ML20151S870
| ML20151S870 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/11/1988 |
| From: | Zahnleuter R NEW YORK, STATE OF |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| OL-3-A-008, OL-3-A-8, NUDOCS 8808160143 | |
| Download: ML20151S870 (21) | |
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~ lifore the Atomie Safety and Licensina Board YN R:prtu
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In the Matter of
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LONG ISLAND LIGHTING CCMPANT
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Docket No. 30-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station
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Unit 1)-
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STATE OF NEW YORE'S RESPONSE TO LILCO'S SECOND SET OF INTERR0CATORIES RECA1 DING CONTENTIONS 1-2, 4-8. AND 10 This pleading responds to the Board's oral ru11=g on May 10, 1988 requiring the Stata of New York to provide additional answers to LILCO's Interrogatories 50-64, 67-74, 76-83,85-105, 108, 112-113, 115-118, 120, and 122-123.
General Obiections concerning all of these interrogatories, the State of New York asserts the fo11oving general objections that were previously mada in the Governments' objections to LILCO's Second Set of Interrogatories Regarding contentions 1-2, 4-8. and 10 (April 20,1988), and were not overruled by the Boardt 8808160143 080711 PDR ADOCK 05000322 o
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1.
The State of New York objects to LILco's Interrogatories to the extent that they call for speculation, which the State of New York is unable to providts The Ammries ahnsit that LILCO sasks 4.41. 1 4.
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separate governmental entities that have independant authority to determine their own actione prior to and during energencies.
According-ly, the State of New York cannot predict what these countias would do.
how they would respond, what plans they would use, or other such mat-If LILCO wants this information, it should obtain it from the cars.
counties in question. The Staca of Iov York notas that the information ta as accessible to LILC0 as it is to the State of New York.
2.
The State of New York objects to the questions addressed to it which seek information about Suffolk County and other counties within the State.
The infornation requested is not within the posseeston or control of the State and thus ca=not be provided to LILCO by the State of New York.
3.
The State of New York objects to LILCO's Interrogatories to the extent that they seek the identification of documents, or production of documents chamaelves, which are in the possessics, custody or control of counties, including Suffolk County.
Such counties are separata, independent governmental entities. The documents are as accessible to LILCO as they are to the Governments, and if LILCO wants these w--.m e s As anovra cotain tnam trou the counties in question..
1 JW 03 '38 19:53 E3:0,N 10 D.O. T.
,,5 Additional Resposees
- 50. For subparts (a) through (s), whatever plans and procedures axist are contained within the New York State Radiological Energency Preparedness Flan f T Comaarcial Ptnser Plant e ("Waw Yaele e* * *
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9 for itssif and needs no summarization. Although the New York State Plan contains detailed county plans for each plant located in New York State except Shoreham, the New York State Plan does not contai'. such detailed county plans for out-of-state plante, and, therefore, is not site-specific for the plants identified in subparts (a) through (s).
The New York State Plan has already been providad to LILCO.
- 51. n) Schenectady, Washington. Rensselaer, Columbia, Greene Albany, Saratoga b) Suffolk, Nassau c) Suffolk, Westchester, Putnam, Dutchess, Columbia d) Washington. Ransselaer, Columbia a) Staten !aland Borough 32.
The State of New York is not aware of any plans and procedures that the pertinent counties might "have, use, follow or otherwise rely upon,"
with the possible exception of the New York State Plaa. Beyond that, the State of New York is unable to speculate, as explained in General objections 1, 2 and 3. -
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- 53. The state of New York does not know how each such county would respond because these counties have not conducted drills or training directed to 1
ingestion pathway and recovery and reentry responses.
- 54. The only responsive "training sessions, drills, and exercises... for an ingestion pathway and recovery and reentry response" that the State of New York is aware of are two meetings attended by a RZPC representa-tive in Anc41 tone..
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- 55. Yes, New York State participated tu the April 1988 Tankee Rows azercise
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... wy we uosecstves, valen nave already been provided to LILCo. Through counsel, the State of New York states that the State of New York is not required by FDfA to participate in this or any azercise because FDfA has no such authority.
- 56. Representatives of the State Waalth Department, State Department of Transportation, State Department of Agriculture and Markets, State Police, State Enargency Management Office and 14diologfcal Emergency Preparedness Group ("RIPG") participated in the Yankee Rove Exercise to the extent warranted by and corresponding to the objectives, which have already been provided by LILCO.
