ML20149L006
| ML20149L006 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/17/1988 |
| From: | Taylor J KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5634 OL-3, NUDOCS 8802240068 | |
| Download: ML20149L006 (7) | |
Text
{{#Wiki_filter:_ _ _ _ _ - _ __ f?63 Y yyyRRwn*G 000KETED February 17I [h88 i. i3 FEB 19 P3 56 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j CUICE C: ??.Ci w < E Before the Atomic Safety and Licensina BE$r21 g-{!"ilf f. !I t t ) i In the Matter of ) Docket No. 50-322-OL-3 ) (Emergency Planning) i LONG ISLAND LIGHTING COMPANY ) ) (Shoreham Nuclear Power Station, ) t Unit 1) ) .) SUFFOLK COUNTY'S ANSWERS TO LILCO'S FOURTH SET OF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING ROLE CONPLICT OP SCHOOL BUS DRIVERS On February 1, 1988, LILCO filed its "Fourth Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers to Suffolk County f and New York State" ("Fourth Discovery Request"). Pursuant to 10 CFR S 2.740b, Suffolk County (the "County") hereby responds to LILCO's Fourth Discovery Request. F i l I. GENERAL RESPONSE 1 i A. All documenta identified in these Answers will be provided within the aime allotted by the NRC's Rules of Practice, f t to the extent the County does not object to their production. i l i 0802240068 890217 PDR ADOCK 05000322 t PDR Q ~
,, tf s' s \\ N-s v. B. The County hereby bjd ts to LILCO's interrogatori'e9 Y and document requests to t.esextent they seek information on p documents outside af the p,ossevaton, custody or control of thq.' County. - s ( C. The Coun.ty objects to all intdrrogatories, document requests, definitions, and instructions. insofar as they require the disclosure of any information pr>tected by the attorney-client privilege or work product-do'ctrine. s i N s' II. ANSWERS TO INTERROGATORIES AN_Q DOCUMENT.REOUESTS s A LILCO Interrocatory No. 45 45. To the extent there have beerfany changes since you responded to LILCO's first' and second sets of interrcgatories and requests for production of documents regarding role conflict of school bus drivers, please respond td~ Requests 1-7 and 18 in LILCO's First Set of Interrogatories and Requests for Production of Documenty Reg 6'rding Role Confl.yct of School Fus Drivers to Suffolk County and Neu-York State, dated January 5, 1988. Answer On February 15, Suffolk County supplemented its Answera to LILCO's First Set of Interrcoatories and Requests for Production of Documents, dated January 5, 1988. See Second Supplement to Suffolk County's Answers to LILCO's First Set of Interrogatories and Document Requests Regarding Role Conflict of School Bus . Drivers, dated February 15, 1988. Should additional information '
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responsive to this Interrogatory become available, LILCO will be '\\ promptly notified and this response will be supplemented j accordingly. In addition, LILCO will be promptly provided with any documents responsive to this Interrogatory, including resumes as such documents become available. s LIr69 Interrocaterv No. 46 46. In particular, for each survey or focus group interview that Professor Cole has done, is doing, or will do in connec'cion with this proceeding, please provide (1) the survey instrument and any drafts of it, (2) the results of the survey, (3) any reports on or analyses of the survey, (4) any tapes or transcripts of the interview, and (5) any reports on or analyses of the interview, h Answer With the exception of the surveys and focua group interviews conducted by Profesnor Cole in connection with the emergency planning proceedings of 1983-84 and the Exercise proceedings of 1986-87, Suffolk County states that, to the oest of its g knculedge, there is no information in existence which is responsive to this Interrogatory. The surveys and focus group interviews conducted by Professor Cole in connection with the emergency planning and E::ercise proceedings would not appear to l l,
be within the scope of this Interrogatory. In any event, such information may be found in the record and is therefore as accessible to LILCO as it is to the County. OBJECTIONS STATED BY COUNSEL All objections and assertions of privilege, or reference thereto, were stated by counsel. Y dbA,pl r Affler s J. Lynn Tayld i. KIRKPATRICK & LOCKHART 1800 M Street, N.W. South Lobby - 9th Floor Washington, D.C. 20036-5891 Attorneys for Suffolk County i February 17, 1988 i -f-a ... m ,_m.,
CCCXETED February 17, f9[E UNITED STATES OF AMERICA T6 fg3 jg p3 $g NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Boa {grlCE OF HOiElanv WCMEimG s srHVlCf' SRANCH ) 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 ANSWERS TO LILCO'S FOURTH SET OF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have been served on the following this 17th 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 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 e
a f 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 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 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 A
4 Douglas J.'Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 I
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. Ad_ _ _ .A ynn N yJpf KIRMATRIG Y LOCKHART 1800 M Street, N.W. South Lobby - 9th Floor Washington, D.C. 20036-5891 By Telecopy ! I e . _ _ _ _ _ _ _ _ _}}