ML20151Y717
| ML20151Y717 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/28/1988 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6205 OL-3, NUDOCS 8805050080 | |
| Download: ML20151Y717 (5) | |
Text
I.$205 LILCO, April 28,1988 (WTED CORPEspoNDENM 000MCIED UtNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION gg gy 2 P(> $2 gr4Cf M We It.* <
OCKEig f HV!Cf.
Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING CONTENTIONS 1-2. 4-8. AND 10 TO SUFFOLK COUNTY AND NEW YORK STATE Pursuant to 10 CFR S 2.742, Long Island Lighting Company, by its counsel, re-quests that Suffolk County and New York State ("Intervenor" or "The Intervenors")
admit or deny, within 10 days of service of this request, the Requests for Admissions contained herein.
INSTRUCTIONS A.
Each request for admission shall be answered separately and fully in writing under oath in accordance with S 2.742 of the NRC's Rules of Practice. To the extent that Intervenors do not have specific, complete, and accurate information with which to answer any request for admission. Intervenors should so state, and the request for admission should-be answered to the extent information is available, identifying each person who is believed to have accurate information with respect thereto.
B.
Each request for admission shall be deemed to be continuing, and Inter-venors are requested seasonably to supplement answers with additional f acts and infor-mation,in accordance with 5 2.740(e)(1) and (2) of the NRC's Rules of Practice.
$$R *$00CK0500032g 00 000Aca O
PDR 3)sd
c s i C.
The words "and" and "or" shall be construed either conjunctively or dis-junctively so as to bring within the scope of these discovery requests any information that might otherswise be construed to be outside their scope.
D.
Wherever appropriate, the singular form of a word shall be interpreted i
in the plural, and vice versa, so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
E.
Wherever appropriate, the masculine form of a word shall be inter-preted as feminine, and vice versa, so as to bring within the scope of these discovery
[
requests any information that might otherwise be construed to be outside their scope.
t F.
If Intervenors object to or claim a privilege (attorney-client, work e
product, or other) with respect to any request for admission, in whole or in part, or seek to withhold any such information because of the alleged proprietary nature of the i
data, please set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the Licensing Board to determine the validity of the objection or claim of privilege.
G.
When, in order to answer a question fully or accurately, it is necessary to distinguish between the responses of individual Intervenors or to identify individual
[
i Intervenors, such distinctions or identifications should be made in the answer.
l DEFINITIONS l
l A.
"LILCO" or "LILCO personnel" means Long Island Lighting Company and any affiliate, agent, employee, consultant, contractor, technical advisor, represen-tative, or other person acting for or on behalf of LILCO, or at LILCO's direction or con-(
l trol, or in concert with LILCO or assisting LILCO.
i l
E l
a~+,n, n,=---
i 3-I B.
"Shoreham" means the Shoreham Nuclear Power Station Unit 1 any part thereof, or any structure, system, component, instrumentation, equipment, or ma-terials included in, or intended to be 11 cluded in, Shoreham.
C.
"Intervenors" means Suffolk County and New York State, or any of them, or any agency thereof and any agent, employee, consultant, contractor, technical advisor, representative or other person acting for or on behalf of them, or at their di-rection and control, or in concert with or assisting them.
REQIJESTS FOR ADMISSIONS 1.
That the enclosed document entitled Suffolk County Radiological Emer-gency Response Plan and dated November 1982 is a true and accurate copy of Volume I of the "Draf t County Radiological Emergency Response Plan" referenced in Suffolk l
County Resolution 111-1983.
2.
That the enclosed document entitled New York State Radiological Emergency Preparedness Plan for Commercial Power Plants is a true and accurate copy of said plan, absent Part III - County Radiological Emergency Preparedness Plans, and j
is the most current revision of said plan. If Intervenors do not so admit, LILCO hereby requests that a copy of the most current revision of said plan be provided promptly.
4 Respectfully submited,
- 3. NYw (JaJnes1. Christman K. Dennis Sisk David S. Harlow Counsel for Long Island Lighting Company l
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond Virginia 23212 DATED: April 28,1988 l
+-
e 9-m-4 m
g e.
e 9
t t
LILCO, April 28,1988 DOCKEIED UW RC l
1B MY -2 P6 42 CERTIFICATE OF SERVICE h77 g
0Chrimu 4 "LovlCf; BRANCH l
In the Matter of LONG ISLAND LIGHTING COMPANY l
(Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S FIRST SET OF REQUESTS FOR ADMIS-S!ONS REGARDING CONTENTIONS 1-2, 4-8, AND 10 TO SUFFOLK COUNTY AND NEW YORK STATE were served this date upon the following by Federal Express as indi-cated by one asterisk, or by first-class mail, postage prepaid.
[
i l
James P. Gleason, Chairman
- Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline
- Adjudicatory File l
Atomic Safety and Licensing Atomic Safety and Licensing l
Board Board Panel Docket i
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East-West Towers, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
L Bethesda, MD 20814 Richard G. Bachmann, Esq.
- U.S. Nuclear Regulatory Commission Mr. Frederick J. Shon
- One White Filnt North i
Atomic Safety and Licensing 11555 Rockville Pike Board Rockville, MD 20852 U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 Herbert H. Brown, Esq.
- l 4350 East-West Hwyr Lawrence Coe Lanpher, Esq.
Bethesda, MD 20814 Karla J. Letsche, Esq.
I Kirkpatrick & Lockhart i
Secretary of the Commission South Lobby - 9th Floor Attention Docketing and Service 1800 M Street, N.W.
i Section Washington, D.C. 20036-5891 U.S. Nuclear Regulatory Commission t
1717 H Street, N.W.
Fabian G. Palomino, Esq.
- Washington, D.C. 20555 Richard J. Zahnleuter, Esq.
j Special Counsel to the Governor t
Executive Chamber Room 229 State Capitol Albany, New York 12224 t
i
I I Alfred L. Nardelli, Esq.
Jonathan D. Feinberg, Esq.
Assistant Attorney General New York State Department of 120 Broadway Public Service, Staff Counsel Room 3-118 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 George W. Watson, Esq.
- Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.
Stephen B. Latham, Esq.
- Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schnelder Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 hh5Lu'
[ DavjMrtfarlow
~
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: April 28,1988