ML20207M041

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NRC Staff Response to Lilco Motion for Discovery of NRC Staff.* Forwards NRC Answers to Lilco 861219 Interrogatories Re Request for Documentation Used in Interpreting Meaning of Phrase Full Participation
ML20207M041
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 01/05/1987
From: Bordenick B
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20207M045 List:
References
CON-#187-2119 OL-5, NUDOCS 8701130069
Download: ML20207M041 (2)


Text

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01/05/87 00CKETED usnac UNITED STATES OF AMERICA

'87 JAN -7 All :39 NUCLEAR REGULATORY COMMISSION OFFitE r.i BEFORE TIIE ATOMIC SAFETY AND LICENSING BOAR 15h b ;E ""

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322-OL-5

)

(EP Exercise)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

NRC STAFF RESPONSE TO "LILCO'S MOTION FOR DISCOVERY OF THE NRC STAFF" LILCO, pursuant to 10 C.F.R. 5 2.720(h)(2)(ii) and (iii), on December 19,

1986, requested the Licensing Board to require the NRC Staff to respond to two discovery requests and to produce one or more knowledgeable NRC employees of the Staff's choice for deposition.

LILCO asserted that answers to these requests are necessary for a proper s

decision in this proceeding and are not obtainable elsewhere.

Specifically, LILCO sought responses to the following two discovery requests:

1.

Please identify and provide copies of any documents, other than NUREG-0654 and actual FEMA post-exercise assessment reports, reHed upon or used by the NRC Staff in interpreting the meaning of the phrase " full i

participation" as that phrase is used in 10 C.F.R. Part

'l 50, App. E(IV)(F) and footnote 4 thereto.

2.

Please identify NRC Staff personnel who are familiar

. with the Staff's interpretation of the phrase " full participation."

In addition, as noted above, T.ILCO requested that the Board instruct the Staff to produce one or more of the Staff employees identified in response to the second interrogatory for deposition.

h gf 8701130069 870105 PDR ADOCK 05000322 y

G PDR

i.

N The NRC Staff is filing its responses to the LILCO Interrogatories, herewith.

In

addition, the Staff will make available the Staff employees identified in response to the second interrogatory for deposition.

See Attached NRC Staff Answers to LILCO Interrogatories of December 19, 1986.

The time and place for such deposition will be arrived at after discussion with counsel for LILCO.

The Board and other parties will be promptly notified of the time and place of any such deposition.

Respectfully submitted,

%% 8'h M/d Bernard M. Bordenick Counsel for NRC Staff Dated at Bethesda, Maryland this 5th day of January,1987

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