ML20149D814
| ML20149D814 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/04/1988 |
| From: | Mccleskey K HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20149D817 | List: |
| References | |
| CON-#188-5553 OL-3, NUDOCS 8802100026 | |
| Download: ML20149D814 (6) | |
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LILCO, February 4,1988 REEATED CORRES?OMDM
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OOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 88 FEB -8 P3 E6 crncc u nc t 1:., ,
Before the Atomic Safety and Licensing Board CGChEigG?."~.91 e d L-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 RESPONSE TO SUFFOLK COUNTY'S FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING THE REMAND ISSUE OF "ROLE CONFLICT" OF SCHOOL BUS DRIVERS Here, in accordance with 10 C.F.R. S 2.742, is LILCO's response to Suffolk County's First Set of Admissions Regarding the Remand Issue of "Role Conflict" of School Bus Drivers, dated January 25, 1988. LILCO admits Requests 1, 3-9,14, and 16-22 and denies Requests 2,10-13,15, and 23.
Moreover, LILCO objects to all 23 Requests, except No. 3, on the ground that they are irrelevant to the issues within the scope of this remand proceeding or irrele-vant to the question of whether LILCO's plan meets NRC requirements.
_Suffolk Coun_tfs_Reguest, for Admission No. I 1
1 That LILCO's new "auxiliary bus driver arrangement" does not include the pro-posed use of LILCO's new "auxillary" school bus drivers in the event of an early dis-missal of schools during a Shoreham emergency.
Response: LILCO admits Request No. I to the extent that it is true that the "auxiliary bus driver arrangement" does not include the proposed use of LILCO's auxiliary school bus drivers during early dismissal, and denies the request to the extent that it implies that LILCO would not provide LILCO school bus drivers for early dismissal. LILCO has stated that it would provide buses or drivers or both to schools during early dismissal if requested to do so.
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Suffolk CountYs Requet for Admission No. 2 That LILCO's new "auxiliary bus driver arrangement" does not include the provi-sion of buses for the 562 new "auxiliary" bus drivers to use in the event of an evacua-tion of schools during a Shoreham emergency.
Response: LILCO admits that, as LILCO has defined the term, "auxiliary bus driver arrangement" does not refer to the provision of buses. LILCO denies Request No. 2 to the extent that it implies that LILCO has not provided for buses for the 562 new "auxil-lary" bus drivers.
Suffolk Countys Re:aust for Admission No. 3 That LILCO's new "auxiliary bus driver arrangement" adds to LERO a minimum of 562 additional personnel.
Response: Admitted Suffolk CountYs Recust for Admission No. 4 That the new 562 "auxiliary" school bus drivers are in addition to (a) the 333 bus drivers who are expected to drive as many as 333 buses to evacuate the transit-dependent general population, according to OPIP 3.6.4, and (b) the drivers expected, under the pre-Revision 9 versions of LILCO's Plan, to participate in the evacuation of the handicapped and parochial and nursery schools, according to OPIP 3.6.5.
Response: LILCO admits part (a) of Request No. 4. LILCO admits part (b) of Request No. 4 as to drivers for the handicapped, and denies part (b) of Request No. 4 as to drivers for parochial and nursery schools.
Suffolk County's Recust for Admission No.5 That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has consented to any LILCO pro-posal to have LILCO employees drive buses to evacuate school children during a Shoreham emergency.
Response: Denied Suffolk Countys Recust for Admission No. 6 That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has consented to have LILCO employees drive school buses containing children during an evacuation from a Shoreham emergency.
Raponse: Denied Suffolk Countfs Requst for Admission No. 7 That, with the exception of the Shoreham-Wading River Central School District, no school superintendent, from any district having schools located in the EPZ, has ;
approved any LILCO "auxiliary" bus drivers as drivers of buses transporting school chil-dren in his or her school district, or under his or her charge.
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Response: LILCO is unable to admit or deny Request No. 7 because it has not sought "consent" from school superintendents. ,
Suffolk County's Request for Admission No. 8 y
That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has consented to allowing LILCO personnel, or "auxiliary" bus drivers, to drive buses under contract to those schools, during a Shoreham emergency.
Response: LILCO is unable to admit or deny Request No. 8 because LILCO has not sought "consent" f rom those schools.
Suffolk County's Request for Admission No. 9 That, with the exception of the Shoreham-Wading River Central School District, no school district, having schools located in the EPZ, has agreed that the safe imple-mentation of a single-wave evacuation of all school children in the EPZ during a Shoreham emergency is feasible.
Response: LILCO is unable to admit or deny Request No. 9, because it has not inquired 01' the school districts located in the EPZ whether in their opinion "the safe imple-mentation of a single-wave evacuation of all school children in the EPZ during a Shoreham emergency is feasible."
