ML20149N050
| ML20149N050 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/23/1988 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NEW YORK, STATE OF |
| References | |
| CON-#188-5688 OL-3, NUDOCS 8803010048 | |
| Download: ML20149N050 (4) | |
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F/fW tELATED CORRESPWg LILCO, February 23,1988 00tKEiED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 FEB 26 P3 36 Before the Atomic Safety and Licensing Board gffig5),gy BRANCi In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S SECOND SET OF REQUESTS FOR ADMISSIONS TO NEW YORK STATE Pursuant to 10 C.F.R. 5 2.742, Long Island Lighting Company, by its counsel, re-quests that New York State admit or deny, within ten days of service of this request, the Requests For Admissions contained herein.
Instructions and Definitions The "Instructions" and "Definitions" for this set of requests are the same as in LILCO's First Set of Requests for Admissions Regarding the Remand Issue of "Role Con-filet" of School Bus Drivers (Jan. 20,1988), at 1-3.
Requests for Admissions 7.
Bus driver training conducted in accordance with plans for nuclear plants in New York State other than Shoreham does not address caring for families of bus drivers in emergencies. Response of the State of New York to LILCO's Second Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers and Amendment and Supplementation of the State of New York's Response to LILCO's First Set of Interrogatories and Requests for Production of Docu-ments Regarding Role Conflict of School Bus Drivers (Jan. 27,1988) at 6 (Interrogatory No. 27).
8803010048 590223 A
PDR ADOCK 05000322
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- 8. Other than information or documents submitted or developed in the emergen-cy planning proceedings in 1983-1984, the State of New York has not been able, to date, to locate any instances of bus drivers, in any emergency, attending 'to the safety of their own families before reporting to perform their bus driving duties. Id. at 4 (Inter-rogatory No. 24); Response of the State of New York to LILCO's Third Set of Interroga-tories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers (Feb. 10,1988) at 8-10 (Interrogatory Nos. 35-37).
Respectfully submitted, b
r?= ! W James N. Christman Mary Jo Leugers David S. Harlow Counsel for Long Island Lighting Company Hunton & Williams i
707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 23,1988 E
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LILCO, February 23,1988 DXKETED usNHC 18 FEB 26 P3 :36 CERTIFICATE OF SERVICE
,gyy, bCKETING l SEHVICI-BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S SECOND SET OF REQUESTS FOR AD-MISSIONS TO NEW YORK STATE were served this date upon the following by telecopier as indicated by one asterisk, or by first-class mail, postage prepaid.
James P. Gleason, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline George E. Johnson, Esq.
Atomic Safety and Licensing Richard G. Bachmann, Esq.
Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of the General Counsel East-West Towers, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Mr. Frederick J. Shon Karla J. Letsche, Esq.
Atomic Safety and Licensing Kirkpatrick & Lockhart Board South Lobby - 9th Floor U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
East-West Towers, Rm. 430 Washington, D.C. 20036-5891 4350 East-West Hwy.
Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Richard J. Zahnleuter, Esq.
Secretary of the Commission Special Counsel to the Governor Attention Docketing and Service Executive Chamber Section Room 229 U.S. Nuclear Regulatory Commission State Capitol 1717 H Street, N.W.
Albany, New York 12224 Washington, D.C. 20555 Alfred L, Nardelli, Esq.
Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel 120 Broadway U.S. Nuc! car Regulatory Commission Room 3-118 Washington, D.C. 20555 New York, New York 10271
Spence W. Perry, Esq.
Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.
Stephen B. Latham, Esq.
Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792
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26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of i
Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 h
James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 23,1988
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