ML20051K003

First Request for Production of Emergency Planning Documents.Certificate of Svc Encl

ML20051K003
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/11/1982
From:	Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	LONG ISLAND LIGHTING CO.
References
ISSUANCES-OL, NUDOCS 8205170284
Download: ML20051K003 (25)

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- .-- .3, UNITED STATES OF AMERICA O D NUCLEAR REGULATIORY COMMISSION #

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LONG ISLAND LIGHTING COMPANY )

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(Shoreham Nuclear Power )

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SUFFOLK COUNTY'S FIRST REQUEST FOR PRODUCTION OF EMERGENCY PLANNING DOCUMENTS TO LONG ISLAND LIGHTING COMPANY Pursuant to 10 C.R.F. 5 2.741, and the Licensing Board's

, Order, dated April 20, 1982, LILCO is requested by Suffolk County to produce at the Shoreham Nuclear Power Plant (or an-other agreed upon location) each of the documents set forth below, within thirty (30) days after service hereof. These document requests pertain to the emergency planning and prepar-edness issues under consideration by the Licensing Board and to whether emargency planning and preparedness for the Shoreham facility complies with 10 C.F.R. S 50.47 and 10 C.F.R. Part 50, l

Appendix E.

l DEFIN7.TIONS AND INSTRUCTIONS

• A. Wherever appropriate, the singular form of a word shall be interpreted as plural and vice versa.

s50 3 B. "And" as well as "or" shall be construed either dis- Ur junctively or conjunctively as necessary to bring within the //

l l scope hereof any information (as defined herein) which might 82 0 517 0egy G

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e otherwise be construed to be outside the scope of these discovery' requests.

C. Wherever appropri' ate, the masculine form of a word shall be interpreted as feminine and vice versa.

D. The term " person" includes any natural person, firm, partnership, educational institution, joint venture, corpora-tion, and any domestic government organization, or group of natural persons or such entities.

E. The term "information" shall be expansively construed and shall include facts, data, theories, analyses, opinions, images, impressions, concepts and formulae.

F. The term " document" shall be expansively construed and shall mean any tangible thing from or on which information can be stored, recorded, processed, transmitted, inscribed, or memorialized in any way by any means regardless of technology or form. Each copy of a document which contains separate no-tations or writings thereon, and each draft of a document which differs in any way ' from the final version of the document, shall be deemed to be a separate document for purposes of these discovery requests. [ Versions of a document which differ in clearly nonsubstantive and unimportant ways from other versions of the document do not need to be considered a' separate docu-ment.]

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G. The term " communication" includes every exchange of information by any means.

H. The term "LILCO," "you," or "LILCO personnel" means Long Island Lighting Company, and any affiliate, agent, employ-ee, consultant, contractor, subcontractor, technical advisor, representative, or other person acting for or on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.

I. The term "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 or associated with Shoreham, ,

whether onsite or offsite.

J. The term " contractor" means any person, not affiliated with LILCO, who performed work relating to Shoreham, on behalf of LILCO and/or pursuant to a contract with LILCO. The term

" subcontractor" means any person, not affiliated with LILCO, who performed work of any kind relating to Shoreham, on behalf of a contractor with whom the person was not affiliated, and pursuant to a contract with such contractor. A person other than a contractor who contracts with a subcontractor shall be deemed a subcontractor.

• K. The words "concerning," " concerns," or any other de-rivative thereof include referring to, responding to, relating to, pertaining to, connected with, comprising, memorializing, commenting on, regarding, discussing, showing, describing, reflecting, analyzing, suppor, ting, contradicting and consti-tuting.

L. If LILCO objects to or claims a privilege (attorney-client, work product, or otherwise), with respect to any docur ment request, in whole or in part, or seeks to withhold docu-ments or information because of the alleged proprietary nature of the data, set forth all reasons and the underlying factual basis for the objection or claim of privilege in sufficient detail to permit the Licensing Board to determine the validity of your objection or claim of privilege. This description should include with respect to each document: the author, ad-dressor, addressee, recipients of indicated and " blind" copies, date of preparation, subject matter, purpose for which it was prepared, number of pages, attachments or appendices, all per-sons to whom distributed, shown or explained, present custo-dian, all persons believed to have a copy of the document, and the nature of the privilege or objection asserted.

