ML20086R863

Interrogatories to Suffolk County & State of Ny Re Identification of Expert Witnesses at Trial Concerning Diesel Generator Contentions.Certificate of Svc Encl.Related Correspondence

ML20086R863
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/27/1984
From:	Twana Ellis HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF, SUFFOLK COUNTY, NY
References
ISSUANCES-OL, NUDOCS 8403010242
Download: ML20086R863 (5)

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,1 p RELATED CORRESPONDENCQ

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.g4 gg 29 RQI$O, February 27, 1984 CFFICE.0F SEL/p)$gi NUCLEAR REGULATONT'fMERICAUNITEDST Before the Atomic Safety and Licensing Board In the Matter of )

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

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(Shoreham Nuclear Power Station, )

Unit 1) )

INTERROGATORIES TO SUFFOLK COUNTY AND THE STATE OF NEW YORK TO: Herbert H. Brown, Esq.

Lawrence Coe.Lanpher, Esq.

Allan R. Dynner, Esq.

Kirkpatrick, Lockhart, Hill, Christopher & Phillips 8th Floor 1900 M Street, N.W.

Washington, D.C. 20036 Counsel for Suffolk County Fabian G. Palamino, Esq.

Special Counsel to the Governor Executive ~ Chamber Room 229 State Capitol Albany, New York 12224 Counsel for State of New York

Long Island Lighting Company,(LILCO), by counsel,

. pursuant.to Section 2.740(b) of the Regulations of.the Nuclear

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.0 Regulatory Commission propounds the following interrogatories which shall be answered separately by Suffnik County and the State of New York. These interrogatories shall be deemed continuing.

1. Identify.each person whom Ouffolk County or New York State intends to call as an expert witness at the trial concerning the diesel generator contentions admitted by the Board in this proceeding on February 22, 1984 and for each such expart identified, state the following:

(a) his present employment or position; (b) his address (c) all educational and professional qualifications which qualify him to render any expert opinion; (d) the subject matter on which he is expected to testify; (e) the substance of his testimony; (f) the bases for all opinions and other testimony he.iu expected to give; and (g) a description of the purpose for which he was employed and the tasks, studies, analyses or examinations which he

! has conducted or intends to conduct prior i

to or incident te expressing any testinony in this. proceeding, the status of all such (l. tasks, studies, analyses or examinations and when they are expected to be completed.

2. Identify all other witnesses whom Suffolk County or-the State of New York expects 'o c call at the trial of the j!:

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diesel geneia' tor' contentions admitted by the Board on February 22, 1984, not identified ~in answer to Interrogatory No. I above,Eand for each such witness, state the following

. (a) his present position or employment; (b) his address; (c.). the nature and expected substance of-his testimony.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

/

r ,' , / /*/, [j, g ErS..lE lis,,kflI Antho 'Ff Earley, Jr.

Hunton & Williams

. Post Office-Box 1535-

- Richmond, Virginia 23212 4

DATED: . February 27, 1984 Y

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_ LILCO, February 27, 1984 I

CERTIF1CATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY

'(Shoreham Nuclear Power Station, Unit 1) r DockettNo. 50-322 (OL)

I hereby certify that copies of Interrogatories to

-Suffolk County and the State of New York were served this date

-.upon the following by first-class mail, postage prepaid, or by hand as: indicated by an asterisk:

i Lawrence-Brenner, Esq. Secretary of the Commission

- Administrative Judge U.S. Nuclear Regulatory Atomic _ Safety and Licensing Commission-

. Board Panel Washington, D.C. 20555 U.S. NRC-4350 East-West Highway Atomic Safety and Licensing

Fourth Floor 1(North Tower)

~

Appeal Board Panel f LBethesda, Maryland 20814)- U.S. Nuclear Regulatory Commission Dr. Peter A.~ Morris Washington, D.C. 20555

- Administrative Judge

~ Atomic Safety and Licensing Atomic Safety and Licensing

' Board Panel Board Panel U.S. NRC U.S. Nuclear Regulatory i4350 East-West Highway- Ccmmission Fourth Floor (North-Tower) Washington, D.C. 20555 Bethesda, Maryland 20814 Robert E. Smith, Esq.

Ihr. George A. Ferguson Guggenheimer & Untermyer-ic ,

Administrative Judge 80 Pine Street Pr ,

School.'of Engineering New York,-N.Y. 10005

-Howard' University 2300. 6th Street,: N.W.

Washington, D.C. 20059-s

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.o Bernard'M.'Bordenick,'Esq. Martin Bradley Ashare, Esq.

David A..Repka, Esq. Attn: Patricia A. Dempsey, Esq.

U.S. NRC .

County Attorney Maryland National Bank: Bldg. Suffolk County Department of Law 7735 Old Georgetown Road Veterans Memorial Highway l- Bethesda, Maryland 20814 Hauppauge, New York 11787 Herbert H. Brown,-Esq. . Stephen B. .Latham, Esq.

Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Alan-R. Dynner, Esq.* 33 West Second Street Kirkpatrick, Lockhart, Hill, P. O. Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor 3500 M Street, N.W. Ralph Shapiro, Esq.

Washington, D.C. 20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Marc W. .Coldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, Esq.

Waltham,. Massachusetts 02154' 3045 Porter Street Washington, D.C. 20008 MHB Technical Associates

.1723 Hamilton Avenue Howard L. Blau

-Suite K 217 Newbridge Road San Jose, California -95125 Hicksville, New York 11801 Mr. Jay Dunkleberger , Jonathan D. Feinberg, Esq.

New York State Energy Office New York State -

Agency Building 2 Department of Public Service Empire. State Plaza Three Empire State Plaza Albany, New1 York 12223 Albany, New York 12223 Fabian G. Palam1no, Esq.

-Special Counsel to the Governor.

Executive Chamber, Room 229 State Capitol Albany, New York 12224

/, l T. Sf)E:l%4#,F I fl c v Hunton & Williams 707 East Main Street P.O. Box-1535.

Richmond, Virginia 23212 DATED: FebruaryL27, 1984