ML20148U548

Lilco Third Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers to Suffolk County & State of Ny.* Certificate of Svc Encl. Related Correspondence

ML20148U548
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/27/1988
From:	Harlow D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF, SUFFOLK COUNTY, NY
References
CON-#188-5481 OL-3, NUDOCS 8802040054
Download: ML20148U548 (7)

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k $421 LILCO, January 27,1988 g RELATED CORRESPONDE.NC$

DOCKETED UNITED STATES OF A51 ERICA USNRC NUCLEAR REGULATORY CO51511SSION iE FEB -1 P4 50 Before the Atomic Safety and Licensinst Board 0FFICE CI SECi;CIWf 00CKETING A SE6vicr.

BRANCH In the 51atter of )

)

LONG ISLAND LIGHTING C051PANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, ) (School Bus Driver Issue)

Unit 1) )

LILCO'S TIIIRD SET OF INTERROGATORIES AND REQUESTS.FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO SUFFOLK COUNTY AND NEW YORK STATE Long Island Lighting Company, by its counsel, propounds the following interroga-tories to Suffolk County and New York State ("Intervenor" or "the Intervenors"), pursu-ant to SS 2.740, 2.740b, and 2.741 of the Nuclear Regulatory Commission's Rules of Practice. By propounding these interrogatories and requests LILCO makes no admission or representation about the proper scope of the issues to be decided or the evidence that may be presented on the school bus driver issue.

INSTRUCTIOliS AND DEFINITIONS The "Instructions" and "Definitions" for this third set of interrogatories on school bus drivers are the same ones set out in LILCO's First Set of Interrogatories and Re-quests for Production of Documents Regarding Role Conflict of School Bus Drivers to Suffolk County and New York State, dated January 5,1988, at pages 1-7.

In addition, the term "bus drivers" as used below refers to people who, as part of their jobs (either part-time or full-time jobs) drive school buses or other buses (for ex-ample, ordinary mass transit buses). The term "school bus drivers" refers to people who drive buses to transport students to or from public, private, or parochial schools.

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The following Requests are numbered beginning where the second set, dated Jan-uary 13,1988, lef t of f.

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS .

31. In the January 19,1988 Response of the State of New York to LILCO's First Set of Interrogatories you list (pp. 4-6) in respcnse to Request No. 8 certain information "provided by the schools to the N ew York State Education De-partment" concerning "student enrollment for schools within the 10-mile E PZ." Please provide the date of this information and list those persons who provided this information to the Educati)n Department. Identify and provide any and all documents f rom which thin information was obtained.

32. In the State of New York's January 19, 1988 Response, you list (pp. 6-8) in response to Request No. 9 certain information "provided by school districts to the New York State Education Department" concerning "the bus compa-nies that contract with each school district imntified in LILCO's Motion at Attachment 1." Please provide the date of t11s information and list those persons who provided this information to the Education Department. Iden-tify and provide any and all documents from which this information was ob-tained.

33. In the State of New York's January 19,1988 Response, you list (pp. 8-9) in response to Request No.10 certain l'sformation "provided by the school dis-tricts" concerning "the number of school bus drivers and mechanics on the payroll of each pertinent school district." Please provide the date of this information and list those persons who provided this information. Identify and provide any and all documents f rom which this information was ob-tained.

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34. Please provide, as agreed in your conversation with LILCO counsel on Janu-  ;

ary 25, 1988, current copies of the radiological emergency preparedness ,

plans for the counties of Orange, Putnam, and Rockland. Please provide as well current copies of the radiological emergency preparedness plans for l the counties of Dutchess, Jef ferson, and Onondaga. j

35. To the extent not provided by your answers to Requests 23 and 24 in LILCO's Second Set of Interrogatories and Requests for Production of Docu-ments Regarding Role Conflict of School Bus Drivers to Suffolk County and t New York State, dated January 13,1988, please provide one example known

• to Intervenors (as defined in Definition F of the "Definitions" cited above)

I of a bus driver who, in aa emergency, attended to the safety of his own  !

family before reporting to perform his bus driving duties. For this example i

please identify the emergency, the date, the organization for which the bus i

driver worked at the time, the duties the bus driver was expected to per-form in connection with the emergency, the length of time before the bus 3 driver reported to perform these duties, and the f amily members whose safety the driver attended to. Identify also the source (person or document -

t or both) of this example. I i 36. Give a second example of a bus driver who, in an emergency, attended to I the safety of his own family before reporting to perform his bus driving du-l i i ties and identify the example and source as requested in Request No. 35 a

above. l

37. Give a third example of a bus driver who, in an emergency, attended to the I

safety of his own family before reporting to perform his bus driving duties  :

1 c and identify the example and source as requested in Request No. 35 above. I i

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38. In your response to LILCO Interrogatory No.1, Suf folk County's Answers to LILCO's First Set of Interrogatories and Document Requests Regarding Role Conflict of School Bus Drivers (Jan. 19,1988), at 3, you refer to Pio-fessor Cole's "contacts with other experts on the subject." Please identify all such contacts.

39. In the same response cited in No. 38 above you refer to the "causes of role conflict and the factors existing on Long Island which could lead to role conflict." Identif y all such "causes" and "f actors."

