ML20151S675

Applicant Exhibit A-30,consisting of Lilco Third Set of Interrogatories & Requests for Production of Documents Re Contentions 1-2,4-8 & 10 to Suffolk County,State of Ny & Town Southampton,

ML20151S675
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/12/1988
From:	Sheffey R HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY
References
OL-3-A-030, OL-3-A-30, NUDOCS 8808160061
Download: ML20151S675 (4)

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DOCKETED UWC UNITED STATES OF AMERICA "I' */5 :51 NUCLEAR REGULATORY COMMIS3 ION OFVmF S n:, -

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_Bafore the Atomic Safety and Lienesing Board In the Matter of )

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LONG ISLAND UGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station. ) ("Best Etforts !ssue) finit1) )

LILCO'S TiURD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING CONTENTIONS 1-2,4-8, AND 10 TO SUFFOLK COUNTY. NEW YORK STATE. AND THE TOWN OF SOUTHAMPTON Long Island Lighting Company, by its counsel, propounds the following inter-

, rogatories to Suffolk County, New York State, and the Town of Southampton ("Interve-nors" or "the Intervenors"), pursuant to SS 2.740,2.740b, and 2.741 of the Nuclear Regu-latory Commission's Rules of Practice. By propounding these interrogatories and j requests for production of docu2nents LILCO makes no admission or representation about the proper scope of the issues to be decided or the evidence that may be pres-ented.

INSTRUCTIONS AND DEFINITIONS Except as supplemented below, the "instructions and Definitions" for this

( third set of interrogatories on the "best efforts" issue are the same ones set out in LILCO's First Set of Interrogatories and Requests for Production of Documents Re-i garding Contentions 1-2, 4-8, and 10 to Suffolk County, New York State, and the Town NUCLEAR REGUL AToRY Co"MICSION of Southampton, dated March 9,1988.

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l 2-SUPPLEMENTA L INSTRUCTIONS The primary documentary basis for these Interrogatories, other than the Shoreham offsite emergency plan and Intervenors' responses to LILCO's summary dispo-sition motions on the realism issues,is the recently produced Suffolk County Emergency Operations Plan. The bulk of the interrogatories concern the production of this Plan, with the goal of eliciting exactly when, if ever, this Plan was produced to LILCO, whether this Plan is current, and who has, or has had responsibility for maintaining this document.

The Interrogatories below request information to the best of the State's or County's current knowledge, belief, and intention (whatever knowledge, belief, or in-tention underlie the answers in responses to summary disposition motions refusing to agree to generally follow the LILCO plan on a given issue). The lack of absolute cer-tainty about the specifics of State / County response should thus not lead to answers that decline to answer on the basis of lack of such certainty.

The following Requests are numbered beginning where the second set, dated March 24,1988, left off.

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INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 124. With respect to the Suffolk County Emergency Operations Plan, please state when,if ever Suffolk County or the State of New York first peduced this document to LILCO in response to discovery requests. Specifically, your answer to this interrogato-ry should include the following:

a. Please list the date, method of transmittal, and spect-fy the request or requests to which this document was produced as responsive.

b. If records sufficient to answer part a above are not in the pammedon of outside Counsel for Suffolk County or the State of New York, then search the files of the Suffolk County Attorney and produce any and all doc-uments from 1982 to the present which would provide a response to this Interrogatory.

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c. If records sufficient to answer part a of this Interrog-atory are not available in the files of the Suffolk County Attorney, please state the name, position, and off!ce location of the person or persons having pos-session, custody, or control of documents which would be responsive to this Interrogatory.

d. If such documents are unavailable, or have been de-stroyed or lost, please describe when, why, and at whose direction this occurred.

125. Please list the names and positions of all persons within the Suffolk Coun-ty or State of New York governments who have copies of all or any part of the Suffolk County Emergency Operations Plan. Specifically, in your response to this in-terrogatory please identify the following persons:

a. Identify the person (s) within the Suffolk County gov-ernment who are responsible for maintaining a mas-ter copy, if any exists, of this document.

b. Identify the person (s) within the Suffolk County gov-ernment who are responsible for updating this docu-ment, or keeping it current.

c. Identify all persons within the Suffolk County and State of New York governments who have a copy or l copies of all or any part of this Plan, and for each person so identified list the specific parts of the Plan in the custody of each.

126. Identify all persons within the Suffolk County or State of New York gov-ernments who assisted in any way in the gathering of documents in preparation for Suffolk County's production of documents responsive to LILCO's discovery requests dated June 2,1982 July 21,1983, August 8,1983, and March 24, 1988 as described in LILCO's Response to "Suffolk County Response to Licensing Board Discovery Inqui-ries," dated June 1,1988. Specifically, in your response to this interrogatory please include answers to the following questions: ,

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a. Identify the person or persons responsible for coordinating the document production effort.

b. Identify the person within the Suffolk County govern-ment who produced the Suffolk County Emergency Operations Plan to Kirkpatrick & Lockhart ("K & L")

for production to LILCO, including the date of such production to K & L.

127. Identify the person within Suffolk County government who provided the copy of the Suffolk County Emergency Operations Plan which was produced to LILCO on or about May 24, 1988.

a. Is the person identified in response to this interroga-tory the same person as previously identified in re-sponse to part of a Interrogatory No.125?

b. Is the document produced to LILCO the same as that maintained by Mr. Petrone?

c. If Mr. Petrone is not the person responsible for main-talning a master copy, please identify the person who has it, or from whom he received it, kdto. b.

Donald P. Irwin "V I K. Dennis Sisk

) Rita A. Sheffey Counsel for Long Island Lighting Company l Hunton & Williams 707 East Main Street P.O. Box..iS35 Richmond, VA 23212 DATED: June 7,1988 l

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