ML20148D070

Lilco First Set of Requests for Admissions Re Remand Issue of Role Conflict of School Bus Drivers.* Changes to Westchester,Wayne & Oswego Counties Emergency Preparedness Plans Requested.W/Certificate of Svc.Related Correspondence

ML20148D070
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/20/1988
From:	Harlow D LONG ISLAND LIGHTING CO.
To:	NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY
References
CON-#188-5404 OL-3, NUDOCS 8801250318
Download: ML20148D070 (7)

Text

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LILCO, January 20,1988

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00CKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'88 JM 22 P2 :23 Before the Atomic Safety and Licensing Board '

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BRAHUi 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 FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING THE REMAND ISSUE OF "ROLE CONFLICT" OF SCHOOL BUS DRIVERS Pursuant to 10 CFR S 2.742, Long Island Lighting Company, by its counsel, re-quests that Suffolk County, New York State, and the Town of Southampton ("Interve-nor" or "The Intervenors") admit or deny, within 10 days of service of this request, the Requests for Admissions contained herein.

INSTRUCTIONS A. Each request for admission shall be answered separately and fully in writing under oath in accordance with 5 2.742 of the NRC's Rules of Practice. To the extent that Intervenors do not have specific, complete, and accurate information with which to answer any request for admission, Intervenors should so state, and the request for admission should be answered to the extent information is available, identifying each person who is believed to have accurate information with respect thereto.

B. Each request for admission shall be deemed to be continuing, and Interve-nors are requested seasonably to supplement answers with additional f acts and informa-tion,in accordance with S 2.740(e)(1) and (2) of the NRC's Rules of Practice.

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8 C. The words "and" and "or" shall be construed either conjunctively or disjunc-tively so as to bring within the scope of these discovery requests any information that ,

might otherwise be construed to be outside their scope.

D. Wherever appropriate, the singular form of a word shall be interpreted in i

the plural, and vice versa, so as to bring within the scope of these discovery requests '

any information that might otherwise be construed to be outside their scope.

- E. Wherever appropriate, the masculine form of a word shall be interpreted as feminine, and vice versa, so as to bring within the scope of these discovery requests any information that might otherwise be construed to be outside their scope.

F. If Intervenors object to or claim a privilege (attorney-client, work product, or other) with respect to any request for admission, in whole or in part, or seek to with-hold any such information because of the alleged proprietary nature of the data, please set forth all reasons and the underlying factual basis for the objection or claim of privi-lege in sufficient detail to permit the Licensing Board to determine the validity of the objection or claim of privilege.

G. When, in order to answer a question fully or accurately, it is necessary to distinguish between the responses of individual Intervenors or to identify individual In-tervenors, such distinctions or identifications should be made in the answer.

DEFINITIONS A. "LILCO" or "LILCO personnel" means Long Island Lighting Company and any affiliate, agent, employee, consultant, contractor, technical advisor, representa-tive, or other person acting for or on behalf of LILCO, or at LILCO's direction or con-trol, or in concert with LILCO or assisting LILCO.

B. "Shoreham" means the Shoreham Nuclear Power Station, Unit 1, any part thereof, or any structure, system, component, instrumentation, equipment, or materials included in, or intended to be included in, Shoreham.

C. "Intervenors" means Suffolk County, New York State, and the Town of Southampton, or any of them, or any agency thereof and any agent, employee, consul-tant, contractor, technical advisor, representative or other person acting for or on be-half of them, or at their direction and control, or in concert with or assisting them.

REQUESTS FOR ADMISSIONS

1. That the Radiological Emergency Preparedness Plan for Westchester Coun-ty (Rev.1/87) ("Westchester County Plan") states that, in the event of a radiological emergency at the Indian Point nuclear power station, bus companies under cor. tract to school districts in the EPZ will provide a sufficient number of buses and drivers to sup-port the evacuation of schoolchildren, in the following words:

Bus companies providing service to individual school districts will maintain their normal responsibilities to the school dis-tricts until all schoolchildren have been moved to their homes or predesignated school reception centers as directed.

Westchester County Plan at A-20.

2. That the Westchester County Plan assumes that, in the event of a ra-diological emergency at the Indian Point nuclear power station, the evacuation of schoolchildren will not be adversely affected by "role conflict" among school bus driv-ers, in the following words:

d. Assumptions: . . . (3) That sufficient numbers of Westchester County public school bus drivers WILL respond to perform evacuation assignments.

Westchester County Plan at A-29 (emphasis in original).

3. That the Wayne County Radiological Emergency Preparedness Plan (Rev. 4 10/1/86) ("Wayne County Plan") provides that, in the event of a radiological emergency at the Robert E. Ginna nuclear power station, additional buses will be provided to schools as needed by the local response organization to etfeet a single wave evacuation:

Evacuating schools within the 10 mile EPZ without adequate transportation to transport their entire student body in one coordinated move will be furnished additional buses or trans-portation on a priority basis by the County Response Organi-zation. When these schools are in session, this action may re-quire that students be held at the school pending further instructions. If required this information will be announced to parents over the EBS broadcast system.

Wayne County Plan at A-8.

4. That the Wayne County Plan provides that, in the event of a radiological emergency at the Robert E. Ginna nuclear power station, buses from outside the EPZ will be used if necessary to support the evacuation of schoolchildren:

Upon receipt of notification of any emergency at GINNA, School Superintendents with schools outside the 10 mile EPZ will be requested to immediately place their school bus fleet and drivers on standby for possible dispatch to an evacuating school or the general public within the EPZ.

Wayne County Plan at A-8.

5. That the Wayne County Plan provides that, in preparing their individual school evacuation plans, the School District Superintendents should provide for backup school bus drivers, as follows:

Alternate bus drivers should be identified, predesignated, and trained (from the school staff).

Wayne County Plan at A-7,

6. That the Oswego County Radiological Emergency Preparedness Plan (Rev.

7/85)("Oswego County Plan") provides that in the event of a radiological emergency at the Nine Mile Point or James A. FitzPatrick nuclear power plants, bus companies under

5-contract to the school districts in the EPZ will provide a sufficient number of buses and drivers to support the evacuation of schoolchildren, in the following words:

Bus companies providing service to individual school districts will maintain their normal responsibilities to the school dis-tricts until all schoolchildren have been moved to their homes or to the predesignated reception center.

Oswego County Plan, Appendix A, Attachment 3 at 17.

Respectfully submitted, khb. 0 W Jamedf N. Christman Mary Jo Leugers David S. Harlow liunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 20,1988

o LILCO, January 20,1988 DMEiw Umc 3 JAN 22 P2 :23 CERTIFICATE OF SERVICE OC Tbi A N .L SR atU 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 FIRST SET OF REQUESTS FOR ADMIS-SIONS REGARDING THE REMAND ISSUE OF "ROLE CONFLICT" OF SCHOOL BUS DRIVERS were served this date upon the following by Federal Express as indicated by an asterisk or by first-class mail, 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 11555 Rockville Pike East-West Towers, Rm. 427 One White Flint North 4350 East-West Hwy. Bethesda, MD 20814 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.

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 Alfred L. Nardelli, Esq.

Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission 120 Broadway Washington,1>.C. 20555 Room 3-118 New York, New York 10271

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 Martin Bradley Ashare, Esq.

Stephen B. Latham, Esq.

• Eugene R. Kelly, Esq.

Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 Jonathan D. Feinberg, Esq.

New York State Department of Pubile Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 c

H $ YM Daviti5.'Harlow Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 20,1988

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