ML20149D784
| ML20149D784 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/05/1988 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, NEW YORK, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5546 OL-3, NUDOCS 8802100015 | |
| Download: ML20149D784 (12) | |
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a srv4 MEEATED CORRESPONQENCQ DOCKETED February N k988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Urtccr; nc':-
i Before the Atomic Safety andLicensino057saidjj,g'TZ
)
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 SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY Suffolk County, by its counsel, propounds the following in-terrogatories to Long Island Lighting Company ("LILCO") pursuant to SS 2.740, 2.740b and 2.741 of the Nuclear Regulatory Com-4 mission's Rules of Practice.
DEFINITIONS AND INSTRUCTIO*t:S l
The "Definitions" and "Instructio.'s" for.this second set of interrogatories and requests for production of documents are the same ones set out in Suffolk County's First 1et of Interroga-tories and Requests for Production of Documents to Long Island Lighting Company, dated January 4,
1988.
However, for purposes of these interrogatories and document requests, LILCO's "auxi-liary bus driver arrangement" refers to the proposal for evacua-l 8802100015 080205 ADOCK 0500 2
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.o ting 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 "Motion for Summary Disposition of Contention 25.C
(' Role Conflict' of School Bus Drivers)," dated October 22, 1987.
The following interrogatories and requests for production of documents are numbered beginning where the first
- set, dated January 4, 1988, left off.
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 33.
Please identify each and every bus company that has entered into contracts with LILCO 'ao provide buses in the event of a Shoreham emergency.
For each bus company, specify whether such company provides buses and/or drivers for schools and/or school districts.
For each such company which provides buses and/or drivers for schools and/or school districts, identify the particular schools and/or school districts with which the company contracts, and specify whether such schools and/or school dis-tricts are in or outside the EPZ.
Provide a copy cf all corres-pondence and documents relating to each and every bus company that has entered into a contract with LILCO.
34.
With respect to each bus company identified in response to Interrogatory 33, please specify the number of buses that are contracted to LILCO and further specify whether such buses are to be used by LILCO for the evacuation of the transit-dependent general population, the evacuation of the handicapped and special facilities, tha evacuation of parochial and nursery schools, the evacuation of public schools, or some other purpose.
If for some other purpose, specify that purpose.
35.
In LILCO's February 4, 1988 "Response to Suffolk County's First Set of Requests for Admissions Regarding the Re-mand Issue of ' Role Conflict' of School Bus Drivers," Suffolk County's Request for Admission No. 5 was denied.
Please provide the basis for LILCO's denial of that Request.
36.
Please identify each and every school district, having schools located in the EPZ, which has consented to any LILCO pro-posal to have LILCO employees drive buses to evacuate school children during a Shoreham emergency.
37.
In LILCO's February 4, 1988 "Response r
Suffolk County's First Set of Requests for Admissions Regard! 1g the Re-mand Issue of
' Role Conflict' of School Bus Drivers," Suffolk County's Request for Admission No. 6 was denied.
Please provide the basis for LILCO's denial of that Request.
38.
Please identify each and every school district, having schools located in the EP::, which has consented to have LILCO em-t l f
ployees drive school buses containing children during an evacua-tion from a Shoreham emergency.
39.
Please provide a list of LILCO "auxiliary" bus drivers and, if such drivers have been or will be assigned as drivers of buses transporting school children from a particular school dis-trict or school within the EPZ, specify the LILCO drivers for each school or school district..
40.
Please specify whether any LILCO "auxiliary" bus drivers have been approved by any school or school district and, if so, identify the school (s) and/or school district (s) which have approved such drivers as drivers of buses transporting school children.
41.
In LILCO's February 4, 1988 "Response to Suffolk County's First Set of Requests for Admissions Regarding the Re-mand Issue of
' Role Conflict' of School Bus Drivers," Suffolk County's Request for Admission No. 15 was denied.
Please provide the basis for LILCO's denial of that Request.
42.
Please identify each and every bus company, under con-tract with schools and/or school districts in the EPZ, which has agreed to allow LILCO or its employees to parform school bus driving duties covered by such contracts. --
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J 43.
Please identify each and every ' school and/or school 1
-district in the EPZ, if any, which has agreed or has indicated that it will or may agree (specifying for each-school and/or school district whether agreement has actually'been obtained or may be obtained) to have its school bus drivers trained by LILCO.
Provide any correspondence or documents relating to this inter-rogatory.
f-44.
Please identify each and every school and/or school L
district in the EPZ, if any, which has agreed to meet with LILCO to discuss LILCO's "auxiliary bus driver arrangement" or which has indicated in any way that it is or is not willing to do so.
In answering this interrogatory, please specify for each school and/or school district whether a meeting has been or has not been agreed to by each school and/or school district identified.
l 45.
