ML20080C702
| ML20080C702 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/25/1983 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080C704 | List: |
| References | |
| ISSUANCES-OL-3, NUDOCS 8308290165 | |
| Download: ML20080C702 (2) | |
Text
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8/25/83 00CMETED USN#.C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION,83 Am 26 A10 53 Before the Atomic Safety and Licensing Board r
c.-e e e:
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-2
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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SUFFOLK COUNTY MOTION TO COMPEL PRODUCTION OF WITNESS AND DOCUMENTS RELATING TO SHOREHAM OFFSITE CONSEQUENCE ANALYSIS Pursuant t.o 10 CFR Section 2. 740 (f), Suffolk County hereby moves the Board to compel LILCO to (a) produce Thomas E.
Pot-ter to be deposed on the subjects of the radiological consequences of an accident at Shoreham and the Shoreham offsite consequence analysis he and Pickard, Lowe & Garrick have performed for LILCO; and (b) produce documents related to the same subjects in'* response to the County's informal interrogatories and requests for production of documents.
Counsel for the County and LILCO have been unable to re-solve this discovery dispute informally.
By agreement of the parties and due to time constraints, the County is filing this l
Motion prior to LILCO's formal request for a protective order.
In light of the discovery schedule set by the Board in its j
Special Prehearing Conference Order of August 19, 1983, it has f
been necessary to notice Mr. Potter's deposition for Wednesday, 8308290165 830825 PDR ADOCK 05000322 Q
PDR l
TSD$
August 31.
Also, within the limits of that schedule it would be most difficult, if not bnpossible, to change the date of Mr.
Potter's deposition.
Accordingly, Suffolk County requests that the Board rule as expeditiously as possible on this matter --
if possible before the end of the week -- and, if necessary, obtain the oral views of the parties by conference call.1/
The grounds for this Motion are set out in detail in the accompanying Memorandum.
Respectfully submitted, David J.
Gilmartin Patricia A.
Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 imw Herbert H.
Brown f
Lawrence Coe Lanpher Karla J.
Letsche KIRKPATRICK, LOCKHART, HILL CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Attorneys for Suffolk County August 25, 1983 l
1/
A copy of this Motion and accompanying Memorandum have been provided today to LILCO's counsel by telecopier, and LILCO's counsel is aware of our request for an expeditious Board ruling by way of conference call.
LILCO counsel re-quested the County state that LILCO requests an opportuni-ty to review the County motion for a reasonable period prior to any conference call.
Accordingly, if the Board desires to schedule a conference call, the County suggests l
that it take place sometime on Friday, August 26.
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