ML20149M761
| ML20149M761 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/22/1988 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#188-5680 OL-3, NUDOCS 8802290052 | |
| Download: ML20149M761 (7) | |
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00CKETED Zebruary 22, 1988 U5NRC UNITED STATES OF AhERICA NUCLEAR REGULATORY COMMISSION QFF CE 55 3? er:iM <
I 3efore the Atomic Safety and Licensina BoardCXETPu f, anU; butrM
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In the Matter of
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Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY
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(Emergency Planning)
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(Shoreham Nuclear Power Station,-
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Unit 1)
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SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIFTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONPLICT OF SCHOOL BUS DRIVERS On February 8, 1988, LILCO filed its "Fifth Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers to Suffolk County and New York State" ("Fifth Discovery Request").
Pursuant to 10 CFR S 2.740b, Suffolk County (the "County") hereby responds to LILCO's Fifth Discovery Request.
I.
GENERAL RESPONSE i
A.
All documents identified in these Answers vill be provided within the time allotted by the NRC's Rules of Practice, to the extent the County does not object t.o their production.
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B.
The County hereby objects to LILCO's interrogatories and document requests to the extent they seek information or documents outside of the possession, custody or control of the i
County.
C.
The County objects to all interre,atories, document requests, definitions and instructions insofar as they require the disclosure of any information protected by the attorney-client privilege or work product doctrine.
II.
ANJWERS TO INTERROGATORIES AND DOCUMENT REODESTS LILCO Interroaatory No. 47 47.
Suffolk County has provided LILCO, under cover letter of February 4, 1988, a number of forms filled out by bus drivers and stating, among other things, that "I cannot and will not agree to drive a school bus in the event of an accident at Shoreham."
An example of such a form is Attachment 1 to this Request.
Who drafted and who participated in preparing this form?
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Answer:
Members of the public contacted counsel for Suffolk County, indicated that drivers wished to sign statements such as the ones provided, and sought advice on how such statements could be drafted.
Following such conversation with counsel for the County, the forms were prepared.
LILCO Interroaator_y _No.
48 48.
Who gave the forms to bus companies or bus drivers on Long Island?
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Answer:
On information and belief, members of the public gave the school bus driver statement forms to school bus drivers on Long Island.
To the extent the aamer of any of such
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individuals are known to Suffolk County, they will not be
. i revealed in order to protect the privacy of.those' individuals.
LILCO Interroaatory No. 49 49.
Wnen were the forms given to the bus tempsnies or bus i
drivero?
Answer Suffolk County does not know the date that the forms were distributed to school bus drivets.
How2Ver, to the extent the forms were dated at the time the stateaents were signed, that date has been provided to LILCO on Vw forms.
LILCO Interrocatory No. 1Q 50.
What bus companiec and bus drivern received the forms?
Answer:
Suffolk County does not know what bus companies i
and bus drivers received che school bus driver statement forms.
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However, since only the names of the school bus drivers have been l
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redacted from copies of the completed forms provided to LILCO, l
the bus company names, if present, are 4,va11able to LILeo.
j LILCO Interrocatorv No. 51 i
51.
How and from whom did suffolk County acquire copies of the completed forms?
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Answer Counsel for Suffolk County received the completed forms from memberr of the public.
LILCO Interroaatorv No. 52 52.
Have other similar forms been given to bus companies or I
bus drivers?
If so, when were they given, by whom, and to whom?
Answer:
On information and belief, Suffolk County has no knowledge about whether similar forms have been given to bus i
companies or school bus drivers.
OBJECTIONS STA'[EP BY COUNSEL All objections and assertion of privilege, or reference thereto, were stated by counsel.
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%#d7d RTI:hael S. Miller J. Lynn Taylor 1
Kirkpatrick & Lockhart 1800 M Street, N.W.
4 South Lobby - Ninth Floor i
Washington, D.C. 20036-5891 i
Attorneys for Suffolk County i
February 22, 1988 4
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00b,Eiro February 221SkRB8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION M FB 25 PI2:06 Before the Atomic Safety and Licensina Board,g g DOCKEimc e. myicy' BRANCH t
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i In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
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CERTIFICATE OF SERVICE
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I hereby certify that copies of SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIFTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have i
been served on the following this 22nd day of February, 1988 by U.S. mail, first class, except as otherwise noted.
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James P. Gleason, Chairman Mr. Frederick J. Shon i
Atomic Safety and Licensing Board Atomic Safety and Licensing Board f
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.
j 513 Gilmoure Drive Spence W. Perry, Esq.
Silver Spring, Maryland 20901 Office of General Counsel i
Federal Emergency Management Agenc i i
Dr. Jerry R. Kline 500 C Street, S.W., Room 840
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Atomic Safety and Licensing Board Washington, D.C.
20472 U.S. Nuclear Regulatory Commission J
Washington, D.C.
20555 W. Taylor Reveley, III, Esq.
i Hunton & Williams Fabian G. Palomino, Esq.
P.O. Box 1535 i
Richard J. Zahnleuter, Esq.
707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 i
State Capitol
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Albany, New York 12224 i
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Joel Blau, Esq.
Anthony F. Earley, Jr., Esq.
Director, Utility Intervention General Counsel i
N.Y. Censumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road l
l Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq.
Ms. Elisabeth Taibbi, Clerk.
l SOffolk 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 i
Alfred L. Nardelli, Esq.
Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Groadway, 3rd Floor H. Lee Dennison Building Roc =a 3-116 Veterans Memorial Highway l
Kew York, New York 10271 Hauppauge, New York 11788 l
KHB Technical Associates Dr. Monroe Schneider j
1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 1
T.r. Jay Dunkleburger George E. Johnson, Esq.
New York State Energy Office Edwin J. Reis, Esq.
Agency Building 2 Office of the General Counsel l
Empire State Plaza U.S. Nuclear Regulatory Comm.
Albany, New York 12223 Washington, D.C.
20555 i
David A. Brownlee, Esq.
Mr. Stuart Diamond i
Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES
?ittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 4
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Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 Michael S. Miller KIRKPATRICK & LOCKHART-1800 M Street, N.W.
j South Lobby - 9th Floor Washington, D.C.
20036-5891 t
j By Telecopy i
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