ML20054F964
| ML20054F964 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/14/1982 |
| From: | Mccleskey K HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SUFFOLK COUNTY, NY |
| References | |
| ISSUANCES-OL, NUDOCS 8206180284 | |
| Download: ML20054F964 (34) | |
Text
I
- 1. , _. LILCO, Juna 14, 1982 7
a UNITED STATES OF AMERICA 2 US I7 H2:02 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-332 OL
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(Shoreham Nuclear Power Station,)
Unit 1) )
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LILCO'S RESPONSE TO SUFFOLK COUNTY'S FIRST REQUEST FOR PRODUCTION OF EMERGENCY PLANNING DOCUMENTS TO LONG ISLAND LIGHTING COMPANY I.
Suffolk County addressed to Long Island Lighting Company (LILCO) certain discovery requests in its First Request for Production of Emergency Planning Documents, dated May 11, 1982.
LILCO's responses appear below. Where a response is "provided," the pertinent documents have been produced at the Washington, D.C. office of the County's counsel.
0 9 3 8206180284 820614 PDR ADOCK 05000332 0 PDR J
-C-5 II.
- 1. Any revisions, additions, corrections or deletions of or to any portions of the emergency response plan made since January 11, 1982. Without limiting the scope of this request, 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."
Response. Provided.
- b. Any revision to page 3-6 that would include lines that appear to have been dropped from that page. ,
Response. Provided.
- c. A Table of Contents for the plan as required by NUREG-0654, Item II. P. 8.
Response. Provided.
- d. Appendix F or any part thereof.
Response. Provided.
! 2. The most current revisions of all Emergency Plan Implementing Procedures. For ease of search, the implementing procedures and revision thereof which the County already has (and thus does not need again) are:
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- a. SP 69.005.02, Rev. B, TECHNICAL SUPPORT CENTER (TSC) ACTIVATION
- c. SP 69.007.01, Rev. B, COMMUNICATIONS EQUIPMENT
- d. THE LONG ISLAND LIGHTING COMPANY, SHOREHAM NUCLEAR POWER STATION, UNIT 1, EMERGENCY PLAN PROCEDURE, CLASSIFICATION, REV. 00.
- e. SF 69.009.01, Rev. C, NOTIFICATIONS
- f. SP 69.013.01, Rev. A, UNUSUAL EVENT
- g. SP 69.014.01, Rev. A, SITE AREA EMERGENCY
- h. SP 69.015.01, Rev. A, SITE AREA EMERGENCY
- 1. SP 69.016.01, Rev. C, GENERAL EMERGENCY
- j. SP 69.020.01, Rev. O, DOWNWIND 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 1
ASSISTANCE
- s. SP 69.050.01, Rev. B, RADIATION DOSES l DURING AN EMERGENCY l
4_
- t. SP 69.051.01, Rev. B, THYROID BLOCKING
- u. SP 69.052.01, 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 a.a. CIP 2, Rev. O, COMMUNICATION EQUIPMENT b.b. CIP 3, EMERGENCY OPERATIONS FACILITY ACTIVATION c.c. CIP 4, SUPPORT CORPORATE HEADQUARTER ACTIVATION d.d. CIP 6, Rev. O, OFFSITE SECURITY e.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. Incorporated into procedure at t.
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 PLANTS AND PROCEDURES Response. Provided.
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 include:
- 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 concerning the proper tone, frequency and decibel level of the sirens in the Prompt Notification System.
Resoonse. Provided.
- 4. All documents, maps, drawings, or other documents concerning the location and size of coverage of the sirens to be utilized in the Prompt Notification System.
Response. This information is included in the Wyle Report.
- 5. All documents studying, analyzing or otherwise concerning the proper placement of the sirens in the Prompt Notification System.
Response. This information is included in the Wyle Report.
- 6. All documents describing, analyzing or concerning how the demography and topography of Suffolk County was considered in designing the Prompt Notification System.
Response. Provided. Pertinent information is also included in the Wyle Report.
- 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.
Response. This information is included in the Wyle Report.
