ML20149K973

Second Suppl to Suffolk County Answers to Lilco First Set of Interrogatories & Document Requests Re Role Conflict of School Bus Drivers.* W/Certificate of Svc.Related Correspondence

ML20149K973
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/15/1988
From:	Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
References
CON-#188-5636 OL-3, NUDOCS 8802240056
Download: ML20149K973 (15)

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" CORRESPONDENCA 1 00CMETED USNRC February 15, 1988 .

4 FEB 19 A9:30 -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION [0C(C { g if,g' BRANCH Before the Atomic Safety and Licensino Board

)

'In the Matter of )

)

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

SECOND SUPPLEMENT TO SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS Suffolk County hereby supplements its Answers of January 19, and its Supplemental Response of January 27, to LILCO's First Set c Interrogatories and Requests for Production of Documents re-garding role conflict of school bus drivers.

LILCO Interrocatory No.1 Sucolemental answer. By letter dated February 12, 1988, the County identified seven witnesses and two tentative additional witnesses. A copy of that letter is attached hereto, and is incorporated by reference herein. It identifies, for each Kh 3s0

witness, the subject matter on which he is expected to testify.

The following additional information is provided in further response to this interrogatory.

The testimony of Dr. Allen Barton will be based generally upon his knowledge and experience in the field of sociology (including the subjects of survey research methods, disaster research, organizational behavior, and role conflict), the literature in those fields, and survey data provided by Dr. Cole.

The testimony of Robert Petrilak and Dr. Bruce Brodsky will be based upon their experience as members of their respective school boards (Mt. Sinai and Middle Country), their knowledge and

, understanding of the positions taken by those boards with respect to LILCO's auxiliary bus driver proposal for evacuation of school children in a Shoreham emergency and the bases for such posi-tions, and their knowledge and experience concerning matters re-lating to the implementability of LILCO's proposal. In addition, Dr. Brodsky's testimony will also be based upon his experience and knowledge gained through his positions with the Brookhaven Town School Boards Association, the Nassau-Suffolk School Boards l Association, and the New York State School Boards Association.

l l The testinony of Dr. Muto, Dr. Koenig, and Dr. Suprina will be based upon their experience as Superintendents of Schools in f

their respective school districts (Longwood, East Meadow, and l Riverhead), their knowledge and understanding of the positions taken by those districts with respect to LILCO's auxiliary bus

! driver proposal for evacuation of school children in a Shoreham I

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emergency and the bases for such positions, and their knowledge and experience concerning matters relating to the implementa- ,

bility of LILCO's proposal. In addition, the testimony of Drs.  ;

Koenig and Muto will be based upon their experience and knowledge gained through their positions with the Nassau-Suffolk School Boards Association.

l The testimony of Messrs. Rossi, Smith, and Dougherty will be based upon their experience as Directors of Transportation for i t

their respective school districts (Middle Country, Longwood, and Riverhead), their knowledge and understanding of the positions l taken by those districts with respect to LILCO's auxiliary bus l driver proposal for evacuation of school children in a shoreham emergency and the bases for such positions, and their knowledge and experience concerning matters relating to the implementabi-  ;

lity of LILCO's proposal. In addition, the testimony of Mr. Rossi l will be based upon his experience and knowledge gained through his position as President of the Suffolk Chapter of the New York ,

Association of Pupil Transportation.  ;

I LILCO Interrocatory No.2 Sucolemental answer. A copy of Dr. Koenig's resume was 7 attached to the February 12 letter referenced in the answer above

and attached hereto. The resumes of the other witnesses will be

, provided as soon as we receive them. I

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LILCO Interrocatory No. 3 Sucolemental answer. Dr. Muto and Messrs. Petrilak, Smith, and Rossi testified in the 1983-84 emergency planning hearings in this proceeding.

LILCO Interrocatory No. 4 Sucolemental answer. The testimony of Dr. Muto and Messrs.

Petrilak, Smith, and Rossi was provided in connection with the 1983-84 hearings.

LILCO Interrocatory No. 5 Sucolemental answer. At this time, we are able to identify the following works, authored by Dr. Barton, which include discussions on the subject of role conflict during disasters:

"Social Organizations under Stress: A Socio-logical Review of Disaster Research," (National Academy of Science - National Research Council:

Washington, D.C., 1963).

