ML20147H812

Suffolk County Fourth Supplemental Response to Lilco First Set of Interrogatories & Requests for Production of Documents Re Role Conflict of School Bus Drivers.* Certificate of Svc Encl.Related Correspondence

ML20147H812
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/03/1988
From:	Taylor J KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
Shared Package
ML20147H796	List: ML20147H790 ML20147H812
References
OL-3, NUDOCS 8803090074
Download: ML20147H812 (7)

Text

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i o RELATED CORRESPONOM DOCMETED Marchi3. II[k UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board jF ICE Cf Efd[iw MIy{gjiERVICf.

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3'

) (Emergency Planning)

(Shoreham Nuclear Power )

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Station, Unit 1). )

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SUFFOLK COUNTY'S FOURTH SUPPLEMENTAL RESPONSE '

TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SQHOOL BUS DRIVERS _

Suffolk County hereby supplements its Answers of January 19, and its Supplemental Responses of January 27, February 15, and '

February 17, 1988, to LILCO's First Set of Interrogatories and ,

Requests for Production of Documents Regarding Role Conflict of I

School Bus Drivers ("LILCO's First Discovery Request").

LILCO Interroaatory No. 11

11. Identify any contacts and communications the Intervenors have had with any school or school district in the EPZ regarding evacuation of those schools during  ;

a Shoreham emergency. Include for each contact and '

! communications, the school or school district contacted and the person talked with, the date of each contact, i and the substance of each conversation. Please produce any documents related to such contacts.  ;

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i Answer. By letter dated February 19, 1988, Karla J. Letsche of Kirkpatrick &~Lockhart contacted the Miller Place Union Free School District. As this contact concerned anticipated i litigation of LILCO's new schools evacuation proposal, the letter I is protected by the work product doctrine and will not be'  !

produced.  !

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All ott.er information responsive to this Interrogatory has s g previously been provided to LILCO. Egg Second Supplement to Suffolk County's Answers to LILCO's First Set of Intt.trogatories , [

and Document Requests Regarding Role Conflict of School Bus .

Drivers, dated February 15, 1988.

Any other contacts Suffolk -

County has had with schools or school districts since the filing of its February 15 Supplemental Response have involved the  !

a

. scheduling and preparation of Suffolk County witnesses for l

, depositions taken by counsel for LILCo. -

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t LILCO Interrocatorv No. 18 e

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18. Please identify and provide a copy of any document not (

already identified in response to interrogatories 7 and. l 1

j 11-14 above on which Intervenors intend to rely in

• support of their position on the issue of whether there will be a sufficient number of school bun drivers to r evacuate schools during a shoreham emergency.  !

l Answer. The following documents will be relied upon by the  !

t Governments in support of their position that LILCO's schools  !

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proposal is inadequate W Mt. Sinal Parents Teachers I > '.1 (1

' Organization Draft Resolution, undd e63 lyt.

iinal Teachers' Association Resolution, undated; Mt. Sinal Union .\ Free School .

Dlstrict ResolutJon, dated October 18,-1983; Middle Country,

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Central'53hbol' District Board of Education Resolution, dated November- 7.1963; l'iddle Island Central School District Sghool

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1-Board Resolution, '

f dated Septate'?er 29, 1983; Miller Place Union Free Schooh. District Board Resolutions, dated Septenber 1, 1983 i

and February 10, 1988. <\

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With the exception of the Miller Place Unljd Fru School l District Board Resolution of February 10, 1988, which was f

provided to LILCO by counsel for Suf folk Cour.ty under cover letter dated February 26, 1988, the othe r resolutions referen&M s

'above, as well as other school resolutions and other documents, y that may be relied upon by Suffolk County', were attached to '

'/

i prefiledtestimonysubmittedbySuffolyCountyinthe 1983-84 i,I k' emergency pfa'nning litigation.

Tilese resolutions are therefore as accessibicho LILCO as Suffolk Count > and are not produced

.with this Supplenental Response. Nevertheless, the information here set forth is responsive to an outstand'ng LILCO discovery request.' In' addition, this information uds reqtasted by counsel

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h5 . . gj'A- 'for'LILCO-'atjthe February 24' deposition of Suffolk County witness

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Respectfully cubmitted,

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_3 ller J. Lynn Taylo{rdgl C H Kirkpattick &-Lockhart 1800 M Street, N.W.

South Lobby - 9th Floor

' Washington, D.C. 20036-5891 March 3, 1988

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,; . TDATED CORRE3@qq 00CKETE0

.USNHC March 3, 1988 UNITED STATES OF AMERICA; ' 18 NM -7 P4 :26 NUCLEAR REGULATORY COMMISSION

.Before the Atomic Safety andLicensinaBoahMfiNG h v^kt s BRANCH

)

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 FOURTH SUPPLEMENTAL RESPONSE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING ROLE CONFLICT OF SCHOOL BUS DRIVERS and SUFFOLK COUNTY'S SECOND 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 3rd day of March, 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 Washington, D.C. 20555 W. Taylor Reveley, III, Esq.

• Hunton & Williams Fabian G. Palomino, Esq. P.O. Box 1535 Richard J. Zahnleuter, Esq. 707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol Albany, New Yerk 12224

r- i 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 Legislatu.a Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway 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 Docketing and Service Section Executive Director Office of the Secretary 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 Fxecutive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-118 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.

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.

Albany, New York 12223 Washington, D.C. 20555 David A. Brownlee, Esq. Mr. Stuart Diamond i Kirkpatrick & Lockhart Business / Financial l 1500 Oliver Building NEW YORK TIMES l Pittsburgh, Pennsylvania 15222 229 W. 43rd Street

! New York, New York 10036 i

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Douglas _J. Hynes, Councilman

! Town Board-of Oyster Bay Town. Hall-Oyster Bay, New York- 11771

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IRKPATRICK & LOCKHART 1800 M. Street,.N.W.

South Lobby - 9th Floor Washington, D.C. 20036-5891

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