ML20147D559

NRC Staff First Set of Interrogatories & Requests to Produce to Suffolk County,State of Ny & Town of Southampton Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence

ML20147D559
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/29/1988
From:	Bachmann R NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY
References
CON-#188-5721 OL-3, NUDOCS 8803040050
Download: ML20147D559 (5)

Text

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02/29/gg eEEATED CORRE.mguM3 h

DOLHCICO V5NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

• 2 MR -2 P2 :31 BEFORE THE ATOVI,C SAFETY AND LIC,E_NSING BOARD f0C b

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BP.MWi in the Matter of

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1.ONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station,

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s Unit 1)

)

NRC STAFF FIRST SET OF INTEPROGATORIES AND REQUESTS TO PRODUCE TO SUFFOLK COUNTY, STATE OF NEW YORK AND T,0WN OF SOUTHAMPTON CONCERNING_ HOSPITAL EVACUATION Pursuant to 10 C.F.R.

Il 2.740, 2.740b and 2.741, and in accordance with the Licensing Board's Order of February 24, 1988, O he t

NRC Staf f hereby serves upon Suffolk County, the State of New York and the Town of Southampton ("Intervenors") the Staff's First Set of Interrogatories and Requests to Produce.

Each interrogatory shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information availabfe to the intervenors, their

officers, directors,

members, employees, advisors, representatives or counsel, based upon the personal knowledge of the person answering.

Intervenors are requested to produce each document identified in response to the subject interroga-tories.

By such reoutst for production of documents, the Staff seeks to inspect and copy pertinent doeurrents which are in the possession, 1/

"Memorandum and Order (Ruling on LILCO's Motion for Summary Disposition of the Hospital Evacuition issue)".

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r i custody or control of Intervenors, their officers, directors, members, employees, advisors, representatives or counsel.

As used herein, the term "documents" shall include any writings, drawings, graphs, charts, and schedules, however produced; photographs or other pictorial representations; recordings and tapes, whether sound or visual; and data

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compilations of whatever form.

In addition, Intervenors are requested, pursuant to 10 C.F.R. 5 2.7t40(e), to supplement their responses as necessary with respect to the identity of each person expected to be called as an expert witness at t

the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance of such testimony, i

l INTERROGATORIES AND DOCUMENT REQUESTS 1.

With regard to hospital evacuation time estimates, Identify the person (s) whom Intervenors expect to call as a witness.

For each witness:

j a.

State the substance of his or her testimony, includino the f

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facts and opinions to which the witness is expected to testifv; i

i b.

Provide the basis for each such opinion; i

c.

Identify and provide all documents, including studies and analyses, upon which the witnesses intend to rely;

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d.

Identify all prior statements made by the witnesses in testimony or depositions, in this or other proceedings, which concern the

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t subject matter of their testimony.

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2.

For each witness identified in response to interrogatory 1,

provide a

statement of the witness' educatinnat and professional i

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g.

- background, with specific reference to his or her qualifications to give the particular testimony.

Respectfully submitted,

/

Richard G. Bachmann Counsel for NRC Staff Dated at Rockville, Maryland this 29th day of February,1988 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3 ttR -2 P2 01 l

REFORE THE ATOPir SAFETY AND LICENSING ROARD I

OP ICE U' SE "I I A'I-l 00CnEMG \\ %"VIC BRANCH i-in the Matter of

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1.ONG ISLAND LIGHTING COMPANY

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Docket No.

50-322 -O L-3

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(Emergency Planning)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

I CERTIFICATE OF SERVICE I

hereby certify that copies of "NRC STAFF FIRST SET OF l

lNT ER ROCATORIES AND REQUESTS TO PRODllCF TO SUFFOLK

COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON CONCFRNING HOSPITAL EVACUATION" in the above-captioned l

i proceeding have been served en the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal rr all system, this 29th day of

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February 1988.

f James F. Gleason, Chairman

• Joel Blau, Esq.

Administrative Judge Director, Utility intervention i

Atomic Safety arc' Licensing Boarc Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue

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Washingtor, DC 20555 Albany, NY 12210 i

Jerry R. Kline*

Fabian C. Palomino, Esq.

Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 1222t4 Frederick J. Shon*

Jonathan D. Feinberg, Esq.

Administrative Judge New York State Department of Atomic 3afety and Licensing Board Public Servict U.S. Nuclear Regulatory Commission Three Empire State Plaza r

Washington, DC 20555 Albany, NY 12223 Philip McIntire W. Taylor Reveley lit, Esq.

Federal Emergency Uanagement Donald P. Irwin, Esq.

Agency Hunton 6 Williams 26 Federal Plaza 707 East Main Street l

Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212 j

l

4-t Douglas J. Hynes, Councilman Dr. W. Reed Johnson Town Board of Oyster Bay 115 Falcon Drive, Colthurst Town Hall Charlottesville VA 22901 Oyster, Bay, New Ycrk 11771 Stephen B. Latham, Esq.

Herbert H. Brown, Esq.

Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.

Attorneys at Law Karla J. Letsche, Esq.

33 Wrst Second Street Kirkpatrick s Lockhart P.lverhead, NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel

• 11.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, DC 20555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel

• Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20D5 Spence W. Perry, Esq.

Martin Bradley Ashare, Esq.

General Counsel Suffolk County Attorney Federal Emergency Management H. L'e Dennison Building Agency Veteran Memorial Highway 500 C Street, SW Hauppauge, NY 11788 Washington, DC 20L72 Anthony F. Earley, Jr.

Dr. Monroe Schneider Ceneral Counscl North Shore Committee Long Island Lighting Company P.O. Box 231 175 East OI:i County Road Wading River, NY 11792 Hicksville, NY 11801 Ms. Nora Bredes Dr. Robert Hoffman Shoreham Opponents Coalition Long Islanc Ccalition for Safe 195 East Main Street Living Smithtown, NY 11787 P.O. Box 1355 Massapecua, NY 11758 William R. Cumming, Esq.

Office of General Counsel Alfred L. Nardelil, Esq.

Federal Emergency Uanagement New York State Department of Law Agency 120 P,roacway 500 C Street, SW Room 3-1'. 8 Washington, DC 20472 Docketing and Service Section*

Barbara Newman Office of the Secretary Director, Environmental Health U.S. Nuclear Regulatory Commission Coalition for Safe Living Washington, DC 20555 Hox 944 Huntincton, New York 11743 e

c ard G. Bachmann Counsel for NRC Staff