ML20150D535

Forwards Executed Verifications of Fr Jones,Fp Petrone, R Jones & J Bilello for Filing W/Suffolk County Answers to Lilco Third Set of Interrogatories Re Contentions 1-2,4-8 & 10,dtd 880706.Related Correspondence

ML20150D535
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/08/1988
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-#388-6686 OL-3, NUDOCS 8807140040
Download: ML20150D535 (5)

Text

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Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Re:

Docket No. 50-322-OL-3

Dear Sir:

Enclosed you will find executed verifications of Frank R.

Jones, Frank P.

Petrone, Richard Jones, and John Bilello, w11ch relata to "Suffolk County's Answers to LILCO's Third Set of Interrogatories and Requests for Production of Documents Regarding Contentions 1-2, 4-8, and 10," dated July 6, 1988.

Pleas:e file these verifications with Suffolk County's foregoing Answers.

Sincerely yours, W

7 Lawrence Coe Lanpher Enclosures cc:

Judge Gleason Judge Kline Judge Shon Dennis Sisk, Esq.

Edwin J. Reis, Esq.

Richard J.

Zahnleuter, Esq.

William R.

Cumming, Esq.

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VERIFICATION Richard Jones, being duly sworn, deposes and says:

that he is currently the Suffolk County Radiological Officer; that he has read SUFFOLK COUNTY'S ANSWERS TO LILCO'S THIRD SET OF INTERROGA-TOETES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2, 4-8, AND 10; that the facts related to Mr. Jones stated in Answers 125-27 are based on his personal knowledge or reasonable inquiry of appropriate County personitel, as well as on additional information provided by Counsel; and that he believes the matters stated therein to be trua to the oest of his knowledge and belief, and therefore >erifies the foregoing on behalf of Suffolk County.

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Richard Egnes State of New York

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/Jf/4/uBN 77"3f c&M a Notary Public in and for the juris-diction aforesaid, hereby certify that Richard Jones, whose name is signed to the foregoing Answers, dated July 6, 1988, has personally sworn before me that the statements in Answers 125-27 therein are true to the oest of his knowledge and belief.

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VERIFICATION John Bilello, being duly sworn, deposes and says:

that he is currently the Acting Director of the Suffolk County Emergency Preparedness Division; that he has read SUFFOLK COUNTY'S ANSWERS TO LILCO'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGAPDING CONTENTIONS 1-2, 4-8, AND 10; that the facts related to Mr. Bilello stated in Answers 124-127 are based on his personal. knowledge or reasonable inquiry of appropriate County personnel, as well as on additional informa-tion provided by Counsel; and that he believes the matters stated therein to be true to the best of his knowledge and belief, and therefore verifies the foregoing on behalf of Suffolk County.

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,/, John Bilello State of New York

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I, // A/t/ Alv M c' 'N, a Notary Public in and for the juris-diction aforesaid, hereby certify that John Bilello, whose name is signed to the foregoing Answers, dated July 6, 1988, has personally sworn before me that the statements in Answers 124-127 therein are true to the best of his know edge and belief.

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VERIFICATION Frank P. Petrone, being duly sworn, deposes and says:

that he is currently the Acting Di actor of the Suffolk County Depart-ment of Fire, Rescue and Emergency Services; that he has been involved in mitters related to the Shoreham Nuclear Power Station since January 1987; that he'has road SUFFOLK COUNTY'S ANSWERS TO LILCO'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENT 10NS 1-2, 4-8, AND 10; that the facts related to Mr. Petrone stated in Answers 126 and 127 are based on his personal knowledge or reasonable inquiry of appro-pelate County personnel, as well as on additional information provided by Counsel; and that he believes the matters stated therein to be true to the best of his knowle ge and belief, and ther.efore verifies the foregoing on behal l Suffolk County.

/N Frank P.

Petrone State of New York

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I, NA#/MW 7/tCOM, a Notary Public in and for the juris-diction aforesaid, hereby certify that Frank P.

Petrone, whose name is signed to the foregoing Answers, dated July 6, 1988, has personally sworn before me that the statements in Answers 126 and 127 therein are true to the best of his knowledge and belief.

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VERIFICATION Frank R. Jones, being duly sworn, deposes and says:

that he is currently the Supervisor of the Town of Islip, Suffolk County, Long Island; that he was involved in matters related to the Shoreham Nuclear Power Station during the period 1982-1986; that he has read SUFFOLK COUNTY'S ANSWERS TO LILCO'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2, 4-8, AND 10; that the facts related to Mr. Jones stated in Answers 124 and 126 are based on his personal knowledge or reasonable inquiry of appropriate Crunty personnel, as well as on additional information provided by Counsel; and that he believes the matters stated therein to be true to the best of his knowledge and belief, and therefore verifies the foregoing on behalf of Suffolk County.

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jf' Frank R J nes State of New York

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Cou,tyejJ p t I, b 70 0-9 4d a Notary Public in and for the juris-diction aforesaid,' hereby certify that Frank R. Jones, whose name is signed to the foregoing Answers, dated July 6, 1988, has personallu sworn before me that the statements in Answers 124 and 126 tharein are true to the best of his knowledge and belief.

OERALYN K. RAGAN

/7 NotAm rueu.c, s.eem.s of New Ys:t

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Commission Egeres Me,sh 30,1811 UA My Commission expires:

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