"Organization and Mass Behavior in the Emergency Social System," in Man and Society in Disaster, i George W. Baker and Dwight Chapman, ed. (New ,

l l York: Basic Books, 1962).

Communities in Disaster, (New York: Doubleday, 1969)

LILCO Interrocatory No. 6 Sucolemental answer. See supplemental answer to Inter-l regatory No. 5. We will supplement this response, if necessary, u

upon further discussion with the newly identified witnesses.

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LILCO Interrocatory No. 7 Sucolemental answer. The works of Dr. Barton are in the public domain, and should be easily accessible to LILCO.

LILCO Interrocatory No. 11 Sumolemental answer. The following "contacts and communi-cations" may be responsive to thic interrogatory: '

l. February 1, 1988, contact between Karla J. Letsche, Kirkpatrick & Lockhart, and Miller Place Union Free School District, Middle Country Central School District and Mt. Sinal Union Free School District, concerning anticipated litigation of LILCO's new school evacuation proposal.

2. February 8, 1988, contact between Karla J. Letsche, Kirkpatrick & Lockhart, and Miller Place Union Free School Dietrict, Mt. Sinai Union Free School District, Middle Country School District, East Meadow Union Free School District, and Riverhead Central School District, concerning anticipated litigation of LILCO's new school evacuation proposal. j

3. February 11, 1988, contact between Michael S. Miller

and Karla J. Letsche, Kirkpatrick & Lockhart, and Middle Country Central School District, Riverhead Central School District, j Comsewogue Union Free School District, Longwood Central School District, and Mt. Sinal Union Free School District conce ning anticipated litigation of LILCO's new school evacuation pro-l posal.

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4. February 12, 1988, contact between Michael S. Miller and Karla J. Letsche, Kirkpatrick & Lockhart, and Middle Country Central School District, Riverhead Central School District, Miller Place Union Free School District, Longwood Central School District, and Mt. Sinal tinion Free School District concerning anticipated litigation of LILCO's new school evacuation pro-posal.

The other information requested by this interrogatory is

• protected from disclosure by the attorney work product priv-ilege.

All objections and assertions of privilege, or reference thereto, were stated by counsel.

- [JJb MicWae Karla .

S. Miller f '

Letsche KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobby - Ninth Floor 1

Washington, D.C. 20036-5891 Attorneys for Suffolk County i

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00CKETED USNRC

'88 FEB 19 A9 30 February 15, 1988 nrFICF 0F FECm_TArY UNITED ST40ESitOP. ANe#fCA NUCLEAR REGULATditN"COMMISSION Before the Atomic Safety and Licensino Board

)

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 SECOND SUPPLEMENT TO SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have been served on the following this 15th day of February, 1988 by U.S. mail, first class, except as otherwise noted.

James P. Gleason, Chairman Mr. Frederick J. Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline William R. Cumming, Esq.

Atomic Safety and Licensing Board Spence W. Perry, Esq.

U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C. 20472

3 Fabian G. Palomino, Esq. W. Taylor Revel <e III, Esq.*

Richard J. Zahleuter, Esq. Hunton & Willii Special Counsel to the Governor P.O. Box 1535 Executive Chamber, Rm. 229 707 East Ma' r ?st State Capitol Richmond, t '

a 23212 Albany, New York 12224 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 Assistant Attorney General Suffolk County Executive New York State Department of Law H. Lee Dennison Building 120 Broadway Veterans Memorial Highway Room 3-118 Hauppauge, New York 11788 New York, New York 10271 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 U.S. Nuclear Regulatory Comm.

Empire State Plaza Office of General Counsel Albany, New York 12223 Washington, D.C. 20555

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a 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 Douglas J. Hynes, Councilman Mr. Philip McIntire Town Board of Oyster Bay Federal Emergency Management Town Hall Agency Oyster Bay, New York 11771 26 Federal Plaza New York, New York 10278

• By Telecopy Kar'la J.

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Letsyhr sob KIRKPATRICK E LOCKHART 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C. 20036-5891 1

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, KIRKPATRICK & LOCKHART soVTN LCBBY ,irni RoCR pex4weg ptgc 19:10 M STREET, N T.

