ML20196F035

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Suffolk County Supplemental Response to Lilco Second Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Stay Where You Are Plan & Certificate of Svc Encl.Related Correspondence
ML20196F035
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 02/26/1988
From: Mark Miller
SUFFOLK COUNTY, NY
To:
LONG ISLAND LIGHTING CO.
References
CON-#188-5703 OL-3, NUDOCS 8803020009
Download: ML20196F035 (9)


Text

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' ff7A3 CELATED CORRESPONoggy 00cMET,E0 USNRs February 26, 1988 18 F89 29 Pi:13 UNITED STATES OF AMERICA ifflCE C NUCLEAR REGULATORY COMMISSION u0CXE hv;U;:m s 4 gpyg' Before the Atomic Safety and Licensina Board E"UOM

)

In the Matter of

)

Docket No. 50-322-OL-3

)

(Emergency Planning)

LONG ISLAND LIGHTING COMPANY

)

)

(Shoreham Nuclear Power

)

Station, Unit 1)

)

)

SUFFOLK COUNTY'S SUPPLEMENTAL RESPONSE TO LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS Pursuant to 10 CFR S 2.740(e), Suffolk County hereby supplements and amends its response to LILCO's Second Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers, dated January 13, 1988.

LILCO Interrocatory No. 29 29.

Please provide an up-to-date copy of all early dismissal and/or emergency plans for each of the schools identified in Attachment 1 of "LILCO's Motion for Summary Disposition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987.

Answer.

Copies of the most recent version of the "Stay Where You Are Plan" and the "Go-Home Plan" for the Riverhead h 0 0o09 080226 9

DOCK o D

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O Central School District are attached.

These plans, both of which are dated SeptZ.mber 1, 1987, were provided to counsel for Suffolk County on February 24, 1988.

The plans are being provided to LILCO in response to LILCO's outstanding document request.

In addition, the plans were requested by counsel for LILCO at the February 18, 1988 deposition of Suffolk County witness Edward J.

Doherty, the Supervisor of Transportation for the Riverhead Central School District.

Respectfully submitted, Wa 1 S. M1;per J. L n Taylor Kirkpatrick & Lockhart 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C.

20036-5891 Attorneys for suffolk County February 26, 1988.

I 00CKETED USNRC February 26, 1988 UNITED STATES OF AMERICA (O

NUCLEAR REGULATORY COMMISSION OFFICE C: SEen:7sgv Reipre the Atomic Safety and Licensino B8dOtriW3 ', sERymr*

DR AN.'y

)

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322-OL-3

)

(Emergency Planning)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S SUPPLEMENTAL RESPONSE TO LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have been served on the following this 26th day of February, 1988 by U.S. mail, first class, except as otherwise noted.

James P. Gleason, Chairman Mr. Frederick J.

Shon 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 James P. Gleason, Chairman William R. Cumming, Esq.

513 Gilmoure Drive Spence W.

Perry, Esq.

Silver Spring, Maryland 20901 Office of General Counsel Federal Emergency Management Agency Dr. Jerry R. Kline 500 C Street, S.W.,

Room 840 Atomic Safety and Licensing Board Washington, D.C.

20472 U.S. Nuclear Regulatory Commission i

Washington, D.C.

20555 W. Taylor'Reveley, III, Esq.

Hunton & Williams Fabian G. Palomino, Esq.

P.O. Box 1535 l

Richard J.

Zahnleuter, Esq.

707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol i

Albany, New York 12224 i

4 s.

Joel Blau, Esq.

Anthony F. Earley, Jr., Esq.

Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq.

Ms. Elisabeth Taibbi, Clerk Suffolk 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 i

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 l

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 Alfred L. Nardelli, Esq.

Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O.

Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq.

l New York State Energy Office Edwin J.

Reis, Esq.

Agency Building 2 Office of the General Counsel Empire State Plaza U.S. Nuclear Regulatory Comm.

i Albany, New York 12223 Washington, D.C.

20555 David A.

Brownlee, Esq.

Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES F

Pittsburgh, Pennsylvania 15222 229 4.

43rd Street i

New York, New York 10036 4

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4 Douglas J. Hynes, Councilman Town-Board of Oyster Bay Town Hall Oyster Bay, New York 11771 Ltd Y

fW M17hael S. Miller

/

KIRKPATRICK in LOCKHART 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C.

20036-5891 By Federal Express i

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r Etuerheab Gentral &chaal District d' owns of Elverhenb. eauthampton 3e Brookhauen roo oswn. Av.no.

Rrverhead. New York 119o12996 Tel. No, (516) 72 T8080 Etcherb N. Suprina, E6.5 Supenntendent of Schools September 1, 1987 Scorge B. Aman. h.B.

