ML20148U522
| ML20148U522 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/25/1988 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5479 OL-3, NUDOCS 8802040045 | |
| Download: ML20148U522 (11) | |
Text
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I WTED CORRW 00CM o
05h C January 25, 1988 UNITED STATES OF AMERICA T8 FEB -1 PS:d3 NUCLEAR REGULATORY COMMISSION VflCE C: 550 ; ye a r
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Before the Atom _ic Safety and Licensina Board DALN
)
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 FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING THE REMAND ISSUE OF "ROLE CONFLICT" OF SCHOOL BUS DRIVERS Pursuant to 10 CFR S 2.742, Suffolk County, by its counsel, requests that LILCO admit or deny, within 10 days of service of this request, the Requests for Admissions contained herein.
INSTRUCTIONS A.
Each request for admission shall be answered separately and fully in writing under oath in accordance with $ 2.742 of the NRC's Rules of Practice.
To the extent that LILCO does not have specific, complete, and accurate information with which to answer any request for admission, LILCO should so state, and the request for admission should be answered to the extent information is available, identifying each person who is believed to have accurate information with respect thereto.
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i B.
Each request for admission shall be deemed to be continuing, and LILCO is requested seasonably to supplement answers with additional facts and information, in accordance with S 2.740(e)(1) and (2) of the NRC's Rules of Practice.
C.
The words "and" and "or" shall be construed either conjunctively or disjunctively so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
D.
Wherever appropriate, the singular form of a word shall be interpreted in the plural, and vice versa, so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
E.
Wherever appropriate, the masculine form of a word shall be interpreted as fcainine, and vice versa, so as to bring j
within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.
l L
i F.
If LILCO objects to or claims a privilege (attorney-client, work product, or other) with respect to any request for admission, in whole or in part, or seeks to withhold any such information because of the alleged proprietary nature of the data, please set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient i
o detail to permit the Licensing Board to determine the validity of the objection or claim of privilege.
DEFINITIQHS A.
"LILCO'" or "LILCO personnel" means Long Island Lighting Company and any affiliate, agent, employee, consultant, contractor, technical advisor, representative, or other person acting for or on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.
B.
"Shoreham" means the Shoreham Nuclear Power Station, Unit 1, any part thereof, or any structure, system, component, instrumentation, equipment, or materials included in, or intended to be included in, Shoreham.
C.
LILCO's "auxiliary bus driver arrangement" refers to the proposal for evacuating school children from the Shoreham 10-mile EPZ during a radiological emergency at Shoreham, by using LILCO employees to serve as auxiliary, or backup, and primary school bus drivers, all as more fully described by LILCO in its L
"Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 2:1 1987. l
REQUESTS FOR ADMISSIONS 1.
That LILCO's new "auxiliary bus driuer arrangement" does not include the proposed use of LILCO's new "auxiliary" school bus drivers in the event of an early dismissal of schools during a Shoreham emergency.
I 2.
That LILCO's new "auxiliary bus driver arrangement" does no,t include the provision of buses for the 562 new "auxiliary" bus drivers to use in the event of an evacuation of schools during a Shoreham emergency.
I l
l 3.
That LILCO's new "auxiliary bus driver arrangement" adds l
to LERO a minimum of 562 additional personnel.
l 4.
That the new 562 "auxiliary" school bus drivers are in addition to (a) the 333 bus drivers who are expected to drive as many as 333 buses to evacuate the transit-dependent general population, according to OPIP 3.6.4, and (b) the drivers expected, under pre-Revision 9 versions of LILCO's Plan, to participate in the evacuation of the handicapped and parochial and nursery schools, according to OPIP 3.6.5.
5.
That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has consented to any LILCO proposal to have LILCO employees drive buses to evacuate school children during a Shoreham emergency.
6.
That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has consented to have LILCO employees drive school buses containing children during an evacuation from a Shoreham emergency.
7.