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MICHAIL $. MILLIA MTT58LICH. PA lu:: HM c:Miticu i iin M14xo February 12, 1988 BY TELECOPY Mary Jo Leugers, Esq.

Hunton & Williams 707 East Main Street Richmond, Virginia 23212 Re: Witness Designation and Availability Dates Dear Mary Jot This is to confirm the designation of witnesses identified to date by Suffolk County for the school evacuation remand proceedin; earlier tvaay. which I reported over the telephone to David Harlow Listed below are the names and titles of the seven individuals I identified to David, their deposition availability dates (which we need to discuss, since some require explanation), and a preliminary / general description of the subject of their anticipated testimony.

to my telephone conversation with David, we were able toIn addition, subsequent identify, tentatively, two additional witnesses, who are also listed below; please note, however, that the actual designation of thethese week additional of Februarywitnesses

22. is subject to confirmation during

1. Allen H. Barton, Professor of Sociology, Columbia University. Dr. Barton is available to be deposed, in New York City, on Wednesday, February 17 (in the afternoon),

Friday, February 19 (in the morning), or at various times during the week of February 22.

Dr. Barton will likely of fer testimony concerning Dr. Cole's survey data and other "sociological issues" related to role conflict.

2. Robert Petrilak, Member of the School Board of Mt. Sinai Union Free School District.

Mr. Petrilak is available to be deposed on Long Island on Thursday, February 18 (in the

e KIRKPATRICK & l.OCKHART Mary Jo Leugers, Esq.

February 12, 1988 Page 2 afternoon) afternoon)., or February 23, 24 or 25 (in the 3 Bruce G. Brodsky, Member of the School Board of Middle Country Central School District, Member of the Brookhaven Town' School Boards Association, Treasurer and Legislative Chairperson of the Nassau-Suffolk School Boards Association, and Member of the New York State School Boards Association. Dr.

Brodsky is availa'ble to be deposed on Long Island on Wednesday, February 24.

4 Nick Muto, Superintendent of Schools, Longwood Central School District. Dr. Muto is available to be deposed on Long Island on Wednesday, February 24-26 (subject to confirmation).

5.

Howard M. Koenig, Superintendent of Schools, East Meadow Union Free School District, and Liaison from the Nassau County Council of School Superintendents to the Nassau-Suffolk School Boards Association. Dr. Koenig is available to be deposed on Long Island on Tuesday, February 16 (in the morning),

Wednesday, February 24 (subject to confirmation), or Friday, February 26 (in the afternoon).

6.

Anthony Rossi, Transportation Director, Middle Country Central School District, and President of the Suffolk County Chapter of the New York Association of Pupil Transportation.

Mr. Rossi is available to be deposed on Long Island on Thursday, February 18 (in the afternoon), or February 22-25.

7 Thomas Smith, Director of Transportation, Longwood Central School District. Mr. Smith is available to be deposed on Long Island on February 24-26 (subject to confirmation).

8 SUBJECT TO CONFIRMATION: Richard N. Suprina, Superintendent, Riverhead Central School District. Dr. Suprina is available to be

1 KIRXPATRICK & LOCKHART l Mary Jo Leugers, Esq.

February 12, 1988 Page 3 deposed on Long Island on February 24-26 (subject to confirmation).

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SUBJECT TO CONFIRMATION: ~

Edward Dougherty, Director of Transportation, Riverhead Central School District. Mr. Dougherty is available to be deposed on Long Island on February 24-26 (subject to confirmation).

Drs.

Brodsky, Muto, Koenig, and Suprina, and Messrs.

aboutproposal."

driver the implementability of LILCO's "auxiliary schoo ,

Attached hereto is Dr. Koenig's resume We will send you the resumes from of the other witnesses as soon a.s we receive them the witnesses.

Messrs. Petrilak, Smith and Rossi from the(Of course, you already know Dr.

when you deposed them and they testified). 1983-84 litigation ,

we will let you know promptly.If and when we identify or confirm any ,

i the scheduling of depositions,As you and I discussed on the telephone '

to determine what is the most '

decide to depose all these individuals. efficient and sensible wa i following two alternatives for your consideration:We would propose the February 16 (11:00 a.ni. ) -- Dr. Koenig, Long Island February 17 (afternoon) --

Dr. Barton, New York City February 18 (afternoon) --

Messrs. Petrilak & Rossi, Long Island February 24 -- One, Two, Three or more witness panels, comprised of Drs. Brodsky, Koenig, Muto, and Suprina, and

, Messrs. Smith and Dougherty (times and combinations to be determined) or, >

February 19 (morning) --

Dr. Barton, New York City  !

