ML20148Q986

Forwards Documents Responsive to Suffolk County First Set of Interrogatories Re Buses & Recruitment of Lero Emergency Workers as School Bus Drivers.Certificate of Svc Encl

ML20148Q986
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/25/1988
From:	Leugers M HUNTON & WILLIAMS
To:	Mark Miller KIRKPATRICK & LOCKHART
References
CON-#188-5439 OL-3, NUDOCS 8802020020
Download: ML20148Q986 (5)

Text

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Mr. Michael S. Miller Kirkpatrick & Lockhart South Lobby - 9th Floor 1800 M Street, N.W.

Washington, D.C. 20036-5891 Documents Responsive to Suffolk County's Request for Production

Dear Mr. Miller:

I have enclosed all documents responsive to Suffolk County's First Set of Interrogatories and Request for Production of Docu-ments to LILCO and a descriptive list of all privileged documents not produced. In addition, without waiving objections made in LILCO's Response, I have enclosed documents concerning buses, the recruitment of LERO-emergency workers as school bus drivers, and job specific training for LERO school bus drivers. I have not produced, however, any documents about general LERO or Class 2 license training. Thus far, planning for job specific training of LERO school bus drivers has just begun.

I have also withheld documents memoralizing LILCO's recent contacts with school districts discussing the release of Revision 9 of the Plan. Following, however, is a list of the schools and school districts contacted along with the dates of those con-tacts.

1. North Shore Christian School January 19

2. Infant Jesus School January 20

3. St. Isidore School January 20

4. BOCES I January 21

5. BOCES II January 21 i

6. Comsewogue UPSD January 19, 20 l

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H UNTON Sc WI LLI AM S Mr. Michael S. Miller January 25, 1988 Page 2

7. Longwood Central SD January 19, 20, 21, 22

8. Miller Place UPSD January 19

9. Mount Sinai UFSD January 20

10. Patchogue-Medford UPSD January 20

11. Port Jefferson UFSD January 20

12. Riverhead Central SD January 20

13. Shoreham-Wading River Central SD January 19

14. South Manor UFSD January 20 The purpose of these contacts was to inform each school and school district that Revision 9 of the LILCO Plan was being re-leased and that they were included in the plan and to see if they had any questions or concerns about LILCO's plans. The contacts were made by the LERIO staff. LILCO objects to the production of these documents, and any other documents concerning LILCO's con-tacts with schools and school districts, because revealing these contacts would greatly hinder LILCO's planning efforts with these schools and school districts and because it could subject LILCO's contacts to harassment and intimidation. Letters sent to the schools and school districts about Revision 9 will be produced later this week.

Furthermore, LILCO does not produce with this letter por-tions of LILCO's plan and procedures concerning school bus driv-ers since all parties were served with Revision 9 of the Plan on January 22, 1988.

Pursuant to our conversation earlier today, LlLCO's witness-es will be made available for deposition according to the follow-ing schedule:

Dr. Dennis Mileti February 3, 12:00 noon (Wash. D.C.) ,

Dr. Michael Lindell February 4, 1:00 p.m. (Wash. D.C.)

Doug Crocker February 2, 11:00 (Long Island)

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H UNTON & . WILLI AM s Mr. Michael S. Miller January 25, 1988 Page.3 I am presently confirming these dates with LILCO's witnesses. If any problems should arise I will contact you promptly. Current resumes for Drs. Lindell and Mileti will be provided later this week.

sincerely yours, f/

Mary Jo Leugers MJL/dl cc: Service List w/o Attachments and Enclosures

LILCO, January 25,1988 WW 9 y 29 P4 35 CERTIFICATE OF SERVICE F Oi 5 L h$d In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of a letter to Mr. Michael S. Miller, Kirkpatrick &

Lockhart, regarding "Documents Responsive to Suffolk County's Request for Produc-tion" were served this date upon the following by telecopier as indicated by one aster-isk, by Federal Express as indicated by two asterisks, or by first-class mail, postage pir paid.

James P. Gleason, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline George E. Johnson, Esq.

Atomic Safety and Licensing Richard G. Bachmann, Esq.

Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 11555 Rockville Pike East-West Towers, Rm. 427 One White Flint North 4350 East-West Hwy. Bethesda, MD 20814 Bethesda, MD 20814 Herbert H. Brown, Esq. **

Mr. Frederick J. Shon Lawrence Coe Lanpher, Esq.

Atomic Safety and Licensing Karla J. Letsche, Esq.

Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.

4350 East-West Hwy. Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.

Secretary of the Commission Richard J. Zahnleuter, Esq.

Atter. tion Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 11 Street, N.W. State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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l Alfred L. Nardelli, Esq. Jonathan D. Feinberg, Esq.

Assistant Attorney General New York State Department of 120 Broadway Public Service, Staff Counsel Room 3-118 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 Spence W. Perry, Esq. Ms. Nora Bredes William R. Cumming, Esq. Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Gerald C. Crotty, Esq.

Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.

Stephen B. Latham, Esq. Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River. NY 11792 26 Federal Plaza New York, New York 10278 A

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Amd llunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 25,1988 l