ML20151A069

Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Lilco.* W/Certificate of Svc.Related Correspondence

ML20151A069
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/01/1988
From:	Leugers M HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-6011 OL-3, NUDOCS 8804060238
Download: ML20151A069 (10)

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LILCO, April 1,1988

. 59MED,9.M_W M M UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION UWC

'88 APR -4 P 5 :05 Before the Atomic Safety and Licensing Board QF5Ic~

OCCXE!M 7 ..A ,

,O in the Matter of ) W"

)

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

) (Emergency Planning)

(Shoreham Nuclear Power, Station ) (Best Efforts !ssue)

Unit 1)

LILCO'S SUPPLEMENTAL RESPONSES AND OBJECTIONS TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2,4-8. AND 10 TO LONG ISLAND LIGHTING COMPANY LILCO hereby supplements its response to Suffolk County's First Set of Interrogatories ,

and Requests for Production of Documents, dated March 15, 1988 and served on LILCO on March 16,1988.

I. GENERAL ANSWERS AND OBJECTIONS TO INTERROGATORIES, DEFINITIONS, AND INSTRUCTIONS LILCO gives the same general answers and makes the same general objections to Suffolk County's Interrogatories, Definitions, and Instructions that it made in response to Suffolk County's First Set of Interrogatories and Requests for Production of Documents. See LILCO's Responses and Objections to Suffolk County's First Set of Interrogatories and Re-quests for Production of Documents (Mar. 30,1988), at 1-2.

D. ANSWERS AND OBJECTIONS TO INTERROGATORIES Suffolk County Interrogatory No.1 Please identify, on a contention-by-contention basis, each witness LILCO expects to call to testify on Contentions 1 and 2 (directing traffic), Contention 4 (removing road obstruc-tions), Contention 5 (activating strens and broadcasting EBS messages), Contention 6 (making protective action decisions), Contention 7 (ingestion pathway), Contention 8 (recovery and re-entry), and Contention 10 (EPZ access control), as set forth in the Licensing Board's order ruling on LILCO's summary disposition motion on the legal authority / realism contentions.

Memorandum and Order (Ruling on LILCO's Motions for Summary Disposition of Contentions 1, 2, 4,5,6, 7, 8 and 10, and Board Guidance on Issues for Litigation) (Feb. 29, 1988). For each witness, other than experts, that LILCO expects to call, state on a contention-by-contention basis the subject matter on which he is expected to testify and the substance of the f acts to which he is expected to testify. For each witness that LILCO expects to call as an expert 8804060230 880401 PDR ADOCK 0500 2

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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 op!nion.

Response:In addition to LILCO's previously designated witnesses, LlLCO currently expects to call John A. Weismantle as one of its witneces during the realism remand proceeding. At present, LILCO expects that Mr. Weismantle will testify about how LILCO's plan and proce-dures accommodate State and County participation in a "best efforts" response to a Shoreham emergency with respect so Contentions 1-2, 4-8, 2nd 10. Mr. Weismantle will rely upon his experience and knowledge of emergency planning and upon Revision 9 of the LILCO Plan, including OPIP 3.1.1. The substance of the facts that he will testify about generally can be found in LILCO's realism summary disposition motions fHed March 20 and December 18, 1987.

In addition, LILCO expects that Mr. Edward Leiberman, who has already been desig-nated as a witness, will also testify on Contention 10.

Suffolk County Interrogatory No._2 For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional qualifications.

Response: Mr. Weismantle's resume was provided to the Co'Jnty in connection with the j February 13 exercise proceeding held during the first half of 1987, and is a part of the record in that proceeding. LILCO provides with this response another copy of hit resume. A more up-to-date resume, if available, will be provided to the County before the end of the 30-day ,

production period.

Suffol.k County Interrogatory Non 3 l Please list any NRC, judicial, administrative, legislative, or other legal proceeding in l

which each witness has testified on any matter related in any way to the substance of the is- .

sues in Contentions 1-2,4-8, and 10. State on a contention-by-contention basis which conten-j tion the witness's testimony concerns. ,

l Response: Mr. Weismantle has testified in numerous LILCO proceedings all of which are well ,

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known to Suffolk County. Since all of his testimony has been in the Shoreha' proceeding, Suffolk County is capable of making its own determination about how it relates to the issues in l Contentions 1-2, 4-8, and 10.

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q Suffolk County Interrogatory No. 4 Please provide a copy of any profiled testimony listed in response to Interrogatory 3 above.

Rmponse: Suffolk County already has the testimony discussed in response to Interrogatory No.

3.

Suf tolk County Interrogatory No. 5 lilease identify all articles, papers, studies, reports, books and other such documents authored or prepared by each witness pertaining to the substance of the issues in Contentions 1-2, 4-8, and 10.

Response: LILCO is not aware of any such documents. If LILCO discovers any such docu-ments LILCO will produce them within the 30-day discovery period.

Suffolk County Interrogatory No. 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 1-2, 4-8, and 10.

Response: See LILCO's response to Suffolk County Interrogatory No. 5 above.

