ML20151S656
| ML20151S656 | |
| 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: | Birkenheier J KIRKPATRICK & LOCKHART |
| References | |
| OL-3-A-028, OL-3-A-28, NUDOCS 8808160047 | |
| Download: ML20151S656 (7) | |
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00CHETED UWC H e xT o N & WI LLI A>t s
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John E.
Birkenheier, Esq.
Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.
Washington, D.C.
20036 Informal Discovery Requests of July 21, 1983
Dear John:
Enclosed are some informal discovery requests.
We would appreciate receiving your responses at your earliest convenience.
I invite you to telephone me right away if there are any problems witn this request.
Sincerely,
/1,k+'W sine A.
Monaghan v
233/663 Enclosure cc:
Stephen B.
Latham, Esq.
Ja.nes B.
Dougherty, Esq.
David A.
Repka. Esq.
Ralph Shapiro, Esq.
8808160047 880712 PDR ADOCK 05000322 NUCLEAR REGULATORY COMMISSION PDR g
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Edward M.
Barrett, Esq.
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b u War of Ira L.
Freilicher, Esq.
Mr. John A. Weismantle smt _._
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4 Mr. Brian R.
McCaffrey f.g;a : _g_ _,,2;,g Mr.
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Carney
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Daverio
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Mr. Anthony M.
Callendrello
" l SE-r' W. Taylor Reveley III, Esq.
James N.
Christman, Esq.
ON Vwn Kathy E.
B.
McCleskey, Esq.
- n.,2 3G.u Ms. Sharon Separ
Informal Discovery Requests of July 21. 1983 For the purposes of set of requests, "document" shall mean and include reports, summaries, notes, surveys, analyses, studies, tests, memoranda, correspondence, letters, telegrams, telexes, cables and writinge of every description including but not limited to, drawings, graphs, charts, photographs, films, videotapes, magnetic tapes, computer tapes and printouts, rid other data from which inf:rmation can be obtained and translated, including :ab runs and survey questionnaires.
As used herein, the singular of any word or phrase includes the plural and the plural includes the singular.
Documents produced in response to this request shall be organized and labeled to correspond with this set of requests.
If any documents covered by this request are withheld under a clain of privilege, furnish a list specifying cach document for which privilege is claimed, together with the following information as to eacn such document:
tha author (s);
the nace and job title of each recipient and person to whom the a copy thereof was furnished; the date; the subject document o:
r.atter of the document; the basis on which the privilege is cla,med; aad the paragraph of this request te which each such document is responsive.
1.
Any correspondence from (or to) Andrew Kanen to (or from) members of the Suffolk County Emergency Plan Steering Committee or other County officials, emplo:ees, or counsel that reic a to emergency planning including, but not limited to, any I
. documents that discuss the relative strengths or weakness of the roads of Long Island (or Suffolk County or any part of Suffolk County) as compared to roadways in other parts of the country or the world.
2.
Any documents regarding the site of the plume pathway emergency planning tone, including but not limited to, documents addressing or discussing how large the EP2 should be and how the decision to make it a certain site was made.
3.
Any documents addressing the question of whether County personnel or other people who might be needed to perform emergency functions will perform their duties in an emergency, or whether for some reason (for example, role conflict or fear for their own safety.), they will. ail to perform their duties or delay in perfcrming thea.
4 Any documents addressing the likely reactions of the public to infer:ction about a nuclear accident at the Shcreham plant er addressing the teactions of people in general to nuclear accidents including, but not limited to, documents discussing whether members of the public will or will not follow instructions from governments or utilities.
5.
All testimony on emergency planning given by any Suffolk County's consultants, officials, employees or representatives in any proceading, be it administrative, legislative or jurisdictional.
The term proceeding in this request shall include all proceedings before Governor Cucto's Shoreham Commission.
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All documents, articles, papers or other publications pertaining to emergency planning, authored or co-authored by
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any of Suffolk County's consultants, officials, employees, or representatives.
7.
All documents analyting, studying or otherwise pertaining to procedures that might be used to notify those within the E?Z who are deaf or hard of hearing.