That, with the exception of the Shoreham-Wading River Central School District, no school superintendent, from any district having schools located in the EPZ, has approved any LILCO "auxiliary" bus drivers as drivers of buses transporting school children in his or her school district, or under his or her charge.
8.
That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has consented to allowing LILCO personnel, or "auxiliary" bus drivers, to drive buses under contract to those schools, during a Shoreham emergency.
9.
Tnat, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has agreed that the safe implementation of a single-wave evacuation of all school children in the EPZ during a Shoreham emergency is feasible.
10.
That the Shoreham-Wading River CJntral School District has not formally agreed to implement, or to allow LILCO to implement, its "auxiliary bus driver arrangement."
11.
That the Shorebem-Mading River Central School District has not formally agreed to have LILCO employees drive school buses containing children from that district during an evacuation from a Shoreham emergency.
12.
That the Shoreham-Wading River Central School District has not formally agreed to allow LILCO personnel, or "auxiliary" bus drivers, to drive buses under contract to that district, during a Shoreham emergency.
13.
That the Shoreham-Wading River Central School District Superintendent has not approved any LILCO "auxiliary" bus drivers as drivers of buses transporting school children from that school district, or under his or her charge.
14.
That no bus companies have agreed to assign to LILCO, or LILCO employees, their contracts with school districts, covering the provision of school bus driving services.
15.
That no bus companies, under contract with school districts in the EPZ, have agreed to allow LILCO or its employees to perform school bus driving duties covered by such contracts.
s 16.
That no bus companies, under contract with school districts in the EPZ, have agreed to release to LILCO, for use by LILCO employees during a shoreham emergency, buses covered by such contracts.
17.
That no school districts outside the EPZ have agreed to release to LILCO, for use by LILCO employees during a Shoreham emergency, buses under contract with such school districts.
18.
That with the exception of the Shoreham-Wading River Central School District, no school district with schools in the EPZ has agreed to have its school bus drivers trained by LILCO.
19.
That with the exception of the Shoreham-Wading River Central School District, no school district in the EPZ has instructed its school bus drivers to accept training by LILCO.
i 20.
That with the exception of the Shoreham-Wading River Central School District, no school district in the EPZ has agreed to have its school children evacuated during a Shoreham emergency to any reception center identified, or to be identified, by LILCO.
21.
That with the exception of the Shoreham-Wading River Central School District, no school district in the EPZ has adopted or approved a plan for the implementation of a single 1
wave evacuation of all the school children in the EPZ during a Shoreham emergency.
22.
That any LILCO evacuation time estimates concerning the evacuation of school children will be based on the assumption that LILCO's "auxiliary bus driver arrangement," or some part thereot, would be implemented.
23.
That under LILCO's "auxiliary bus driver arrangement,"
it is assumed by LILCO that no LILCO employees serving as "auxiliary," backup, or primary bus drivers would experience role conflict during a Shoreham emergency.
Respectfully submitted, YY
/
k W
Karla J.
Letsche Michael S. Miller Kirkpatrick & Lockhart 1800 M Street, N.W.
South Lobby - 9th Ploor Washington, D.C.
20036 Attorneys for Suffolk County January 25, 1988 4
CZKEIED U%RC January 25, 1988 UNITED STATES OF AMERICA T8 F8 -1 PS :03 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board h f7 k h p[(
I BRANCH
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CEPTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING THE REMAND ISSUE OF "ROLE CONFLICT" OF SCHOOL BUS DRIVERS have been served on the following this 25th day of January, 1988 by U.S. mail, first class, except as noted:
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, Erg.
513 Gilmoure Drive 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
e
=
Joel Plau, 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 Hickaville, 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 Stat;on 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 Drynnison 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 office of the General Counsel Empire State Plaza 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 6
O Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 kt U
A Richael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Mailed on January 25, 1988 and By Hand Delivery on January 26, 1988 By Telecopy By Federal Express