ML20147D596

Lilco Second Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers to Suffolk County & State of Ny.* Certificate of Svc Encl.Related Correspondence

ML20147D596
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/13/1988
From:	Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF, SUFFOLK COUNTY, NY
References
CON-#188-5364 OL-3, NUDOCS 8801200228
Download: ML20147D596 (6)

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A j3ft[ LILCO, January 13, 1988 e

'i ?EEATED CORRESP0ffENJg 00CXETED UNITED STATES OF A31 ERICA NUCLEA R REGL LATORY COh! MISSION.

'88 JAN 19 20:27 Before the Atcmic Safety _and Licensing Bgg]: r1/. '

BRANCH In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 30-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station. ) (School Bus Driver Issue)

Unit 1) )

LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO EL'FFOLK COUNTY AND NEW YORK STATE Long Island Lighting Company, by its counsel, propounds the following interroga-tories and requests for documents to Suffolk County and New York State pursuant to 10 C.F.R. SS 2.740, 2.740b, and 2.741. By propounding these interrogato"les and requests LILCO makes no admission or representation about the proper scope of the issues to be decided or the evidence that may be presented.

INSTRUCTIONS AND DEFINITIONS The "Instructions" and "Definitions" for this second set of interrogatories on school bus drivers are tne same ones set out in LILCO's Ficst Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers to Suf folk County and New York State, dated January 3,1988, at pages 1-7.

In addition, the term "bus drivers" as used below refers to people who, as part of their jobs (either part-time or full-time jobs) drive school buses or other buses (for ex-ample, ordinary mass transit buses). The term "school bus drivers" ref ers to people who ,

drive buses to trar. sport students to or f rom public, private, or parochial schools.

8801200228 880113 PDR ADOCK 05000322PDR; O

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The following Requests are numbered beginning where the first set, dated January 5,1988, lef t of f.

INTERROGATORIES AND REQU_ESTS FOR PRODUCTION OF DOCUMENTS Interrogatories

23. Identity by type of emergency, location of emergency, a'.d date of emer-gency all past emergencies (for example, floods, fires, sr )wstorms, or hur-ricanes) known to Intervenors or their Contractors or mentioned in docu-ments in the possession, custody, or control of Intervenors or their Contractors in which bus drivers were called upon to transport people be-cause of the emergency -- for example, to transport school pupils or other members of the public either to their homes (for example, in early dismiss-al of Jehools) or to places of safety away from their homes. Include in "emergencies" any event (for example, snowstorms) that caused a school to dismiss earlier than usual. In each such emergency, how many bus drivers were called upon to transport people because of :he emergency?

24. How many instances are known to Intervenors or their Contractor 3 " ra-ported in documents in their possession, custody, or control of bus drivers, in any emergency, attending to the safety of their own f amilies before re-porting to perform their bus driving duties? For each of the bus drivers who, in an emergency of any Kind, attended to the safety of his own f amily before reporting to perform his bus driving duties, provide the following in-formation:

a. What relationship to the driver (for example, son or wife) was the person or persons whose saf ety the driver attended to before per- ,

forming his bus-driving duties?

b, What was the emergency?

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c. What was the date of the f ailure to perform or delay in performing?

d. What person or what document has the information about the f ailure to perform or delay in performing?

e. For each delay in performing. how long was the delay?

25. Of the school bus drii ers wno serve the schools listed in Attachment i to "LILCO's Slotion for Summary Disposition of Contention 25.C (' Role Con-flict' of School Bus Drivers)," dated October 22, 1987, how many have other members of their f amilies living in the Shoreham ten-mile EPZ?

26. When the school bus drivers who serve each of the schools specified in At-tachment I to "LILCO's Alotion for Summary Disposition of Contention 25.C (' Role Conflict' cf School Bus Drivers)," dated October 22.1987, are trained for their jobs, what are they told about

a. Dealing with emergencies of any kind?

b. Performing their duties when schools dismiss early?

c. Caring for their own f amilies in cases of early school dismissals or emergencies?

d. Providing notice to the school or bus compan) when they will not perform their jobs?

27. When bus drivers are trained to drive buses for radiological emergency plans for nuclear plants in New York State other than Shoreham, what are they told about caring for their f amilies in emergencies?

23. Please list all New York State and Suffolk County agencies, personnel, and Contractors who were asked to provide the information to respond to this Second Set of Interrogatories and Requests.

Document Requests s

29. Please provide an up-to-date copy of all early dismissal and/or emergency plans for each of the senools identified in Attachment 1 of "LILCO's Slotion

,, 's for Summary Dispositloc of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated Octo'ser 22,1987.

30. Please provide a copy of all documents used in preparing the answers to Requests 23-28 atove.

. AY j' James N. Chriftman Mary Jo Leugers Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 13,1988 l

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'l LILCO, January 13,1988 00LKETED USNnC y aml 19 NO:29

_ CERTIFICATE OF SERVICE ,

f0 1C l I SRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO SUFFOLK COUNTY AND NEW YORK STATE were served this date upon the following by telecopier as indicated by one asterisk, by Feder-al 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 Coc Lanpher, Esq.

1 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 f 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

l 1 l t s 1 Alfred L. Nardelli, Esq. Jonathan D. Feinberg, Esq.

Assistant Attorney General i 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 a .

/ James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 13,1988