ML20195D483
| ML20195D483 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/15/1988 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Gleason J, Kline J, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20195D490 | List: |
| References | |
| CON-#288-6559 OL-3, NUDOCS 8806230132 | |
| Download: ML20195D483 (2) | |
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Gleason, Chairman Dr. Jerry R.
Kline By Telecopier Mr. Frederick J.
Shon Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Docket No. 50-322-OL-3 Emergency Planning
Dear Judge Gleason and Members of the Board:
Enclosed, pursuant to the Board's June 10 teleconference Order disposing of realism /best efforts issues, is LILCO's Brief on the Appropriate Remedy for Intervenors' Failure to Comply with Board Orders.
Consistent with the June 10 Order, LILCO has pro-posed in its Brief prompt further discovery restricted to issues over which the Board has retained jurisdiction:
those relating to the existence and production of the Suffolk County Emergency Operations Plan and why it and other accurate information and documents dealing with emergency planning and response, either intended explicitly for Shoreham or adaptable to Shoreham, were not produced before the last few weeks.
e Also being sent to the Board today by LILCO are requests for subpoenas to two former Suffolk County employees, Richard C.
Roberts and William Regan, fcr their testimony on the subject of the Suffolk County Plan and related matters.
LILCO's Brief proposes, at page 26, an eleven-day schedule for the conduct of this discovery by deposition of various pres-ent and former Suffolk County and New York State officials.
Each of these persons had been noticed for deposition as of June 10, when the Board issued its teleconference Order; several of them had been noticed several weeks previously.
Given the past 8806230132 880615 ADOCK 0500 2
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.IUNTON & WILLI AM s June 15, 1988 Page 2 difficulties with scheduling discovery, even pursuant to Board Order, LILCO's Brief proposes specific times and places for each proposed deposition.
The first deposition would commence next Monday, June 20, at 9:00 a.m.
in Albany (Germano); the last would begin at 9:00 a.m. on June 30 in Albany (Axelrod).
LILCO's Brief also notes that on June 7 LILCO served Inter-venors by telecopy with its Third Set of Interrogatories on real-ism /best efforts issues.
These interrogatories cover generally the same subject-matter as the depositions being sought for June 20-30.
LILCO has reason to believe that, in light of the Board's June 10 teleconference Order, Intervenors do not intend to re-spond to these interrogatories absent an explicit order from the Board.
Because of the short time between now and the proposed com-mencement of this discovery schedule, LILCO requests that the Board issue an Order this week, explicitly confirming the June 20-30 deposition schedule and the requirement for responses on June 21 to LILCO's Third Set of Interrogatories.
Respectfully ' submitted, r :.
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Donald P.
Irwin cc w/ enclosures:
Service List
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