ML20148H868
| ML20148H868 | |
| 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-#188-5409 OL-3, NUDOCS 8801270320 | |
| Download: ML20148H868 (13) | |
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RCLATED CCR6ESPONDE@g 00CKETED USHRC J nuaw 22, 1988
'88 y 26 101 58 UNITED STATES OF AMERICA NUCLEAR REGULATORD COMMISSION 00CKi.ig.:A" Before the Atomic Safety and Licensina Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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i STATE OF NEW YORK'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY In accordance with the Board's 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), dated December 30, 1987, and pursuant to 10 CFR Sections 2.740, 2.740b and 2.741, the State of New York asks LILCO to answer the interrogatories and to respond to the document requests set forth below.
l Please answer all interrogatories separately, fully and under 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 interrogatories and document request are the same as the ones attached to "Suffolk County's First Set of Interrogatories and h!O 00 g2
])Sg3 l
0 l
e e
Request for Production of Documents to Long Island Lighting-
' Company," 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 studenes to or from public, private or parochial schools.
Il!TERROGATORIES AND DOCUMENT REQUESTS 1.
Describe all emergencies known to LILCO or LILCO's witnesses, or referred to in documents in LILOO's or LILCO's witnesses' possession, custody or control, in which bus drivers were called upon.to transport people to their homes or to places of safety away from their homes because of the emergency.
The term "emergencies" includes, for example, such events as floods, fires, hurricanes, explosions and hazardous waste releases.
Specifically describe, on a lettered subpart by subpart basis:
(a) the type of emergency; (b) the location of the emergency; (c) the date and time of the emergency; (d) the number or bus drivers who l
transported people; (e) the number of people who were transported; (f) the number of bus drivers who were expected to report for work but who did not rm ort to work; (g) the reason why those bus drivers did not report to work; and (h)
I the number of people who were expected to be transported by the bus drivers but who were not transported by the bus drivers ;'ecause the hus drivers did not report to l l
O work.
With respect to emergencies reterred to in documents in LILCO's or LILCO's witnesses' possession, custody or control, provide these documents.
2.
Describe all instances of inclement weather known to LILCO or LILCO's witnesses, or referred to in documents in LILCO's or LILCO's witnesses' possession, custody or control, in which bus drivers were called upon to transport schoolchildren to their homes or to places of safety away from their homes because of the inclement weather.
The term "inclement weather" includes, for example, snowstorms.
Specifically describe, on a lettered subpar't by subpart basis:
(a) the type of inolenent weather; (b) the location of the inclement weather; (c) the date and time of the inclement weather; (d) the number of bus drivers who transported schoolchildren; (e) the number of schoolchildren who were transported; (f) the number of bus drivers who weye e.xpected to report for work but who did not report to work; (g) the reason why those bus drivers did not report to work, and (h) the number of schoolchildren who were expacted to be transported by the bus drivers but who vere not transported by the bua drivers because the bus drivers did not report to work.
With respect to such instances of inclement weather referred to in docunents in LILCO's or LILCO's witnesses' possession, custody or control, provide tnese documents. l l
3.
Describe all instances known to LILCO or LILCO's witnesses, or reported in documents in LILCO's or LILCO's witnesses' possession, custody or control, when bus drivers, in an emergency, attended to the safety of their own families before reporting to perform their bus driving duties.
Specifically describe, on a lettered subpart by subpart basis, for each bus driver:
(a) the person (for example, child or spouse) that the bus driver attended to first; (b) the type, location, date and time of the emergency; (c) the lengtn of the concomitant delay in reporting to work.
With respect to emergencies referred to in documents in LILCO's or LILCO's witnessecs' possession, custody or control, provide these dcouments.
4.
Describe all instances known to L1LCO or LILCO's witnesses, or reported in documents in LiLCO's or LILCO's witnesses' possession, custody or control, when bus drivers, in an emergency, performed their bus driving duties and then attended to the safety of their own families.
