ML20080D550
| ML20080D550 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/06/1984 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080D538 | List: |
| References | |
| ISSUANCES-OL-3, NUDOCS 8402090157 | |
| Download: ML20080D550 (8) | |
Text
._
LILCO, February 6, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
Before the Atomic Safety and Licensing Board 7
In the Matter of-
)
)
LONG TSLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning (Shoreham Nuclear Power Station, )
Proceeding)
-Unit 1)
)
LILCO'S REQUEST FOR EXPEDITED PRODUCTION OF DOCUMENTS LILCO hereby requests.that New York State produce the fol-lowing documents:
1.
The complete listing of documents prepared in response to a New York Freedom of Information Act request by~the Town of Southampton.
Pages 5 through 9 of this listing are attached to the " Comments of the Town of Southampton on the Proposed Rules and Procedures for the Disaster Preparedness Commission Under Notice, dated July 2, 1983" (August 24, 1983) filed with the DPC, and are attached hereto; and 2.
A copy of each and every document referred to in the listing described in item 1 above.
I These documents-describe New York State's review of LILCO's offsite radiological emergency response plan.
As such, i
they are central to an understanding of the testimony to be filed by New York State witnesses on March 2, 1984 and are also 8402090157 840206 PDR ADOCK 0500032g Q
f
. j central to LILCO's ability to conduct fruitful discovery of l
those proposed witnesses between now and February 17.
In view of their importance, the imminence of the time at which they 4
will be needed, and the fact that they have already been iden-tified, physically examined and inventoried by the Sia'e of New York, LILCO requests that these documents be produced.'medi-ately, and in any event no later than February 8.
LILCL will, of course, pay all reasonable copying-fees for reproduction of these documents.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY By
's
" Donald P.
Irwin HUNTON & WILLIAMS 707 East Main Street P.O.
Box 1535 Richmond, Virginia 23212 DATED:
February 6, 1984
Attachment:
Pages 5 through 9 of document listing attached to Town of Southampton's Comments dated August 24, 1983, covered by a letter from John F.
Shea, Esq.,
August 23, 1983.
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TWOMEY. LATHAM & SHEA ATTOmteEYS AT LAWF 33 WEST SSCOng 4TREET l
p O. eOs see alVERHEAD. Msw YORK 21901 9,eOmAs A TwOwev. Ja.
9 NORTw MAIN STREET STgpMEN S LATHAM 3AST MAwpTON. N v.11937 JoseN F. S:45 A. HI stSi m 3100 Stel 3441800 WOSSWT D PfEE cmaisTOPasa o. usu.sv August 23, 1983 Mr. James A. Bertan Department of Health Bureau of Management Services ESP Tower Builoing Room 1009 Albany, New York 12237 New York State Disaster Preparedness Re:
Commission Rules and Procedures D6ar Mr. Bertant our firm is special counsel to the Town of On behalf of Southampton, we are submit-Soutnampton.
ting with this letter comments on the proposed rules and procedures for the Disaster Preparedness Commission, which were issued earlier this summer for public com-ment.
Sincerely, e
A JfhnF.Shea, III JFSalam Enclosure EXPRBSS MAIL DCen h a L Cjy{}
a va u,.,,
C U ANAGlVE 1:.t.ngcgg hYs DEPT.at HEALTH
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f _-_-_-______ -__ ___ _. _ ~ 7 ~ ~~~ ~ ' ^
letter to Cordaro from Hennessy with attachment 6/8/82 (review of Shoreham plan) letter to Trunto from Davidof f with attachment 6/11/82 (letter of 5/17/82 to Davidof f from Trunso) letters from McQueen to various persons various dates letter to Pachman from Mennessy 7/29/82
" Analysis of Shoreham Offsite Emergency Plan" 6/1/82
" summary of Comments' on Sections A, C, and J of undated the Shoreham-suffolk County Off-site Plan" letter from Hennessy to Wolosin 5/26/82 5/17 and 19/82 legislative contact reports letter to Cordaro from Hennessy with attachments 5/17/82 (letter of 5/10/82 from Cordaro to Hennessy) meno to stasiuk from Davidoff 5/17/82 handwritten notes 5/14/82 press release, statement by Governor Cuomo 4/19/83 and 5/16/83 The following materials may be responsive documents, but York state they are being withheld on the grounds specified. The New 3)
Disaster Preparedness Commission and/or the New York State Department of Health reserve the right to amend l
l Mr. M111ock, Mr. Phillips and Mr.
l exemptions or objections.
Zahnleuter are attorneys employed by the State who func l
attorneys.
referenced by the following code system refers to inter-agency materials which are not:
1)
"A" statistical or factual tabulations or datas (i) instructions to staff that affect the public, or (ii) final agency policy or d'eterminationst (iii) m
[\\s
-u-refers to intra-agency material which are nots 2)
"B" statistical or factual tabulations or data:
(i) instructions to staf f that af fect the public, er I
(ii) f final agency policy or determinations (iii) refers to material prepared for litigation; 3)
"C" 4)
"D" refers to attorney work product refers to" materials protected by attorney-client privilege.
