ML20151S635

Applicant Exhibit A-27,consisting of Ltr , Requesting Responses to Informal Discovery Requests No Later than 830715

ML20151S635
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/12/1988
From:	Monaghan J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Letsche K KIRKPATRICK & LOCKHART
References
OL-3-A-027, OL-3-A-27, NUDOCS 8808160038
Download: ML20151S635 (3)

Text

.

~

-z 7 00thEIin U%hQ H t: rr o x & WI L LI A. st s '88 E 11 P5 :51 n c..,s.m sr.ccr o c. so, isas RtcHMoNo. VtnotxtA 20c12 ,

u U x i, ... i.no 3,.

. e. co t .wi60,

.o. .

...........e.......o t c s c . o ., c eo4 7e .eseo DOCMo.swger,, 9'.e.y.6fope

. ... e s . . . . .

,,s.,..........~...c. June 29, 1983 r 6c .. 24566.000003 e..c:,e.. o...ru. 8552

, .,u o 6 . . .. ... .. . n . . .

SY TELECOPY_

Karla J. Letsche, Esq.

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

Washington, D.C. 20036 Informal Discovery Requests

Dear Tip:

• LILCO's Informal Discovery Requests aimed at clarifying some questions we had concerning Suffolk County's, SOC's, and the Town of Southamption's contentior; are beingWe "beamed up" to have provided you this afternoon via our talking computers.

references to the Contentions for your convenience. .

We would appreciate receiving resper.ses to these in-formal discovery requests at your earliest convenience, but no To facilitate your response, you later than July 15, 1983. the same time; need not send all your responsive materials at etc. as soon please feel free to send responsive documents,As we have done for you in the past, as they become available.

we would urge you to identify the question or questions to which each document is responsive.

Please do not hesitate to call me if you have any questions about these or any other discovery matters.

Sincerely, 2.J Ui QB%$oh b [ .

Jessine A.NUCLEAR Menachan G RtGULATORY COMMIS$1CN 28'l/668 Cm h o-3n+3 ti C h iM Exh.ib, Z 7

.nclosure hnm;d RM-cc: Edward M. Barrett, Esq. __ _ _ IM . m "

Ira L. Freilicher, Esq. 0 .____

b,a -

Mr. John A. Weismantle _w Mr. Brian R. McCaffrey  ;, .,y gg ~~

o Mr. Charles A. Daverlo .

~

..c,

' Mr. Anthony M. Callendrello ~ ' - -M 2N-- - - -

W. Taylor Reveley, III, Esq. C' C.u  ;

James A. Christman, Esq. _ ;T __ _ . _ . . .

, - . . _. -~ - - - -

)

o I

i INFORMAL DISCOVERY REQUESTS For the purposes of this request "document" shall mean and include reports, summaries, notes, surveys, analyses,

studies, tests and writings cf every description including, but

not limited to, drawings, graphs, charts, photographs, vid-eotapes, magnetic tapes, computer tapes and print-outs and other data from which information can be obtained and trans-lated, including tab runs and survey questionnaires.

I. Suffolk County Contentions SC Contention 1- Command and Control

1. SCl- A For each of the following activities listed in Conten-tion 1, state specifically which cases, statutes, regu-

, lations, ordinances or other provisions of law on which you rely for the statement "New Ycrk inw explicitly prohibits several of the actions which LILCO proposes to take under the Transition Plan.":

1. directing traffie

2. blocking roac.'rys

3. setting up barriers in roadways, or channeling traffic

4. posting traffic signs on. roadways

5. removing obstructions fre.? public roadways, including the towing of private vehicles 4

6. activating sirens and directing the broadcast of emergency broadcast system messages.

7. making decisions and official recommendations to the public as to the appropriate actions neces-sary to protect the public health and safety, including directing an evacuation and/or special facilities, prohibiting traffic, milk and dairy I '

i 5

I a

s-IV. Miscellaneous -

102. Are there any local emergency evacuation plans or simi-lar local plans drafted by Suffolk. county, any village .

or any town, for Brookhaven National Laboratory, Mill-stone, or Connecticut Yankee? If such plans do exist, please provide copies. If no such plans exist,.please explain why Suffolk County does not consider such plans to be necessary.

103. If emergency planning is deemed by the NRC to be possi-ble for Loti Island and a plan is approved by the NRC, will Suffolk County or any of Suffolk County's officials take action to prohibit county employees from responding in an emergency other than by appealing the NRC's decision to the courts?

104. If emergency planning is deemed by the NRC to be possi-ble and a plan is approved by the NRC, will the County adopt regulations, ordinances, or provide LILCO with a permit to conduct any of the activities necessary to execute the emergency plan which the County, in its

. contentions, has classified as illegal? ,

105. Provide copies of all documents and information commu- '

, ' nicated, submitted or provided to Governor Cuomo's Shoreham Commission, to any member of that Commission or to arq staff personnel affiliated with that Commis-sion by suffolk County, its consultants or its agents.

106. Provide copies of the notes and slides of the speakers who made oral remarks or statements to Governor Cuomo's Shoreham Commission on June 28, 1953, plus any other documents that the County speakers drafted or had drafted in preparation for the County's presentation to the Commission.

107. Provide a copy of the remarks or statement that Peter Cohalan, Suffolk County Executive, read as part of the County's presentation to Governor Ouomo's Shoreham Com- ,

mission on June 28, 1983, i i

.J

$ i 3

1 9

, , - - - - . - - - , - , .--,,n,-, ,,.nn,-...~.--,,,--__----,._-- ,,,-n------ - - - - , - , - - ~ - - , , --