Specifically describe, on a lettered subpart by subpart basis, for each bus driver:
(a) the person (for example, child or spouse) that the bus driver attended to after performing his or her bus drivir.g duties; (b) the type, location, date, and time of i
the emerge.ncy, With raspect to emergencies referred to in documents in LILCO's or LILCO'r witneases' possession, custody or control, provide these documents.
I l !
e 5.
How many of the school bus drivers serving the schools
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listed in Attachment 1 to "LILCO's Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987, have members of their families living in the shoreham ten-mile EPZ?
6.
How many of LILCO employees who have agreed to serve as bus drivers have members of their families living in the Shoreham ten-mi,le EPZ?
7.
For the school bus drivers who verve each of the schools specified in Attachment 1 to "LILCO"s Motioh for Summary Disposition of Contention 25.C (' Role Conflict ~ of School Bus Drivers), dated October 22, 1987, specifically describe, on a lettered subpart by subpart basis, how their job training addresses:
(a) dealing with emergencies of any kind; (b) performing their duties when schools dismiss early; (c) caring for their own families in cases of early school dismissals or escrgencies; (d) providing notice to the school and bus company whcc + aey will not perform their jobs.
8.
Provide an up-to-date copy of all early dismissal and emergency plans for each of the schools identified in attachment 1
.if "LILeo's Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers),"
dated October 22, 1987. ;
9.
Elaborate on the statements made on page 16 of "LILCO's Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987, and elaborate on the statements made by Mr. Crocker in paragraph 15 of his associated affidavit, by providing, on a lettered subpart by subpart basis, the following information with respect to non-LILCO school bus drivers who LILCO relies upon to drive buses to implement LILCO's new schools evacuation proposal:
(a) amount of money and other considerations LILCO will give to each school bus driver for each hour of classrcom training on Shoreham emergency planning; (b) amount of money and other considerations LILCO will give to each school bus driver for each hour spent participating in drills and exercises; (c)-amount of money and other considerations LILCO will give to each school bus driver for each hour spent responding to an actual emergency at Shoreham; (d) amount of money and other considerations LILCO will give to each school bus driver as a sign-on or a year-end bonus or as a bonus of any type; (e) amount of money and other considerations LILCO will give to 9ach school bus driver for any reason not stated above.
The term "other l
considerations" includes, but is not limited to, reimbursement for mileage, child care, telephone installation l
and maintenance, meals, lodging, insurance, driver's license l
al.,
gistration, as well as the actual provision of services, objects or benefits such as child care, telephones, t f
vehicles, utilities, leave, stock or incentives of any kind.
10.
Elaborate on the statements made on page 16 of "LILCO's Motion for Summary Disposition of Contention 25.C (' Role' ConflicL' of School Bus Drivers)," dated October 22, 1987, and elaborate on the statements made by Mr. Crocker in paragraph 16 of his associated affidavit, by providing, on a
'ettered sobpirt by subpart basis, the following information with respect to LILCO-employed LERO workers who LILCO relies upon to drive buses to implement LILCO's new schools evacuation proposal:
(a) amount of money and other considerations LILCO will give to each bus driver for each hour of classroom training on Shoreham emergency planning; (b) amount of money and other considerations LILCO will give to each bus driver for each hour spent participating in drills and exerciseat (c) amount of money and other considerations LILCO will give to each bus driver for each hour spent attending, or studying for, school bus driver l
training classes for a class 2 license, and taking the class 2 driving test; (d) amount of money and other considerations LILCO will give to each bus driver for each hour spent 1
responding to an actual emergency at Shoreham; (e) amount of money and other considerations LILCO will give to each bus driver as a sign-on or year-end bonus or as a bonus of any type; (f) amount of monsy and other considerations LILCO will give to each bus driver for any reason not stated above.
The i
term "other considerations," as used herein, has the same meaning as is set forth in Interrogatory No.
9.
11.