- 57. The objectives are responsive, ar.d they have been previously provided to LI:.CO.
$8. Ranseslaar County participated in the Yankee Rows exercies in the sense that a county representative reviewed a notification telephone call.
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- 59. g answer to Interrogatory No. 58.
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- 60. See answer to Interrogatcry No. 54.
l 61.
53 arsver to Interrogatory No. 52.
The State of New York to unable to speculate sa explained in General objections 1, 2 and 3.
- 62. For Indian Point only, the personnel responsible for the activities delineated in Interrogatory No. 49 are id atified in the New York State Plan. For the other three plants, see Interrogatory answer 50 (b), (c) and (s).
In the absence of a site-specific plan for these three plants and training of any kind, the State of New York is unable to speculate about who would be responsible, as explained in General Objections 1, 2 and 3, 63.
For Indian Point only, the functions and activities of the agencies listed in subparts (a) through (f) are set forth in the New York State Plan. For the other three plants, see Interrosacory answer 50 (b), (c) tad (s).
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would differ from functions and activities performed for Shoreham b***u'*l far iht HHimi fli fl1TTh in the fastmars' hW111 f4 jections and offer of Proof, the State of New York has not adopted any l
Plan or otherwise traised or planned for responding to a Shorebsn i
anergency. Accordingly, the State of New York is in no position to 1
provide further responsive information.
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E.3 64 As explained in General Objections 1, 2 and 3 the state of New York is unable to speculate about what would prevent "other countiae and other pertinent jurisdictions in New York State" from using $h, "plana, procedures and resources" referred to in the interrogatory. What prevents the State of New York from responding to a Shoreham accident in the same way that the State of New York might respond to aa saargency at the referencad plants is that the State of New York doesn't know what plans, procedures and resources would be needed for a Shoraham accident because, for the reasons set forth in the Governments' objection and Offer of Proof, the State of New York has not adopted any plan or otherwise trained or planned for responding to a shoreham emergency.
Accordingly, the State of New York is in no position to provide further responsivs information.
67 The interrogatory appears to ask whether coordination of ingestion pathway and recovery and reentry activities has occurred among four entities (State of New York Suffolk County, utilities, and offaite responsa organizations) for Millstone; then for Oyster Creaki then for Eaddaa Facki then for Indian Point.
The answer is that for each nuclear power plant, coordination amous the four entities has not occurred.
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2, counties ara contained in each individual county plan and the New York State Phn, all of which have been previously provided to LILC0 and all of which can be read by L:LCO. The plans are used for each county only.
69.
Nine Mile Point /Pitzpatrick: Oswego, Wayne, Cayuga, Onondaga, Madison, Oneida. Levia, Jef ferson, Ontario, Seneca --.. _ _ _ - - -
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Ginna: Wayue, Monroe. Celeans, Gaasses, Livingston, Ontario. Yates,
$sneca, Cayuga, Onondaga, Steuben, Wyoaing, Oswego e n
- w. m., rusnam, accr.ana, westchester, Sullivan, Ulster, New York City, Dutchess. Nassau, Suffolk As amplaioM in General Objections 1, 2 and 3, the State of New York is unable to speculate about what em nty plans and procedures would attuab-ly be "used, followed or othervios ralled upon by thst county" or if a county does not have plant and proes&res, "how they wuld respond."
- 70. Ultimata responsibility in chia ars3 is assigned to the New York State Dissster Preparedtaas Coastasic,c ara in turn, to the 1sdiological Caergency Preparednese Group, dirt.cted by Jesse Papile.
- 71. With respect to (b), sh General Objections 1. 2 and 3.
Withrespuetto
's) and Indian Point. the New York ft.ste Plan, including the county plans for the councias within t;t e l>0 mile EPZ, identifies persons who would "make an ingestion pethvay and recovery and reentry response."
With respect to (a) and Millstone NAddam Nach and Oyster Creek, ths l
State of New York is unable to anasse becaur s ac county plans exist and l
co drills, azercise or trainLig cencarning an ingestion pathway ara recovery and reentry response 't.ve cccurred.
- 72. Wayne and Monroe Counties have particip.ited in the activities set forth in subparts (a) through (f) in cencoction with an exercise on October 28 and 29, 1987.