- 8. All documents analyzing, reviewing or concerning the procedures to be used to notify those within the EPZ who are deaf or hard of hearing.
Response. Provided.
- 9. All maps, drawings or other documents concerning the placement of tone activated radios within the Prompt Notification System network.
Response. This information is included in the Wyle Report.
- 10. All documents analyzing, studying o: otherwise concerning the basis for placement (ref. #9) of the tone activated radios and the effectiveness of such radios.
Response. This information is included in the Wyle Report.
- 11. All correspondence with the NRC regarding the Prompt Notification System, including that of August 20, 1981.
Response. Provided.
- 12. All documents describing procedures for use of the Prompt Notification System including:
- a. How it is activiated.
Response. This information is included in LILCO's i
l Emergency Response Plan (LILCO plan), previously provided to the County.
?
- b. Who may activate it.
Response. This information is included in the document entitled "Suffolk County's Draft Emergency Plan as of March 10, 1982," as supplemented by a letter from Herb Brown dated March 26, 1982 (County plan).
- 13. All documents analyzing, reviewing or otherwise concerning under what emergency conditions the Prompt Notification System should be utilized. This request includes documents 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.
Response. None.
- 14. All documents detailing the method for prompt notification of any boats within the EPZ.
1 Response. This information is in the LILCO plan.
- 15. Any field surveys conducted for development of the Prompt Notification System, as described in NUREG-0654 App.
3-11.
1 Response. This information is included in the Wyle i
( Report.
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- 16. All documents studying, analyzing or otherwise concerning whether the s'irens in the Prompt Notification System can be distinguished by the human ear from other sirens.
Response. None.
- 17. All documents analyzing, describing or concerning the effect of varying meteorological conditions on the effectiveness of the sirens.
Response. Provided. Pertinent information is also included in the Wyle Report.
Public Education and Information
- 18. The general comprehensive information pamphlet described at page 8-18 of the plan.
Response. See the response to item 8. 20.
- 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.
Response. Provided. The information supplied is also based upon guidelines in NUREG-0654.
- 20. All documents describing the information regarding r
radiological ' emergency preparedness placed or to be placed in telephone books, _ utility bills, television and radio announcements, and newspapers including:
- a. The specific content of such information.
- b. The format of such information.
- c. The frequency with which such information will be repeated by the various media described above.
Response. See the response to item 8.
- 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.
Response. None.
- 22. All information kits to be distributed to the news media in the event of a radiological emergency.
Response. Provided.
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- 23. All documents concerning the location, content and format of all poster's and decals to be utilized to inform the transient or resident population of Suffolk County of d
protective measures to be taken in a radiological emergency.
Response. None.
- 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:
- a. To determine how to disseminate public i
information on emergency preparedness.
- b. To establish the methods and content of the public information sources described in Requests 18 through 23.
3 Response. None.
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- 25. All documents which concern or analyze the relative merits of various means to provide public infcrmation to ensuie preparedness to respond to a radiological emergency.
1 Response. None.
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- 26. All documents analyzing, studying or otherwise concerning the most effective method to inform the transient and/or permanent population within Suffolk County of the protective actions to be taken in the event of a radiological emergency at Shoreham.
Response. None.
- 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.
Response. None.
- 28. All documents assessing the attitudes or perceptions of the residents of Suffolk County regard!.ng which government body or organi=ation would provide the most reliable information and recommendations in the event of a radiological emergency.
Response. None.
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- 29. The contents of all prepared messages to be disseminated j to the public in the event of a radiological emergency.
Response. None.
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- 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 organization with which he is affiliated.
Response. None.
Assessment and Monitoring
- 31. The dose assessment model in Shoreham's RMS system, referred to on p. 7-12B of the plan.
Response. Provided.
- 32. Any documents analyzing, reviewing or otherwise concerning the dose assessment model in comparison with the requirements of NUREG-0654 Model A criteria (Appendix 2).
Response. Provided.
- 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.
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- 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 rejected.
Response. Provided.
- 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 number of composition of the survey teams to be.
dispatched in the event of a site or general emergency.
Response. This information is included in the LILCO plan and NUREG-0654.
