ML20054H243
| ML20054H243 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/22/1982 |
| From: | Mcmurray C, Shapiro R, James Shea Cammer & Shapiro, KIRKPATRICK & LOCKHART, NORTH SHORE COMMITTEE AGAINST NUCLEAR & THERMAL POLLU, SHOREHAM OPPONENTS COALITION, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8206230149 | |
| Download: ML20054H243 (48) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
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LOMG TSLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.
) (Emergency Planning (Shoreham Nuclear Power -) Proceedings)
Station, Unit 1) )
)
.)
CONSOL7 DATED EMERGENCY PLANI.ING CCNTENTIONS INTRODUCTION Pursuant to 10 CFR S2.714 and the Board's Order of April 20, 1982, Suffolk County, the Shoreham Cpponents Coalition (SOC), and the North Shore Committee Against Nuclear and Thermal Pollution (NSC) hereby submit the following contentions with respect to those emergency planning issues that the Board has defined as presently subject to litigation in the Shoreham operating license proceedings.
At the Prehearing Conference of April 14, 1982, the Board restricted the issues regarding emergency planning "on which we can proceed to litigation" (Tr. 760). That area was defined as "the licensee's actions under its emergency plan whether those actions be onsite or offsite...." Tr. 760; see Tr. 746-747.
The Board reiterated (Tr. at 799) that the focus of the conten-tions was to be on "LILCO's actions, where those actions are 320623014? 820622 -
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e a not dependent upon coordination with the County." Tr. 799. In ,
its Order of April 20, 1980, the Board stated that the inter-venors were to file contentions " based on LILCO's emergency plan" and offered several examples of issues falling within the bounds it had described. Order at 7. In light of the above guidance, the intervenors have confined their contentions to that area of emergency planning that the Board has scheduled for consideration, as defined above.
The Board further ordered that Suffolk County, SOC and NSC file consolidated contentions. Order at 8; Tr. at 802-803.
This pleading represents substantial effort, and hours of dis-cussion among counsel for the intervening parties, to comply with that request. Drafts of the contentions were sent to counsel for the NRC and LILCO on June 17 and 18, 1982, followed by a two-hour conference call among the parties on June 21, 1982 during which they discussed the admissibility of the con-tentions. See Order at 8. Some of the revisions suggested at that time by counsel for the NRC and LILCO were incorporated into this pleading.
i It bears noting that on June 11, 1982, Suffolk County, I
j SOC, the NRC staff, and LILCO entered into a " Resolution of SC l Contention 28(a)(iii)/90C Contention 7A(3) and SC Contention l 27(c)/ SCC Contention 3(c)." As stated in that ag reement , it l
was understood that the resolution of the iodine monitoring i t issue was "without prejudice to the right of SC or SOC to submit a contention in the emergency planning proceeding which would contest the adequacy of iodine monitoring at Shoreham...[A]ny such contention will be submitted by June 22, 1982, or within 14 days after the information to be delivered pursuant [to the resolution] has been received by the County, whichever is later." Since the information on iodine monitoring has not yet been received from LILCO, Suffolk County and SOC reserve the right to submit an iodine monitoring contention at a later date.
Likewise, the parties reserve the right to submit a con-tention concerning the Technical Support Center when that fa-cility is completed.
CONTENTIONS EPl: OVERALL ONSITE PLAN INADEQUACY (SC, joined by NSC and SOC)
The LILCO plan as a whole is inadequate under 10 CFR 550.47, 10 CFR Part 50, Appendix E, and NUREG 0654 criteria because LILCO has not sought to identify and evaluate local conditions in Long Island that could influence the content of the public notification system, public education program, acci-dent assessment and monitoring systems, protective action meas-ures, and evacuation time estimates referenced in the LILCO plan and used in preparation of that plan.
