|
---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20150D4711988-07-0606 July 1988 Suffolk County Answers to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10.* W/Supporting Documentation & Certificate of Svc. Related Correspondence ML20150D5071988-07-0505 July 1988 State of Ny Response to Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2, 4-8 & 10 to Suffolk County,State of Ny & Town of Southampton.* W/Certificate of Svc.Related Correspondence ML20155C0791988-06-0707 June 1988 Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* Notices of Depositions & Certificate of Svc Encl.Related Correspondence ML20155C5671988-06-0303 June 1988 State of Ny Response to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl. Related Correspondence ML20151T6251988-04-22022 April 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Licensee.* W/Certificate of Svc. Related Correspondence ML20151T4391988-04-22022 April 1988 Govt Answer & Addl Objections to Lilco Second Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Answers & Objections Listed.Notification to County Executive & Certificate of Svc Encl.Related Correspondence ML20151T5701988-04-22022 April 1988 Govt Answers to NRC Staff Interrogatories Re Contentions 1-2,4-8 & 10.* W/Certificate of Svc.Related Correspondence ML20151T8001988-04-20020 April 1988 Govts Objections to Lilco Second Set of Interrogatories Re Consumptions 1-2,4-8, & 10.* Certificate of Svc Encl.Related Correspondence ML20148S8381988-04-12012 April 1988 Suffolk County Fifth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20151F2041988-04-0909 April 1988 Suffolk County Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* W/Certificate of Svc.Related Correspondence ML20151A0691988-04-0101 April 1988 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 ML20148L9181988-03-31031 March 1988 NRC Staff First Set of Interrogatories to Suffolk County,Ny State & Town of Southampton Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20150F8941988-03-30030 March 1988 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 ML20148L9021988-03-28028 March 1988 Suffolk County Supplemental Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl. Related Correspondence ML20148K2151988-03-25025 March 1988 Lilco Responses & Objections to Suffolk County Third Set of Interrogatories & Requests for Production of Documents Re Emergency Broadcast Sys.* W/Supporting Documentation & Certificate of Svc.Related Correspondence ML20148K4421988-03-24024 March 1988 Lilco Second Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8,& 10 to Suffolk County,State of Ny & Town of Southampton.* Certificate of Svc Encl.Related Correspondence ML20148K1771988-03-24024 March 1988 Lilco Second Set of Requests for Production of Documents Re Lilco Emergency Broadcast Sys to Suffolk County.* Util Makes No Admission or Representation About Proper Scope of Issues to Be Decided.W/Certificate of Svc.Related Correspondence ML20148K2201988-03-23023 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Realism.* W/Certificate of Svc.Related Correspondence ML20148K1571988-03-23023 March 1988 Suffolk County Response to Lilco First Set of Interrogatories Re Contentions 1-2,4-8 & 10.* Certificate of Svc Encl.Related Correspondence ML20148K3881988-03-23023 March 1988 Response of Suffolk County to Lilco 880311 Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl ML20150D1571988-03-18018 March 1988 Response of State of Ny to NRC Staff First Set of Interrogatories & Requests for Production of Documents Re Hosp Evcacuation Time Estimates.* Certificate of Svc Encl. Related Correspondence ML20150D0791988-03-16016 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to NRC Staff & Fema.* Certificate of Svc Encl.Related Correspondence ML20150D0121988-03-15015 March 1988 Suffolk County First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Lilco.* Certificate of Svc Encl.Related Correspondence ML20150C6511988-03-15015 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Hosp Evacuation Time Estimates.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20150A8081988-03-11011 March 1988 Suffolk County Third Set of Interrogatories & Requests for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20150A9581988-03-11011 March 1988 Lilco Supplemental Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* W/Certificate of Svc. Related Correspondence ML20150A9421988-03-11011 March 1988 Lilco Motion to Compel Answers to Certain Interrogatories & Requests for Production of Documents.