ML20148D392
| ML20148D392 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/19/1988 |
| From: | Taylor J KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#188-5402 OL-3, NUDOCS 8801250381 | |
| Download: ML20148D392 (27) | |
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QECATED CORRESP0jiDEJSPJ 000Mtito USHI?c January 19, 1988 10 JM 22 P2:19 UNITED STATES OF AMERICA 0FFICE 0; 3agg gg y NUCLEAR REGULATORY COMMISSION 00CMEi:NG 4 SEi'Vicr' BRANCH Before the Atomic Safety and Licensina Board
)
In the Matter of )
) Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY ) (Emergency Planning
)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS On January 5, 1988, LILCO filed its "First Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers to suffolk County and New York State" ("First Request"). Pursuant to 10 CFR S 2.740b, Suffolk County (the "County") hereby responds to LILCO's First Request.
I. GENERAL RESPONSE A. All documents identified in these Answers will be provided within the time allotted by the NRC's Rules of Practice, to the extent the County does not object to their production.
8801250381 880119 PDR ADOCK O g2 $
t B. The County hereby objects to LILCO's interrogatories and document requests to the extent they seek information or documents outside of the possession, custody or control of the County.
II. ANSWERS TO INTERROGATORIES AND DOCUMENT REOUESTS Identification of Witnesses LILCO Interrocatory No. 1
- 1. Please identify each witness Intervenors expect to call to testify on any factors concerning "whether, in light of the potential for role conflict, a sufficient 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 Conflict" of School Bus Drivers) (December 30, 1987) at 5. For each witness, other than experts, that Intervenors expect to call, state the subject matter on which he is expected to testify and the substance of the facts to which he is expected to testify. For each witness that Intervenors expect to call as an expert witness, state the subject matter on which he is expected to testify, the substance of the facts and opinions to which he is expected to testify, and the summary of the grounds for each such opinion.
Answer. At this time, the County has identified one witness, Stephen Cole, whom it expects to testify on the County's behalf at the hearing ordered by the Board in its December 30 Memorandum and Order. The County is currently in the process of identifying other witnesses who may be called to testify at the hearing. When such witnesses are identified, the County will e
promptly notify ~LILCO and the County's Answers will be supplemented accordingly.
Professor Cole has testified in previous Shoreham emergency planning hearings and thus is well known to LILCO. He is expected to offer testimony regarding surveys of Suffolk County bus drivers and firemen he conducted in 1982. Copies of those surveys were provided to LILCO in connection with the prior role conflict proceeding. Professor Cole will testify that the results of those surveys support the Governments' contention that role conflict will substantially reduce the number of available bus drivers in the event of a radiological emergency at Shoreham.
Professor Cole may also offer testimony about the nature and causes of role conflict and the factors existing on Long Island which could lead to role conflict among emergency workers, including school bus drivers, during a Shoreham accident. Apart from the surveys noted above, his testimony will be based upon 1
his general knowledge of literature in the field, and contacts with other experts on the subject. Further research, analysis and investigation by Professor Cole may lead to further bases for the testimony described above and testimony on additional matters not yet known to the County.
LILCO Interroaatorv No. 2
- 2. For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional qualifications.
Answer. A copy of Professor Cole's current vitae is attached to this response.
LILCO Interrocatory No u_1
- 3. Please list any NRC, legislative, or other legal proceeding in which each witness has testified on any matter concerning role conflict or school evacuations during disasters or emergencies.
Answer, Professor Cole has previously testified in the f Shoreham hearings on the topic of role conflict among Emergency personnel. He has not appeared as a witness in any other proceeding on the subject topics.
LILCO Interrocatory No. 4
- 4. Please provide a copy of any prefiled testimony listed in response to Interrogatory 3 above.
Answer. Professor Cole's prefiled testimony was provided to LILCO in connection with earlier hearings on the role conflict issue.
LILCO Interrocatory No. 5
- 5. Please identify all articles, papers, and other documents authored or coauthored by each witness on the subject of role conflict or school evacuations during disasters or emergencies.
1
Answer. . Professor Cole has conducted and documented two surveys on the issue of role conflict. Those surveys, referenced above, have already been provided to LILCO. In additien, Professor Cole discusses role conflict in his sociology textbook, The Sociolooical Orientation (2d ed., Harper & Row). The book is generally available to the public and thus will not be provided by Suffolk County.
