ML20147D585

Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers to Town of Southampton.* Certificate of Svc Encl.Related Correspondence

ML20147D585
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/15/1988
From:	Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	SOUTH HAMPTON, NH
References
CON-#188-5365 OL-3, NUDOCS 8801200223
Download: ML20147D585 (4)

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i LILCO, January 15,1988 C0CKETED U5NFC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1B JAN 19 N0:26 OFFICE Di 5f Ch Iti' 00CKE TING .'. SEbvif.E 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, ) (School Bus Driver Issue)

Unit 1) )

LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCIIOOL BUS DRIVERS TO Tile TOWN OF SOUTIIAMPTON Long Island Lighting Company ("LILCO"), by its counsel, propounds the following interrogatories to the Town of Southampton pursuant to SS 2.740, 2.740b, and 2.741 of the Nuclear Regulatory Commission's Rule of Practice. By propounding these interrog-atories, LILCO makes no admission or representation about the proper scope of the is-sues to be decided or the evidence that may be presented.

1. Will the Town of Southampton sponsor any witnesses on any factors con-cerning "whether, in light of the potential for role conflict, a sufficier.t number of school bus drivers can be relied upon to perform emergency evacuation duties," Memorandum and Order (Ruling on Applicant's Motion of October 22,1987 for Summary Disposition of Contention 25.C Role Con-f!!ct of School Bus Drivers)(December 30,1987) at 5, or attempt to intro-duce any evidence, other than that which will be presented by Suffolk County or the State of New York?

8801200223 880115 PDR ADOCK 05000322 0 PDR t --

2. If the response to Interrogatory No.1 is anything other than no, please an-swer all questions propounded and produce all documents requested in LILCO's First and Second Set of Interrogatories and Requests for Produc-tion of Documents Regarding Role Conflict of School Bus Drivers to Suffolk County and the State of New York.

Respectfully submitted, W _

fiaW4Cf^

liunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 15, 1988

LILCO, January 15, 1988 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING CO51PANY (Shoreham Nuclear Power Station Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO THE TOWN OF SOUTHAMPTON were served this date upon the following by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.

James P. Gleason, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline George E. Johnson, Esq. **

Atomic Safety and Licensing Richard G. Bachmann, Esq.

Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 11555 Rockville Pike East-West Towers, Rm. 427 One White Flint North 4350 East-West Hwy. Bethesda, MD 20814 Bethesda, MD 20814 Herbert H. Brown Esq. **

Mr. Frederick J. Shon Lawrence Coe Lanpher, Esq.

Atomic Safety and Licensing Karla J. Letsche, Esq.

Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.

4350 East-West Hwy. Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.

• Secretary of the Commission Richard J. Zahnleuter, Esq.

Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W. State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

. 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 Spence W. Perry, 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 Gerald C. Crotty, 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 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 MAed la J Hunton & Williams 707 East Main Street P.O. Box 1535

Richmond, Virginia 23212 i

j DATED: January 15,1988 l

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