ML20149D796
| ML20149D796 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/01/1988 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| References | |
| CON-#188-5552 OL-3, NUDOCS 8802100019 | |
| Download: ML20149D796 (4) | |
Text
I LILCO, Fcbruary 1,1988 CEEATED CORRESPONOW4 DOCKETED i
USNt!C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 FEB -8 P3 :49 GFFICE Gi Lett3u.'
Before the Atomic Safety and Licensing Board 00CKEilNG A 'iEitV!Cf, BRANCH In the Mattor of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
) (School Bus Driver Issue)
Unit 1)
)
LILCO'S FOURTH 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.
INSTRUCTIONS _ A ND DEFINITIONS The "Instruct!ons" and "Definitions" for this fourth set of interrogatories on school bus drivers are the same ones set out in LILCO's First Set of Interrogatories and Requests 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.
The following Requests are numbered beginning where the third set, dated January 27,1988, lof t off.
8002100019 asopot PDR ADOCK 050003D2 0
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 45.
To the extent there have been any changes since you responded to LILCO's first and second sets of interrogatories and requests for production of docu-ments regarding role conflict of school bus drivers, please respond to Re-quests 1-7 and 18 in LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers to Suffolk County and New York State, dated January 5,1988.
46.
In particular, for each survey or focus group interview that Professor Cole has done, is doing, or will do in connection with this proceeding, please provide (1) the survey instrument and any draf ts of it, (2) the results of the survey, (3) any reports on or analyses of tbc survey, (4) any tapa' or tran-scripts of the interview, and (5) any reports on or analyses of the interview.
2
?_
ames N. Christfnan Counsel for 1ong Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 1,1988
i LILCO, FGbruary '1,1988 DO(.KE T ED UbNRC
'N FEB -8 P3 :49 C_ERTIFIC ATE OF SEPVICE OFFirt. & 56.Rt1 A A Y 00tMEimc & 'iEavicf.
BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S FOURTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO SUFFOLK COUNTY AND NEW YORK STATE were served this date upon the following by telecopier as indicated by one asterisk, by Feder-al Express as indicated by two asterisks, or by first-class mail, 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, Maryland 20901 Washington, D.C. 20555 Dr..!erry 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 One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy.
Rockville, MD 20852 Bethesda, MD 20814 Herbert H. Brown, Esq.
- Mr. 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 Tcwers, Rm. 430 1800 M Street, N.W.
4350 East West Hwy.
Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Secretary of the Commission Richard J. Zahnleuter, Esq.
Attention Dockethig 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 l
Washington, D.C. 20555 2
f 4 Alf red L. Nardelli, Esq.
Jonathan D. Feinberg, Esq.
Assistant Attorney General New York State Department of 120 Broadway Public Service, Staff Counsel Room 3-118 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 Spence W. Perry, Esq.
Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Gerald C. Crotty. Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.
Stephen B. Latham, Esq.
Suffolk County Attorney Twomey, Latham & Shea Budding 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Lh.OE& w James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 1,1988 l
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