ML20076D295

Request for Production of Documents Re Emergency Response Plan.Certificate of Svc Encl

ML20076D295
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/19/1983
From:	Birkenheier J KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
Shared Package
ML20076D288	List: ML20076D286 ML20076D292 ML20076D295
References
NUDOCS 8308230336
Download: ML20076D295 (6)

Text

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UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION USNRC Before the Atomic Safety and Licensing B03rd!JG 22 A10:07 0FFICE OF SEC%iAn v 00CKETING & SERvig'

) BRANCH In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

)

(Shoreham Nuclear Power Station, )

Unit 1) ) ,

)

SUFFOLK COUNTY REQUEST FOR PRODUCTION OF DOCUMENTS BY LONG ISLAND LIGHTING COMPANY Pursuant to 10 CFR S2.741, LILCO is requested by Suffolk County to produce for inspection and copying, at the offices of Kirkpatrick, Lockhart, Hill, Christopher & Phillips, the documents specified below that are within the possession, cus-tody, or control of LILCO.

Definitions and Instructions For Document Production The definitions and instructions applicable to these Re-quests are the same as those set forth in Suffolk County Interrogatories to Long Island Lighting Company, filed simulta-neously herewith, and hereby incorporated by reference, except that subparts L through P, and W, of such Definitions and Instructions are not applicable to these Requests.

8308230336 830819

{DRADOCK 05000322PDR

Requests

1. Provide a copy of the mailing list or lists for LILCO's

" Keeping Current" newsletter.

2. Provide copies of all documents, other than those already provided, concerning the preparation of the LILCO Transi-tion Plan and any revisions thereto.

3. Provide copies of all documents concerning evacuation time estimates, traffic congestion or conditions, roadway capacities, public mobilization, and evacuation headways in the event of a radiological emergency at Shoreham, other than those identified in the index of documents available for review at KLD, provided by counsel for LILCO on August 10, 1983.

4. Provide an up-to-date resume of, and all studies, papers, articles, reports, books, and other such documents, published or unpublished, concerning emergency planning, authored or prepared by, each of the persons LILCO intends to call as a witness, including those identified in re-sponse to Suffolk County Request 1 of July 18, 1983.

5. Provide copies of all remarks or statements, read as part of LILCO's presentation to Governor Cuomo's Shoreham Commission at the Commission's hearing on June 28, 1983, other than the presentation by Matthew Cordaro.

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6. Provide copies of all training materials, and procedures,

, manuals or other materials used by LILCO or its employees

! in preparing for, or responding to, non-nuclear emergencies.

7. Provide copies of all documents that were or are intended i to be distributed to LILCO personnel subsequent to February 1,-1982, concerning emergency planning at Shoreham, including, but not limited to, documents con-cerning participation of LILCO employees in offsite emer-gency planning, LERO, or LERO training.

8. Provide copies of all documents concerning Reuben Goldblatt's derivation of estimated route times for evacu-ation buses, including documents upon which such estimates were based.

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9. Provide copies of all documents analyzing, studying, evaluating or otherwise concerning the notification and evacuation of elderly and handicapped persons within the EPZ.

l 10. Provide copies of LILCO's agreements with' Texaco and Agway referred to in LILCO's response to Suffolk County Request 32 of July 18, 1983, and provide copies of all documents l concerning either or both of those agreements.

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11. Provide copies of all communications between LILCO and the New York Telephone Company concerning services relating to emergency preparedness at Shoreham.

32. In its response to Suffolk County Request 94 of July 18, 1983, LILCO referred to " documents relied on in prepara-tion of Appendix A." Identify such documents, and provide copies.

13. Provide copies of all " periodic newsletters mailed to the entire EPZ population" subsequent to February 1, 1982.

(See response to first NSC Request 10).

Respectfully submitted, Dated: August 19, 1983 David J. Gilmartin Washington, D.C. Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 B,h -

Kar)% J. Letsche Christopher M. McMurray John E. Birkenheier KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County

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. O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 000KETED USNPC Before the Atomic Safety and Licensing Board <

l

'83 NJG 22 A10:08

)

In the Matter of ) 0FFICE OF SEcq mg

) 00CMETinG r LONG ISLAND LIGHTING COMPANY ) Docket No. 58AS%srgygg g

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County Interrogatories to Long Island Lighting Company and Suffolk County Request for Production of Documents by Long Island Lighting Company have been sent to the following this 19th day of August, 1983 by U.S. mail, first class, except as otherwise noted:

James A. Laurenson, Chairman Ralph Shapiro, Esq.

Atomic Safety aid Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D.C. 20555 New York, New York 10016 Dr. Jerry R. Kline *W. Taylor Reveley, -III, Esq.

Atomic Safety and Licensing Board Hunton & Williams U.S. Nuclear Regulatory Commission P.O. Box 1535 Washington, D.C. 20555 707 East Main Street Richmond, Virginia 23212 Mr. Frederick J. Shon Atomic Safety and Licensing Board Stephen B. Latham, Esq.

U.S. Nuclear Regulatory Commission Twomey, Latham & Shea Washington, D.C. 20555 33 West Second Street Riverhead, New York 11901 David J. Gilmartin, Esq.

Suffolk County Attorney Docketing and Service Section H. Lee Dennison 3uilding Office of the Secretary Veterans Memorial Highway U.S. Nuclear Regulatory Commission Hauppauge, New York 11788 Washington, D.C. 20555 Bernard M. Bordenick, Esq. Eleanor L. Frucci, Esq.

David A. Repka, Esq. Atomic Safety and Licensing O.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U. S. Nuclear Regulatory Commission Washington, D.C. 20555

• By Federal Express

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. o Nora Bredes Stewart M. Glass, Esq.

Executive Director Regional Counsel Shoreham Opponents Coalition Federal Emergency Management 195 East Main Street Agency Smithtown, New York 11787 26 Federal Plaza, Room 1349 New York, New York 10278 MHB Technical Associates 1723 Hamilton Avenue James B. Dougherty, Esq.

Suite K 3045 Porter Street, N.W.

San Jose, California 95125 Washington, D.C. 20008 Qu Ra(L -

John t. Birkenheier KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 DATED: aaarf/CY /*183 U '

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