1*he New York state Plan, including tb4 Vayne and Monroe County Plans, were used and the a:nregriata state and county officials identified in those plant participe. cad.
8ee also the chronology of 1
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,,g svents leading up 19 th18 sgartif as. whfeh has nia edy b e = s u..u J LILCO. Sgg answer to Interrogatory No. 76.
73.
}gg answer to Interrogatories Nos. 72 and 76, and Canaral Objections 1 j
2 and 3.
74.
The New York State Plan identifies the local offices, functions and activities of the State Department of Haalth. State Department of
(
Transportation. State Department of Agriculture and Markata. State Police. State Esargency Management organisation and Radiological !aar-gency Prepareduse Group. The New York State Plan has b un provided to LILCO and can be read by LILCO.
P 76.
As to the last centence regarding "documents used by these counties."
ges General Objections 1, 2 and 3.
The counties of Orleans. Genene.
Livingston Ontario. Yates. Saneca. Cayuga Onondaga, Steuben. Wyoming and Oswego were involved in the October '87 Ginna exarcise in the sense that they received notification and communication. Wayne and Monroe Countias participated to the extant that counties in a 10 mile IPZ normally participsca, se set forth in the New York State Plan, including the Wayne and Monro. County Plans. all of which have already been provided to LILCO.
77.
See the chronology of events already provided to LILCO.
Among other thine, on 6/18/87, a nesting occurred among stata and local energency i
management officials. On 8/27/87, a meeting occurred among county chief executives and state officials. On 9/12/87 and 9/23/87, meetings g
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occurred among state officials and local personnel including cooperative eatension personnal.
- 73. Tne Wayne and Monroe County EOC was activated and remained operational.
ne other counties in the 50 mile EPZ did not activate an roc, except in the sense chac notification and communications were received hence no "county operatione" were directed.
- 79. De State of New York objects because the interrogatory is vague and calla for a legal conclusion. D e S*. ate of New York, through counsel, states that 10 CYR Part 50. Appendix 1. Section 17.F.1. requires that a site-specific ingestion pathway and plume EFZ demonstration aust be made for each NTCL plant (including Shoreham) as a precondition to licensing above 5% power.
See eleo GM PR-1.
LILCO's counsel any analyse the applicable regulations and guidance if LILCO wishes an interpretation of applicable regulations and guidancel the State of New York has no obligation to perform such a service for LILCO.
80.
See answer to Interrogatory No. 79.
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- 81. A single Ginna axercise does not demonstrate the ability of the State of I-New York to respond to an energency at other nuclear pow r plants because ch' State of New York has not drilled or trained concerning plants other than Ginna, including Shorehaa. B is is the best answer possible given the confusing nature of the quastion. __
AN 03 '5818:57 RE3:CN :0 0.0.7.
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- 82. see answer to Interrogatory No, 79. To reiterate, the State of New Tork, through couneel, states that 10 C7R Part 30, Appendia E.Section IV.F.1. requires a successful ingestion pathway demonstration for Shorahaa.
83.
See General objections 1, 2 and 3.
The draf t FENA post-emercise report for Ginna has been returned to FIMA at FEMA's request and no final report has been provided to the State of New York.
85.
The phrase "routines" applies to all countias in the state that could be involved in an emergency in an ingestion pathway EPZ capacity.
It encompasses pre-exercise neetinge, post-exercise weer.ucs, discussions e tMios and telephones, discussions during training, etc. T14 "routines" are learned and practiced by all ingestion pathway cw nties and are not, to the knowledge of the State of New York, embodied or compiled in any written compendium.
86.
The main assumption (from which other assumptions are derived) that is 1
unwarranted is that counties play a ainor role.
Counties are the primary, first lins of defense and play a major role in an emergency.
LILCO fails to appreciate this paramount concept and that shortcoming pervades LILCO's assumptions.
87.
The "detailed State and local government drills and exercises" refer to seven years worth of ari.orienes chronicled in FIMA's post-exercise assessaants, all of which have been provided by the State of New York to l l
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AN 03 '88 18: 57 REG %N 10 *. C. r.
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LII.C0 or can be easily obtatned by LILC0 on its own, and all of which
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88.
We answer to Interrogatory No. 110 regarding recovery and reentry la just as applicable to this interrest, tory concerning both ingestion pathway and recovery and reentry.
- 89. S_ee answer to Interrogatory No. 85.