Please identify each and every school district and/or school in the EPZ, if any, which has instructed its school bus drivers to accept training by LILCO or which has indicated that j.
it will or will not so instruct its drivers.
In answering this interrogatory, please specify for each school and/or school dis-t trict whether an instruction to accept LILCO's training has or i
j has not been given.
I 46.
In LILCO's February 4, 1988 "Response to Suffolk Cou.1ty's First Set of Requests for Admissions Regarding the Re-
]
I mand Issue of ' Role Conflict' of School Bus Drivers," Suffolk i
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County's Request for Admission No. 20 was denied.
Please provide the basis for LILCO's denial of that Request.
47.
Please identify each and every school district and/or school in the EPZ, if any, which has agreed to have its school children evacuated during a Shoreham emergency to any reception center identified, or to be identified, by LILCO.
Have any school districts and/or schools refused to have their school children evacuated to any such reception centers.
If so, please identify.
48.
In LILCO's February 4, 1988 "Response to Suffolk County's First Set of Requests for Admissions Regarding the Re-mand Issue of ' Role Conflict' of School Bus Drivers," Suffolk County's Request for Admission No. 21 was denied.
Please provide the basis for LILCO's denial of that Request.
l 49.
Please identify each and every school district and/or school in the EPZ, if any, which has adopted or approved a plan l
for the implementation of a single-wave evacuation of school children in the EPZ during a Shoreham emergency.
l 50.
Please identify each and every assumption underlying l
l LILCO's evacuation time estimates concerning the evacuation of school children under LILCO's "auxiliary bus driver arrangement,"
or some part thereof.
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1 51.' In LILCO's February 4, 1988 "Response to Suffolk County's First Set of Requests for Admissions Regarding the Re-mand Issue of
' Role Conflict' of School Bus Drivers," Suffolk County's Request for Admission No. 23 was denied.
Please provide the basis for LILCO's denial of that Request.
52.
Is it assumed by LILCO that no LILCO employees serving as "auxiliary,"
backup or primary bus drivers under LILCO's "auxi.liary bus driver arrangement" will experience role conflict during a Shoreham emergency?
Is it assumed by LILCO that no such LILCO employees would abandon _their LERO jobs or fail to report for duty due to role conflict during a Shoreham emergency?
For each of the above, please specify each and every basis of the assumptions made by LILCO, and produce any documents related to such assumptions.
53.
Please identify each and every contact or communication in which any person or group has attempted to persuade school districts and/or schools (or representatives or employees of school districts and/or schools) to participate in LILCO's "auxi-liary bus driver arrangement" or otherwise to cooperate with LILCO with regard to the evacuation of schools during a Shoreham emergency.
Please specify for each such contact and/or communi-cation, the school district or school contacted.and the person (s) talked with, the date of each contact or communication, and the substance of each communication or contact.
Please produce any documents related to any such contacts or communications.
t -
4 54.
Please. identify each and every bus company which has been contacted by L'.' LC O with regard to LILCO's "auxiliary bus driver arrangement" concerning the evacuation of schools during a Shoroham emergency.
Please specify which such bus companies have decli.ned to participate in LILCO's "auxiliary bus driver arrange-ment" or have declined to contract with LILCO for the provision of buses.
Specify the reasons that each such bus company has de-clined to participate, and produce any documents related to this interrogatory.
55.
To the extent there have been any changes since you have responded to Suffolk County's first set of interrogatories and requests for production of documents, please again respond to Requests 1 through 32 of Suffolk County's First Set of Interroga-tories and Requests for Production of Documents to Long Island Lignting Company, dated January 4, 1988.
56.
Please identify and provide a copy of any document not already identified in response to the above interrogatories and/or Suffolk County's First Set of Interrogatories and Requests for Production of Documents to Long Island Lighting Company, i
dated January 4, 1988, on which LILCO intends to rely in support i
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.8 of its position on the issue of whether there will be a
sufficient number of school bus drivers to evacuate schools during a shoreham emergency.
Respectfully submitted, k
2 Michael S. Miller, J. Lynn Taylor Attorneys for Suffolk County KIRKPATRICK & LOCKKART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036
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February S.
1988 i
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s CXKETED U5NPC Februarv 5, 1988 l
UNITED STATES OF AMERICA '88 FEB -8 P4 09 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensi fBdaSdjl((h BRANCm
)
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 SUFFOLK COUNTY'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO LONG ISLAND LIGHTING COMPANY ha.ve been served on the following this 5th day of February, 1988 by 4.S. mail, first class, except as notod:
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 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 4
s 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 Requiatory 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 Sar 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 4
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s Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 J
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AW hYO Michael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor j
Washington, D.C.
20036-5891 i
By Telecopy i
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