ML20196D263
| ML20196D263 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/08/1988 |
| From: | Christmas J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5591 OL-3, NUDOCS 8802170061 | |
| Download: ML20196D263 (5) | |
Text
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LILCO, February 8,1988
@ LED CORRESPONDENCR 000KETED USHRC UNITED STATES OF AMERICA i
'88 FEB 11 P6 51 NUCLEAR REGULATORY COMMISSION 0FFlCE 0; SEUOM 00CKEliNG A SEiWifl.
Before the Atomic Safety and Licensing Board BRANCH In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station.
) (School Bus Driver Issue)
Unit 1)
)
LILCO'S FIFTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO SUFFOLK COUNTY AND NEW YORK STATE Long Island Lighting Company, by its counsel, propounds the following interroga-tories to Suffolk County and New York State ("Intervenor" or "the Intervenors"), pursu-ant to SS 2.740, 2.740b, and 2.741 of the Nuclear Regulatory Commission's Rules of Practice. By propounding these interrogatories and requests LILCO makes no admission or representation about the proper scope of the issues to be decided or the evidence that may be presented on the school bus driver issue.
INSTRUCTIONS AND DEFINITIONS The "Instructions" and "Definitions" for this fif th set of interrogatories on school bus drivers are the same ones set out in LILCO's First Set of Interrogatories and Re-quests for Production of Documents Regarding Role Conflict of School Bus Drivers to Suffolk County and New York State, dated January 5,1988, at pages 1-7.
The following Requests are numbered beginning where the fourth set, dated February 1,1988, lef t off.
8002170061 880200 PDR ADOCK 05000322 G
PDR DSo3
- s.,
INTERROUSTORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
- 47. SuffoS: 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 draf ted 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 whort did Suffolk County acquire copies of the completed forms?
- 52. Have other similar it,rms been given to bus companies or bus drivers? If so, when were they given, by whomt and to whom?
mes N. Christm'an ounsel for Long Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 8,1988
a Attechm:nt 1 I am a bus driver employad by 4#d#
[.
a-bye company and I drive a school bus for the h.
School District.
I have I
'besptaldthataccordingtoanemergencyplanproposed by LILCO, I may be expected to drive a school bus in the event of a radiological accident at the Shoreham plant, as part of either an early dismissal or en evacuation of schools.
This is *) state thatt 1.
I will not participate in implementing any LILCO emergency plan for Shoreham, and 2
I cannot and will not noree to drive a school bus in the avet.
of an accident at Shoreham, 8 / fY Signature i
Date
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/
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e LILCO, February 8,1988 Oct,8 TIED usNRC gg m 11 P6'41 CERTIFICATE OF SERVICE pgcc 0; bat W['
OCKE M Gla %"
BitANCH 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 FIFTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS TO SUFFOLK COUNTY AND NEW YORK STATE were served this date upon the following by telecopier as indicated by one asterisk, by Federal Ex-press as indicated by two asterisks, or by first-class mail, postage prepaid.
James P. Gleason, Chairman Atomic Safety and Licensing l
Atomic Safety and Licensing Board Board Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Commission I
Silver Spring, Maryland 20901 Washington, D.C. 20555 t
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 One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy.
Rockville, MD 20852 Bethesda, MD 20814 Herbert H. Brown, Esq.
- Mr. Frederick J. Shon Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.
4350 East-West Hwy.
Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Secretary of the Commission Richard J. Zahnleuter, Esq.
I Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W.
State Capitol Washington, D.C. 20555 Albany, New York 12224 j
Atomic Safety and Licensing f
Appeal Board Panel U.S. Nuclear Regulatory Commission L
Washington, D.C. 20555 t
I
a :
. Alfred L. Nardeill, Esq.
Jonathan D. Feinberg, Esq.
Assistant Attorney General New York State Department of 120 Broadway Public Service, Staff Counsel Room 3-118 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12213 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 Gerald C. Crotty. 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 26 Federal Plaza New York, New York 10278
.. ~
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/ James N. Christinan Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 8,1988