Spffolk County's Recust for Admission No._10 That the Shoreham-Wading River Central School District has not formally agreed to implement, or to allow LILCO to implement, its "auxiliary bus driver arrangement."
R_psponse: LILCO is unable to admit or deny Request No.10 because it is not clear from the request what is meant by "formally agreed." LILICO admits that it has to written agreement with Shoreham-Wading River.
S_uffolk County's Requests for Admission No.11 That the Shoreham-Wading River Central School District has not formally agreed to have LILCO employees drive school buses containing children from that district dur-int an evacuation from a Shoreham emergency.
Response: LILCO is unable to admit or deny Request No.11 because it is not cleai from the request what is meant by "formally agreed." LILCO admits that it has no written agreement with Shoreham-Wading River.
Su_ffolk County's Requests for Admission No.12 That the Shoreham-Wading River Central School District has not formally agreed to allow LILCO personnel, or "auxiliary" bus drivers, to drive buses under contract to that district, during a Shoreham emergency.
Response: LILCO is unable to admit or deny Request No.12 because it is not clear f rom the request what is meant by "formally agreed." LILCO admits that it has no written agreement with Shoreham-Waoing River.
'4 Suffolk County's Request for Admission No.13 l
That the Shoreham-Wading River Central School District Superintendent has not approved any LILCO "auxniary' bus drivers as drivers of buses transporting school chil-dren from that school district, or under his or her charge.
Rescopse: LILCO is unable to admit or deny Request No.13 because the final list of LILCO "auxiliary" tus drivers has not been prepared.
Suffolk Countv's Recust for AdmLdon No.14 That no bus companies have agreed to assign to LILCO, or LILCO employees, their contracts with school districts, covering the provision of school bus driving ser-vices.
Response: LILCO admits that it has not asked any bus company to "assign" a contract with school districts to LILCO, and denies the remainder of Request No.14.
Suffolk, County's Request for Admission No.15 That no bus companies, under contract with school districts in the EPZ, have agreed to allow LILCO or its employees to perform Schoo. bus driving duties covered by such contracts.
Reponse: Denied Suffolk County's Requmt for Admission No.16 That no bus companies, under contract with schoci districts in the EPZ, have agreed to release to LILCO, for use by LILCO employees during a Shoreham emergency, buses covered by such contracts.
Rsponse: LILCO admits that it has not asked bus companies under contract with school districts in the EPZ to release to LILCO buses covered by such contracts, and denies the remainder of Request No.16.
Suffolk County's Request for Admission No.17 That no school districts outside the EPZ have agreed to release to LILCO, for use by LILCO employees during a Shoreham emergency, buses under contract with such school districts.
Response: LILCO admits that it has not requested school districts outside the EPZ to release to LILCO buses under contract with those school districts, and denies the remainder of Request No.17.
Suffolk County's Request for Admission No.18 That with the exception of the Shoreham-Wading River Central School District, no school district with schools in the EPZ has agreed to have its school bus drivers trained by LILCO.
1 Response: LILCO is unable to admit or deny Request No.18, because there are out-standing offers from LILCO to school districts to train school bus drivers.
Suffolk County's Request for Admission No.19 That with the exception of the Shoreham-Wading River Central School District, no school district in the EPZ has instructed its school bus drivers to accept training by LILCO.
Response: LILCO is unable to admit or deny Request No.1?, because there are out-standing offers from LILCO to school districts in the EPZ to train bus drivers, Suffolk County's Request for Admission No. 20 That with the exception of the Shoreham-Wading River Central School District, no school district in the EPZ has agreed to have its school children evacuated during a Shoreham emergency to any reception center identified, or to be identified, by LILCO.
Response: Denied Suffolk County's Request for Admission No. 21 That with the exception of the Shoreham-Wading River Central School District, no school district in the EPZ has adopted or approved a plan for the implementation of a single wave evacuaton of all the school children in the EP2 during a Shoreham emer-gency.
Response: Denied Suffolk County's Request for Admission No. 22 That any LILCO evacuation time estimates concerning the evacuation of school children will be based on the assumption that LILCO's "auxiliary bus driver arrange-ment," or some part thereof, would be implemented.
Response: LILCO admits that one of the assumptions of LILCO evacuation time esti-mates concerning the evacuation of school children is that LILCO's "auxiliary bus driver arrangement" or some part thereof, would be implemented.
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h I Suffolk County's Request for Admission No. 23 That under LILCO's "auxiliary bus driver arrangement," it is assumed by LILCO that no LILCO employees serving as "auxiliary," backup, or primary bus drivers would experience role conflict during a Shoreham emergency.
Response: Denied Respectfully submitted, AMB.
dames y Christman /
H athy SB. McCleskey y N ary Jo Leugers Counsel for Long Island ighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 4,1988 i