M. If any document called for herein has been destroyed, that document is to be identified as described in the second sentences of "L", above. LILCO also is requested to state the date of destruction, person authorizing destructior., and person destroying the document.

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e N. Information furnished in answer to a document request may be furnished by refe,rence to the answer provided for anoth-

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er document request, provided the other referenced answer fully responds to each request for information contained in the re-quest. Separate answers should be provided for each request and each subpart thereof. The County is interested in receiv-ing the relevant data asked for and any means of providing such data which are less time-consuming for the responder but which are nevertheless complete and fully understandable will satisfy the intent of these requests.

O. As used herein:

(1) The term " plan" or emergency response plan shall ,

refer to the Shoreham Emergency Plan as descri- ,

bed in SNRC 568, dated May 27, 1981, and SNRC 656, dated January 11, 1982.

(2) " Analysis" means research, investigation, audit, inspection, review, testing, monitoring, or any other method or form of examining data and/or forming conclusions or recommendations.

(3) "NRC" means the Nuclear Regulatory Commission and its staff, any division or section thereof, any staff member thereof, or any agent, consul-l tant, contractor, subcontractor, technical advi-l l sor, employee, or representative of the NRC.

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A DOCUMENT REQUESTS 1

General . ..

1.

Any revisions, additions, corrections or deletions of or i to any portions of the emergency response plan made since January 11, 1982. h.'thcut limiting the scope of this re-quest, such documents should include, to the extent they exist:

a. Those items listed on pages 4-4 and 4-8 of the plan as "under development".

b. Any revision to page 3-6 that would include lines that appear to have been dropped from that page.

c. A Table of Contents for the plan as required by NUREG 0654, Item II. P. 8.

d. Appendix F. or any part thereof.

2. The most current revisions of all Emergency Plan Implementing Procedures. For ease of search, the imple-menting procedures and revision thereof which the County already has (and thus does not need again) are:

a. SP 69.005.02, Rev. B, TECHNICAL SUPPORT CENTER (TSC)

ACTIVATION

b. SP 69.005.03, Rev. B, OPERATIONAL SUPPORT CENTER (OSC)

ACTIVATION -

c. SP 69.007.01, Rev. B, COMMUNICATIONS EQUIPMENT t

d. THE LONG ISLAND LIGHTING COMPANY, SHOREHAM NUCLEAR POWER STATION, UNIT 1, EMERGENCY PLAN PROCEDURE, CLASSIFICATION, Rev. 00.

e. SP 69.009.01, Rev. C, NOTIFICATIONS l l

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f. SP 69.013.01, Rev. A, UNUSUAL EVENT

g. SP 69.014.01, Rev. A, ALERT

h. SP 69.015.01, Rev. A, SITE AREA EMERGENCY

i. SP 69.016.01, Rev. C, GENERAL EMERGENCY

j. SP 69.020.61, Rev. O, DOWN WIND SURVEYS

k. SP 69.022.01, Rev. A, DETERMINATION OF OFFSITE DOSES

1. SP 69.024.01, Rev. A, WATERBORNE RELEASE DOSE PROJECTION

m. SP 69.026.01, Rev. A, PROTECTIVE ACTION RECOMMENDATIONS

n. SP 69.030.01, Rev. B, EVACUATIONS DURING AN EMERGENCY

o. SP 69.030.02, Rev. D, PERSONNEL ACCOUNTABILITY

p. SP 69.030.03, Rev. A, CONTAMINATION CONTROL DURING EMERGENCIES

q. SP 69.040.01, Rev. C, PERSONNEL INJURY

r. SP 69.041.01, Rev. C, OFFSITE MEDICAL ASSISTANCE

s. SP 69.050.01, Rev. B, RADIATION DOSES DURING AN EMERGENCY

t. SP 69.051.01, Rev. B, THYROID BLOCKING

u. SP 69.062.01, Rev. B, EMERGENCY RESPONSE FACILITIES EQUIPMENT CONTROL AND READINESS CHECK

v. SP 69.070.01, Rev. B, RE-ENTRY

w. SP 69.070.03, Rev. A, TERMINATION OF THE EMERGENCY AND RECOVERY

x. SP 69.080.01, Rev. B, SEARCH AND RESCUE

y. SP 69.090.01, Rev. B, DOCUMENTATION AND RECORD KEEPING DURING AN EMERGENCY

z. CIP 1, CORPORATE NOTIFICATIONS I

1 a.a. CIP 2, Rev. O, COMMUNICATIONS EQUIPMENT b.b. CIP 3, EMERGE,NCY OP,ERATIONS FACILITY ACTIVATION c.c. CIP 4, SUPPORT CORPORATE HEADQUARTER ACTIVATION d.d. CIP 6, Rev. O, OFFSITE SECURITY c.e. CIP 10, Rev. O, RECOVERY f.f. CIP 11, Rev. O, ADMINISTRATION .

