ML20148U461

Notice of Deposition.* Notice of Deposition Upon Oral Exam of DM Crocker on Lilco Proposal for Evacuating School Children from Plant 10 Mile EPZ During Radiological Emergency.Certificate of Svc Encl.Related Correspondence

ML20148U461
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/25/1988
From:	Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:
References
CON-#188-5478 OL-3, NUDOCS 8802040028
Download: ML20148U461 (8)

Text

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pf 79 RELATED 00RRf.SPONDM 00CKEiEO USMC January 25, 1988 UNITED STATES OF AMERICA 8 FEB -1 P5:06 NUCLEAR REGULATORY COMMISSION Befort the Atomic Safety and Licensina Board [0CEd*f';ffk EPADt

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

NOTICLQF DEPOSITION PLEASE TAKE NOTICE that Suffolk County, by counsel, pursuant to 10 CFR S 2.740a of the Nuclear Regulatory Commission's Rules l

of Practice, Will tak.e the deposition upon oral examination of Douglas M. Crocker, on the subject of LILCO's "auxiliary bus driver arrangement" -- that is, LILCO's proposal for evacuating j school children from the Shoreham 10-mile EP2 during a radiological emergency at Shoreham, by using LILCO employees to serve as auxiliary (or backup), and primary school bus drivers, all as more fully describod by LILCO in its "Motion for Sumary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987. The deposition will be taken before a notary public and court reporter on Tuesday, February 2, 1984 at 11:00 a.m. and thereafter until the taking of the deposition may be completed, at the offices of the suffolk County l

i yn

T Attorney, Building 158 North County Complex, Veterans Memorial Highway, Hauppeuge, New York 11788.

The deponent is directed to produce at the deposition, for inspection and copying, any and all documents, including without limitation notes, records, reports, memoranda, correspondence,

, studies, analyses, papers, writings, photographs, recordings, and other materials of any kind or nature whatsoever, in his i

possession, custody or contro1 or in the possession, custody or control of representatives, employees, attorneys, assigns, or 9

anyone acting on his behalf, which are relevant to the issue

) stated above.

I Respectfully submitted, l

i

$$ilxll $$$u' Michael S. Miller J. Lynn Taylor

! Kirkpatrick & Lockhart' 1800 M Street, N.W.

South Lobby - 9th Floor l Washington, D.C. 20036 1

January 25, 1988 j

1 3

i t

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January 25, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board I

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

NOTICE OF DEPOSITION PLEASE TAKE NOTICE that Suffolk County, by counsel, pursuant to 10 CFR S 2.740a of the Nuclear Regulatory Commission's Rules of Practice, will take the deposition upon oral examination of Dennis S. Mileti, on the subject of LILCO's "auxiliary bus driver arrangement" -- that is, LILCO's proposal for evacuating school children from the Shoreham 10-mile EPZ during a radiological emergency at Shoreham, by using LILCO employees to serve as auxiliary (or backup), and primary school bus drivers, all as more fully described by LILCO in its "Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987. The deposition will be taken before a notary public and court reporter on Wednesday, February 3, 1988 at 12:00 noon and thereafter until the taking of the deposition may be completed, at the offices of Kirkpatrick & I

s Lockhart, 1800 M Street, N.W., South Lobby - 9th Floor, Washington, D.C. 20036.

The deponent is directed to produce at the deposition, for inspection and copying, any and all documents, including without limitation notes, records, reports, memoranda, correspondence, studies, analyses, papers, writings, photographs, recordings, and other materials of any kind or nature whatsoever, in his possession, custody or control or in the possession, custody or control of representatives, employees, attorneys, assigns, or anyone acting on his behalf, which are relevant to the issue stated above.

Respectfully submitted, 144u2&

Michael S. Miller J. Lynn Taylor Kirkpatrick & Lockhart 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C. 20036 January 25, 1988

l 4 .  !

i 1

January 25, 1988 '

UNITED STATES OF AMERICA f NUCLEAR REGULATORY COMMISSION l 33, tore the Atomic Safety and Licensina Board

)  ;

In the Matter of )  ;

) i LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3  !

) (Emergency Planning)

(Shoreham Nuclear Power Station, ) [,

Unit 1) ) (

) i, I

NOTICE OP DEPOSITION f I

PLEASE TAKE NOTICE that Suffolk County, by counsel, pursuant ,

to 10 CFR $ 2.740a of the Nuclear Regulatory Commission's Rules '

of Practice, will rake the deposition upon oral examination of  !

Michael K. Lindell, on the subject of LILCO's "auxiliary bus driver arrangement" -- that is, LILCO's proposal for evacuating school children from the Shoreham 10-mile EPZ during a radiological emergency at Shoreham, by using LILCO employees to serve as auxiliary (or backup), and primary school bus drivers, all as more fully described by LILCO in its "Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987. The deposition will be taken before & notary public and court reporter on Thursday, February 4, 1988 at 1:00 p.m. and thereafter until the taking of the deposition may be completed, at the offices of Kirkpatrick &

1 s i

Lockhart, 1800 M Street, N.W., South Lobby - 9th Floor, Washington, D.C. 20036.

3 The deponent is directed to produce at the deposition, for inspection and copying, any and all documents, including without i

limitation notes, records, reports, memoranda, correspondence, studies, analyses, papers, writings, photographs, recordings, and j other materials of any kind or nature whateqever, in his possession, custody or control or in the possession, custody or control of representatives, employees, attorneys, assigns, or i anyone acting on his behalf, which are relevant to the issue f stated above.

I j Respectfully submitted, i

l Y&df/ 7&fw Michael S. Miller j J. Lynn Taylor i

i Kirkpatrick & Lockhart 1800 M Street, N.W.

) South Lobby - 9th Floor i Washington, D.C. 20036

! January 25, 1988 l

l

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en aTFD CORRESPONOLNCA Qq U2h4C January 25, 1988 UNITED STATES OF AMERICA Id Etl ~1 PS :06 NUCLEAR REGULATORY COMMISSION Orrv ..

Before the Atomic Safety and Licensino Board 00CMYUdr;7 MIQ BRANcq

)

In the Matter of )

l

)

l l

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station. )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of NOTICE OF DEPOSITION of Dennis S. M11eti, Michael K. Lindell and Douglas M. Crocker have been served on the following this 25th day of January, 1988 by U.S. mail, first class, except as noted:

James P. Gleason, Chairman

• Mr. Frederick J. Shon

• Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 James P. Gleason, Chairman Dr. Jerry R. Kline

• 513 Gilmoure Dtive Atomic Safety and Licensing Board Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 W. Taylor Revely, III, Esq. ** George E. Johnson, Esq.

• Hunton & Williams Richard G. Bachmann, Esq.

P.O. Box 1535 U.S. Nuclear Regulatory Comm.

707 East Main Street Office of General Counsel Richmond, Virginia 23212 Washington, D.C. 20555 Richard J. Zahnleuter, Esq. ** William R. Cumming, Esq.

• Special Counsel to the Governor Spence W. Perry, Esq.

Executive Chamber, Rm. 229 Federal Emergency Management Agency State Capitol 500 C Street, S.W., Room 840 Albany, New York 12224 Washington, D.C. 20472

't t

Stephen B. Latham, Esq.

Twomey, Latham a Shea 33 West Second Street P.O. Box 298 Riverhead, New York 11901 i

l Michael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobuy - 9th Floor Washington, D.C. 20036-5891 Mailed on January 25, 1988 and By Hand Delivery on January 26, 1988 By Federal Express