- b. Any document analyzing, studying or describing the deployment of the survey teams.
l Response. Provided.
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- c. Any document studying or analyzing the time required to dispatch the survey i
teams and/or the time required for them to reach the various off-site monitors.
Response. Documents regarding the time required to dispatch the survey teams are provided; see also the responses to items 34a, 34b, and 50. No documents exist regarding the time required for the survey teams to reach the various offsite monitors.
- d. Any documents studying or analyzing possible obstacles, such as impassable roadways due to evacuation or adverse environmental conditions, that might prevent field monitoring teams from reaching the off-site monitors.
Response. None.
- e. Any document studying, analyzing or concerning the use of real time monitors capable of remote interrogation.
Response. Provided.
- f. All documents analyzing, studying or commenting upon LILCO's decision to dispatch survey teams only at the site
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emergency and general emergency stages of an accident.
Response. See the responses to items 34a and 34b.
- g. All documents concerning the communications capabilities of the survey teams.
Response. Provided,
- h. All documents concerning training of the survey teams.
Response. Provided. See also the response to item 63.
- 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.
Response. Provided.
- 36. Sections 3 and 4 of the document identified in the immediately preceding request, including all Tables and Figures in those Sections.
Response. See the response to item 35.
- 37. All meterological data utilized by Pickard, Lowe and Garrick, Inc. in the CRAC (or CRACIT) Cod'e 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.
Response. Provided on June 3, 1982.
- 38. All the raw meterological data provided by LILCO or any other person to Pickard, Lowe and Garrick to derive the meterological data described in the immediately preceding request.
Response. These documents will be provided as soon ns they are gathered from the various sites.
- 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.
Response. Provided. See also the response to item 35.
- 40. All documents concerning LILCO's capability to predict and trace plume travel after a radiological emergency at Shoreham, including:
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- a. Documents concerning the equipment to be
. utilized in this assessment effort.
- b. Documents concerning the degree of accuracy of said equipment.
Response. Provided. See also the response to item 32.
- 41. Any documents reflecting any other consequence analysis studies (other than the Pickard, Lowe and Garrick draft document referenced above and the FSAR) which reflect the potential censequences of a serious radiological emergency at Shoreham.
Response. None.
Protective Actions
- 42. All documents concerning assessments, studies, evaluations or analyses, performed or relied upon by LILCO, of the relative benefits of various protective actions under.the specific circumstances and conditions existing in the Shoreham vicinity and in Suffolk County.
This request includes documents which assess the dose reductions expected in Suffolk County if sheltering were the recommended protective action.
Response. Provided.
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- 43. All documents assessing the protective actions to be recommended fbr persons for whom sheltering is not immediately available (for instance, those people on beaches or hiking trails). ,
Response. See the response to item 42'.
- 44. All documents detailing, analyzing, describing, or otherwise concerning when in the course of a radiological emergency LILCO may make protective action recommendations to public officials concerning individuals who are:
- a. In schools.
- b. On beaches.
- c. In hospitals.
- d. In large workplaces.
Response. See the response to item 42.
- 45. All documents analyzing, assessing or concerning how the activities of individuals outside i In-mile EPZ (assuming arguendo that a 10 ras- t' r ' were utilized) may affect or interfere with protective act2ons for persons within that zone, including but not limited to:
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- a. The effect on residents of the eastern end of Long Island who may be outside a 10-mile EPZ, but who may evacuate west,
.through the EPZ.
- b. The effect on others outside the EPZ who may choose to evacuate, thus causing greater demand on evacuation routes, roadway facilities, and emergency personnel.
Response. None.
'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.
Respon- See the response to item 42. See also the C'anty plan.
- 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 preparedness in Suffolk County.
Response. LILCO has from time to time polled the residents of Suffolk County about their opinions on a
9 variety of subjects, some of them involving nuclear power. None of the polls has been used in planning for passible emergencies at_the Shoreham Station or in working with Suffolk County in preparing the County's emergency plan, and therefore the response to this request is "none." Request #47 is so broadly worded, however, that it could conceivably refer to almost any information about the people of Suffolk County. If the request is intended to be more comprehensive than we have interpreted it, it ic overbroad and outside the proper scope of discovery in this proceeding.