Assistant Supenntenant TO:

All Administrators / Supervisors FROM:

Richard N. Suprina [

RE:

Revised Emergency "Stay Where You Are plan" Please make certain that plan is utilized.

the following revised emergency

_ STAY WHERE YOU ARE PLAN When the stay-where-you-are signal is flashed, all elementary and secondary pupils will remain in their respective buildings.

One phone line will be held cicar in each building for the sole purpose of receiving and transmitting emergency traffic with the District Office.

The Riverhead Central School District Central Office, which is located at 700 Osborne Avenue, Riverhead, Telephone No. 727-8080, on behalf of the Districtwill handle all emergency-related information and direct school buildings.

the same to the appropriate One vehicle containing a two-way radio will be placed on the grounds of each school in the district to provide emergency communication with the Transportation Office,and/or the District Office should the telephone lines go dead.

Transportation Supervisor will be responsible The for the assignment of said vehicles.

The building principal must make certain that at information from the vehicle to the principal.least one faculty / sta School bus drivers will be called by the Transportation Office staff at All drivers, and driver substitutes will be asked tothe bus garage and by immediately to the school bus garage in anticipation of a potent ial report need to transport another location. students from any of the District buildings to All nonpublic schools as to the emergency status. in the District will be advised promptly Because of the ir physical School and Middle School have been designatedsi:e and facilities Riverhead High

?allout shelters.

These buildings will serve as central safety a s in the event the need arises to evacuate any of the elementury buildings.

y a,.>. n n.

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2-L Revised Emergency "Stay Where You Are Plan"

~

September 1, 1987 i

Pulaski Street pupil,s will be housed in the Middle School, Phillips Avenue School and Roanoke Avenue School pupils will be transported to the High School gym while Riley Avenue and Aquebogue pupils are transported to the High School auditorium.

The Superintendent and Assistant Superintendent of Schools will serve as emergency coordinators for the District together with Town, County, State and Federal authorities.

RNS:ge cc:

Transportation Supervisor Dr. Raymond DeFeo, Supt. of Schools Building Principals Dr. Aman, Ass't Supt.

Dr. Krouse v

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.i101878

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Etuerheah Gentral School District Eowns of Elverhenb. Southampton & Erockhauen roo oseeme Avenue Ftrverhead. New York 11901 2996 Tet No ($16) 727 8080 Etcharb N. euprins. Eb.B,

September 1, 1987 George W. Aman. ph.B.

Supermiencent of Schoots Assistant Supermtendent TO:

All Administrators / Supervisors RichardN.Suprina[

FROM:

RE:

Revised Emergency "Go-Home Plan" Please make certain that the following revised emergency plan is utilized.

GO-HOME PLAN This plan is submitted in accordance with the district's intention to be prepared for emergency situations which may arise.

The Riverhead Central School District covers a geographical distance of approximately twenty miles from east to west and consists of seven (7) scaarate school buildings, including five elementary schools, one Middle School, and one Central High School that houses approximately 1100 pupils.

There are also five (5) non-public schools in the area.

The Riverhead Central School District owns 56 vehicles and transports approximately 4000 pupils daily on 47 vehicles.

The District also transports the majority of its handicapped students.

Af ter considering the aforementioned circumstances, the Riverhead Central School District intends to utill e the following "GO-HOME" plan since it seems to be the most practical for the district:

When the go-home signal is flashed, all elementary and secondary pupils wh are not transported to school will walk home.

School bus drivers will be called by the Transportation Office Staff at the bus garage and by the Transportation Supervisor.

Their home and business phones are posted in the bus garage and the Transportation Supervisor's office.

In the event that a driver cannot be reached, or cannot report immediately the Transportation Supervisor will assign an approved substitute driver to drive a bus.

Secondary pupils from the High School and Middle School will be taken home first to await the arrival of younger children in the home.

At the same time as these students are taken home, students from the non-public elementary schools will be taken home on another set of buses.

Buses will then return to the public elementary schools and will take those students home along with students from Mercy High School and the H.B. Ward Vocational School.

Regular routes will be used but stops will be consolidated.

Total time should not exceed one hour and a half.

In the event of floods, alternate bus routes have been established and are availabic in the transportation office.

,101879

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Revised emergency "Go-Home Plan" September 1, 1987 j

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/ '1 faculty and staff will remain in the areas of basic assignment or in the assignment provided by their immediate supervisor until all children have been fully dismissed from-school and their supervisor has granted them permission to leave.

RNS:ge Transportation Supervisor cc:

Dr. Raymond De Feo, Supt. of Schools Building Principals Dr. Aman, Ass't Supt.

Dr. Krouse yJ1018S0