ML20215N622
| ML20215N622 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/03/1986 |
| From: | Zeugin L HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF |
| References | |
| CON-#486-1396 OL-5, NUDOCS 8611070085 | |
| Download: ML20215N622 (6) | |
Text
gg LILCO, Nov:mber 3,1986 UNITED STATES OF AMERICA RELATED QMdESEiDNUr.hg NUCLEAR REGULATORY COMMISSION USNRC
~
~86 NOV -6 All 39 Before the Atomic Safety and Licensing Board CFFICi
- n 00CXLirn;, s ' mr~
In the Matter of
)
U fW^
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO NEW YORK STATE l
Long Island Lighting Company, by its counsel, propounds the following interroga-tories to New York State, pursuant to SS 2.740,2.740b and 2.741 of the Nuclear Regula-tory Commission's Rules of Practice. In responding to these interrogatories and re-quests, New York State should follow the instructions and definitions contained in LILCO's First Set of Interrogatories to Intervenors, dated October 29,1986.
When used in these interrogatories and requests, "New York State" or "New York State personnel" means New York State, or any agency thereof and any elected official, appointed official, legislator, agent, employee, consultant, contractor, technical advis-or, representative or other person acting for or on behalf of them, or at their direction and control, or in concert with or assisting them.
INTERROGATORIES AND REQUESTS FOR PRODUCTION 1.
Please identify by (1) plant, (2) date, (3) scope (10-mile,50-mile EPZ, both),
(4) scale (full-scale or partial), and (5) nature (regular, remedial, etc.) each FEMA-graded emergency planning exercise for nuclear power plants in which New York State personnel have participated (by developing, reviewing, or approving exercise scenarios and/or objectives, or by participating in the exercise itself) during the last five years.
8611070085 061103 PDR ADOCK 05000322 Dss 3
2.
Please identify all New York State personnel who have been involved, at any time in the last five years, in the development, review, or approval of scenarios and/or objectives for FEMA graded exercises for nuclear power plants in New York State.
3.
Please provide copies of all (1) final scenarios, (2) final objectives which were developed, reviewed, or approved by the New York State personnel identified in response to the previous interrogatory, (3) all documents prepared by New York State personnel identified by response to the previous interrogatory as part of their develop-ment, review, or approval of those scenarios and/or objectives, and (4) FEMA post-exercise assessments for each such exercise.
4.
For each FEMA graded exercise for nuclear power plants in New York State in which New York State personnel have participated or have developed, re-viewed, or approved the scenario and/or objectives, in the last five years please identi-fy (1) the total number of hospitals located in the emergency planning zone and (2) the number of hospitals that participated in the exercise. Please provide the same infor-mation for schools (public, private, parochial an6 nursery), and for nursing homes and adult homes.
S.
Please identify all FEMA graded exercises, within the last five years, for nuclear power plants located in New York State as well as those located in other states, in which New York State personnel have participated in the ingestion pathway portion of the exercise. Please identify all New York State personnel who participated in those exercises.
6.
For each FEMA graded exercise for nuclear power plants in New York State in the last five years in which New York State personnel have participated or
have developed, reviewed, or approved the scenario and/or objectives for the exercise, please provide the following information:
a.
the number of buses, ambulances and ambulettes that participated in the exercise, b.
the number of reception centers and cong: agate care centers that participated in the exercise and the theoretical capacity of those fa-
- cilities, c.
a description of the equipment, number of personnel and facilities that were used during the exercise for the monitoring and decontamination of evacuees and vehicles at reception centers, d.
a description of the equipment, number of personnel and facilities that were used during the exercise for the monitoring and decontamination of evacuees from nursing and adult homes, e.
the number of traffic impediments that were posed to the emergen-cy response organization, f.
the number of traffic posts that were staffed, the number of traffic control personnel that staffed them, and the number of traffic posts that were observed by FEMA, g.
whether rumor control capabilities were tested and the method used for testing.
7.
Did any FEMA graded exercise conducted in the last five years in which New York State personnel participated include a hypothesized wind shif t during the ac-cident? If yes, please identify each such exercise. During any of those exercises, was an evacuation recommendation rescinded as a result of a wind shif t? If so, please de-scribe and identify and provide copies of pertinent documentation.
8.
Please identify all New York State personnel who have been involved in the development of programs to train and evaluate New York State personnel who are to respond to an emergency at nuclear power plants in New York State.
_4_
9.
What sample groups, sample sizes or sampling criteria are used by the per-sons identified in Interrogatory 8 to evaluate the ability of New York State personnel to respond to an emergency at a nuclear power plant or to evaluate the effectiveness of a training program.
Respectfully submitted, h- -
Lee B. Zeug(yfin&
Donald P. I tn Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 3,1986
LILCO, N v:mber 3,1986 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-5
-I hereby certify that copies of LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO NEW YORK STATE were served this date upon the following 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 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 Panel Third Floor, Room 3-116 U.S. Nuclear Regulatory Commission New York, New York 10271 Washington, D.C. 20555
- - - _ ~___
Spence W. Perry, Esq.
Ms. Nora Bredes William.R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency-135 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Gerald C. Crotty, Esq.
Counsel to.the Governor Mr. Jay Dunkleberger.
Executive Chamber i
New York State Energy Office 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 p
.33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway j
Riverhead, New York 11901 Hauppauge, New York 11787 -
j Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee i
Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 Jonathan D. Feinberg, Esq.
i l
New York State Department of
)
Public Service, Staff Counsel Three Rockefeller Plaza i
Albany, New York 12223 I
i
'^'
i Ee#B. Zeugly y
.Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 i
DATED: November 3,1986 1
l i
1 f
i
_ _ _ _ _ -___,__ _ _ __. _ _ _ _ _ _ _ _ _-_.__. --