LILCO Interrogatory _No2_E
- 6. Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses, or other documents with respect to any of the following:
(a) Role conflict during large-scale disasters or emergencies especially concerning, but not limited to, school bus drivers or other persons who traditionally do not have emergency roles during emergencies.
(b) School evacuations or plans for school evacuations for disasters or emergencies, including, but not limited to, a Shoreham emergency.
Answer. Egg Answers to Interrogatory Nos. 1 and 3-5 above.
Additional research and analysis by Professor Cole may result in further written studies, reports, analyses or other such documents.
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LILCO Interrocatory No. 7
- 7. Unless the answer to. Interrogatory 6 above is a simple negative, please identify'and provide a copy of each document.
Answer. Egg Answer to Interrogatory Nos. 5 and 6 above.
Identification of Information LILCO Interrogatory No. 8
- 8. Pleare identify the number of students currently enrolled at each school located in the 10-mile EPZ for Shoreham as identified in "LILCO's Motion for Summary Disposition of Contention 25.C ("Role Conflict" of School Bus Drivers) (October 22, 1987) (hereinafter "Motion") at Attachment 1, and the source of this information. Identify which of these schools are on split sessions and provide the current number of ,
students in attendance during each split session for t each school.
! Answer. The information requested by this Interrogatory is not within the possession, custody or control of the County. On information and belief, such information is in the possession, custody or control of the school districts which govern the schools at issue. The school districts are separate and distinct political entities from the County.
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o LILCO'Interrocatory No. 9
- 9. Please identify each and every bus company that contracts with each school identified.in LILCO's Motion at Attachment 1 to transport school children. For each '
school, specify which bus companies provide buses and drivers.
Answer. Egg Answer to Interrogatory No. 8 above.
LILCO Interrocatory No. 10
- 10. Identify the number of school bus drivers under contract to or on the payroll of each school and school district in the EPZ identified in LILCO's Motion at Attachment 1. Specify the number of drivers that are designated for each school.
Answer. Egg Answer to Interrogatory No. 8 above.
LILCO Interrocatory No. 11
- 11. Identify any contacts and communications the Intervenors have had with any school or school district in the EPZ regarding evacuation of those schools during a Shoreham emergency. Include, for each contact and communications, the school or school district contacted and the person talked with, the date of each contact, and the substance of each conversation. Please produce any documents related to such contacts.
Answer. The County objects to this Interrogatory to the extent it seeks contacts and communications by counsel protected from disclosure by the attorney work product privilege, i
-7_
I Notwithstanding this objection, and without waiving any privilege that may apply, the County states that aside from those associated with testimony preparation and the hearing on schools issues in 1983-84, there have been no such contacts or communications between the County and any school or school district in the EPZ regarding evacuation of those schools during a Shoreham emergency.
LILCO Interrocatory No. 12
- 12. Identify any contacts the Intervenors have had with any bus companies under contract to the schools and school districts in the EPZ regarding evacuation of those schools during a Shoreham emergency. Include, for each contact, the bus company contacted and the person talked with, the date of each contact, and the substance of each conversation. Please produce any documents related to such contacts.
Answer. The County objects to this Interrogatory to the extent it seeks contacts by counsel protected from disclosure by the attorney work product privilege. Notwithstanding this objection, and without waiving any privilege that may apply, the County states that aside from those associated with Dr. Cole's previous survey of school bus drivers discussed in Dr. Cole's previously filed testimony, there have been no such contacts between the County and any bus companies under contract to the schools and school districts in the EPZ regarding evacuation of those schools during a Shoreham emergency.
a LILCO Interrocatory No. 13
- 13. Identify any contacts the Intervenors have had with any bus companies on Long Island, to the extent not identified in Interrogatory 13, regarding evacuation of those schools during a Shoreham emergency. Include, for each contact, the bus company contacted and the person talked with, the date of each contact, and the substance of each conversation. Please produce any documents related to such contacts.
&qwer. The County objects to this Interrogatory to the extent it seeks contacts by counsel protected from disclosure by the attorney wotx product privilege. Notwithstanding this objection, and without waiving any privilege that may apply, the County states that there have been no such contacts between the County and any bus companies on Long Island regarding evacuation of the schools and school districts in the EPZ during a Shoreham emergency. See also Answer to Interrogatory No. 12.
