ML20196H394

Lilco Second Supplemental Responses & Objections to State of Ny First Set of Interrogatories & Requests for Production of Documents.* W/Certificate of Svc.Related Correspondence

ML20196H394
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/07/1988
From:	Leugers M HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF
References
CON-#188-5778 OL-3, NUDOCS 8803110019
Download: ML20196H394 (6)

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f[7[ gnAnoCOKR N A M LILCO, March 7,1988 00CKETED V5NRC UNITED STATES OF AMERICA '88 MAR -9 N0:30 NUCLEAR REGULATORY COMMISSION O FifCE L! I N :,1 M <

00CKt li'm e. Envn:L BRMM Before the Atomic Safety and Licensing Board in the Matter of )

)

LONG 1SLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station. ) (School Bus D.'iver Issue)

Unit 1) )

LILCO'S SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO NEW YORK STATE'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS LILCO hereby supplements its responses to the State of New York's First Set of Interrogatories and Request for Production of Documents, dated and served on LILCO on January 22,1988.

I. GENERAL ANSWERS AND OBJECTIONS TO INTERROGATORIES DEFINITIONS AND INSTRUCTIONc.

LILCO gives the same general answers and makes the same general objections to New York State's interrogatories, Definitions, and Instructions that it made in response to Suffolk County's First Set of Interrogatories and Request for Production of Docu-ments. See LILCO's Responses and Objections to Suffolk County's First Set of Interrog-atories and Request for Production of Documents (January 20,1988), at 1-2.

D. SUPPLEMENTAL ANSWERS TO INTERROGATORIES.

New York State Interrogatory No.13 Does LILCO now have in its possession, custody or control any information that is in addition to or different from the information set forth in the "Response of the State of New York to LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers," dated January 19, 1988, and "LILCO's Motion for Summary Dispasition of Contention 25.C (' Role Conflict' of School Bus Drivers)," dated October 22, 1987, concerning: (a) the number of students g311oo19600307 e o ADOCK 0"000322 PDR }f5 9 l

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.j currently enrolled at each school located in the ten-mile EPZ for Shoreham (s_e_e LILCO Interrogatory No. 0): (b) which of these schools are on split sessions and the number of students in attendance during each split session for each school (s_ee LILCO Interrogato-ry No. 8); (c) the identification of each and every bus company that contracts with each school located in the ten-mile EPZ for Shoreham to transport school children (see LILCO Interrogatory No. 9): (d) which of these bus companies provide buses and drivers to wnich schools (seee LILCO Interrogatory No. 9): (e) the number of school bus drivers under contract to or on the payroll of each school located in the ten-mile EPZ for Shoreham (see LILCO Interrogatory No.10): (f) the number of these drivers that are designated for each school (s_ee LILCO Interrogatory No.10)? If the answer is affirma-tive, provide on a lettered subpart by subpart basis, the additional or different infor-mation.

SUPPLEMENTAL llESPONSE: LILCO supplements its response to New York State in-terrogatory No.13(d) and (e) with the following information which is different f rom that found in LILCO's summary disposition motion:

Buses and Drivers on Contract to EPZ School District Bus Company School Shoreham-Wading River Seaman Bus 30 buses / drivers Central School District Longwood School District Suburbia Bus 94 buses / drivers Miller Place School 51edibus 3 vans / drivers District Seaman Bus 1 bus / driver Patchogue-Medford Crimson Coach 1 van / driver School District Comsewogue School Medibus 30 buses / drivers District 6 handicapped vehicles / drivers 12 vans / drivers South Manor School Adelwerth Bus 10 buses / drivers District

) ~3-OBJECTIONS STATED BY COUNSEL All objections and references to objections were stated by counsel.

Respectfully submitted.

W . 1M Jamb gq)fistm[ag Mary Jo Leugers Counsel for Long Island Lighting Company l{unton & Williams 707 East Main Street P.O. Box 1535 l

Richmond, Virginia 23212 DATED: March 7,1988

) LILCO March 7,1988 00htiE0 UvNRC

'88 IWI -9 N0130 CERTIFIC ATE OF SERVICE ON!CE :i iMt IM r DOCK {IING 4 S!ftVjCT BRANCH In the Matter of LONG ISLAND LIGHTINO COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S SECOND SUPPLEMENTAL RESPONSES AND OBJECTIONS TO NEW YORK STATE'S FIRST SET OF INTERROO.tTORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS were served this date upon the fol-lowing by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mall, 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 One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy. Rockville, MD 20E52 Bethesda, MD 20814 Herbert H. Brown, Esq.

• Mr. Frederick J. Shon ** Lawreace 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. /

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 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 b

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.i Alf red L. Nardelli, Esq. Jonathan D. Feinberg, Esq.

Assistant Attorney General New York State Department of 120 Broadway r Public Service, Staff Counsel '

5toom 3-118 Three Rockefeller Plaza jzew York, New York 10271 f, Albany, New York 12223 Spence W. Perry, Esq. ** Ms. Nora Bredes ,

William R. Cumming Esq. Executive Coordinator it Federal Emergency Management Shoreham Opponents' Coalition Agency yi 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C.' 20472 s Evan A. Davis, EscP Mr. Jay Dunkleberger , s,' Counsel to the Governor i New York State Energy Office '_' Executive Chamber-Agency Building 2 State Capitol Empire State Plaza 1 Albany, New York 12224 i 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 Veteraas Memorial Highway l P.O. Box 298 Hauppauge, New York 11788 i Riverhead, New York 11901 l Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 I

Agency Wading River, NY 11792 M Federal Plaza New York, New York 10278 N . N

._Ma {J ers g Hunton & Williams 707 East Main Street

, P.O. Box 1535 Richmond, Virginia 23212 DATED: March 7,1988 J

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VERIFICATION Douglas M. Crocker, being 'first duly sworn on oath, deposes and says: ths,t he is curren 1y the Manager, Nuclear Emergency Preparedneca, Nuclear Operations Support Department for Long Island M.ghting Company; that he has personal knowledge of a portion of the subject matter of this litigation; thAt responsibia e'orporate employees have provided him with additional ,

facts necessary to provide the information contained in the foregoing Answurs to Interrogatories; that he has read the arswers, and L. nows the contents thereof; and that based upon such int.irmar".on cd which he has eersonal knowledge and with which he 1 has been provided, he is informed and believes the matters stated therein to be true, and on thase grounds alleges that the matters stated therein are true and therefore verifies the forgoing on behalf of Long Island Lighting Company.

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DoingTaTM. Crocker State of New York SS:

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a Notary Public in and for id, harab: certify that Douglas M.

the jur s ceion 'afo Crocker hose name s igne1 to the foregoing Answers to Interrogstories, dated f # 47 _, 1988, has personally sworn l

l before me that the statements therein are true to the boot of his

' knowledge and belief.

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