g.g. CIP 12, Rev. O, DOCUMENTATION AND RECORD KEEPING h.h. CIP 15, Rev. O, THYROID BLOCKING i.i. CIP 21, EMERGENCY ORGANIZATIONS j.j. CIP 22, Rev. O, REVISION AND APPROVAL OF PLANS AND PROCEDURES k.k. CIP 23, Rev. O, DISTRIBUTION OF PLANS AND PROCEDURES Public Notification System -

3. All documents, other than the Wyle Research Report of April, 1982, concerning the Prompt Notification System discussed on page 6-14 of the plan. These documents in-clude:

a. All drawings, blueprints or other documents detailing the design of the Prompt Notification System. <

b. All documents analyzing or comparing the design of the Prompt Notification System with the requirements of NUREG 0654 Appendix 3.

c. All documents detailing the specifications of the Prompt Notification System.

d. All documents studying, analyzing or otherwise con-cerning the proper tone, frequency and decibel level of the sirens innthe Prompt Notification System.

4. All documents, maps, drawings, or other documents concern-ing the location and size of coverage of the sirens to be i utilized in the Prompt Notification System.

i S. All documents studying, analyzing or otherwise concerning the proper placement of the sirens in the Prompt Notification System, l

[ 6. All documents describing, analyzing or concerning how the i

demography and topography of Suffolk County was considered in designing the Prompt Notification System.

7. All documents studying, analyzing or otherwise concerning whether the sirens can be heard on all beaches and remote areas within the EPZ defined in the plan.

8. All documents analyzing, reviewing or concerning the pro-cedures to be used to notify those within the EPZ who are deaf or hard of hearing.

9. All maps, drawings or other documents concerning the pla-cement of tone activated radios within the Prompt Notification System network.

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10. All documents analyzing, studying or otherwise concerning l the 'b asis for placement (.ref. # 9) of the tone activated radios and the effectiveness of such radios,

11. All correspondence with the NRC'regarding the Prompt Notification System, including that of August 20, 1981.

12. All documents describing procedures for use of the Prompt Notification System including:

a. How it is activated.

b. Who may activate it.

13. All documents analyzing, reviewing or otherwise concerning under what emergency conditions the Prompt Notification System should be utilized. This request includes docu-ments concerning use of the Prompt Notification system early in an emergency (such as at the alert stage) for notification of areas (such as beaches) where sheltering may not be a viable option.

14. All documents detailing the method for prompt notification of any boats 'within the EPZ.

15. Any field surveys conducted for development of the Prompt Notification System, as described in NUREG 0654 App. 3-11.

16. All documents studying, analyzing or otherwise concerning whether the sirens in the Prompt Notification System can be distinguished by the human ear from other sirens.

17. All documents analyzing, describing or concerning the effect of varying meteorological conditions on the effec-tiveness of the sirens.'

Public Education and Information

18. The general comprehensive information pamphlet described at page 8-18 of the plan.

! 19. All documents reviewing, analyzing or concerning the basis for including the information supplied in the above-described pamphlet, or for deleting any information from it.

20. All documents describing the information regarding radio-logical emergency preparedness placed or to be placed in telephone books, utility bills, television and radio an-nouncements, and newspapers including:

a. The specific content of such information.

b. The format'of such information. I

c. The frequency with which such information will be repeated by the various media described above.

21. All documents describing the special educational programs for organizations and groups described at page 8-18 of the plan, including all literature or other documents to be distributed to such organizations or groups.

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22. All information kits to be distributed to the news media in the event of a r,adiolo,gical emergency.

! 23. All documents concerning the location, content and format of all posters and decals to be utilized to inform the transient or resident population of Suffolk County of protective measures to be taken in a radiological emer-gency.