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KIRKPATRICK & LOCKHART I Mary Jo Leugers, Esq.

February 12, 1988 Page 4

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February 23 (afternoon) -- Messrs. Rossi & Petrilak February 24 -- Dr. Brodsky February 24 and 25 (as required) -- the remaining witnesses of two or, at most,If preferred, three days.all the witnesses could be deposed over the '

scheduling the depositions for the week of February 22That would require (Dr. Barton could be made available during that week) .

be happy to talk to you about this matter.I will be in the office on S As I mentioned to David Harlow, given the above witness availability dates, there obviously can be no depositions this coming Monday, February 15.

Thus, unknown wewitnesses) will consider your February 8 notice of depositions (for +

to have been withdrawn. ,

Sincerely, i

Michael S. Miller cc: All Counsel i

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IENARD W. KCENIG, Ph.D.

31 Greenhill IAne Huntington, New York 11743 Telepnone No.

(516) 368-52 N StPIRINIT.NDENT OF SciOOLS EDUCATICN: Ph.D. -

New York Lbiversity - 1980 Educational khinfetration M.A. -

New York Lbiversity - 1970 Educational Administration B.A. -

Queens Cb11ege (CUNT) - 1966

_ __-- Political Science / Psychology EXPERIDiCE: Septernber 1983 - Present i Superintendent of Schools EastYork.

New Meadow Lhion Free School District, East hbadow, July 1974 to Septaber 1983 Assistant Superintendent for Achinistration Harborfields Responsibilities Central Sebool District, Greenlawn, New York.

Included:

Personnel (all units and class-ifications.), Otrnpensatory Education (Chapter I/PSIN.),

Negotiations (all units.), Out-of-District Funding, Public Relations, and other duties stich overlap curricultru and instruction and business. ped the areas of October 1971 to Septaber 1973 District Manager for Adninistration and Business Affairs (kmnunity Schl District 24 - Flushing, New York Cbmrunity School District 26 - Fresh Weadm, New York Besponsibilities Included:

of a budget of core than $20,000,000 Preparation and whinistration (30) schools. District purchasing, accounting,for as cany as thirty i major and minor plant inprovements and enmmity liaison, i

Febntary 1968 to October 1971 Teacher of Mathenatics and Social Studies - Grades G-8 Teacher - Grade 6 and Assistant Dean of Students Intercediate School 61, Cbrona, New York In addition to the above, during the tire that I was pre;mring l for a career in education, I was sployed as a social worker with the New York City Department of Sacial Services and as an Official Cburt of Labor.Reporter for the N.Y.C. Civil Cburt and the N.Y.S. Department 1

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, RE3GE OF IKMARD W. KENIG, Ph.D.

Page 2 1KNTS:

Fellow - Education Professions Development Act (EFOA)

Fellowship - New York University - 1973/1974 President - Phi Delta Kappa - NYU Chapter - 1977/1978 Quadrant Cbuncil of leader School- Superintendents Southeast Quadrant of the Nassau Cbunty

- 1986/1987 '

l Naticnal Vice-President- Region I, National Association of '

Federally Inpacted Schools - 1985 / present.  !

ACTIVE Mi5fESICNAL American Association of School Adninistrators

.AFTILIATICNS Association for Supervision & Curriculum Develognent American Educational Research Association New York State Cbuncil of School Superintendents Nassau Cbunty Cbuncil of School Superintendents New York thiversity Adninistrators kundtable Thi Delta Kappa INIVESITI Adjunct Professor of Educational Adninistration AFFILIATKNS New York thiversity 1980 - present Icog Island thiversity 1982 - present Chairperson - Dean's Professional Education Advisory Ctanittee - C.W. Post Canpus of L.I.U.

i PESCNAL Ibru: July 9, IMO DATA Warried, two children Height 6' ise ight 210lbs.

Excellent Health with no rhysical dinhilities Placanent credentials are a Mlable upon request frun the New York lbiwrsity Office of Mu ational P1acanent.

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