- 48. All documents describing, studying or otherwise concerning evacuation time estimates for the Shoreham EPZ (or any part thereof), which LILCO developed, considered, or relied upon in preparation of its emergency plan or which has been prepared subsequent to preparation of the plan.
Response. Provided. See also the County 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 response personnel. The columns 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.
Response. None.
- 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.
Response. Provided.
- 51. Any documents prepared for or relied upon by LILCO to determine 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.
Response. None.
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- 52. Any documents studying, analysing or concerning the effect-of other emergency responsibilities or emergency _
conditions on the ability of off-site response personnel.
to respond on-site in the event of a radiological emergency.
Response. None.
- 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 personnel, including:
- a. The curriculum for such training;
- b. The textual materials to be distributed; and
- c. The frequency and duration of such training.
Response. Provided.
- 54. All documents detailing the training to be given to personnel of off-site agencies expected to respond to radiological 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; ano
- d. LILCO's training capacity-(i.e., how many can LILCO train during a given period).
Response. Provided.
Medical Facilities
- 55. All documents concerning the availability of medical facilities in the event of a radiological emergency, including:
- a. All documents reflecting the basis for LILCO's decision to rely on Central Suffolk Hospital for treatment of contaminated individuals.
Response. None.
- b. All documents reflecting the bases of LILCO's decision to rely on a hospital in Philadelphia, Pennsylvania for back-up medical services.
Response. None.
- c. All documents concerning the availability of potential back-up hospitals or other medical facilities closer to the potential victims of an emergency at Shoreham.
Response. Provided.
- 56. All documents considering, analyzing or concerning the possibility that Central Suffolk Hospital 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.
Response. None.
The Emergenc z_ Operations Facility (EOF)
- 57. All documents, plans, drawings, and other documents demonstrating the ability of the Emergency Operating Facility (EOF) to accommodate County, Federal and State officials.
Response. See response to item number 53.
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-26x
- 58. All documents demonstrating, analyzing or studying the conformance of the EOF to NUREG-0696 and NUREG-0654.
Response. Provided. See also the response to items 53 and 63.
- 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.
Response. Provided. See also the response to item 3a.
- 60. All documents concerning the bases for LILCO's decision to activate the EOF only upon dc :laration of a Site Area or General Emergency, as noted in the plan at page 7-3A.
Response. Provided. See also the LILCO plan.
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- 61. All documents reflecting any analyses, studies or consideration of the conditions under which the EOF should be activated.
Response. See the responses to items la, 42, 58, and 60.
Plan Review and Integration
- 62. All documents demonstrating emergency planning coordinaton with the State of Connecticut.
Response. See the New York State Plan.
- 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:
- a. All documents assessing training of personnel; and
- b. All documents assessing emergency preparedness drills or exercises conducted by LILCO or in which LILCO has been or will be a participant.
Response. Provided. See also the responses to items 53 and 58.
- 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 preparedness; and
- b. Any assessment or comments by LILCO or any representatives thereof regarding the radiological emergency response plan of the State of New York and LILCO's role therein.
Resoonse. Provided.
- 65. All contracts or agreements with any persons concerning preparation of LILCO's emergency plan (or any portion thereof), including:
- a. Al] such contracts or agreements concerning development 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; and
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- c. All such contracts or agreements calling for rev'iew or assessment of LILCO's plan, in whole or in part.
Response. There are hundreds of documents that might be responsive to this request, broadly interpreted, and therefore we object to this request as overbroad. Our understanding is that counsel for the County will specify more precisely which documents the County wants LILCO to provide.
- 66. All correspondence or documents reflecting contact with the NRC regarding the merit of LILCO's emergency plan, including all correspondence or other contacts concerning the emergency plan deficiencies enumerated in the Safety Evaluation Report (SER) Supplement No. 1, September 1981.
Response. Provided.
- 67. All documents or correspondence concerning the effects of LILCO, its contractors, subcontractors or consultants to resolve the emergency planning deficiencies enumerated in the SER, Supp. I and the results of such efforts.