40. In your response to LILCO Interrogatory 21 (dated January 19,1988) you say that "[f]urther research, analysis and discovery may reveal additional State and/or local laws, regulations and ordinances that would be violated by LILCO's proposal." Have you identified any such laws, regulations, or ordinances? If so, what are they?

41. Are you aware of an) contacts or communications in which any person or group has attempted to persuade schools or school districts (or representa-tives or employees of schools or school districts) not to participate in LILCO's auxiliary school bus driver arrangement or otherwise not to coo-perate with LILCO with regard to the evacuation of schools during a Shoreham emergency? If so, please identify such contacts and communica-tions. To the extent that such information is available to you or can be. ob-tained, please include, for each contact and communication, the school or school district contacted and the person talked with, the date of each con-tact, and the substance of each conversation. Please produce any docu-ments related to such contacts.

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42. Are you aware of any contacts or communications in which any person or  !

group has attempted to persuade any bus companies under contract to .

schools and school districts not to participate in LILCO's auxiliary school I bus driver arrangement or otherwise not to cooperate with LILCO with te-gard to the evacuation of schools during a Shoreham emergency? If so, [

please identify those contacts as requested in Request No. 41 above, j

43. Are you aware of any contacts or communications in which any person or group has attempted to persuade any bus company on Long Island, to the i

extent not identified in Request No. 42, not to participate in LILCO's auxil- l lary school bus driver arrangement or otherwise not to cooperate with  ;

LILCO with regard to the evacuation of schools during a Shoreham emer- t gency? If so, please identify those contacts as regnested in Request No. 41 above.

44. Are you aware of any contacts or communications in which any person or group has attempted to persuade any school bus drivers on the payroll of or  ;

under contract with schools or school districts not to participate in [

LILCO's auxiliary school bus driver arrangement or otherwise not to coo-  !

perate with LILCO with regard to the evacuation of schools during a l

Shoreham emergency? If so, please identify those contacts as requested in  ;

i Request No. 41 above.

l ADS. h/C (JamefN. Christman Mary Jo Leugers '

David S. Harlow ,

t Hunton & Williams i 707 East Main Street

[

{ P.O. Box 1535  !

j Richmond, Virginia 23212 l

4 DATED: January 27,1988 l i

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LILCO, January 27,1988 s

00f.KETED V%RC

'88 FEB -1 P4 51 CERTIFICATE OF SERVICE OFFICE CF nCftflAPY 00CKETING A SERylCf.

BRANCH In the 51atter of LONG ISLAND LIGHTING CO51PANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S THIRD SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCU51ENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVEP.S TO SUFFOLK COUNTY AND NEW YORK STATE were served this date upon the following by telecopier as indicated by one asterisk, or by first-class mall, postage prepaid.

James P. Gleason, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring,51aryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline George E. Johnson, Esq.

Atomic Safety and Licensing Richard G. Bachmann, Esq.

Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 11535 Rockville Pike East-West Towers, Rm. 427 One White Flint North 4350 East-West Hwy. Bethesda,51D 20814 Bethesda,51D 20814 Herbert H. Brown, Esq.

• Str. Frederick J. Shon Lawrence Coe Lanpher, Esq.

Atomic Safety and Licensing Karla J. Letsche, Esq.

Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 51 Street, N.W.

4350 East-West Hwy. Washington. D.C. 20036-5891 Bethesda, SID 20814 Fabian G. Palomino, Esq.

• Secretary of the Commission Richard J. Zahnicuter, Esq.

Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W. State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing '-

Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C, 20555

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.g.  ;

s Alfred L. NartMit. Esq.- JDLathan D. Feinberg, Esq.

Assistant Attornay Genarat New Yo?X Stato Department of 120 Broadway Publie Service, $taff Counsel  !

Room 3-118 .

Threa Sockefeller Plaza [

New York, New York 307,T1 - Altany, IJew York 12223 ,

. . t Spence W. Perry, Esq.

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Ms. Nora Breder .

William R. Cumming. Esq. Execudve Coorcunator -

Federal Emergcacy Manegn;9ni sfioream 07ponents' Coalition Agency 195 East Na.In fitr9et 500 C Street, S.W., Atxe 6% . Smithtown, New York 11137 i Washington, D.C. 2G472 Gerald C. Crotty, F;sq.  !

Mr. Jay Dunklebergvr . Counsel to the Governor {

New Yoric State Energy Offlee Executive Chamber ,

Agency Building 2 State Caphi .

Empire State Plaza . .

Alhany, New York 12224 ,

Albany, New York 172?3 E. Thomas Boyle, Esq.

Stephen B. Latham, Esq. Suffolk County Attorney Twomey, Latham & SihCa Building 1$8 North County Complex ,

33 West Second Street Veterans Memorial H!ghway P.O. Box 298 Hhuppauge, Ntw York 11788 Riverhead, New York Ali/01 l l',r. Mer. roe Schneider

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Mr. Philip McIntire Morte Shore Committee l Federal Emergency Management P.it fgix 231 '

Agency Wading Rwer, NY 11792  :

26 Fede&1 Plaza  !

New York. New York 10218 [

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( DavidT Harlow

~ 5. AMe  :

l l Hunton & Williams i i

707 East Main Street I l P.O. Box 1535 '

l Richmond, Virginia 23212 l DATED: January 27,1988  !

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