ML20148S838

Suffolk County Fifth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence

ML20148S838
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/12/1988
From:	Taylor J KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
CON-#288-6093 OL-3, NUDOCS 8804200047
Download: ML20148S838 (6)

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ELAltD CORRL5PON%

April 12, 1988 88 FR 15 32:52 UNITED STATES OF AMERICA , . ,

NUCLEAR REGULATORY COMMISSION [,0 ORAhCi

$ I-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) )

)

SUFFOLK COUNTY'S FIFTH SUPPLEMENTAL RESPONSE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONPLICT OE_FCHOOL BUS DRIVERS Suffolk County ("the County") hereby supplements its Answers of January 19, and its Supplemental Responses of January 27, February 17, and March 3, 1988, to LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers ("LILCO's First Discovery Request").

LILCO Interrogatory No. 8

8. Please 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 each school, hhk kbO$k $ Oh g2 }g9)

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-~ - - - - -

Answer. Counsel for Suffolk County has been provided with the following school enrollment information by its school official witnesses as of April ,2, 1988: there are 976 elementary students, 684 junior high students, 572 senior high students and 118 private and parochial students enrolled in Mt.

Sinal School District; in Riverhead Central School District, approximately 2,705 students are enrolled in the Riley Avenue and Pulaski Street Elementary Schools and the Riverhead Junior High and Riverhead High Schools; and approximately 10,000 students are enrolled in Longwood Central School District.

LILCO Interrogatory No. 9 i

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. Counsel for the County has been provided with the following information by its school official witnesses regarding bus company contracts with school districts located within the Shoreham 10-mile EpZ: Longwood Central School District contracts l

with Suburbia Middle Island Bus Company for the use of 89 buses to transport its public, private and parochial school population

, and with Noyl Equipment for the use of 57 vehicles to transport 1

children with special needs; and Mt. Sinai School District contracts with Harborview Coram Bus company for the use of 27 j l

2-

[ .__ ______ _ _

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i buses to transport its public school children and 11-mini-vans to '

transport its private and parochial school children and children l r

with special needs.

LILCO Interroaatorv_No. 21 '

21. Please list each and every State and local law, j regulation, and ordinance that Intervenors claim might  ;

make LILCO's proposal to evacuate schools in the EPZ in ;

i a single wave illegal.  ;

t Answer. In addition to information already provided to

'. t L:LCO by the County in its Answer of January 19, 1988 and in its  !

t Supplemental Response of January 27, 1988, the County may also I

, rely on the following State and local laws and regulatiens:  ;

Title D-6 of Chapter 21 of the Nassau County Administrative Code; t ar.d Article 3 of Chapter VI of the New York State Transportation Regulation.

i i r

l i t l Respectfully submitted,

w i ieKaelys. Millq/

J. Lynn Taylor

! I i Kirkpatrick & Lockhart 1800 M Street, N.W.  !

l, 1 South Lobby - 9th Floor W&shington, D.C. 20036-5891 L i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION F Ig}'U^" ,hf Before the Atomic Safety and Licensino Board i

4 r

)

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  ;

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I hereby certify that copies of SUFFOLK COUNTY'S FIFTH l SUPPLEMENTAL RESPONSE TO LILCO'S FIRST SET OF INTERROGATORIES r REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have been served on ,

the following this 12th day of April, 1988 by U.S. mail, first  :

class, except as otherwise noted. [

t l 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. Gleason, Chairman William R. Cumming, Esq.

• 513 Gilmoure Drive George W. Watson, Esq. j Silver Spring, Maryland 20901 Office of General Counsel {

Federal Emergency Management Agencyi Dr. Jerry R. Kline 500 C Street, S.W., Room 840 t Atomic Safety and Licensing Board Washington, D.C. 20472 [

U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 W. Taylor Reveley, III, 9sq. * {

Hunton & Williams ,

, Lawrence C. Lanpher P.O. Bcx 1535 (

i Karla J. Letsche 707 East Main Street  !

i Michael S. Miller Richmond, Virginia 23212 Kirkpatrick & Lockhart [

1 1800 M Street, N.W.

South Lobby - 9th Floor i 4

Washington, D.C. 20036-5891 l J

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 Shore 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 Empire State Plaza Office of the General Counsel U.S. Nuclear Regulatory Comm.

, 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 r

Douglas J. Hynes, Councilman Town Board of Oyster Bay Adjudicatory File Town Hall Atomic Safety and Licensing Oystur Bay, New York 11771 Board Panel Docket U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 a

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rkpat ick & LoV4 hart 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C. 20036-5891 By Telecopy