ML20148H847

State of Ny First Set of Interrogatories & Request for Production of Documents to NRC Staff & Fema.* Certificate of Svc Encl.Related Correspondence

ML20148H847
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/22/1988
From:	Zahnleuter R NEW YORK, STATE OF
To:	Atomic Safety and Licensing Board Panel
References
CON-#188-5410 OL-3, NUDOCS 8801270315
Download: ML20148H847 (6)

Text

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3 JAN 26 R2:i)0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFlCE C7 SECnnu <

00CXEiiNG 6 sEpvicr Before the Atomic Safety and Licensina Board In the Matter of )

)

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

)

Unit 1) )

)

STATE OF NEW YORK'S FIRST SET OF INTERROGATORIES AND REOUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF AND FEMA In accordance with the Board's Memorandum and Order (Ruling on Applicant's Motion of October 22, 1987 for Summary Disposition l of Contention 25.C Role Conflict of School Bus Drivers), dated December 30, 1987, and pursuant to 10 CFR Sections l

2.720(h) (2) (ii) , 2.740, 2.740b, 2.741 and 2.744, the State of New l York asks the NRC Staff and FEMA to answer the interrogatories i and to respond to the document request set forth below.

Please answer all interrogatories separately, fully and under l

l oath, and please produce the requested documents at the offices of the Special Counsel to the Governor, Capitol, Room 229, Albany, New York.

The definitions and instructions for this set of l

interrogatories and document request are the same as the ones attached to "Suffolk County's First Set of interrogatories and 8801270315 880122 ADOCK 05000322 97 PDR o PDR .

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e Request for Production of Documents to the NRC Staff and FEMA,"

dated January 4, 1988. In addition, the term "bus drivers" means people who drive school buses or other buses, such as mass transit buses, either part-time or full-time. The term "school bus drivers" means people who drive buses to transport students to or from public, private or parochial schools.

Interroaatories and Document Recuests

1. When bus drivers for nuclear plants other than Shoreham are trained to drive buses during radiological emergencies, what, if anything, are they told, on a plant by plant basis, about caring for their families in emergencies?

2. Do any radiological emergency response plans for nuclear plants other than Shoreham rely either fully or partially on utility employees to drive buses for school children? If the answer is affirmative, please identify the particular nuclear plants and the relevant pages of the corresponding radiological emergency response plans.

3. Has the NRC or FEMA ever met (on or about January 14, l

1988 or at any other time), or engaged in telephone conversations or discussions, with LILCO regarding in any l

way LILCO's schools evacuation proposal? If the answer is affirmative:

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(a) identify the dates and locations of the meetings or the dates of the telephone conversations or discussions; (b) identify all attendees or participants; (c) specifically describe all statements that were made about LILCO's schools evacuation proposal; (d) attribute all such statements to particular individuals; and (e) provide any documents that concern LILCO's schools evacuation proposal that were produced in preparation for, during, or as a result of the meetings, telephone conversations or discussions.

4. Provide a copy of all documents used in preparing the answers to these interrogatories.

5. List, on a numerical interrogatory by interrogatory basis and on a lettered subpart by subpart basis, all people who were asked to provide information or documents in response to: (a) this pleading; (b) the pleading submitted by Suffolk County entitled, "Suffolk County's First Set of Interrogatories and Request for Production of Documents to the NRC Staff and FEMA," dated January 4, 1988.

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Richard J._2ahnieuter Fabian G. Palcmino Special Counsel.to the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 Attorneys for Mario M. Cuomo Governor, and the State of New York

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o 00LKE TEE-USMC DATE: Januarg 2g g8g g UNITED STATES OF AMERICA gffICE Ok SEU<tiuy NUCLEAR REGULATORY COMMISSION OCMCig ci<vict, Before the Atomic Safety and Licensina Board 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 the "State of New York's First Set of Interrogatories and Request for Production of Documents to the NRC Staff and FEMA" have been served on the following this 22nd day of January, 1988 by U.S. mail, first class, except as noted by an asterisk.

Mr. Frederick J. Shon Spence W. Perry, Esq.*

Atomic Safety and Licensing Board William R. Cumming, Esq.

U.S. Nuclear Regulatory Commission Office of General Counsel, Washington, D.C. 20555 Federal Emergency Management Agenc 500 C Street, S.W., Room 840 Washington, D.C. 20472 Dr. Jerry R. Kline Mr. James P. Gleason, Chairman 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

r Anthony F. Earley, Jr., Esq. Joel Blau, Esq.

General Counsel Director, Utilitiy Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi Mr. Donald P. Irwin Clerk Hunton & Williams Suffolk County Legislature 707 East Main Street Suf folk County Legislature P.O. Box 1535 Office Building Richmond, Virginia 23212 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 Shorehan Opponents Coalition U.S. Nuclear Regulatory Commission 195 East Main Street 1717 H. Street, N.W.

Smithtown, New York 11787 Washington, D.C. 20555 Adrian Johnson, Esq. Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-16 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 E. Thomas Boyle Lawrence Coe. Lanpher, Esq.

Suffolk Countl Attorney Kirpatrick & Lockhart Building 158 North County complex 1800 M. Street, N.W.

Veterans Memorial Highway South Lobby - Ninth Floor Hauppauge, New York 11788 Washington, D.C. 20036 Mr. Jay Dunkleburger George Johnson

• New York State Energy Office U.S. Nuclear Regulatory Commission Agency Building #2 Washington, D. C. 20555 Empire State Plaza Albany, New York 12223

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Mr. James P. Gleason Douglas J. Hynes Charirman Town Board of Oyster Bay Atomic Safety and Licensing Board Town Hall 513 Gilmoure Drive _

Oyster Bay, New York 11771 Silver Spring, MD 20901 David A. Brownlee, Esq. Mr. Philip McIntrie Kirkpatrick & Lockhart FEMA 1500 Oliver Building 26 Federal Building Pittsburgh, Pennsylvania 15222 Washington, D.C. 20555 Mr. Stuart Diamond Business / Financial NEW YORK TIMES 229 W. 43rd Street New York, New York 10036

-G J Y h Yb b9 Richard (J.'fahhleuter, j Esq.

Deputy Speci'al Counsel-to the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 (518) 474-1273

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