ML20150D574

Forwards Suffolk County Documents in Response to Lilco Second Set of Interrogatories & Document Requests Re Contentions 1-2,4-8 & 10.W/o Encls.Related Correspondence

ML20150D574
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/06/1988
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Sisk D HUNTON & WILLIAMS
References
CON-#388-6690 OL-3, NUDOCS 8807140053
Download: ML20150D574 (2)

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Hunton & Williams P.O. Box 1535 707 E. Main Street Richmond, Virginia 23212 Re: Docket No. 50-32?-OL-3

Dear Dennis:

In accordance with the Board's Order on June 29, we are producing herewith on behalf of Suffolk County documents which are responsive to LILCO's Second Set of Interrogatories and Document Requests Regarding Contentions 1-2, 4-8, and 10.

The documents being produced fall into several categories.

First, we are producing various plans and portions of plans of other counties. These plans are responsive to LILCO Interroga-tory Nos. 68 and 69. We believe many, if not all, of these plans may be out of date.

Second, as indicated in our June 3 responses to Interroga-tory Nos. 52, 54, and 118,1/ we are producing documents related to Millstone, Plum Island, and Fishers Island. Again, many of these documents may be out of date. In addition, Suffolk County amends its answer to Interrogatory No. 54 to state that an exer-cise, which may have included some recovery and reentry activi-ties, was conducted at the Millstone Plant by the State of Connecticut and the Town of Waterford, on March 19, 1982.

Suffolk County was not a participant in that exercise.

Third, in Interrogatory No. 120, LILCO seeks any Suffolk County plans and procedures for responding to nuclear and non-1/ See Suffolk County's Further Responses to LILCO's Second Set of Interrogatories Regarding Contentions 1-2, 4-8, and 10, dated June 3, 1988.

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0 Dennis Sisk,i Esq.

July 6, 1988

'Page 2 nuclear emergencies. Such County plans are being produced, even though in many cases they are out of date. Further, it is our belief that many of the documents already are in LILCO's posses-sion.

Finally, and again responsive to Interrogatory No.120, we are producing the new Annex K (actually entitled Annex B) to the Operations Plan. I am informed that although Annex B bears a December 1986 date, it was only received by the County from the "State in May 1988. I further am informed that no other updates of the Operations Plan exist.

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Sincerely yours, Lawrence ce Lenpher Enclosures cc w/o encls: Judge Gleason Judge Kline Judge Shon Richard J. Zahnleuter, Esq.

Edwin J. Reis, Esq.

William R. Cumming, Esq.

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