ML20214J504
| ML20214J504 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/26/1986 |
| From: | Monaghan J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SUFFOLK COUNTY, NY |
| References | |
| CON-#486-1691 OL-5, NUDOCS 8612010332 | |
| Download: ML20214J504 (5) | |
Text
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at u it.u G0 Hatse0 H DEN Ct Nov mber 26,1986 DOCKETEP
'1% C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'86 NOV 28 P6 :12 Before the Atomic Safety and Licensing b[aEd;,,
1 In the Matter of
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LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S SUPPLEMENTAL RESPONSES TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. 5 2.740(e) of the NRC Rules of Practice, LILCO supple-ments its October 27,1986, Responses and its November 10,1986, Supplemental Re-sponses to Suffolk County's First Set of Interrogatories and Request for Production of Documents.
SUPPLEMENTAL RESPONSES Suffolk County Interrogatory No. 6 Without waiving its prior objections, LILCO supplements its prior responses to SC Interrogatory No. 6. In its November 10,1986, Supplemental Responses, LILCO pro-vided a list of LERO workers present at the EWDF on the day of the Exercise, instead of the roster which it was unable to locate. Since that time, the roster has been locat-ed and is provided with these responses.
Suffolk County Interrogatory Ned Without waiving its prior objections, LILCO supplements its prior responses and identifies the following organizations as participants in the February 13,1986, Exer-cise;(a) KLD Associates;(b)Impell Corporation;(c) the State of Connecticut;(d)
Brookhaven National Laboratory, U.S. Department of Energy; and (e) Institute of Nuclear Power Operations (INPO).
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II.
Suffolk County interrogatory No.11 Without waiving its prior objections, LILCO supplements its responses to SC In-terrogatory No.11 by providing with these responses recently discovered correspon-dence with the United States Coast Guard.
Suffolk County laterrogatory No. 24 Among the post-exercise training documents produced to Suffolk County on November 5,1986, were two drill critiques prepared by Impell Corporation and dated October 31,1986. Af ter LILCO's November 10,1986, Supplemental Responses were filed, a memorandum clarifying certain sections of the October 31 drill critiques was prepared by Impell. A copy of that memorandum is enclosed. Also enclosed are the ob-jectives for the June 6,1986, September 10, 1986, September 17, 1986 and October 1, 1986 drills and some additional player logs from these drills; these documents were re-cently located.
As counsel for Suffolk County is aware, a videotape of the ENC during the October 1 drill was recently discovered. A copy is provided with these responses.
Suffolk County Interrogatory No. 32 Without waiving its prior objections, LILCO is providing a copy of a memoran-dum entitled "LILCO's Response to NRC and FEMA Comments on Emergency Exercise Held on February 13,1986" with these responses.
Respectfully submitted, 0 /A M k / b i
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l f6ssine A. Monaghan LKaren L. Donegan Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 26,1986
ATTACHMENT 1 DOCUMENTS PROTECTED BY ATTORNEY-CLIENT PRIVILEGE OR THE WORK PRODUCT DOCTRINE 1.
Interview Notes By:
Charles A. Daverio Date:
Undated Re:
Notes of interviews with LERO players; prepared in anticipation of litigation Custodian:
Charles A. Daverio Hunton & Williams Recipient:
None Privilege:
Work Product 2.
Timeline By:
Vicki Palmiotto Date:
Undated Re:
Timeline of EBS Messages; prepared in anticipation of litigation Custodian:
Charles A. Daverio Hunton & Williams Recipient:
None Privilege:
Work Product t
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I
LILCO, November 26,1986 HELATED coRRESPONDENCL 00LMEIL!:
CERTIFICATE OF SERVICE UiN"U
'86 NOV 28 P6 :12 In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)CFFict. _.
2 Docket No. 50-322-OL-5 00CKE DW; s.i ^ -
BR A N t.H A
I hereby certify that copies of LILCO'S SUPPLEMENTAL RESPONSES TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRO-DUCTION OF DOCUMENTS were served this date upon the following by Federal Ex-press as indicated by an asterisk, or by first-class mail, postage prepaid.
John H. Frye, III, Chairman
- Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers 4350 East-West Hwy.
Bernard M. Bordenick, Esq.
- Bethesda, MD 20814 Oreste Russ Pirfo, Esq.
Edwin J. Reis, Esq.
Dr. Oscar H. Paris
- U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 7735 Old Georgetown Road Board (to mailroom)
U.S. Nuclear Regulatory Commission Bethesda, MD 20814 East-West Towers 4350 East-West Hwy.
Herbert H. Brown, Esq.
- Bethesda, MD 20814 Lawrence Coe Lanpher, Esq.
Karla J. Letsche, Esq.
Mr. Frederick J. Shon
- Kirkpatrick & Lockhart Atomic Safety and Licensing Eighth Floor Board 1900 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C. 20036 East-West Towers, Rm. 430 4350 East-West Hwy.
Fabian G. Palomino, Esq.
- Bethesda, MD 20814 Richard J. Zahnleuter, Esq.
Special Counsel to the Governor Secretary of the Commission Executive Chamber l
Attention Docketing and Service Room 229 Section State Capitol U.S. Nuclear Regulatory Commission Albany, New York 12224 1717 H Street, N.W.
Washington, D.C. 20555 Mary Gundrum, Esq.
Assistant Attorney General Atomic Safety and Licensing 120 Broadway Appeal Board Panel Third Floor, Room 3-116 U.S. Nuclear Regulatory Commission New York, New York 10271 Washington, D.C. 20555 i
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Spence W. Perry, Esq.
- Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federa1 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 Gerald C. Crotty, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York Stata Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq.
Stephen B. Latham, Esq.
- Eugene R. Kelly, Esq.
Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 NY ine A. Monaghan
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Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 26,1986 7
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