24. All studies, analyses, surveys or other documents which LILCO prepared or upon which LILCO relied (in whole or in part) or which were reviewed:

1. To determine how to disseminate public informa-tion on emergency preparedness. ~

2. To establish the methods and content of the pub-lic information sources described in Requests 18 through 23.

a j 25. All documents which concern or analyse the relative merits i

of various means to provide public information to ensure preparedness to respond to a radiological emergency.

26. All documents anhlyzing, studying or otherwise concerning the most effective method to inform the transient and/or permanent population within Suffolk County of the protec- l l

tive actions to be taken in the event of a radiological

emergecy at Shoreham.

27. All documents forming the bases for LILCO's conclusions (plan at 5-24) that the Emergency Communications Director shall coordinate the dissemination of information to the public, the news media and public officials.

28. All documents assessing the attitudes or perceptions of the residents of Suffolk County regarding which government body or organization would provide the most reliable information and recommendations in the event of a radio-logical emergency.

29. The contents of all prepared messages to be disseminated to the public in the event of a radiological emergency.

30. All contracts, agreements, correspondence or other such documents between LILCO and any person concerning public information or education about Shoreham, including any contract or agreement with Mr. David Garth or any organi-zation with which he.is affiliated.

Assessment and Monitoring

31. The dose assessment model in Shoreham's RMS system, re-ferred to on p. 7-12B of the plan.

32. Any documents analyzing, reviewing or otherwise concerning the dose assessment model in comparison with the require-ments of NUREG 0654 Model A criteria (Appsndix 2).

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33. Any documents concerning or analyzing LILco's ability to draw and analyze samples.'.from the post accident sampling facility, including:

a. The time necessary to draw and analyze samples.

b. Any methods that may have been reviewed that would result in more expeditious drawing and analysis of the samples.

c. Why any methods in b above may have been rejec-ted.

34. All documents analyzing or otherwise concerning LILCO's methods for off-site radiological monitoring including:

a. Any documents forming (in whole or in part) the basis for the num,ber and composition of the survey teams to be dispatched in the event of a. site or general emer-gency.

b. Any document analyzing, studying or describing the deployment of the survey teams.

c. Any document studying or analyzing the time required to dispatch the survey teams and/or the time required for them to reach the various off-site monitors.

d. Any documents studying or analyzing possible obsta-cles, such as impassable roadways due to evacuation or adverse environmental conditions, that might pre-vent field monitoring teams from reaching the off-site monitors. l 6

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e. Any document studying, analyzing or concerning the use of real time mon.itors capable of remote inter-rogation.

f. All documents analyzing, studying or commenting upon LILCO's decision to dispatch survey teams only at the site emergency and general emergency stages of an accident.

g. All documents concerning the communications capabili-ties of the survey teams.

h. All documents concerning training of the survey teams.

35. Any revisions, updates, or final version of the SNPS site Consequence Analysis, authored by Pickard, Lowe and Garrick, Inc. and dated March 25, 1982.

36. Sections 3 and 4 of the document identified in the immediately preceding request, including all Tables and Figures in those Sections.

37. All meterological data utilized by Pickard, Lowe and Garrick, Inc. in the CRAC (or CRACIT) Code regarding Shoreham, including the complete data for every hour of the entire year of the code. This information should be provided on tape suitable for input into a computer in the CRAC or CRACIT format.  !

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38. All of the raw meterological data provided by LILCO or any other person to Pickard, Lowe and Garrick to derive the meterological data descr'ited in the immediately preceding

request.

39. All population data input utilized by Pickard, Lowe and Garrick in the SNPS Site Consequence Analysis. These data should also be provided on tape suitable for input into a computer.

40. All documents concerning LIuJO's capability to predict and trace plume travel after a radiological emergency at Shoreham, including:

a. Documents concerning the equipment to be utilized in this assessment effort.

b. Documents concerning the degree of accuracy of said equipment.

41. Any documents reflecting any other consequence analysis studies regarding (other than the Pickard, Lowe and Garrick draft document referenced above and the FSAR) which reflect the potential consequences of a serious ra-diological emergency at Shoreham.

Protective Actions

42. All documents concerning assessments, studies, evaluations or analyses, performed or relied upon by LILCO, of the 1

l relative benefits of various protective actions under the specific circumstances and conditions existing in the l

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Shoreham vicinity and in Suffolk County. This request  !

l includes documents which. assess the dose reductions expec-l ted in Suffolk County'if sheltering were the recommended protective action.