* Related Documentation & Certificate of Svc Encl ML20150A9521988-03-11011 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Related Correspondence ML20150C9911988-03-11011 March 1988 Response of State of Ny to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Objections Stated. W/Certificate of Svc.Related Correspondence ML20150A8561988-03-10010 March 1988 Suffolk County Responses & Objections to Lilco First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20150A8431988-03-10010 March 1988 Suffolk County Responses & Objections to NRC Staff First Set of Interrogatories & Request for Production of Documents Re Hosp Evacuation.* Related Correspondence ML20150A8881988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents.* Related Correspondence ML20150A9111988-03-10010 March 1988 Lilco Responses & Objections to Suffolk County Second Set of Interrogatories & Request for Production of Documents.* Util Objects to Interrogatory 1 as Vague,Overbroad & Unduly Burdensome.W/Certificate of Svc.Related Correspondence ML20150A9341988-03-0909 March 1988 Suffolk County Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl ML20150A9641988-03-0909 March 1988 Lilco First Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County, State of Ny & Town of Southampton.* W/Certificate of Svc. Related Correspondence ML20150A9671988-03-0909 March 1988 State of Ny First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* W/Certificate of Svc.Related Correspondence ML20196H3941988-03-0707 March 1988 Lilco Second Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20196H4361988-03-0707 March 1988 Lilco Responses & Objections to Suffolk County First Set of Interrogatories & Request for Production of Documents Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8421988-03-0404 March 1988 Response of State of Ny to Lilco Second Set of Requests for Admissions Re Role Conflict of School Bus Drivers.* Lilco Second Set of Requests for Admissions Deemed Untimely. Certificate of Svc Encl.Related Correspondence ML17342B4211988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8061988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence ML20147H8571988-03-0303 March 1988 Suffolk County Second Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H7901988-03-0303 March 1988 Suffolk County Second Supplemental Response to Lilco Second Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Lilco Interrogatories 28 & 29 Addressed.Related Correspondence ML20147H7991988-03-0303 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8121988-03-0303 March 1988 Suffolk County Fourth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence ML20196G1121988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to NRC Staff Re Hosp Evacuation Issue.* Related Correspondence ML20196G1301988-03-0101 March 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to FEMA Re Hosp Evacuation Issue.* Definitions & Instructions for Answering Interrogatories Encl.W/Certificate of Svc.Related Correspondence ML20196G1081988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Emergency Broadcast Sys.* Certificate of Svc Encl.Related Correspondence ML20147H8031988-02-29029 February 1988 Lilco Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20196G1371988-02-29029 February 1988 Suffolk County First Set of Interrogatories & Request for Production of Documents to Lilco Re Hosp Evacuation.* Certificate of Svc Encl.Related Correspondence 1988-07-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
[Table view] |
Text
-- - - -- - -
+t:' $f '
RELATED COMMLSPONDtNGA .
@. March 6, ~1987 DSCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . ._,
T1 tuR 11 Pl2q2 DEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECf ETAFY 00CKETINfi & SEPVifE.
BRANC!!
In the Matter of )
)
LONG ISLAND LIGIITING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
- NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO FEMA AND 'THE NRC STAFF The NRC Staff hereby1 supplements its previous responses, dated -
February 17, 1987 - and March 2,1987, to "Suffolk County, State of New York and Town of Southampton's First Set of Interrogatories and Request ' for ' Production of Documents to FEMA and the NRC Staff" 4
(" Discovery Request").
i 4
I. RESPONSES TO INTERROGATORIES INTERROGATORY NO.1 i Lewis G. Hulman has been _ designated by the Staff to testify on the matters set forth in the Staff's response to Interrogatory No.1 of NRC Staff Supplemental Response to Intervenors' First Set of Interrogatories and Request for Production of Documents to FEMA and the NRC Staff, 4
dated March 2,1987.
Mr. Hulman replaces Mr. Soffer as a witness in this matter., and will be made available for deposition in piece of Mr. Soffer at the time and place - previously arranged for deposition of Messrs. I;antor and Soffer.
I B703130090 870306 g i DR ADOCK0500g2
,,,------,,,rw..,--- -,.--,,-,---------------_,..,-,,-----,-._c -
. . . . , . . . . - - . , - , - . - - - - , , - - , - ~ , - , - .
1
_g-D INTERROGATORY NO. 2
- Mr. Hulman's resume is attached to this response.