J t t EP2: PROMPT NOTIFICATION SYSTEM (SC, joined by NSC and SOC) i i
LILCO intends that individuals situated within a 10-mile radius of the pia.7t will be alerted to a radiological emergency
- through 89 sirens and approximately 150 tone alert receivers (Plan at 6-14 through 6-16; Wyle Laboratories Report WR 82-10 at 4-3). LILCO's system, known as the " Prompt Notification System," is inadequate to effectively notify the population which may be af fected by a radiological emergency and thus i
fails to meet the requirements of 10 CFR SS50.47(b)(5) and (6),
10 CFR Part 50, Appendix E, and NUREG 0654, Items II.E and F.
In particular, Suffolk County contends that LILCO's notifica-tion system has the following deficiencies:
A. LILCO has failed to demonstrate that the siren cover-
, age will not be constricted significantly during ad-i i
verse weather conditions.
B. LILCO has not adequately demonstrated that in the event of a loss of power to all or part of the sys-tem, it could provide backup power in time to offer I
timely warning to the population.
C. The LILCO plan, as augmented by the Wyle Peport, calls for signs to be placed on beaches and other i recreational areas to provide information on actions i
f f to be taken in case of a radiological emergency at the Shoreham facility. LILCO has f ailed to provide reasonable assurance that notification through the use of signs will be effective. Specifically:
(1) LILCO has not adequately demonstrated that tran-sients on a beach or in a park will be alerted to read the signs or draw a connection between the sirens and the signs - i.e., that upon hear-ing sirens, the transient population will look for or refer to the proposed signs for informa-tion.
(2) LILCO has provided inadequate assurances that the signs will be placed at appropriate inter-vals along beaches or in parks, etc., and will be of appropriate size to make them easily observed and understood in an emergency by the population they are intended to aid.
j (3) LILCO's plan does not provide for maintenance and protection of the signs.
D. LILCO's prompt notification system does not provide complete siren coverage of all of the population
( within the EPZ as shown by the gaps evident on the map appended to the Wyle Report. LILCO has not ade-quately provided for notification of individuals who may be within the areas not covered by sirens.
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E. For notification of large facilities within a 10-mile zone around the Shoreham Plant (including 50 schools, 15 nursery schools, 14 nursing homes, 36 recreational areas, and 11 major employers), LILCO intends to alert a central location within each such facility with a tone alert radio. This places the responsi-bility for notifying the remaining inhabitants of each large facility upon the institution or organiza-tion in question. LILCO's plan is inadeguate in that:
(1) It has failed to demonstrate that each such fa-cility has sufficient in-house paging or alert-ing capabilities to carry out the notification task. Nor has it demonstrated that each facili-ty has developed appropriate messages and instructions to disseminate to its personnel, and that each facility intends to hold drills to test the adequacy of its internal notification system.
(2) It has failed to demonstrate that each such organization or facility has agreed to bear no-tification responsibilities and that such responsibilities will be effectively implemen-ted.
< a F. There is no indication within the LILCO plan that LILCO has in place an effective program to properly verify the operability of the tone alert system.
! G. LILCO has failed to demonstrate that 10-mile siren i
coverage is the proper coverage for the Shoreham fa-cility. The large population groups located just outside a 10-mile radius zone, and the potential com-plications to emergency response resulting from move-4 ment of persons from outside a 10-mile radius zone to within that zone, require that placement and coverage
- include such population groups. This is also neces-
- sary to assure that such population groups have accu-l rate information on the state of emergency conditions so as to guide their own behavior and to control the spread of rumors.
H. The system does not provide for notification of those who are deaf or hard of hearing.
EP3: MEDICAL AND PUBLIC HEALTH SUPPORT (SC, joined by NSC and SOC)
A. Suffolk County contends that LILCO, by designating i
4 Central Suffolk Hospital as the primary medical fa-4 cility to treat contaminated individuals, and further by designating University Hospital in Philadelphia, Pennsylvania for backup medical treatment, has failed l
to provide adequate medical services for contaminated individuals as required by 10 CFR 550.47(b)(12), 10 CFR Part 50, Appendix E, Items IV.E.5 through 7, and NUREG 0654, Items K and L. Specifically:
(1) Central Suffolk Hospital may itself become sub-ject to radiological exposure and/or evacuation given its location approximately nine miles from the Shoreham site (Plan at 6-21).
