ML20207C752
| ML20207C752 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/17/1988 |
| From: | Taylor J KIRKPATRICK & LOCKHART, LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| OL-3-I-SC-004, OL-3-I-SC-4, NUDOCS 8808100153 | |
| Download: ML20207C752 (6) | |
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UNITED STATES OF AMERICA
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Before the Atemic Safety and Licensina Boa rd DOCC w.,
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power
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Station, Unit 1)
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SUFFOLK COUNTY'S FIFTH SUPPLEMENTAL RESPONSE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT _OF SCHOOL BUS DRIVERS Suffolk County ("the County") hereby supplements its Answers
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f of January 19, and its Supplemental Responses of January 27, Fe b r ua r y 17, and-Ma t s h 3, 1988, to LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Role Conflict of School Bus Drivers ("LILCO's First Discovery Request").
LILCO Interrocatory No. 8 8.
Please identify the number of students currently enrolled at each school located in the 10-mile EPZ for Shoreham as identified in "LILCO's Motion for Summary Disposition of Contentien 25.C ("Role Conflict" of School Bus Drivers) (O;tober 22, 1987) (hereinafter "Motion") at Attachment 1, and the source of this information.
Identify which of these schools are on split sessions and provide the current number of
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students in attendance dur ng each split session for s
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each school.
8808100153 800517 PDR ADOCK 05000322 g
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w Answer _.
Counsel for Suffolk' County has been provided with the.following school' enrollment information by its school
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official witnesses as of April 12, 1988:. there are 976 elementary students, 684 junior highl students, 572 senior high students and 118 private and parochial students enrolled in Mt.
Sinal School District; in Riverhead Central School' District, approximately 2,705 students are enrolled in the Riley Avenue and Pulaski Street Elementary Schools and the_Riverhead Junior High and Riverhead High Schools; and approximately 10,000 students are enrolled in Longwood Central School District.
LILCO Interrocatory No. 9 9.
Please identif y each and every bus company that
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contracts with each school identified in LILCO's Motion at Attachment 1 to transport school children.
For each school, specify which bus companies provide buses and drivers.
Answer.
Counsel for the County has been provided with the following information by its school official witnesses regarding bus company contracts with school districts located within the Shoreham 10-mile EPZ:
Longwood Central School District contracts with Suburbia Middle Island Bus Company for the use of 89 buses to transport its public, private and parochial school population and with Noyl Equipment for the use of 57 vehicles to transport children with special needs; and Mt. Sinai School District contracts with Harborview Coram Bus Company for the use of 27 O
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-i buses' to transport its public school children and 11 mini-vans to I
transport its private and parochial school children and children with special needs.
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LILCO Interrocatory No. 21 21.
Please list each and every State and local law, regulation,-and ordinance that Intervenors claim might make LILCO's proposal to evacuate schools in the EPZ in a single wave illegal.
Answer.
In addition to information already provided to LILCO by the County in its Answer of January 19, 1988 and in its Supplemental Response of January 27, 1988, the County may also rely on the following State and local laws and regulations:
Title D-6 of Chapter 21 of the Nassau County Administrative Code; and Article 3 of Chapter VI of the New Yor< State Transportation Regulation.
Respectfully submitted, A
ae!]S. Millak J.
Lynn Taylor Kirkpatrick & Lockhart 1800 M Street, N.W.
Scuth Lobby - 9th Floor Washington, D.C.
20036-5891 April 12,1988 O - - _.. -... -
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- i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of
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LONG ISLAND, LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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CERTIFICATE OF SERVICE 3-I hereby certify that copies of SUFFOLK COUNTY'S FTTTH SUPPLEMENTAL RESPONSE TO LILCO'S FIRST SET OF INTERRO O
REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS have the following this 12th day of. April, 1988 by U.S. mail, first class, except as otherwise noted.
James P. Gleason, Chairman Atomic Safety and Licensing Board Mr. Frederick J. Shon Nuclear Regulatory Commission Atomic Safety and Licensing Board U.S.
U.S.
Washington, D.C.
20555 Nuclear Regulatory Commission Washington, D.C.
20555 James P. Gleason, Chairman 513 Gilmoure Drive William R. Cumming, Esq.
Silver Spring, Maryland 20901 George W. Watson, Esq.
office of General Counsel Dr. Jerry R. Kline Federal Emerger.cy Management Agenc) 500 C Street, S.W.,
Room 840 A omic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20472 Washington, D.C.
20555 W. Taylor Reveley, III, Esq.
- Hunton & Williams Lawrence C. Lanpher 1
P.O.
Box 1535 Karla J. Letsche Michael S. Miller 707 East Main Street
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Kirkpatrick & Lockhart Richmond, Virginia 23212 1800 M Street, N.W.
South Lobby - 9th Floor
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Wa shington, D.C.
20036-5891
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Joel Blau, Esq.
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Director, Utility Intervention Anthony'F. Earley, Jr.,
Esq.
General Counsel N.Y. Consumer Protection Board Suite 1020 Long Island Lighting Company 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. "homas Boyle, Esq.
Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney bldg. 158 North County Complex Suffolk County Legislature
'*eterans Memor tal Highway Suffolk County Legislature Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 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 Executive Director Docketing and Service Section Shoreham Opponents Coalition Office of the Secretary 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
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120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 KRB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue Suite K North Shore Committee P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq.
New York State Energy Office Edwin J. Reis, Esq.
Agency Building 2 Office of tne General Counsel Empire State Plaza U.S. Nuclear Regulatory Comm.
A'bany, New York 12223 Washington, 9.C.
20555 David A. Brownlee,.Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEh YORM TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10u36
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' Douglas J..Hynes, Councilman
- Town Board -of Oyster Bay Adjudicatory File O.
1 Town Hall Oyster-Bay, New York Atomic Safety and Licensing
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11771 Board Panel Docket U.S.
Washington, D.C. Nuclear Regulator
.20555 3
n t a yF~I rkpat ick & Lo hart 1800 M Street, N.W.
South Lobby - 9th Floor Washington,-D.C.
20036-5891 By Telecopy O
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