LILCO Interrocatory No. 14
- 14. Identify any contacts the Intervenors have had with any school bus drivers on the payroll of or under contract with schools or school districts in the EPZ regarding evacuation of those schools during a Shoreham emergency. Identify, for each contact, the person talked with, the date of each contact, and the substance of each conversation. Please produce any documents related to such contacts.
Answer. The County objects to this Interrogatory to the extent it seeks contacts by counsel protected from disclosure by the attorney work product privilege. Notwithstanding this
objection, and without waiving any privilege that may apply, the County states that on June 23, 1986, Messrs. Herbert Drown and Lawrence Lanpher of Kirkpatrick & Lockhart met with school bus driver association representatives on Long Island. LILCO-personnel and attorneys were also present at that meeting.
Except as stated in the Answer to Interrogatory No. 12, there have been no other contacts between the County and any school bus drivers on the payroll of or under contract with schools or school districts in the EPZ regarding evacuation of those schools during a Shoreham emergency.
LILCO Interrocatory No. 15
- 15. State, for all nuclear power plants in New York State other than Shoreham, whether schools and school districts in the EPZs for those plants plan to evacuate school children in a single wave or in multiple waves.
In responding to this request, identify this information on a county-by-county basis for each nuclear power plant in New York.
Answer. Without conceding the relevance of the information sought, Suffolk County states that the requested information is no F. within the possession, custody or control of the County. To the extent such information is in the emergency plans for those other plants, such information is as accessible to LILCO as it is to the County.
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o LILCO-Interrocatory No. 16
- 16. State, for all nuclear power plants in New York State other than Shoreham, whether schools and school districts in the EPZs for those plants plan to use bus drivers to evacuate school children in addition to-school bus drivers ordinarily on the payrolls of or under contract to these schools and school districts.
In responding to this request, identify this information on a county-by-county basis for each nuclear power plant in New York.
Answer. Egg Answer to Interrogatory No. 15 above.
LILCO Interrocatory No. 17
- 17. For the additional bus drivers, if any, identified in response to Interrogatory 16 above, identify the type of training the bus drivers receive and the laws, regulations, and ordinances that govern the use of these additional bus drivers to evacuate school children during a radiological emergency.
Answer. Eeg Answer to Interrogatory No. 15 above and No. 21 below.
Identification of Other Documents LILCO Interrocatory No. 18
- 18. Please identify and provide a copy of any document not already identified in response to Interrogatories 7 and 11-14 above on which Intervenors intend to rely in support of their position on the issue of whether there will be a sufficient number of school bus drivers to evacuate schools during a Shoreham emergency.
Answer. At this time, the County has not identified any documents on which it intends to rely, other than the surveys referenced above. To the extent any additional, non-privileged documents responsive to this Interrogatory are identified, they will be produced on a timely basis by the County. Similarly, to the extent any dccuments responsive to this Interrogatory are identified but not produced by the County because of privilege, such documents and tt:e nature of the privilege claimed will be sufficiently described to permit the Licensing Board to determine the validity of the claim of privilege.
Alleged Deficiencies in LILCO's Proposal to Use LERO School Bus Drivers to Evacuate Schools in the EPZ LILCO Interrocatory No. 19
- 19. Please list each and every factor that Intervenors claim might make LILCO's proposal to evacuate all schools in the EPZ in a single wave unworkable and inadequate to protect the public health.
Answer. The County believes that the following factors render LILCO's proposal to evacuate all schools in the EPZ in a single wave unworkable and inadequate to protect the public health:
- a. LILCO lacks the legal authority to implement its school evacuation proposal;
- b. The school districts have not agreed to LILCO's proposal, nor is there any assurance that the school districts could or would do so;
- c. The school bus drivers on the payroll of or under contract to the school districts have not agreed to LILCO's proposal, nor is there any assurance that they would do so;
- d. Neither the LILCO Plan, nor LILCO's school evacuation proposal, specifies the location of relocation / reception centers to which LILCO proposes to transport school children;
- e. LILCO's proposal fails to indicate the amount of time necessary to accomplish an evacuation of school children out of the EPZ;
- f. LILCO lacks the capability and the legal authority required to train adequately the LERO personnel necessary to its proposal; I
- g. LILCO's proposal fails to specify how LILCO could or would recruit, train and license its 562 employees who would serve as bus drivers; l
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- h. LILCO has not entered into contracts to secure the 562 buses LILCO states would be needed to transport school children, nor is there any assurance that such buses are even available;
- i. LILCO has not specified how additional LERO bus drivers would be recruited and what qualifications they would be required to meet;
- j. LILCO has not indicated how the LERO bus drivers would or could be notified, mobilized, preassigned to bus yards, dispatched, coordinated and controlled;
- k. LILCO has not indicated how it would attempt to implement either an early dismissal or an evacuation of school children out of the EPZ; and
- 1. LILCO has not indicated whether it has even considered the impact on the implementability of its Plan of having 562 additional personnel to mobilize, dispatch, communicate with, supervise, coordinate, manage, and control.