Unless the answer to interrogatory 6 above is a simple negative, please identify each document in LILCO's response to these Interrogatories according to Definition J and provide a copy of each document.

Response: See LILCO's response to Suffolk County Interrogatory No. 5 above.

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Respectfully submitted.

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Jameb S. L an Mary Jo L g s i

l i llunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 l DATED: April 1,1988 1

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• PROFESSIONAL QUALIFICAT!ONS JOHN A. WEISMANTLE Vice President Engineering LONG ISLAND LIGHTING COMPANY My name is John A. Weismantle and my business address is Long Island Lighting Company (LILCO),1660 Walt Whitman Road. Melville New York 11747. I have been an employee of LILCO since 1965.

I was awarded my Bachelor of Arts degree with a Pre-Engineering major from Columbia College in New York City in 1963. I subsequently earned two degrees in Mechanical Engineering from Columbia School of Engineering in New York City - a Bachelor of Science degree in 1964 and a Master of Science degree in 1965. In 1970. I was again awarded a Master of Science degree, this time in Nuclear Engineering Sci-ence, from Long Island University in Brookville, New York. I also attended the Pubile Utilities Executive Program at the University of Michigan ..) 1979.

I was employed by LILCO in 1965 as an Assis* ant Engineer. In 1969 I was named Section Head in the Power and Instrumentation civ:.sion. I remained in this ca-pacity through 1973. In this position, I assumed a wide range of responsibilities related to new and existing steam plants, a new nuclear plant and gas tur0ines. These responsibilities included acting as Project Coordinator for Northport Units 3 and 4 (two 400 MW oil-fired units) and lead mechanical engineer for these units. I also served as lead mechanical engineer on balance of plant for the 320 MW Shoreham Nuclear Power Station as well as Project Engineer for Holbrook Power Station 1500 MW of gas tur-J bines).

JOHN A. WEISMANTLE J Page As Section Head in the Power and Instrumentation Division, my special as-1 signments included acting as Chairman of the Engineering Productivity Task Force and

! a member of the Construction Manpower Task Force. In both of these positions the conclusions and recommendations ! proffered were accepted. .

'In 1974, I served as Licensing Engineer for the Jamesport Nuclear Power Station. This was a full-time ipecial assignment to d! rect completion of Stata Siting and NRC Construction Permit Applications wnich were behind schecule. I was respon-sible for direction and coordination of internal departments and numerous consultants.

In this capacity, I saw to it that the lost time was made up and that applicattuns were submitted by the original deadline.

From 1974 to 1975, I was the Manager of the System Planning Division. As

! manager of this division, I was responsible for generation, bulk transmission and interconnection planning. I had direct supervisory respont:ility over 12 graduate engi-i neers plus support personnel. l In 1975, I assumed the position of Project Manager for tha Jarnesport Nucle- ,

ar Power Station. I remained in this position until late 1976, assumlag responsibility for

i two 1150 MW PWR nuclear units. At the time ! assumed this position, the project was l

< in the state and tederal licensing stage with preliminary engineering and construction planning proceeding. Eventually, a single 300 MW coal unit received a State Siting Cer-tificate.

From 1977 to 1978. I served as LILCO's first Research and Development Di-i rector. In addition to organizing a corporate Research and Development program, de- ,

veloping a five year plan, and establishing procedures, I represented LILCO on external l

research and cevelopment committees. One of my special adgnments involved acting 1

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a JOHN A. WEISMANTLE Page .

as Chairman of the LILCO Load Management Task Force, where my conclusions and recommendations were accepted.

From 1978 to 1981. I was Manager of LILCO's Planning Depariment. In this capacity, I was responsible for short term and long range planning of LILCO's electric facilittes and corporate r+. search and development function. The Planning Departmsnt comprises three divisions - System Planning (involving s'ab-transmission and inter-connections), Area Planning (involving sub-transmission and distribution), and Research and Development. I had direct supervisory responsibility over a staff of 30 graduate en-gineers plus support personnel. Furthermore I directed preparation of a wide ran2e of technical and economic reports in addition to serving as 5 member of the 1:!LCO ao hoc l task force on coal.

As Manager of the P!anning Department. I represen'.ed t.!LCO on the follow-ing incustry committees: the EEC System Planning Committa. ESEERCO Administra-tive Committee. NYPP Generation Planning Advisory Succommittee, and EPRI Ad-vanced Power Systems Task Forets (Chairman of Clean Gaseous Fuels Program

Committeel.

In 1981. I was named Manager of the Power Engineering Department. In this j capacity. I was responsible for the Port Jeiterson Coal Conversion conceptual design.

cost estimate, and license applications, all of which is currently undergoing the state 11-l censing process. In addition. I was responsible for att major capital (above $25,000)im-l provement projects for existing fossil plants. Other esponsibilities included the fie.ds of gas system planning and engineering mechanical engtreering -- Shoreham support.  ;

and direct supervisory responsibility for a staff of over 35 graduate engineers plus sup-port personnel. I represented LILCO on the EE! Prime M6 vers Committee and the EPRI ,

Fossil Fue.' Power Task Force.