5)
"E" DATE DOCUMENT transmittal slip to Axelrod/DPC from Davidoff/DPC 4/26/83 with two attachments (" suggested questions for handwritten note from Stasiuk/ panel" and a consideration by the Shoreham DON to Axelrod/DPC concerning questions which should be these materials contain preliminary emphasized):
suggestions, recommendations opinions, conjecture and deliberations pertaining to the consequence 9 of radioactive materials releases, A, 8.
document is being released but portion containing 4/26/83 opinion, conjecture and beliefs concerning possible Atomic Safety and Licensing Board decisions is being redacted, A, S.
non-final, draf t, working copy of essay headed by t
undated "this memorandum summarizes the recent events concerning the Shoreham Nuclear Power Station.",
A, B.
working copies of a letter to non-final, draf t, stampo received the New York Times concerning a 2/27/83 editorial 3/11/83 Shoreham, A, B.
re:
meno to Millock/ DOM from Davidoff/DPC concerning 3/4/83 a draft reply to Brenner's 3/28/83 meno, with attachment (draft, non-final response dated 3/3/83) this is deliberative material, A, B, E.
memo to Axelrod/DPC from Millock/ DOM concerning 3/7/83 resolution of Cohalan v. New York State Disaster Preparedness Commission with attachments (draft, non-final working copy of a stipulation of F
dicontinuance)' A, B, C, D, E.
.q.
a 2/23/83 meno from Millock/DOH to Axelrod/DFC con erning events pertaining to Shoreham, A, B, C, D, E.
1/19/83 meno to Castellano/DPC from Davidoff/DPC is being released but portion pertaining to interpretation and opinion of the hearing and news coverage is being redacted, A, B.
2/16/83 meno to Axelrod/DPC from Millock/DOH concerning failure of suffolk County to prepare a response plan, A, B, C, D, E.
2/11/83
'meno from slocum/ DON to Axelrod/DPC concerning an editorial written by M. Patterson in Newsday on 2/7/83: this memo contains opinions, conjecture, evaluations, recommendations and deliberative material, A, B.
1/30/82 meno to DPC members fr.om Davidoff/DPC transmitting DPC's staff's review of the adequacy of LILCO's plant this meno contains non-final, opinions, conclusions, evaluations and recommendations by staff which have not been acted upon the the DPC memberst these documents constitute deliberative materials: attachments are an excerpt from NUREG-0654 and a completed review sheet, A, B.
undated non-final, draft working copy of a DPC resolution pertaining to shoreham and associated planning, A, B.
12/6/82 non-final, draft, working copy of a DPC press release concerning proposed 12/8/82 DPC meeting, f
A, B.
various dates drafts of Hennessy's letter of 11/29/82 to i
Cohalan, A, B.
11/24/82 meno from Czech /DPC to Davidoff/DPC containing non-final, preliminary advisory comments, opinions, evaluations, beliefs, conjecture and deliberative material pertaining to the adequacy of LILCO's plan, A, 8.
11/23/82 meno from Czech /DPC to Davidoff/DPC containing same subject matter as~ described directly above, A, B.
e l
I
l
-s-11/19/83 meno to Czech /DPC from Clemente/DPC containing same subject matter as described directly above for 11/24/82 meno A, B.
11/15/82 memo to " Larry"/DPC from " Jim P."/DPC containing same subject matter as described above for 11/24/82 meno, A, B.
11/9/82 draft, non-final working copies of letter to Cohalan from Hennessy, A, B.
10/25/82
,meno to Czech /DPC from Lowery /DPC containing same subject matter as described directly above for 11/24/82 meno, A, B.
9/16/82 meno to Czech /DPC from Clemente, same as 11/24/82 meno A, B.
9/15/82 meno to Dillenbeck/DPC from Albertin/ DOT, same as 11/24/82 meno, A, B.
9/13/82 meno to Davidoff/DPC from Czech /DPC, same as 11/24/82 meno, A, B.
9/8/82
'meno to Czech /DPC from Popile/DPC, same as 11/24/82 meno, A, B.
7/23/83 darft, non-final letter from Hennessy to Pachman.
5/18/82 meno from Phillips/DOH to Millock/DOH concerning legal issues pertaining to LILCo's plan, A, B, D, E.
5/17/82 meno to "REPG Staf f" from Davidof f concerning assignments for Shoreham plan review, A, B.
11/30/82 meno to DPC members from Davidoff/DPC containing non-final, preliminary advisory comments, opinions, evaluations, beliefs, conjecture and deliberative material pertaining to the adequacy of LILCO's plan, A, B.
7/18/83 meno to Davidof'f/DPC from Zahnleuter/ DOM advising of the applicable comment period for regulations, A, B, D, E.
e o
e
- i,
7/1/83 meno to Aberaathy/DOH from Duncan/DOH circulating for internal review proposed, draf t, regulations and regula':ory impact statement, this is deliberative material, A, B.
6/27/83 meno to Taylor / DOM from M111ock/ DOM transmitting a revised, proposed regulation transmittal form for further internal review, this is deliberative material, A, B, D, E.
6/20/83 meno to Millock/ DON from Bahnleuter/ DOM with
, attachments (rating sheet for "shoreham Offisite Emergency Plan" and pages 31-79 of an unidentified document) circulating non-final, draft, proposed regulation _ transmittal form for internal review, this is deliberative material, A, B, D, E.
5/17/83 meno to Millock/ DON from Eahnleuter/ DON
, discussing and identifying several possible modifications of proposed regulation transmittal form, this is deliberative material, A, B, D, E.
5/11/83 slip from slocum/DOH to Duncan/ DOM expressing comments on proposed regulation transmittal form, this is part of the internal review process and is deliberative material, A, B.
4/29/83 meno to Millock/ DON from Zahnleuter/ DON requesting comments and opinions concerning draft proposed regulation transmittal form, this is part of the internal review process and is deliberative material, A, B, D, E.
4/29/83 same as meno directly. above,'but containing handwritten comments, A, B, D, E.
l 5/18/83 meno to Duncan/ DON from Holohean/ DOM expressing comments on proposed regulation transmittal form, this is part of the internal review process and is deliberative material, A, B.
undated handwritten meno from Millock/ DOM to Axelrod/DPC/ DON concerning possible contents of the proposed draft regulations, this is deliberative material and part of the internal review process, A, B, D, E.
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