'INTERRCGATORY NO 3 Documents . which Mr. Hulman has identified to date as documents upon which he intends to rely are:
(1) Technical Guidance for Siting . Criteria Development, .
NUREG/CR-2239, SAND 81-1549, December 1982 (2) Demographic Statistics Pertaining to Nuclear Power Reactor Sites, NUREG-0348, October 1979.
(3) Calculations referenced in Testimony of Fred C. Finlayson and Edward P.
Radford, insofar as relevant, in this proceeding, Wednesday, July 11, 1984, pp.12317, et seq.
(4) Shoreham, DES, FES, and SER (5) Review and Evaluation of the Indian Point Probabilistic Safety Study, NUREG
/CR-2934, S AND82-2929, December 1982 (6) Reassessment of the Technical Bases for Estimating Source Terms, NUREG-0956 (Draft), July 1985
-(7) Sandia Report: Estimates of the Financial Consequences of Nuclear Power Reactor Accidents, David R. Strip ,
NUREG/CR-2723, SAND 82-1110, September 1982 (8) FES Related to the Operation of Limerick i Generating Station, Units 1 and 2, NUREG-0974, April 1984 (9) NUREG-0654-REP-1, Rev.1 (10) Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of 1
.- m -- , . - - - .,w.,_ -
--~,, ,--.-y,-,,,-__,, ,,r,,, ,%- , ,_._.,_r _.,._,,,-.._-n, ,_,_,.m,.-._ , _------_, . _ _ . - ,,_ _ , _ .., , , ,-._-.
7.,-
7-Light Water . Nuclear Power Plants, NUREG-0396, EPA 520/1-78-016, December 1978-INTERROGATORY NO. 4 Mr. Hulman testified in the Limerick,' Midland, and Byron
. proceedings on matters related .to accident analyses, accident risks, and accident consequences.
INTERROGATORY NO. 5 Mr. Hulman has not authored any documents within the scope of this interrogatory.
II. RESPONSES TO DOCUf.!ENT REQUESTS All documents identified in answers to the above interrogatories are available in the NRC Public Document Room.
l l
l Res cetfully submitted, 3 v [
rg , ohnson Counsel fo NRC Staff l Dated at Bethesda, f.faryland this 6th day of March,1987 l
.9
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matt'er of )
)
LONG -ISLAND LIGHTING COMPANY ') Dcchet No.1 50-322-OL-3
) (Emergency Planning)
(Shoreham . Nuclear Power Station, )
Udt 1) )
AFFIDAVIT OF LEWIS G. HULMAN I, Lewis G. Hulman , being duly sworn, do depose and state the following:
, 1. I am the Chief of the Plant Systems Branch , Divisien of Boiling Water Reactors, in the Office of Nuclear Reactor Regulation ,
1 U.S. Nuclear Regulatory Commission. A copy of my professional qualifications g attached to my affidavit.
- 2. I have provided supplemental answers to Interrogatories 1 through 5 contained in "Suffolk County, State of New York and Town of i Southampton's First Set of Interrogatories and Request for Production of o Documents to FEMA and the NBC Staff," filed .Tanuary 28, 1987.
- 3. The responses referred to above are true and correct "to the best of my personal knowledge and belief.
O Oudo ,
- A von Lewis G. Ilulman N Subscribed and sworn to before me this 6th day of March,1W
% )- .' YSA&Wu Notary' Public My commission expires: '7///9d
b rf .
LEWIS G. HULMAN PROFESSIONAL QUALIFICATIONS I am the Chief of the Plant Systems Branch, Division of Boiling Water i Reactors, in the Office of Nuclear Reactor Regulation. I was formerly the Chief of the Accident Analysis Branch, Chief of Systems Interaction
~ Branch and Chief of the Hydrology-Meteorology Branch, also both in the Office of Nuclear Reactor Regulation.
My formal education consists of study in Engineering at the University of Iowa where I received a BS in 1958, and an MS in Engineering Mechanics and Hydraulics in 1967. In addition, I have taken postgraduate courses at ' the University of Nebraska, MIT, Colorado State University, and the University of California, and numerous management, technical and computer utilization courses sponsored by the government.