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. JOHN A. WEISMANTLE Page l In June 1982, I became responsible for the satisfactory implementation of

, the Shoreham onsite and local emergency plans. In carrying out this assignment, I re- ,

I ported to the Vice President of Engineering who has corporate lead responsibility for emergency preparedness, in September 1983 I became full-time manager of the Local Emergency Response Implementing Organization, a group of over 30 professionals plus i

support personnel.

From 1983 to 1985 I was the Manager for the Local Emergency Response Or-ganization (LERO). I directed the development and impMmentation of a unique off-site s

' nuclear emergency plan which relles entirely on utility workers, private companies and ,

volunteer organizations. An approved off-site plan is the final Fequirement for a full power license for Shoreham. My responsibilities included development and mainte-nance of the plan, preparation and administration of a training program for 2200 ,

workers, estab!!shing several emergency f acilities and direc*ing all preparations for a I federally graded exercise held in February,1956. I made prnentations to senior man-agement and the Board of Directors, presented tastimony en more than 50 Lees in a protracted and bitterly contested licenslag hearing, ad advanced LILCO's position at debates and before the media.

From 1984 to 1985 I was the Manager of the F?cilities Planning Department.

In March,1934 LlLCO reorgani?ed and I was appointed to fill th!.s position in addition to i continuing as Manager of LERO. I reported to the Vice President of Corporate Phn-l l ning, and directed over 25 engineers with the responsibility for planning LILCO's elec- ,

tric f acilities and ccrporate R ,k P program, from 1985 to the present ' have been Vice Presidera of Engineering, In l

November of 1985 I was elected to this position. I report to the senior V!ce President l

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4 JOHN A. WEISSIANTLE

! Page :

of Enginecting and Operations, five departments report to me: Power Engineering, l

Electrical Engineering, Environmental Engineerir.g. Engineering Design and Stapping, and Engineering Analyst 4. These departments contain over 200 personnel, Sly responsibilities include al.1 engineering and design fc.t' improvements to LILCO's fossii j ' generating stations. We are also responsible for engineering and design of balance of plant impiovements at the 300 A!W Shnrenam Nuchar Power Piant. Engineering also

provides operating support for our entire electric system, in connection with my professional experience and qualifications, I have prepared and presented testimony on a vide range of technica12md econorth issues at I numerous proceedings. Includidg the 1979 State Energy 5f aster Plan hearings, in elec-l tric rate cases finvolving corporate capital oudget and Research and Development pro-

, grams), and in hearing ::efore tne State 51 ting Board, the Suelest Regulatory Comin!s-

) ston, State Legislative Commissions (in*,'olving cogen ration and researen and i

j development), and the federal Energy Reguutory Commiss:.n.

l  ! have ceen a '!cer. sed Protessional Engineer in tr.e state of New York s;nce l 1970, Sly profes5 tonal affiliatices include membertW in the American Soc!ety of .\te-chsnical Engineers ( ASNtSh at?.3 past memnership on :ne Power Test Code Committee --

t Condensers and Feecwrer Featers, and (no Executive Committee, Long Island Section.

i am also a past memter of EE! Prime Slovers and System Plann:ng Committees. EPR!

fossd Perwer Plant and Advacced Fossil Power Systems Task Force, and several NYPP ano ESEERCO Committees.

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4 LILCO, April 1,1988 toutlic um

'88 H -4 PS :05 CERTIFICATF OF SERVICE

g. ,

00CMitar,A nuwu' 3RANN in the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's Supplemental Responses and Objections to Suffolk County's First Set o' Interrogatories and Requests for Production of Docu-ments Regardirq Contentions 1-2,4-8, and 10 to Long Island Lighting Company were served this date upon the following t;y Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.

James P. Gleason, Chairman " Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and I,1 censing 513 Gilmoure Drive Board Panel Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline "

Atomic Safety and Licensing Richard G. Bachmann, Esq. "

Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy. Rockville,, MD 20852 Bethesda, MD 20814 Herbert H. Brown, Esq. "

! Mr. Frederick J. Shon " Lawrence Coe Lanpher, Esq.

Atomic Safety and Licensing Karla J. Letsche, Esq.

i Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.

4350 East-West Hwy. Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq. "

l Secretary of the Commission Richard J. Zahnicuter, Esq.

Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.C. Nuclear Regulatory Commission Room 229 1717 H Street, N.W. State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing Alfred L. Nardelli, Esq.

Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission 120 Broadway

, Washington, D.C. 20555 Room 3-118 i New York, New York 10271 I

4 Spens W. Perry, Esq. ** Ms. Nora Bredes William R. Cumming, Esq. Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.

Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.

Stephen B. Latham, Esq. ** Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee i

Federal Emergency Management P.O. Box 231 l Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq.

New York State Department of Public Service, Staff Counsel

, Three Rockefeller Plaza

! Albany, New York 12223 s _

l Ma Jo_ p;rs Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: April 1,1988 l

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