43. All documents assessing the protective actions to be recommended for persons for whom sheltering is not immediately available (for instance, those people on bea-ches or' hiking trails) .

44. All documents detailing, analyzing, describing, or other-wise concerning when in the course of a radiological emer-gency LILCO will make protective action recommendations to public officials concerning individuals who are:

a. In schools,

b. On beaches.

c. In hospitals.

d. In large workplaces.

45. All documents analyzing, assessing or concerning how the activities of individuals outside of a 10-mile EPZ (assum-ing arguendo that a 10 mile EPZ were utilized) may affect or interfere with protective actions for persons within that zone, including but not limited to:

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a. The effect of residents of the eastern end of Long Island who may be outside a 10-mile EPZ, b~ut who may evacuate west, through the EPZ.

b. The effect of others outside the EPZ who may choose to evacuate, thus causing greater demand on evacua-tion routes, roadway facilities, and emergency per-sonnel.

46. All documents analyzing, studying or concerning the effect of Long Island's unusual topography upon the protective actions it will recommend to public officials.

47. Any documents analyzing, surveying, studying or concerning the sociological or psychological profile of the residents of Suffolk County that may be pertinent to emergency pre-paredness in Suffolk County.

48. All documents describing, studying or otherwise concerning evacuation time estimates for the Shoreham EPZ (or any "

part therof), which LILCO developed, considered, or relied upon in preparation of its emergency plan or which has been prepared subsequent to preparation the plan.

Staff Augmentation and Emergency Workers

49. Any revisions to Table 5-1 of the plan describing the extent'to which LILCO intends to augment its emergency I

response personnel. The cclumn describing LILCO's ability to augment its emergency response staff within 30 minutes of an accident is presently missing from Table 5-1 of the plan.

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50. All documents concerning the ability of LILCO emergency response personnel to reach the Shoreham site in the event of a general evacuation or other adverse conditions.

51. Any documents prepared for or relied upon by LILCO to de-termine the effects of potentially conflicting demands or role conflicts, such as family obligations, on the ability of LILCO and/or off-site response personnel to respond effectively to a radiological emergency.

52. Any documents studying, analyzing or concerning the effect of other emergency responsibilities or emergency condi-tions on the ability of off-site response personnel to respond on-site in the event of a radiological emergency.

53. Any documents specifying, in detail greater than that briefly outlined in Chapter 8 of the emergency plan, the training to be given to LILCO emergency response person-nel, including:

a. The curriculum for such training;

b. The textual materials to be distributed; and

c. The frequency and duration of such training.

54. All documents detailing the training to be given to per-sonnel of off-site agencies expected to respond to radio-logical emergencies on-site, including: -

a. The curriculum for such training;

b. All textual materials to be distributed;

c. The frequency and duration of such training; and l

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d. LILCO's training capacity (i.e. , how many cao LILCO train during a given period).

Medical Facilities

55. All documents concerning the availability of medical faci-lities in the event of a radiological emergency, includ-ing:

a. All documents reflecting the basis for LILCO's decision to rely on Central Suffolk Hospital for the treatment of contaminated individuals,

b. All documents reflecting the bases of LILCO's decision to rely on a hospital in Philadelphia, Pennsylvania for back-up medical services.

c. All documents concerning the availability of potential back-up hospitals or other medical f acilities closer to the potential victims of an i

emergency at Shoreham.

56. All documents considering, analyzing or concerning the possibility that Central Suffolk Hopsital may itself fall within the plume exposure EPZ and the effect such an event would have upon the availability _ of medical treatment for contaminated persons.

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The Emergency Operations Facility (FOF)

57. All documents, plans, drawings, and other documents demon-strating the abilit'y of 't'he Emergency Operating Facility (EOF) to accomodate County, Federal and State officials.

58. All documents demonstrating, analyzing or studying the conform?'ce of the EOF to NUREG 0696 and NUREG 0654.

59. All documents describing, analyzing, or concerning any or all communications systems from the EOF to County, State and Federal agencies, including:

a. The reliability of such communications;

b. Backup systems for such communications; and

c. Design specifications for such systems.

60. All documents concerning the bases for LILCO's decision to activate the EOF only upon declaration of a Site Area or General Emergency, as noted in the plan at page 7-3A.

