ML20149M786
| ML20149M786 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/22/1988 |
| From: | Zahnleuter R NEW YORK, STATE OF |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#188-5679 OL-3, NUDOCS 8802290078 | |
| Download: ML20149M786 (6) | |
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00CKEIT'L-DATE:
February 22, 199&C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFF DOC ll; ~~' " W.
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Before the Atomic Safety and Licensinct Board 5 NC In the Matter of
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IDNG 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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RESPONSE OF THE STATE OF NEW YORK TO LILCO'S FIFTH SET 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 Fifth Set of Interrogatories and Requests for Production of Docu.7ents Regarding Role Conflict of School Bus Drivers to Suffolk County and New York State," dated February 8, 1988 ("LILCO's Fifth Set of Interrogatories and Requests").
.To the extent that LILCO's Fifth 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 St ate of New York objects.
School districts, bus concanies and county governments are autonomous from the State of New York and are not within the State of New 8802290078 8B0222 PDR ADOCK 050 2
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c York's centrol.
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 Fifth 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.
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i LILCO Interrocatories Nos. 47-52
- 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 egree 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?
- 48. Who gave the forms to bus companies or bus drivers on Long Island?
- 49. When were the forms given to the bus companies or bus drivers?
- 50. What bus companies and bus drivers received the forms?
- 51. How and from whom did Suffolk County acquire copies of the j
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i completed forms?
- 52. Have other similar forms been given to bus companies or bus drivers?
If so, when were they given, by whom, and to whom?
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'These interrogatories are not. directed to the State
. Responses:
. of New York.
Obie.ctions Stated by Counsel Counsel states all objections, assertions of privilege, and answers not requiring verification.
'O L
Fab'ian G. P%ogipo Richard J. 5atfnleuter Special Counsel to the Governor Attorneys for Mario M. Cuomo Governor, and the State of New York f
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DOCKEiCD MNRC R243 DATE: February 22, 8
YikElk C I UNITED STATES OF AMERICA N
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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L CERTIFICATE OF SEFVICE I hereby certify that copies of the "Response of the State of New York to LILCO's Fifth Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers" have been served on the following this 22nd 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
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Anthony F.
Earley, Jr.,
Esq.
Teal Blau, Esq.
General Counsel Lirecter, Utility Intervsation Iong Island Lignting Company N.Y. Consumer Prot.mtson Board r
175 Eaet Old Country Road Suite 1020 h'
Hicksville, New York 11801 Albany, Nr.c York 1227.0 Ms. EJicabeth Taibbi Mr. Donald P.
Irvin
'E Hunton & Williaus i
Clerk suffolk County Legislature 707 East Main Street
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Suffolk County Legislature P.O. Box 1535 Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 E
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Mr.
L.F.
Britt Stephen B.
Latham, Esq.
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Lcng Island Lighting Company Twomey, Latham & Shea f
Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 22 f
E Wading River, New York 11792 E
Ms. Nora Bredes Docketing and Service Section gh
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Executive Director Office Jf the Secretary Shoreham opponents Coalition U.S. Nuclenr Regulatory Comnissivo
[5 195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
2 05 f,5 Adrian Johnson, Esq.
Hon, Patrick G. Hsipin New York State Department of Law Suffolk County Executive HE 120 Broadway, 3rd Floor M.
Lee Dennison Building 7'
Room 3-16 Voterans Memorial Highway gy New York, New York 10271 Hauppauge, New York
?1788
- 7 MHB Tecanical Associates Dr. Monroe Schneider
@p 1723 Hamilton Avenue North Shere Committee j[
Suite K P.O.
Box 231 r,_
I San Jose, California 95125 Wading River, New York 11792 E. Thomas Boyle Lawrence Coe Lanpher, tag.
!I Suffolk County Attorney Kirpatrick & Acckhart h-Building 158 North County Complex 1800 M Stre2t, N.W.
Veterans Memorial Highway South Lobby - Ninth F10cr 3-g Hauppauge, New York 11786 Washington, D.C.
20016 I=
Mr. Jay Dunkleburger George Johnson New York State Energy Office U.S. Nuclear RequLatory Commission WF Agency Building #2 Washington, D.
C.
20555
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Empire State Plaza g;
Albany, New York 12223 F_"
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- t 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 FEMA Kirkpatrick & Lockhart 1500 Oliver Building 26 Federal. Plaza Pittsburgh, Pennsylvania 15222 New York, New York 10278 l
Mr. Stuart Diamond Business / Financial NEW YORK TIMES 229 W.
43rd Street New York, New York 10036 Richard J./ fZril,d u t e r, E s q.
Deputy Special' Counsel to the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 (518) 474-1273 By Tolecopier By Federal Express l
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