My employment with NRC (formerly AI:C) dates from February 1971 with both the Office of Nuclear Reactor Regulation and the former Office of Reactor Safeguards, and for consultation on the siting of materials-utilization facilities. I have been responsible for the assessment of the potential for accidents resulting from natural phenomena, accident analysess, system performance under accident conditions, the generation and transport of fission and activation products within and outside nuclear power plants,- fire protection, health physics, plant systems, and the radiological consequences of accidental releases.
A scheduled reorganization of NRC has identified me as Chief of the
- Severe Accident Issues Branch in the Office of Research. This reorgani-zation is scheduled for implementation on April 12, 1987. My responsi-bilities under this reorganization will include resolution of severe accident issues , assessment of severe accident phenomenology, implementation of the Commission's Severe Accident Policy, accident consequences and source terms and analysis techniques, Safety Goal evaluation and l implementations, the development knd implementation of containment performance design objections, accident management analysis , and the agency technical focal point on emergency preparedness and siting I
rulemakings.
From November, 1985 until the reorganization, I have been Chief of
- l. the Plant Systems Branch, Division of Boiling Water Reactor Licensing, MRR. In this position I have been responsible for review of plant systems and environmental assessments. Included in the scope of l
responsibilities has been activities associated with fire protection, contain-
- ment and penetration leak testing, feedwater systems, radwaste j
- occupational and offsite exposures, fuel handling, flood protection, water l supply adequacy, accident analyses, generators, turbines, water i chemistry and environmental assessments of licensee proposalsc T have also been a participant in a staff initiative to identify potential i
improvements in boiling water reactor containments to improve their ability to mitigate the consequences of severe accidents.
-_~ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . . _ . _ . - _ . __. , _ _ _ _. ._, _ _ . -_ - - -
. . , -. - r ;
., r. ,
~ $
7 '
l From ' December, 1981 through November 1, 1985 I supervised the preparation of all the accident sections for draft and final Environmental, Impact Statements, Safety Evaluation Reports; and participated in the 1 staff's ' evaluation of Zion, Indian Point and Limerick and GESSAR standard plant design PR A's. In addition, I participate:d in the ..
development of the technical bases for safety guides, and standards, and ,
in research assessments.
From lifarch 1980 through mid-April 1981 I was employed in private' industry as a Vice President with ' Tetra Tech, Inc. in Pasadena, L California. During this period I was responsible for busineri development, and for managing several contracts involving various engineering studies. including several contracts " for government and industry. Of note were studies of a nuclear power plant in Yugoslavia for the International Atomic ; Energy A gency, risk and risk aversion studies in the Dominican RepuMic, is refinery intako desfrn in Indonesia, and Hurricane risk assessments in Texas, North Carol! Iia, Florida, and
- New Jersey. ,
From 1968 to 1971, I wcs a ' hydraulic Engineer with the Corps of Engineers' Hydrologic Engineering Center in Davis, California, where I worked as a consultant for 1most Corps' offices, participated 'zy an instructor in training courses, aind conducted research.
~
From 1963 to 1968, I .was a Nupervisory IIydraulic Endneer with the
- Philadelphia District, Coirps of Engineers. As Assistant - Chief of the Hydrology Branch, I wsn responsible for design espects of multi-purpose
. dams, navigation projects, coastal engineering de relopment and special studies on modeling of dams, inlets, water supply, and shoaling, . salt u water intrusion, andtthe effects '6f dredging.
From 1958 to 1963, ~ I ..was a Ilydraulic Enginar with the Omaha Dietrict of the Corps of Engineers. I was responsible for the hydraulic design of flood control channels, hydraulic design of structures for large dams and several flood control projects. I also received training in, probabilistic . -
i assessments, hydrologic engineering, structural engineering, sedimentation, river training studies and design , and water resource project formulation.
l , .
