ML20149L046
| ML20149L046 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/16/1988 |
| From: | Zahnleuter R NEW YORK, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5644 OL-3, NUDOCS 8802240089 | |
| Download: ML20149L046 (6) | |
Text
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i RELATED CORRESMOEM 00CMETED DATE:
February SY,RCiggg 58 FB 19 P4 57 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE ;F Scc 7 g7fp 00CXEiim;,5 gg,<vjer*
NC4 Before the Atomic Safety and Licensina Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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i RESPONSE OF THE STATE OF NEW YORK TO LIILO'S FOURTH 3ET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS This is the State of New York's response to "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," dated February 1, 1988 ("LILCO's Fourth Set of Interrogatories and Requests").
To the extent that LILCO's Fourth Set of Interrogatories and Requests seeks information and documents of any sort that are not within the possession, custody or control of the State of New York, but, rather within the possession, custody or control of school districts, bus companies or county governments (including Suffolk County), the State of New York objects.
School districts, bus companies and county governments are autonomous from the State of New York and are not within the State of New 88022400B9 880216 PDR ADDCK 05000322 b
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York's control.
Accordingly, the burden of obtaining such information is the same for LILCO as it is for the State of New York.
To the extent that LILCO's Fourth Set of Interrogatories and Requests seeks information and documents of any sort that are protected against disclosure, for example, by attorney work product doctrine, the State of New York objects.
LILCO Interroaatory No. 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 documents regarding role conflict of school bus drivers, please respond to Requests 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.
Resoonse:
As of this time, there have been no such changes.
LILCO Interrocatory No. 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 drafts of it, (2) the results of the survey, (3) any reports on or analyses of the survey, (4) 2
any tapes or transcripts of the interview, and (5) any reports on or analyses of the interview.
Response
This interrogatory is not directed to the State of New York.
Obiections Stated by Counsel Counsel states all objections, assertions of privilege, and answers not requiring verification.
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t Fabian (.pZahnleuter 6mino Richard J.
Special Counsel to the Governor Attorneys for Mario M.
Cuomo Governor, and the State of New York i
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00LKETE0 USNRC 18 FEB 19 P4 '47 DATE: February 16; 1988 0FFICE U SECRt1ARY 00CKEliNG A SEi'VICI.
UNITED STATES OF AMERICA BRANCH NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station
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Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of the "Response of the State of New York to LILCO's Fourth Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers" have been served on the following this 16th day of February 1988 by U.S. mail, first class, except as noted by asterisks.
Mr. Frederick J.
Shon Spence W.
Perry, Esq.
Atomic Safety and Licensing Board William R.
Cumming, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel, Washington, D.C.
20555 Federal Emergency Management Agenc 500 C Street, S.W., Room 840 Washington, D.C.
20472 Dr. Jerry R.
Kline Mr. James P.
Gleason, Chairman 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
Anthony F.
Earley, Jr., Esq.
Joel Blau, Esq.
General Counsel Director, Utility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi Mr. Donald P.
Irwin clerk Hunton & Williams Suffolk County Legislature 707 East Main Street Suffolk County Legislature P.O.
Box 1535 Office Building Richmond, Virginia 23212 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 Commission 195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 Adrian Johncon, Esq.
Hon. Patrick G.
Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 3-16 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 E. Thomas Boyle Lawrence Coe Lanpher, Esq.
Suffolk County Attorney Kirpatrick & Lockhart Building 158 North County Complex 1800 M Street, N.W.
Veterans Memorial Highway South Lobby - Ninth Floor Hauppauge, New York 11788 Washington, D.C.
20036 Mr. Jay Dunkleburger George Johnson New York State Energy Office U.S.
Nuclear Regulatory Commission Agency Building #2 Washington, D.
C.
20555 Empire State Plaza Albany, New York 12223
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Mr. James P. Gleason Douglas J. Hynes Chairman Town Board of Oyster Bay Atomic Safety and Licensing Board Town Hall 513 Gilmoure Drive Oyster Bay, New York 11771 Silver Spring, MD 20901 David A. Brownlee, Esq.
Mr. Philip McIntrie Kirkpatrick & Lockhart FEMA 1500 Oliver Building 26 Federal Plaza Pittsburgh, Pennsylvania 15222 New York, New Ycrk 10278 Mr. Stuart Diamond Business / Financial NEW YORK TIMES 229 W.
43rd Street New York, New York 10036 i
U Richard /J[Zahnleuter, Esq.
Deputy special Counsel to the Governor Executive Chamber I
Capitol, Room 229 Albany, New York 12224 (518) 474-1273 l
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