90 (a), (b) Not all of this information was "made available" or "actually used" during the Ginna F.xercise because the scenario did not require all of this data. Appropriate information was available for decision making.
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(c) Information is updated by various agencies to greatly varying extents.
g General Objestions 1, 2 and 3 regarding information compiled by counties and other e.;!tties independent of the State of New York, such as the Cooperativs Extension. :"C0 should contact these entition directly since they are independent of the State of New York.
I 91.
See General objections 1, 2 and 3.
As indicated in the answer to Interrogatory No. 90, many agencias becona involved in an energency and the eatsat of their involvement is dependent on the nature of each emergency; it te not possible to be more precisa. Additional ingestion pathway training is needad, particularly for those counties outside the plune aaposure 172... _ -
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- 53 FG*CN 10 D.O.7
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- 92. The quotations referred to in the interrcgatory originate from this "mo new tora scate agency has worked out procedures, dedicat-ed rescurces or trained personnel for ingestion pathway data collection and analysis at the Shorehan site." The sentence is structured around New York State agencies and Shor-ahms,..but tha interryu7-ir --
structured around a "county-by-county basis for all counties in New York Stata." The originating sentence does not pertain to counties and, hence, the State of New York is unable to provide responette inforna-tion.
- 93. Some training and preparation has been conducted for some countiaa in the Nina Mila Point /Fitzpatrick ingestion pathway because these counties are cosemon to the Ginna ingestion pathway. See Interrogatory No. 69 to determine common countise. Countiae in New York State other than theas common counties have not received the same type and amount of prepara-tion because there have been no other ingestion pathway exercises, the Ginna exercise being the first and only one, to this date. Additional training is needed, but not scheduJed, for the Indian Point and Nine Eila Point area.
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- 94. See General Objecticus 1, 2 and 3.
The State of New York does not know whether the councias could have "made an ingestion pathway reopense" at i
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that time, such less what the quality of that response would have been.
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l 95.
Ingestion pathway response planning will take the forn of ongoing l
l training with the counties in question. Training spread out over a 12 l
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,,a month per134 should provide a more meaningful indication of what re-sources will be av.11able for an actual response.
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- 96. Ige, General objections 1. 2 and 3.
Upon information and belief, county offices of emergency preparedness have the location of the local cooper-ative extension offices on file.
97.
(a) The "eita-specific implonanting procedurse" are the responsibility of the countine. Counties work with state agencies, but the."site-epecific impinaanting procedures" are actually developed by the counties.
S,ee General objectione 1, 2 and 3.
te (b) Counties are responsible for impisaanting thees procedures.
(c) Training has occurred in the Ginna area. The State used the New York State Plan and the count:,se utilized, upon information and belief, their "site-specific implementing procedures."
98 The ILEPG Affidavit at 10 does not state that "there are ' detailed procedures' which so 'beyond the generic Plan and county-specific agends' (sic]." Rather, it states that the State Plan "depends on the development of detailed procedures going beyond gh9 gg {g g county-specific addenda." These "detailed procedures" are developed by counties and retained by them. sge General Objectione 1, 2 and 3.
99.
8,ee, General objections 1, 2 and 3.
The State of New York is unable to speculate how much time would be required. One unknown variable would - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - - _ - - _ _
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i be whether counties would or could devote full-g gg g g g g7 indeterminate snount of time to training, etc.
100. Through counsel, the State of New York states that the deposition of Donald DeVito, takan by LILCO, indicated that the State does not have an EOC on 14ng Island. A reading of the deposition transcript, however, indicates, for example, that some operations during Hurricana Gloria were directed for a time from a makeshift field office on Long Island.
Concerning county 10Cs on Was Island. ama f.anarel Ahd***daa= 1 O u 3.
101. The State of New York is unable to speculate on Suffolk or Nassau County's responses. & General Objections 1. 2 and 3.
Three respon-eive occurrences that involved the State Emergency Management Office consisted of crisis management responses during Burricane Gloria, a coastal storn in 1984 and the Grucci fireworks explosion. Activities included seeking financial aid, supplying electric generators, coor-dinating local agencies.
102. Without having the benefit of training and participating in an azercise.
the State of New York is unable tc. state how the counties would or could support such an ingestion pathway response. & General Objections 1. 2 and 3.