Discovery and further investigation and analysis of LILCO's new school svacuation proposal, including review of Rev. 9 of the Plan if and when it is issued, may reveal additional factors l
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4 which, in the County's opinion, would make LILCO's proposal unworkable and inadequate to protect the public health.
LILCO Interrocatory No. 20
- 20. To the extent not covered by the answer to Interrogatory 19 above, please list every respect in which Intervenors claim that LILCO's procedures for using auxiliary school bus drivers to evacuate school children are inadequate.
Answer. Egg Answer to Interrogatory No. 19 above. Further, it is impossible to provide a complete answer until the LILCO procedures referenced in Interrogatory 20 are identified and produced to the County for review.
LILCO Interrocatorv No. 21
- 21. Please list each and every State and local law, regulation, or ordinance that Intervenors claim might make LILCO's proposal to evacuate schools in the EPZ in a single wave illegal.
Answer. At this time, the County has determined that LILCO's proposal may violate the following State law provisions:
Sections 3623 and 3624 of the Education Law; Section 3635 of the Transportation Law; Part 156 of Title 8 of the Official Compilation of Codes, Rules and Regulations of the State of New i York; Part 6 of Title 15 of the Official Compilation of codes, i Rules and Regulations of the State of New York.
l Further research, analysis and discovery may reveal additional State and/or local laws, regulations and ordinances that would be violated by LILCO's proposal.
LILCO Interrocatory No. 22
- 22. Please list each and every State and local law, regulation, or ordinance that the Intervenors claim that LILCO must satisfy to use auxiliary school bus drivers and buses to evacuate school children during a Shoreham emergency.
Answer. Egg Answer to Interrogatory No. 21 above.
OBJECTIONS STATED BY COUNSEL .
All objections and assertions of privilege, or reference thereto, were stated by counsel.
A
- u. % u n aulo, c/ MichajlSrMi'ller
(',-JfLyynTaylorV 9
KIRKPATRICK & LOCKHART i 1800 "M" Street, N. W.
South Lobby - Ninth Floor Washington, D. C. 20036-5891 Attorneys for Suffolk County January 19, 1988 4
l e.
VERIFICATION Frank P. Petrone, being duly sworn, deposes and says: that he is currently the Special Assistant to the Suffolk County Executive; that he has been involved in matters related to the Shoreham Nuclear Power Plant since January 1987; that he has read the County's Answers to LILCO's First Set of Interrogatories and Document Requests Regarding Role Conflict of School Bus Drivers and know the contents thereof; that the facts stated in the County's Answers are based on his personal knowledge or on reasonable inquiry of appropriate County personnel, as well as on
- additional information provided by counsel; and that he believes the matters stated therein to be true to the best of his knowledge and belief, and therefore verifies the foregoing on behalf of Suffolk County.
J
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( f rank P. Petrone State of New York ) SS:
I, k m d A G . T W J L o,4. , a Notary Public in and for the jurisdiction aforesaid, hereby certify that Frank P. Petrone, whose name is signed to the foregoing Answers to Interrogatories, dated January 19, 1988, has personally sworn before me that the statements therein are true to the best of his knowledge and belief.
- W L Y~) ( U l _ 0 b ( L 4 0 0 G
/ Notary PubfiC (11 A C. TAYLOR NOTARY PUBUO State of New York My Commission expires:
rio. s2 4sisiss.ss<4 w ccurn, Commission Expres My 31,1911 l
l VITA l
Stephen Cole I Birth Date.
June 1 1941 Home Address 23 Mt. Grey Road Stonybrook, New York 11790 Phone: 516-751-6588 Office Address.