1
Response. Provided. See also the response to item 66.
Respectfully submitted, i / [/Ah/
W.(tay'lp.Reveley, III '~
~
James NV Christman Kathy E. B. McCleskey Hunton & Williams P.O. Box 1535 Richmond, Virginia 23212 Dated: June 14, 1982
In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
, I hereby certify that copies of LILCO's Response to Suffolk County's First Request for Production of Emergency Planning Documents to Long Island Lighting Company were served j upon the following by first-class mail, postage prepaid, or by
! Federal Express (as indicated by an asterisk), on June 14, 1982:
3 Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Board Panel i Atomic Safety and Licensing U.S. Nuclear Regulatory
, Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 I Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris
- U.S. Nuclear Regulatory
- Administrative Judge Commission
. Atomic Safety and Licensing Washing ton, D.C. 20555 t
Board Panel U.S. Nuclear Regulatory Bernard M. Bordenick, Esq.*
, Commission David A. Repka, Esq.
Washington, D.C. 20555 U.S. Nuclear Regulatory l Commission i Dr. James H. Carpenter
- Washington, D.C. 20555 j Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.
- Board Panel Attn
- Patricia A. Dempsey, Esq.
U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 Secretary of the Commission U.S. Nuclear Regulatory Commission j Washing ton, D.C. 20555 i
Herbert H. Brown, Esq.** Howard L. Blau, Esq.
Lawrence Coe Lanpher, Esq. 217 Newbridge Road Karla J. Letsche, Esq. Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Matthew J. Kelly, Esq.
8th Floor New York State Energy Office 1900 M Street, N.W. Agency Building 2 Washing ton, D.C. 20036 Empire State Plaza Albany New York 12223 Mr. Mark W. Goldsmith Mr. Jay Dunkleberger Energy Research Group New York State Energy Office 400-1 Totten Pond Road Agency Building 2 Waltham, Massachusetts 02154 Empire State Plaza Albany, New York 12223 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 Stephen B. Latham, Esq.*
Twomey, Latham & Shea 33 West Second Street P.O. Box 398 Riverhead, New York 11901 Ralph Shapiro, Esq.*
Cammer and Shapiro, P.C.
9 East 40th Street New York, New York 10016 A // // /'
athy/E. Bi/KcCleskey /
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 14, 1982 l
- To be delivered by hand.
I
.-.o In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
_ Docket No. 50-322 (OL)
I hereby certify that copies of LILCO's Response to Suffolk County's First Request for Production of Emergency Planning Documents to Long Island Lighting Company were served upon the following by first-class mail, postage prepaid, or by Federal Express (as indicated by an asterisk), on June 14, 1982 Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris
- U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washing ton, D.C. 20555 Board Panel U.S. Nuclear Regulatory Bernard M. Bordenick, Esq.*
Commission David A. Repka, Esq.
Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter
- Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.
Board Panel Attn: Patricia A. Dempsey, Esq.
U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washing ton, D.C. 2v555 Veterans Memorial Highway Hauppauge, New York 11787 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555
f - -
Herbert H. Brown, Esq.** Howard L. Blau, Esq.
Lawrence Coe Lanpher, Esq. 217 Newbridge Road Karla J. Letsche, Esq. Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Matthew J. Kelly, Esq.
8th Floor New York State Energy Office 1900 M Street, N.W. Agency Building 2 Washington, D.C. 20036 Empire State Plaza Albany New York 12223 Mr. Mark W. Goldsmith Mr. Jay Dunkleberger Energy Research Group New York State Energy Office 400-1 Totten Pond Road Agency Building 2 Waltham, Massachusetts 02154 Empire State Plaza Albany, New York 12223 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 Stephen B. Latham, Esq.*
Twomey, Latham & Shea 33 West Second Street P.O. Box 398 Riverhead, New York 11901 Ralph Shapiro, Esq.*
Cammer and Shapiro, P.C.
9 East 40th Street New York, New York 10016 A A H 'll /'
' athy/E. Bl/pcCleskey r Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 14, 1982
- To be delivered by hand.
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