103. For a statement of when the State of New York had auch discuestos.a. who attended them and what was discueeed, em the chronology of events regarding the Ginna exercise. This document has already been produced _
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M 03 'sa 13:00 RG:0N 10 :,0.7, to LILCO. For countiae not involv6d in the Cinna exercise, no such discussione have occurred.
104. 83 Interrogatory Answer No. 103.
(a) Discuseigge hays 1:st nerittrevi in instannes adiese desiset it azorcises have not been held.
(b) and (c) les, General objections 1, 2 and 3.
The State of New York is e
unable to speculate about when discussions might occur in the future or whether they can result in any meaniusful preparation for an ingestion pathway response.
105. Rosarding local government personnel, see General objections 1, 2, and 3.
Regarding State personnel, they are "not primarily identifiad" because the individuals who will perform the functions set forth in the New York State Plan will be selected at the time of an accident based on criteria such as the type, time and location of the accident, and the degree of expertise required. Consequently, it is not possible to "identify" the "unidentified" State personnel, se this i=terrogatory attempts to do.
108. The New York State Plan does not contain complace instructions on recovery. However, the context in which the Monroe County Plan is "true" is that state agencies referred to in the New York State Plan depend on internal "routines" and instructions to mount a recovery response.
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Jw 03 'B8 19: 00 RG:CN 10 L C. L 2, a 112. As stated in the REPG Affidavit at 21, the degree of complamity would depend on detailed preparation and planning, plus the availability and knowledge of particular individuals at the tina of an accident.
113. & General objections 1, 2 and 3. Other agencies that have the respon-eibility alluded to in the interrogatory are local (ir.cluding counties) health deparements, or other comparable local officiais.
115 & General Objections 1, 2 and 3.
"More or less support" is a term that cannot be reduced to a tangible entity.
It is highly variable and it depends on governmental infrastructure. instantaneous levels of capabilities, staffing. absenteeiss, training, esperience, etc.
116. The parts of the New York State Plan that were not tested during the Ginna Exercise were the Westchester Rockland, Orange Putnam and Oswego appendicies of the New York State Plan.
117. Plus Island ar.d Fisher's !. land are within M111 scone's plune arposure EP2.
l 118. See General Objections 1, 2 and 3.
A copy of the Fisher's Island plan hoo elseady b asa peeddsJ ty sk c6.6..f N.. T..L 6.1,T1,46.
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120. Copies of plana that may be responsive have already been provided to LILCO by the State of New York.
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M 03 '59 19:01 FE3:Cti 10 0.0.T.
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122. 83 nterrogatory Answer No. 63.
It is not possible to state what the State of New York would do differently at shorehaa than at other nuclear plants because, for the reasons set forth in the Governments' April 13 Objections and Offer of Proof, the State'of New York has not adopted any plan or otherwise trained or planned for raeponding to a shoreham emergency. Accordingly, the State of New York is in no position to provide further responsive information.
All objections have been stated by counsel.
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Richard J. p p @ r Deputy Spec m Counsel to the Governor Executive Chamber capitol, Roca 229 Albany, NY 12224 Attorney for Governor Cuomo and the State of New York i
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Jw 03 'sa 19:03 Ft3:cN :a 0.c.7.
DATE. June 3, 1988 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomie Safety and Licensine Board In the Matter of
)
IDNG ISIAND LIGHTING COMPANY
)
)
Docket No. 50-322-oL-3 (Shoreham Nuclear Power Station
)
(Emergency Planning)
)
Unit 1)
)
)
i CEMT!FICATE OF SERVic; Response to LILCO's Second Set of Interrogatories Contentions 1-2, 4-8, ng this 3rd day of June 1988 by U.S. Mail,and 10" have been served on the follow noted by asterisks.
first class, except as Mr. Frederick J. Shon
- Atomic Safety and Licensing Board Spence W. Perry, Es U.S. Nuclear Regulatory Commission William R. Cumming,q.Esq.
Washington, D.C.
20555 Office of General Counsel, Federal Emergency Manage =ent Agency 500 C Street, S.W., Room 840 Washington, D.C.
20472 Dr. Jerry R. Kline
- Atomic Safety and Licensing Board Mr. James P. Gleason, Chairman
- U.S. Nuclear Regulatory Co::cnission Atomic Safety and Licensing Board Washington, D.C.
U.S. Nuclear Regulatory Commission 20555 Washington, D.C.