State University of New York at Stony Brook Department of Sociology Stony Brook, New York 11794 Phone- 516-632-7732 Education:
B.A., Columbia College, 1962 Ph.D., Columbia University, 1967 Academic Appointments:
1964 Lecturer, Barnard College 1965 Lecturer, Columbia University 1966-67 Instructor of Sociology, Columbia University 1966-76 Researcl. Associate, Bureau of Applied Social Research, Columbia University 1967-68 Assistant Professor, Department of Sociology, Columbia University 1968-70 Assistant Professor, Department of Sociology, State University of New York at Stony Brook 1970-73 Associate Professor, Department of Sociology, State University of New York at Stony Brook 1973-Present Professor, Department of Sociology, State University of New York at Stony Brook 1977-Present Research Associate, Center for the Social Sciences, Columbia University 1987 Visiting Profesor, Institute of Sociology, University of Warsaw, Poland Ho no r a r y,,S,o,c i_e_t i e s a nd Awa r d s -
1962 Phi Beta Kappa, Magna Cum Laude, Columbia College 1962 Honorary Woodrow Wilson Fellow 1962-63 National Science Foundation Fellow
! 1963-66 National Institutes of Health, Public Health Service Fellow 1963 Bobbs-Merrill Award l 1965-66 John W. Burgess Honorary Fellow of the Faculty of Political Science, Columbia University 1971-72 Ford Foundation Faculty Research Fellow 1976-Present Sociological Research Association i
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Page 2 Honorary Societies and Awards (continued...)
1978-79 Guggenheim Foundation Fellowship 1978-79 Fellow, Center for Advanced Study in the Behavioral Sciences, Stanford, California 1980 Presented annual paper at Sociological Research Association Dinner 1984-Present SUNY Faculty Exchange Scholar Professional Activities _:
From 1966 to the present I have served as a consultant to the following organizations on various applied sociological research projects.
1966-68 Social Welfare Research Council, CUNY 1970-71 Center for Research on the Acts of Man, Un.'.versity of Pennsylvania 1973-present Newsday 1973-79 Committee on Science and Public Policy (COSPUP),
National Academy of Sciences 1977 Brookhaven National Laboratories 1978 The Baltimore Sun 1979 National Bureau of Economic Research 1981 Long Island Lighting Company 1982 The Boston Globe 1982-83 University of California at Irvine 1984 State of California 1982-present Suffolk County (New York) 1987 Commonwealth of Massachusetts I have also served on the editorial boards of the following journals: Sociology of Education, Sociological Quarterly.
American Journal of Sociology. Th'e American Sociologist.
I have served as a referee for more than a dozen other journals, for the National Science Foundation, the National Institutes of Health, the National Institute of Education, as well as other public and private granting agencies.
Over the last fifteen years I have presented more than 40 invited lectures at professionr1 conferences and educational institutions all over North America and in Europe.
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Page 3 Publications.
BOOKS 1969 The Unionization of Teachers: A Case Study of the ~
UPT. New York: Praeger Press. (ReprTnted by Arno Press, 1980).
1972 T_he Sociological Method- 1980, 3rd enlarged edition. New York: Harper and Row 1973 Social Stratification in Science (with Jonathan R. Cole). Chicago: The University of Chicago Press. (Paperback edition published in 1981) .
Translated into Chinese by Gu Xin Light Daily Press, 1988 (with a new introduction).
1975 The Sociological orientation. 1979 2nd enlarged edition. New York: Harper and Row 1978 Peer Review in the National Science Foundation Phase I- (with Jonathan R. Cole and Leonard nubin).
Washington, D.C. National Academy of Sciences.
1981 Peer Review in the National Science Foundation' Phase II (with Jonathan R. Cole). Washington, D.C.: National Academy of Sciences.
1988 Social Influences on the Growth of Scientific Knowledge (with Jonathan R. Cole). Cambridge:
Harvard University Press. (forthcoming)
PAPERS (an asterisk indicates a refereed journal) 1961 "The Charitable Impulse in Victorian England "
King's Crown Essays 9 3-28.
1964 "Inventory of Empirical and Theoretical Studies of Anomie" (with Harriet A. Zuckerman). In Marshall Clinard ( Ed . ) , Anomie and Deviant Behavior. New York. Free Press, pp. 24323f3.
- 1967 "Scientific output and Recognition: A Study in the operation of the Reward System in Science" (with Jonathan R. Cole), American Sociological Review 32, 377-390. Reprinted as a Bobbs-Merrill Reprint and as an XIP Publication.