I I have published in journals or periodicals of the American Society of Civil Engineers, the American Water Works Association, the Journal of Marine Geodesy, the National Society of Professional Engineers , the 1 American Gecphysical Union , Physics Magazine, the American . Nuclear l Society and in internal technical papers and semirar proceedings of tho l Corps of Engineers, the AEC, and the NRC.
i I am a registered Professional Engineer in the States of Nebraska and /
California. I am a member .of the American Society of Civil Engineers, i the American Meteorological Society, and the American Gecphysical Union.
l l
l i
- , , - , _ _ -. - , _ - . . _ , J....~_.-_._--.. ~?
F""f,1 y y
- u. w x -
.=
,j$ }V A- I
, . UNITED STATES OF AMERICA 00LMETED z/ NUCLEAR REGULATORY COMMISSION USNRC lf "
' BFFCBE THE ATOP'M SAFETY AND LICENSING BOED HAR 11 Pl2:12 e
OFFICE OF SECEETAnY
-In the Matter of- ) SOCKETING & SEltvicf.
2
. ) .
BRANCH A LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
^ ,(Shorchum Nuclear Power Station, )
Unit 1) )
3.
CERTIFICATE OF SERVICE
'I' ilereby certify that coIies S of "NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND
-PUQUEST FOR PRODUCTION OF DOCUMENTS TO- FEMA AND THE NRC -
STAFF" in . the - above-captioned proceeding have been served on 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 mail system this 6th day of March 1987:
.Morton B. Margulies, Chairman * - Joel Blau, Esq.
pdministrative Judge . Director, Utility Intervention
- ntomic Safety and Licensing Board Suite ~1020 U.S.- Nuclear Regulatory Commission- 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 X . Jerry R. Kline* Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor
' Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear P.egulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 I .'
t
- . Frederick J. .Shon* Jonathan D. Feinberg, Esq.
Administrative Judge New York. State Department of a Atomic Saf'ety and Licensing Board Public Service
.U.S. Nuclear Regulatory Commission Three Empire State Plana Weahington, DC 20555 Albany, NY 12223 Philip ftcIntire W. Taylor Reveley III, Esq.
Federal Emergency Management Donald P. Irwin, Esq.
Agency - Hunton a Williams
. 126 Federal Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY' 10278 Richmond, VA 23212" Douglas J. Hynes. Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 i
i ..
F
'l
s., 1
- .u
< o jq
-y f g ,
-L1 1
Stephen B. Latham, Esq. Herbert H. Brown, Esq.
Twomey, Latham a Shea - Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
- 33 West Second Street Kirkpatrick & Lockhart Riverhead, NY 11901 4 South Lobby .- 9th Floor 4 > 1800 M Streeti NW Atomic Safety and Licensing h
s U.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 20555
+ Spence W. Perry, Esq.
Martin Bradley Ashare, Esq. General Counsel Suffolk County Attorney Federal Emergency Management H. Lee Dennison Building Agency ; ,
Veteran's Memorial Ifighway 500 C Street, SW l Hauppauge, NY ' 11788 Washington, DC 20472 i
Dr. ' Monroe .3chneider , Robert Abrams, Esq.
North Shore Committee Attorney General of the State P.O. Box 231 of New York Wading River, NY 11792 Attn: Peter Bienstock, Esq.
Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center
< 195 East Main Street Room 46-14 Smithtown, NY ~ 11787 New York, NY 10047
- i Anthony F. Earley, Jr. William R. Cumming Esq.
General Counsel Office of General Counsel Long Island Lighting Company Federal Emergency Management i 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW Washington, DC 20472 Dr. Robert Hoffman s Long Island Coalition for Safe Docketing and Service Section*
Living , Office of the Secretary P.O. Box 1355 , ! U.S. Nuclear Regulatory Commission
( Massapequa, NY 11758 Washington, DC 20555 <
Mary M. Gundrum, Esq. Barbara Newman New York State Department of Law Director, Environmental Health 120 Broadway Coalition for Safe Living 3rd Floor, Room 3-116 Box 944
- New York, NY 10271 Huntington, New York 11743
/ . c-t i J%
<Ccorge E.' Jolynson Counsel for)1RC Staff
. . . . . _ _ . . - - . - . . - - - - - _ . . .- - . -.-_-__ - .- - - - -