ML20148K220

Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Realism.* W/Certificate of Svc.Related Correspondence

ML20148K220
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/23/1988
From:	Zahnleuter R NEW YORK, STATE OF
To:	LONG ISLAND LIGHTING CO.
References
CON-#188-5963 OL-3, NUDOCS 8803310042
Download: ML20148K220 (7)

Text

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00CKETED USNRC O N g ggsPONDENOW DATE: March 23, 1988

'88 HM 28 P4 @3 UNITED STATES OF AMERICA cpp;cg g,c ggu 7Ac, NUCLEAR REGULATORY COMMISSION 00CXEinn4 g msf' DIGhDi Before the Atomic Safety and Licensina Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

)

Unit 1) )

i RESPONSE OF THE STATE OF NEW YORK TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING REALISM This is the State of New York's response to "LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Contentions 1-2, 4-8, and 10 to Suffolk County, New York State, and the Town of Southampton," dated March 9, 1988

("LILCO's First Set of Realism Interrogatories and Requests").

To the extent that LILCO's First Set of Realism Interrogatories and Requests seeks information and documents of any sort that are not within the possession, custody or control of the State of New York, but, rather within the possession, custody or control of counties, towns, school districts, or other local governments (including Suffolk County and the Town of Southampton), the State of New York objects. Counties, towns, school districts, or other local governments are autonomous from 8803310042 880323 g PDR ADOCK 050 3y2 G

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the State of New York and are not within the State of New York's control. Accordingly, the burden of obtaining such information is the same for LILCO as it is for the State of New York.

To the extent that LILCO's First Set of Realism Interrogatories and Requests seeks information and documents of any sort that are protected against disclosure, for example, by attorney work product doctrine, the State of New York objects.

LILCO Interrocatory Nos. 1-7

1. Please identify, on a contention-by-contention basis, each witness Intervenors expect to call to testify on Contentions 1 and 2 (directing traffic,), Contention 4 (removing road obstructions), Contention 5 (activating sirens and broadcasting EBS messages), Contention 6 (making protective action decisions),

Contention 7 (ingestion pathway), contention 8 (recovery and reentry), and Contention 10 (access control) as set forth in the Boards order ruling on LILCO's summary disposition motion on the realist contentions. Memorandum and Order (Ruling on LILCO's Motions for Summary Disposition of Contentions 1,2,4,5,7,8 and 10, and Boetd Guidance on Issues for Litigation) (Feb. 29, 1988).

For each witness, other than experts, that Intervenors expect to call, state en a contention-by-contention basis the subject matter on whica he is expected to testify and the substance of the facts to which he is expected to testify. For each witness that Intervenore expect to call as an expert witness, state on a contention-by-contention basis the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expected to testify, and the summary of the grounds for each such opinion.

Response: As of this date, the State of New York has not identified any witnesses it expects to call to testify on Contentions 1,2,4,5,6, 7,8 and 10.

2. For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional 2

T qualifications.

Respons_e: See the response to Interrogatory No. 1.

3. Please list any NRC, legislative, or other legal proceeding in which each wintess has testified on any matter related in any way to the substance of the issues in Contentions 1-2, 4-8, and

10. State on a contention-by-contention basis which contention the witness's testimony concerns.

Response: See the response to Interrogatory No. 1.

4. Please provide a copy of any prefiled testimony listed in response to Interrogatory 3 above.

Response: See the response to Interrogatory No. 1.

5. Please identify all articles, papers, and other documents authored or coauthored by each witness pertaining to the substance of the issues in Contentions 1-2, 4-8, and 10.

Response: See the response to Interrogatory No. 1.

6. Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses, or other documents with respect to the substance of the issues in Contentions 1 , 4-8, and 10.

Resoonse: See the response to Interrogatory No. 1.

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7. Unless the answer to Interrogatory 6 above is a simple l negative, please identify each document in the Intervenors' l

response to these Interrogatories according to Definition K and l

provide copy of each document.

l Response: Sgg the response to Interrogatory No. 1.

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I' Obiections Stated by Counsel l

l Counsel states all objections, assertions of privilege, and answers not requiring verification, l

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f Richard J. Tahnleuter Special Counsel to the Governor Attorneys for Mario M. Cuomo, c Governor, and the State of New York 4

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00LKETED (BNRC DATE: March 23, Igp8 MAR 28 P4 :44 UNITED STATES OF AMERICA Of flCE !? S E C.Et. i A r. <

NUCLEAR REGULATORY COMMISSION 00 M g E8vict,-

Before the Atomic Safety and Licensina Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station )

)

Unit 1) )

I CERTIFICATE OF SERVICE I hereby certify that copies of the "Response of the State of New York to LILCO's First Set of Interrogatories and Request for Production of Documents Regarding Realism" have been served on the following this 23rd day of March 1988 by U.S. Mail, first class, except as noted by asterisks.

Mr. Frederick J. Shon Spence W. Perry, Esq.

Atomic Safety and Licensing Board William R. Cumming, Esq.

U.S. Nuclear Regulatory Commission Office of General Counsel, Washington, D.C. 20555 Federal Emergency Management Agenc 500 C Street, S.W., Room 840 Washington, D.C. 20472 Dr. Jerry R. Kline Mr. James P. Gleason, Chairman Atomic Safety ar.d Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 l

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Anthony F. Earley, Jr., Esq. Joel Blau, Esq.

General Counsel Director, Utility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi Mr. Donald P. Irwin Clerk _

Hunton & Williams Suffolk County Legislature 707 East Main Street Suffolk County Legislature P.O. Box 1535 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 Ragulatory Commission 195 East Main Street 1717 H Street, N.W.

Smithtown, New York 11787 Washington, D.C. 20555 Adrian Johnson, Esq. Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-16 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 E. Thomas Boyle Lawrence Coe Lanpher, Esq.

Suffolk County Attorney Kirpatrick & Lockhart Building 158 North County Complex 1800 M Street, N.W.

Veterans Memorial Highway South Lobby - Ninth Floor Hauppauge, New York 11788 Washington, D.C. 20036 l

Mr. Jay Dunkleburger Edwin J. Reis New York State Energy Office U.S. Nuclear Regulatory Commission Agency Building #2 Washington, D. C. 20555 Empire State Plaza Albany, New York 12223 l

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'r 6-I Mr. James P. Gleason Douglas J. Hynes Chairman Town Board of Oyster Bay Atomic Safety and Licensing Board Town Hall 513 Gilmoure Drive Oyster Bay, New York 11771 Silver Spring, MD 20901 David A. Brownlee, Esq. Mr. Philip McIntrie Kirkpatrick & Lockhart FEMA 1500 Oliver Building 26 Federal Plaza Pittsburgh, Pennsylvania 15222 New York, New York 10278 Mr. Stuart Diamond Business / Financial NEW YORK TIMES 229 W. 43rd Street New York, New York 10036

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c /b 'Y ), 4 Richard J/'Zahnleuter, Esq.

Deputy SpecieI Cdunsel to the Governor

Executive Chamber Capitol, Room 229 Albany, New York 12224 (518) 474-1273

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