Page 4 PAPERS Continued....
- 1968 "Visibility and the Structural Bases of Awareness in Scientific Research" (with Jonathan R. Cole),
American Sociological Review 33, 397-413.
- 1968 "The Unionization of Teachers Determinants of Rank-and-File Support," Sociology of Education 41, 66-87 Reprinted in Donald A. Erickson (Ed.),
Educational Orgar.ization and Administration.
Berkeley: McCutchin~ Publishing CorporatToii~ 1977.
- 1969 "Teacher's Strike: A Study of the conversion of Predisposition into Action," American_ Journal of Soci_ ology 74, 506-520. Reprinted as Warner Modular Publication R809 Reprinted in Donald Gerwin (Ed.), The Employment of Teachers, Some Analytical Views. Berkeley: McCutchan Publishing Corporation, 1974.
- 1969 "Determinants of Faculty Support of Student Demonstrations" (with Hannelore Adamsons),
Sociology of Education 42, 315-329.
- 1970 "Professional Status and Faculty Support of Student Demonstrations" (with Hannelore Adamsons),
Public Opinion Quarterly 34, 389-394.
- 1970 "Professional Standing and the Reception of Scientific Papers," American Journal of Sociology, 76, 280-306. Reprinted as Bobbs-Merrill Reprint S-678. Reprinted in B.T. Eiduson and L. Beckman (Eds.), Science as a Career Choice. New York Russell Sage Foundation, 1973, pp. 499-512.
Reprinted in P. Weingart (Ed.),
Wissenschaftssoziologie I. Athenaeum Verlag, 1973.
- 1971 "Measuring the Quality of Sociological Papers"
< (with Jonathan R. Cole) American Sociologist
- 13-29.
l 1972 "Continuity and Institutionalization in Science: A Case Study of Pailure." In Anthony Obserschall (Ed.), The Es_tablishment of Empirical Sociology.
New York: Harper and Row, pp.73-129. Reprinted in Wolf Lepennies (Ed.), Geschichte der Soziologie Suhrkamp Verlag (Frankfurt am Main), vol. 4,31-110, 1981.
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Ptga 5 PAPERS Continued....
- 1972 "Illness and the Legitimation of Failure" (with Robert Lejeune), American Sociological Review 37, 347-356. Reprinted in Leo G. Reeder (Ed.), , Hand-book of Scales and Indices of Health Behavior, 1977.
Reprinted in Cary S. Kart (Ed.), Dominant Issues in Medical Sociol,ogy. (First edition) Reading, Mass ?
Addison Wesley Publishing Co., 1977. (Second Edition) 1986. Reprinted in Howard Robboy and Candice Clark (Eds.), Social Interaction, St. Martin's Press, New York, 1986.
- 1972 "The Ortega Hypothesis" (with Jonathan R. Cole),
Science 178 (October), 368 375. Reprinted in Eire Gebhardt, Socio).ogy of Science. New York:
Seabury Press, 1930.
1975 "The Growth of Scientific Knowledge: Theories of Deviance as a Case Study." In Lewis Coser (Ed.),
The Idea of Social Structure: Papers in Honot of Robert K. Merton. New York: Harcourt. Brace, Jovanovich, pp.'~175-220.
1976 "The Reward System of the Social Sciences" (with Jonathal R. Cole). In Chsrles Frankel (Ed.),
Controversies and Decisions: The Social Sciences and Public' Policy,. New York: Russell Sage, '
l p;. . 55-88.
1 l 1977 "Peer Review in the American Scientific Community" l
(with Jonathan R. Cole and Leonard Rubin),
Scientific American 237, No. 4 (October), 34-41.
1978 "Measuring the Cognitivt Statt of Scientific Disciplines" (with Jonathan R. Cole and Lorraine Dietrich). In Yenuda Elkana, Robert K. Merton,
~
Arnold Thackray, and Harriet A. Zuckerman (Eds.),
Toward a Metric of Science: The Advent of Science ind'icators7 New York: John Wiley.
1978 "Scientific Reward Systtas: A Comparative Analysis." In Robert Alun Jones (Ed.), Research I in the Sociology _of Knowledge, Science, and Art.
Greenwich, Conn.: Johnson Associates, Inc.
l pp. 167-190.
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l Pago 6 PAPER,S, Continued....
- 1979 "Which Researcher Will Get the Grant?" (with J. R. Cole), Nature 279, 575-576.
