ML20148J136

Advises That Affidavits of Fr Jones,Gj Blass,Fp Petrone & Fg Palomino Filed on 880119 W/Suffolk County,State of Ny & Town of Southampton Response in Opposition to Lilco Motion. Encl Original Signature Pages Being Filed Today

ML20148J136
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/20/1988
From:	Lanpher L KIRKPATRICK & LOCKHART
To:	Gleason J, Kline J, Shon F Atomic Safety and Licensing Board Panel
References
CON-#188-5407 OL-3, NUDOCS 8801270365
Download: ML20148J136 (5)

Text

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• 4 5%7 KIRKPATRICK & LOCKHART SOUTH LOBBY 9TH FLOOR ygg ExcHANcsrtAct 1800 M STREET, N.W. U sTATt m WASHLNGTON, D.C. 200M 5891

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Tttzcanta aco rma 00CKEllNG A Sl#Gaautam 3R AHCettr$8ULOH, PA Hm4m LAWRENCE CoE LANPHER ("D 3NW CO2) 77$9011 January 20, 1988 James P. Gleason, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket No. 50-322-OL-3

Dear Members of the Board:

The affidavits of Frank R. Jones, Gregory J. Blass, Frank P.

Petrone, and Fabian G. Palomino were filed yesterday with the "Suffolk County, State of New York, and Town of Southampton Response in Opposition to LILCO's Motion for Summary Disposition of Contentions 1-10 With Respect to 10 CFR 9 50.47(c)(1)(i) and

, (ii)." The original signature pages were not filed yesterday.

The original signature pages are being filed today, via copy of this letter, with the Docketing and Service Section.

Sincerely, 4t@M Lawrence Coe Lanpher Enclosures cc: Donald P. Irwin, Esq.

I George E. Johnson, Esq.

William R. Cumming, Esq.

Fabian G. Palomino, Esq.

Stephen B. Latham, Esq.

Docketing and Service Section 8801270365 ADDCK BB $22 PDR PDR 'h G U' J

and belligerency against the County. LILCO's conduct not only lacks good faith toward the County, it is marked by repeated acts of bad faith, f

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~( dp e ) ' / E'r a jfk . Jones Sworn before me this

day o January 19 in the State of New York.

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13. Many other examples could be cited from the period 1982 to the present, which would demonstrate that LILCO has not engaged in a sustained good faith effort to secure and retain Suffolk County participation in emergency planning. Rather, LILCO has engaged in hostile, deceitful activities on a continu-ous basis that have not manifested good faith.

Subscribed to before me this /C)l day of January 1988.

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My Commission expires:

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(Notary Public)

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2. I have reviewed LILCO's December 18, 1987 Summary Disposition Motion concerning 10 CFR S 50.47(c)(1)(1) and (ii).

LILCO asserts therein that it has made a sustained good faith effort over-the years to secure and retain the participation of Suffolk County and the State of New York in emergency planning for Shoreham. The purpose of this affidavit is to state that during 1987, the period of which I have personal knowledge as a Suffolk County official, LILCO made no effort, let alone a good faith one, to secure the County's participation.

3. The LILCO Summary Disposition Motion contains no facts related to any alleged LILCO effort in 1987 to secure the participation of the Suffolk County government in emergency planning for Shoreham. As the Shoreham coordinator in the Suffolk County Executive's office, I would have been informed if LILCO had made such an effort. I recall no such effort by LILCO during my tenure in Suffolk County government.

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JAM IT 17W \

(Date)' tg j/ Prank P. Petrone Duly sworn before me this l-l day of January, 1988, in hIJ , ' Pni I - '

, New York.

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11. In conclusion, it is my opinion that LILCO has made no sustained good faith effort to secure the participation of New York State in emergency planning for Shoreham.

t Subscribed to before me this f .l ' day

' of January 1988.

/* A t; Fablan G. Palomino

, My Commission expires //!30fM (date)

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