20555 l
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- ED 10 O' O A-
" ~ 7 i~
Anthony F. Earley, Jr., Esq.
General Counsel Joel Blau, Esq i
Long Island Lighting Company Director, Utility Intervention 175 East Old Country Road N.Y. Consumer Protection Board suite 1020 Nicksville, New York 11801 i
Albany, New York 12210 i
l Ms. Elisabeth Taibbi
(
Clerk Mr. Donald P. Irwin
- Suffolk County Legislature Hunton & Williams suffolk County Legislature 707 East Main street office M11 ding P.O. Box 1535 Veterana Namorial Highway Richmond, Virginia 23212 Hauppauge, New York 11788 Mr. L.F. Britt Long Island Lighting Company Stephen B. I4 tham, Esq.
Shoreham Nuclear Power Station Twomey, Latham & Shea North Country Road 33 West Second Street Wading River, New York 11792 Riverhead, New York 11901 Ms. Nora Bredes Executive Director Docketing and Service Section Shoreham opponents Coalition Office of the Secretary 195 East Main Street U.S. Nuclear Regulatory Commission Smithtown, New York 11787 1717 H Street, N.W.
Washington, D.C.
20555 Adrian Johnson, Faq.
New York State Department of Law Hon. Patrick G. Ralpin 120 Broadway, 3rd Floor Suffolk County Executive Roca 3-16 H. Lee Dennison Building New York, New York 10271 Veterans Mescrial Highway Hauppauge, New York 11788 MRB Technical. Associates 1723 Hamilton Avenue Dr. Nonroe Schneider Suite X North Shora Committee P.O. Box 231 San Jose, California 95215 Wading River, New York 11792 E. Thomas Boyle Suffolk County Attorney lawrence Coe Ianpher, Esq.
- Building 158 North County Complex Kirpatrick & Lockhart Veterans Memorial Highway 1400 M Street N.W.
Hauppauge, New York 11788 South Icbby
, Ninth Floor Washington, D.C.
20036 Mr. Jay Dunkleburger New York state Energy office Edwin J. Reis ***
Agency Building #2 U.S. Nuclear Regulatory Commission Empire State Plaza Washington, D. C.
20555 Albany, New York 12223 1
,3 m as 'se 19:04 RE3:0N 10 0'0'I' p
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I
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Mr. James P. Gleason Chairman Daglas J. Hynes i
l Atoalc Safety and Licensing Board Town Board of oyster Bay 513 Gilmours Drive Town Hall silver spring, MD 20901 oyster Bay, New York 11771 I
David A. Brownlee, Esq.
Kirkpatrick & Lockhart Mr. Philip McIntrie FEMA 1500 oliver Building 26 Federal Plaza Pittsburgh, Pennsylvania 15222 New York, New York 10278 Mr. stuart Diamond Business / Financial Adjuicatory File NEW YORK TIMES Atoalc safety and Licensing 229 W. 43rd streat Board Panel Docket New York, New York 10036 U.S. Nuclear Regulatory commission Washington, D.C.
20555 4
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NYs
. of Economic Development Alfred E. saith Office Building 17th Floor Albany, New York 12225 (518) 474-1273 By Telecopier alsu By Federal Express By hand delivery
AN 03 'ss 13:51 EE3:cN :0 D.C.T.
STATE OF Ntw YORK Extcutivt CHAwsta
,,,, m ALeaxy laaa4 smw cow.w = mo wan June 3. 1988 Sv Telecopter from Hauppaug K. Dennis Sisk. Zag.
Hunton & Williams P.O. Boz.1535 707 East Main 8treet Richmond. VA 23212
Dear Dennis:
Additional responses of the State of New York to LILCO's realias inter-rotatorias are attached.
I intend to supply a signed verification name week upon ny return to Albany.
I have obtained deposition dates for the State personnel discussed in tha Board's oral ruling of May 10. 1988. James Papile. Janas Saranski and Lawrence Czech will be available for deposition at 1:00 P.M. in Albany on Friday, June 17. 1988. Dr. Azeirod will be available for deposition at 2:00 P.M. in Albany on Thursday. July 7,1988. I will contact you as soon se possible concerning a specific location for the depositions.
Please contact me at your convenienes if there is anything you wish to discuss.
Sincerely.
/
Richard J.
ahnleuter Deputy Special Counsel to the Governor RJZ/ mar Attachments a
_