1979 "Comment on a paper by Michael overington," The American Sociolqqist 14 (February), 17-19.
- 1979 "Age and Scientific Performance," American Journal of Sociology 84, 958-977.
1980 "Comments on ' Indicators of Scientific Manpower',"
Scientometrics, Vol. 2, No. 5-6, pp. 405-409.
Translated Int'o Russian, 1997.
1981 "The Functions of Classical Theory in contemporary Sociological Research" (with K. Adatto). In F. Kuklick (Ed.), Research in the Sociology of Knowledge, Science, and Art III,. Greenwich, Conn.: Johnson Associates, Inc.
- 1981 "Chance and Consensus in Peer Review," (with J. R. Cole and G. Simon), Science 214, (20 November 1981), 881-886.
- 1982 "NSF Peer Review (continued)" (with J.R. Cole and Gary Simon) Science, 215 (22 January, 1982) 344-8.
- 1963 "The Hierarchy of the Sciences?", American Journal of_ Sociology 89, 111-139. Translated into Polish in J. Niznika, ed. Rozwoj nauki a spoleczny kontekst poznania Warsaw
- Panstowowe Wydawnictwo Naukowe, 1987
- 1984 "Little Science Big Science Revisited,"
Scientometrics (with G.S. Meyer) 7, 443-458 1984 "Experts' Consensus and Decision Making at the l Mational Science Foundation," (with J. R. Cole) in Kenneth Warren, Selectivity and Information Systems: Survival of the Fittest, (New York:
l Praeger Science P'6511shers)
- 1986 "Sex Discrimination and Admission to Medical School: 1929-1984,"
American Journal of Sociology, 92 (549-567).
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,, Page 7 PAPERS Continued....
1987 "Formation of Public Opinion on Complex Issues The Case of Nuclear Power" (with R. Fiorentine) in H. O'Gorman, ed.
Surveying Social Life Essays in Honor of Herbert Hyman (Middletown, Conn.: Wesleyan University
~~
H.
Press)in press.
- 1987 "Testing the Ortega Hypothesis: Milestone or Millstone?" Scientometric" (with J.R. Cole) 12, 327-335 (Entire issue ' devoted to examination of 1972 paper "The Ortega Hypothesis.")
- 1988 "Do Journal Rejection Rates Index Consensus? A Reply to Hargens." American Sociological Review (with G. Simon and J.R. Cole) forth-coming in February issue.
1988 "Discrimination Against Women In Science:
The Confusion of Outcome with Process,"
(with R. Fiorentine), J. R. Cole and H. A.
Zuckerman, eds. Women in Science (Nett York:
Norton), in press.
1988 "Confusing Outcome with Process in the Analysis of Sex Discrimination" reply to Grosse (with R. Fiorentine) American Journal of Soctology, forthcoming.
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00(.KE TED January 19,Ihb8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 18 JMi 22 P219 Before the Atomic Safety a nd Lice n s i no BcEEd'! Ui H.( Rt. iAn y vant imG !. Scavict' BRANCH
)
In the Matter of )
)
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 SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have been served on the following this 19th day of January, 1988 by U.S. mail, first Class.
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. GleaFon, Chairman William R. Cumming, Esq. **
513 Gilmoure rive Spence W. Perry, Esq.
Silver Spring, Maryland 20901 office of General Counsel Federal Emergency Management Agency Dr. Jerry R. Kline 500 C Street, S.W., Room 840 Atomic Safety and Licensing Board Washington, D.C. 20472 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 W. Taylor Reveley, III, Esq.
- Hunton & Williams Fabian G. Palomino, Esq. P.O. Box 1535 Richard J. Zahnleuter, Esq. 707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol Albany, New York 12224
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Joel Blau, Esq. Anthony F. Earley, Jr., Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq. Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, .New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C. 20555 Alfred L. Nardelli, Esq. Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Sbore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq. **
New York State Energy Office Edwin J. Reis, Esq.
Agency Building 2 U.S Nuclear Regulatory Comm.
Empire State Plaza Office of General Counsel Albany, New York 12223 Washington, D.C. 20555 David A. Brownlee, Esq. Mr. Stuart Diamond ,
Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W. 43rd Street New York, New York 10036 l
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Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 b
KIR LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington,-D.C. 20036-5891
- By Federal Express
- By Mail on Service Date and by Hand on January 20, 1988 1
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