8.
All documents analyting, studying or otherwise pertaining to the traffic or radiological conditions that might exist during a radiological emergency.
9.
All documents analyting, studying or otherwise pertaining to the various protective actions available for the pluce exposure pathway EPZ during emergency conditions, and the bases for choosing one of those actions.
10.
All documents analyting, studying or otherwise pertaining to avacuatien time estimate studies for Long Island.
11.
All documents analyting, studying er otherwise pertaining to analyses, studies or surveys regarding the voluntary evacuation, shadow effect or cther actions by people outside the EPZ.
12.
All documents identifying, analyting, studying or otherwise perraining to the pessibility that LILCO and non-LILCO personnel expected to report ec the site for emergency duty would fail to report (or to report in a timely manner) because of conflicting family or other duties that would arise in the event of a radiological emergency.
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. 13.
All documents analyzing, studying or otherwise pertaining to public education progracs to inform the population potentially effected by a radiological emergency of the initial and subsequent actions to be taken in the event of a radiological emergency.
14.
All documents regarding the particular social and psychological profile of Suffolk County's residents and the probable response of particular groups, such as the economically disadvantaged to various bducational programs.
15.
All documents analyzing, studying or otherwise pertaining to a PRA consequence analysis applicable to Shoreham.
16.
All documents detailing, analyzing, studying or otherwise pertaining to the best cechods for prompt actification of any boats within the EP;.
17.
All documents pertaining to or analyzing the relative merits of various ceans of'providing public information to ensure preparedness to respond to a radicicgical emergency.
13.
All documents analy ing, studying or otherwise pertaining to the cost effective method to inform the transient or permanent population or both within Suf folk County of the protective actions needed to be taken in the event of a radiological e=ergency at Shoreham.
19.
All documents studying, analyzing, or otherwise pertaining to possible obstacles such as impassible roadways due to evacuation or adverse environmental conditions, that e
l might prevent field monitoring teams from reaching the offsite i
monitors.
20.
All documents pertaining to consequence adalysis studies that reflect the potential consequences of a serious radiological emergency at Shoreham.
21.
All documents pertaining to the County's organitation for coping with emergencies that do not involve nuclear power.
22.
All documents pertaining to the County's procedures for coping with emergencies that do not involve nuclear power.
23.
All documents analyzing, studying, critiquing, or pertaining to the County's plan or plans for dealing with emergencies that do not involve nuclear power.
24 All documents relied upon in preparing the County's plan or plans for dealing with emergencies that do not involve nuclear power.
25 All documents indicacing the division of I
responsibility for preparing the County's plan or plans for dealing with emergencies that do not involve nuclear power, the schedule by which the plan or plans were to be completed, and ene persons, if any, who received the plan or plans.
26.
All documents pertaining to the County's organization and procedures for coping with emergencies involving the Brookhaven National Laboratory.
27.
All documents analyting, studying, critiquing, or pertaining to the County's plan for dealing with emergencies that involve the Brookhaven National Labora:ory.
28.
All documents indicating the division of responsibility for preparing the County's plan for dealing with emergencies that involve the Brookhaven National Laboratory, the schedule by which the plan was to be completed, and the persons, if any, who reviewed the plan.
29.
All other documents pertaining to emergency planning for emergencies involving the Brookhaven National Laboratory.
30.
All documents pertaining to the County's organization and procedures for coping with emergencies involving the Millstone Point Suclear Power Station.
31.
All documents analyzing, studying, critiquing, or pertaining to the County's plan for dealing with emergencies involving :he Millstone Point Nuclear Power Plant.
32.
All documents indicating the di/ision of responsibility for precaring the County': plan for dealing with emergencies involving the Millstone Poin: Muelaar Power i
Station, che schedule by which the plan was to be ccepleted, and the persons, if any, who reviewed :he plan.
33.
All documents reflecting any mee:ings or contacrs involving Suffolk County's officers, personnel, contractors, subcontractors, consultants or other representatives and pertaining to emergency planning.
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