ML20196B052
| ML20196B052 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/25/1988 |
| From: | Latham S SOUTHAMPTON, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5516 OL-3, NUDOCS 8802080017 | |
| Download: ML20196B052 (5) | |
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55/f 00LKETED UNITED STATES OF AMERICA NUCLEAR REGUIATORY CONNISSION Before the Atomic Safety and Licensina Board fiff E 3 SiU. u In the Natter of
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LONG ISLAND LIGHTING CONFANY )
Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power
)
(School Bus Driver Issue)
Station, Unit 1)
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THE TOWN OF SOUTHAMPTON'S RESPONSE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO THE TOWN OF SOUTHAMPTON The Town of Southampton responds to LILCO's First Set of Interroatories and Request for Production of Documents, dated and served on the Town of Southampton on January 15, 1988.
LILCO Interroaatory No. 1 Will the Town of Southampton sponsor any witnesses on any factors concerning "whether, in light of the potential for role conflict, a sufficient number of school bus drivers can be relied upon to perfcra emergency evacuation duties,a gangrandum and Order (Ruling on Applicant's Notion of October 22, 1987 for Summary Disposition of Contention 25.C Role Conflict of School Bus Driers) (December 30, 1987) at 5, or attempt to introduce any evidence, other than that which will be presented by Suffolk County or the State of New York?
Responset No.
Respectfully sybuitte M3A~
Stephen Lathan i
8802000017 080125 PDR ADOCK 05000322 G
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I Twomey, Latham, Shea & Kelley l
33 West second street P.O. Box 398 Riverhead, NY 11901
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Dated January 25, 1988 I
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VERIFICATION JOHN BENNETT, being duly sworn, deposes and says:
that he is the Town Attorney for the Town of Southampton, that he has read the Answer to Interrogatory f1; and that based upon such information of which he has :personal knowledge and with which he has been provided, he is 'nformed and believes that matters stated therein to be true to the best of his knowledge and
- belief, and on these grounds alleges that the matters stated therein are true and therefor ve les the foregoing on behalf of the Town of Southampton.
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J HN BENNE Sworn to before me h
26* day of Ja ry, 1988.
b 9Mh to<t USA MX MAROTTA Notary Pwtfe, State of Now York No. 52-48'J7160. SuMA Cou Comrniulon D$es May 26,19 e
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CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY ihkd % g' r
(Shoreham Nuclear Power Station, Unit K
Docket No. 50-322-OL-3 BRANCW I hereby certify that copies of the Town of Southampton's l
Response to LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers to the Town of Southampton were served this date upon the following by first-class mail, postage prepaid.
James P. Gleason, Chairman George E. Johnson, Esq.
Atomic Safety and Licensing Richard G. Bachmann:, Esq.
Board U.S. Nuclear Regulatory Comm.
513 Gilmours Drive 11555 Rockville Pike Silver Spring, Maryland 20901 One White Flint North Bethesda, MD 30814 Dr. Jerry R. Kline Atomic Safety and Licensing Herbert H. Brown, Esq.
Board Lawrence Coe Lanpher, Esq.
U.S. Nuclear Regulatory Com.
Karla J. Letsche, Esq.
East-West Towers, Room 427 Kirkpatrick & Lockhart 4350 East-West Highway South Lobby - 9th Floor Bethesda, MD 20814 1800 M Street, N.W.
Washington, D.C.
20036-5891 Mr. Frederick J. Shon Atomic Safety and Licensing Fabian G. Palomino, Esq.
Board Richard J. Zahnleuter, Esq.
U.S. Nuclear Regulatory Com.
Special Counsel to the East-West Towers, Room 430 Governor 4350 East-West Highway Executive Changer Bethesda, MD 20814 Room 229 State Capitol Secretary of the Commission Albany, NY 12224 Att Docketing and Service Sect.
Alfred L. Nardelli, Esq.
U.S. Nuclear Regulatory Com.
Assistant Attorney General l
1717 H Street, N.W.
120 Broadway, Room 3-118 Washington, D.C.
20555 New York, NY 10271 Atomic Safety and Licensing Spence W. Perry, Esq.
j Appeal Board Panel William R. Cumming, Esq.
U.S. Nuclear Regulatory Comm.
FEMA Washington, D.C.
20555 500 C Street, S.W., Room 840 Washington, D.C.
20472 Atomic Safety and Licensing Board Panel Mr. Jay Dunkleberger i
U.S. Nuclear Regulatory Comm.
New York State Energy Office Washington, D.C.
20555 Agency Building 2 i
s Empire State Plaza Albany, NY 12223 James M. Christman, Esq.
Mary Jo Leugers, Esq.
Hunton & Williams 707 East Main Street P.O.
Box 1535 Richmond, VA 23212 Mr. Philip McIntire FEMA 26 Federal Plaza New York, NY 10278 Jonathan D. Feinberg, Esq.
New York State Dept. of Public Service, Staff Counsel 3 Rockefeller Plaza Albany, NY 12223 Ms. Nora Bredes Executive Coordinator Shoreham opponents' coalition 195 E. Main Street Smithtown, NY 11787 Gerald C. Crotty, Esq.
Counsel to the Governor Executive Chamber State Capitol Albany, NY 12224 Martin Bradley Ashare, Esq.
Eugene R. Kelly, Esq.
Suffolk County Attorney H. Lee Dennison Building Veterans Memorial Highway i
Hauppauge, NY 11787 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Wading River, NY 11792
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STEPHE(1). LATHAM Dated:
February 1, 1988 4
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