclear Regulatory Commission Office of General Counsel; I Washington, D.C. 20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C. 20472 y sv*w' y'c--t v g. me r-- t- M- *C*+ r-

0 Anthony F. Earley, Jr., Esq. Bernard M. Bordenick, Esq.

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 l',787 Washington, D.C. 20555 MHB Technical Associares Hon. Peter Cohalan 1723 Hamilton Avenue Suffolk County Executive Suite K H. Lee Dennison Building San Jose, California 95125 Veterans Memorial Highway Hauppauge, New York 11788 Martin Bradley Ashare, Esq. Fabian G. Palomino, Esq.

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