61. All documents reflecting any analyses, studies or consi-deration of the conditions under which the EOF should be activated.

Plan Review and Integration ,

62. All documents demonstrating emergency planning coordina-tion with the State of Connecticut.

63. All documents concerning studies or assessments by LILCO or by any other person of the adequacy of the LILCO plan, in whole or in part, including:

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a. Is11 documents assessing training of personnel;

b. 'All documents assessing any emergency preparedness drills or exercises conducted by LILCC or in which LILCO has been er will be a participant;

64. All correspondence or documents reflecting contact with

! the State of New York, or any agencies thereof, regarding emergency preparedness including, but not limited to:

a. Any assessment or comment by the State of New York concerning LILCO's emergency plan or emergency pre-paredness;

b. Any assessment or comments by LlaCO or any represen-catives thereof regarding the radiological emergency response plan of the State of New York and LILCO's role therein.

65. All contracts or agreements with any persons concerning preparation of LILCO's emergency plan (or any portion thereof), including:

a. All such contracts or agreements concerning develop-ment of the plan or portions thereof;

b. All such contracts or agreements for development, manufacture, and/or installation of all systems which are part of LILCO's emergency response plan;

c. All such contracts or agreements calling for review or assessment of LILCO's plan, in whole or in part.

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66. All correspondence or documents reflecting contact with the NRC regarding the me.rits of LILCO's emergency plan, including all correspondence or other contacts concerning the emergency planning deficiencies enumerated in the Safety Evaluation Report (SER) Supplement No. 1, September 1981.

67. All documents or correspondence concerning the efforts of LILCO, its contractors, subcontractors or consultants to resolve the emergency planning deficiencies enumerated in the SER, Supp. 1 and the results of such efforts.

Respectfully submitted, DAVID J. GILMARTIN PATRICIA A. DEMPSEY Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 Herbert H. Brown Lawrence Coe Lanpher Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Floor Washington, D.C. 20036 (202) 452-7000 May 11, 1982 Attorneys for Suffolk County

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Ilatter of )

)-

LONG ISLAND LIGHTING COMPANY )' Docket No. 50-322 (O.L.)

)

(Shoreham Nuclear Power Stations, )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of "3UFFOLK COUNTY'S FIRST REQUEST FOR PRODUCTION OF EMERGENCY PLANNING DOCUMENTS TO THE LONG ISLAND LIGHTING COMPANY," dated May 11, 1982, have been served to the following on May 11, 1982 by U.S. Mail, first class, except as otherwise noted.

Lawrence Brenner, Esq. Ralph Shapiro, Esq.

Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Dr. James L. Carpenter 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W. Taylor Reveley III, Esq.*

Washington, D.C. 20555 Hunton & Williams P.O. Box 1535 Dr. Peter A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board Mr. Jay Dunkleberger U.S. Nuclear Regulatory Commission New York State Energy Office Washington, D.C. 20555 Agency Building 2 Empire State Plaza Edward M. Barrett, Esq. Albany, New York 12223 General Counsel Long Island Lighting Company Stephen B. Latham, Esq.

250 Old , Country Road Twomey, Latham S Shea Mineola, New York 11501 Attorneys at Iav P.O. Box 398 Mr. Brian McCaffrey* 33 West Second Street Long Island Lighting Company Riverhead, New York 11901 175 East Old' Country Road Hicksville, New York 11801

Marc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road - -

P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.

New York Public Service Commission MHB Technical Associates The Governor Nelson A. Rockefeller 1723 Hamilton Avenue Building Suite K Empire State Plaza San Jose, California 95125 Albany, New York 12223 Hon. Peter Cohalan David H. Gilmartin, Esq. Suffolk County Executive Suffolk County Attorney. County Executive / Legislative County Executive / Legislative Bldg. Building Veterans Memorial Highway- Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Atomic Safety and Licensing Ezra I. Bialik, Esq.

Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Bureau Washington, D.C. 20555 New York State Department of Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing .

Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Commission Bernard M. Bordenick, Esq. Washington, D.C. 20555 David A. Repka, Esq.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Matthew J. Kelly, Esq.

Staff Counsel, New York State Public Service Commission 3 Rockefeller Plaza Albany, New York 12223

• By Federal Express Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS

! 1900 M Street, N.W., 8th loor Washington, D.C. 20036 May 11, 1982

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