Elaborate on the statements made on page 16 of "LILCO's Motion for Summary Disposition of contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987, and elaborate on the statements made by Mr. Crocker ir paragraphs 15 and 16 of his associated affidavit, by answering the following.
When the LILCO-employed bus drivers referred to in LILCO's schools evacuation proposal perform their bus driving duties during their regular working hours, will these bus drivers receive money and other considerations for performing their bus driving duties in addition to receiving their regular hourly wages?
If the answer is affirmative, specify the amount of money and other considerations.
The term "other considerations," as used herein, has the same meaning as is set forth in Interrogatory No.
9.
I 12.
Has LILCO ever met (on or about January 14, 1988 or at l
any other time), or engaged in telephone conversations or 1
discussions, with the NRC or FEMA regarding in any way LILCO's schools evacuation proposal?
If the answer is affirmative:
(a) identify the dates and locations of the P
meetings or the dates of the telephone conversations; (b) identify all attendees or participants; (c) specifically E;
1 describe all statements that were made about LILCO's schools evacuation proposal; (d) attribute a]l such statements to particular individuals; and (e) provide any documents that concern LILCO's schools evacuation proposal that were produ. id in preparation for, during, or as a result of the meetings, telephone conversations or discussions.
13.
Does LILCO now have in its possession, custody or control any information that is in addition to or different from the information set forth in the "Response of the State of New York to LILCO's First Set of Interrogatories and Requests for Production of Documents Regard-ing Role Conflict-of School Bus Drivers," dated January 19, 1988, and "LILCO's Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987, concerning:
(a) the number of students currently enrolled at each school located in the ten gile EPZ for Shoreham (ggg LILCO Interrogatory No. 8); (b) which of these schools are on split sessions and the number of students in attendance during each split session for each school (see LILCO Interrogatory No. 8); (c) the identification of each and every bus company that contracts with each school located in the ten-mile EPZ for Shoreham to transport school children (ggg LILCO Interrogatory No. 9); (d) which of,those bus companies provide busos and drivers to which schools (Egg 4
LILCO Interrogatory No. 9; (e) the number of school bus.
drivers under contract to or on the payroll of each school located in the ten-mile EPZ for Shoreham (ggg LILCO Interrogatory No. 10) ; (f) the number of these drivers that are designated for each school (agg LILCO Interrogatory No.
10)?
If the answer is affirmative, provide, on a lettered subpart by subpart basis, the additional or different information.
14.
Provide a copy of all documents used in preparing the answers to these interrogatories.
15.
List, on a numerical interrogatory by interrogatory basis and on a lettered subpart by subpart basis, all people, including, but not limited to, LILCO witnesses, who were asked to provide information or documents in response to: (a) this pleading; and (b) the pleading submitted by Suffolk County entitled, "Suffolk County's First Set of l
Interrogatories and Request for Procuction of' Documents to l
Long Island Light.ing Cormany," dated January 4, 1988.
Respectfully submitted, I
/f /?
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Ch' Richardp.3hhdleuter r
i Fabian G\\,Phl'omino I
Special Counsel to the Governor Exocutive Chambsr Capitol, Room 229 Albany, New York 12224 Attorneys for Mario M.
Cuor.o, Governor, and the Sta%e of New York l
DOCKETED USNRC DATE: Januaryg2 g8 UNITED STATES OF AMERICA 0FFICE ci SE q g y NUCLEAR REGULATORY COMMISSION 00CHEimG A SEsvJci,-
BRANCH Before the Atomic Safety and Licensina Board In the Matter of
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IDNG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station
)
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Unit 1)
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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 Long Island Lighting Company" 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 Ot2 ice 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
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 Suffolk County Legislature P.O.
Box 1535 Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, Mew York 11788 Mr.
L.F, Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shorehan 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 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
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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.
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Suffolk County 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 EEpire State Plaza j
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 1">00 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 J$/] /
b kh h t
'Richar J
a leuter, Esq.
Deputy.pec al Counsel to the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 (518) 474-1273 By Telecopier e