(2) University Hospital is too distant to provide timely treatment of contaminated individuals.
(3) LILCO has not demonstrated that Central Suffolk Hospital has the capacity to treat and/or decon-taminate the many contaminated and injured per-sons who may require treatment in the event of a radiological emergency.
B. Furthermore, LILCO has failed to adequately demon-strate that ground transportation (Plan at 6-21A) is l adequate for conveyance of contaminated individuals 1
l to Central Suffolk Hospital under the congested traf-fic or radiological conditions that might exist dur-ing a radiological emergency. Thus, LILCO has failed to satisfy 10 CFR S50.47(b)(12), 10 CFR Part 50, Appendix E, Item IV.E.6, and NUREG 0654, Item II.L.4.
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C. The LILCO plan does not contain up-to-date agreements with Central Suffolk Hospital, University Hospital or the Wading River Fire District for emergency medical services to be provided by those facilities.
. Moreover, the agreements in the plan with Central Suffolk Hospital and the Wading River Fire Department lack specific information to determine whether those organizations can provide necessary medical services in the event of a radiological emergency. Thus, LILCO has failed to satisfy 10 CFR SS50.47 (b)(3) and (12),
10 CFR 50, Appendix E, and NUREG 0654, Items II.C.4 and L.4.
EP4: FEDERAL RESOURCES (SC, joined by NSC and SOC)
The LILCO plan fails to provide for incorporation of Federal response capabilities into the plan. The plan makes no mention of specific Federal resources expected to arrive at the facility and their estimated time of arrival, nor does it iden-tify specific utility and local resources available to support the Federal response. Thus, Suffolk County contends that LILCO has not satisfied the requirements of 10 CFR SS50.47 (b)(1),(2) and (3), 10 CFR Part 50, Appendix E, Item IV.A.7, and NUREG 0654, Items A.2 and 3, and C.l.
EP5: PROTECTIVE ACTIONS (SC, joined by NSC and SOC)
Suffolk County contends that LILCO has not met the re-quirements of 10 CFR S50.47(b)(10), 10 CFR Part 50, Appendix E or NUREG 0654, Item II.J with respect to development and imple-mentation of a range of protective actions for emergency work-ers and the public within the plume exposure pathway EPZ and with respect to development of guidelines for the choices of such actions. In particular:
A. The LILCO plan and procedures do not adequately dis-cuss the bases for the choice of recommended protec-tive actions (i.e., the choice between various ranges of evacuation vs. sheltering vs. other op'tions) for the plume exposure pathway EPZ during emergency con-ditions. In addition, LILCO has not assessed the relative benefits of various protective actions under the particular conditions existing in the Shoreham vicinity. Thus, LILCO does not have sufficient know-ledge or information to provide reliable, accurate protective action recommendations.
B. The LILCO plan does not provide an adequate evacua-tion time estimate study to assist it in recommending
- protective actions to State and local agencies.
While there are evacuation time estimates contained i
in the implementing procedure entitled, " Protective Action Recommendations," they'are faulty in the fol-lowing respects:
(1) The LILCO evacuation time estimates do not take into consideration the particular local condi-tions surrounding the Shoreham facility.
Rather, the evacuation time estimates are based upon an arbitrary 10-mile area around the Shoreham site.
(2) There is no estimate for evacuation of the entire EPZ.
(3) The estimates fail to account for voluntary eva-cuation or other actions (such as persons enter-ing the EPZ to assist family members) by people in adjacent zones within the EPZ, or in areas outside the EPZ, and the effects of such actions on the evacuation times and the choice of recom-mended protective actions.
(4) The estimates are based on an unrealistic as-sumption that only twenty minutes will be re-quired for mobilization of the affected popula-tion.
(5) The zonal configuration for which each estimate is made is approximately a 45 degree sector -
4 e well below the suggested subarea aggregations detailed in NUREG 0654, Appendix 4. Therefore, the time required to evacuate the larger zones detailed in NUREG 0654 may be underestimated.
C. The LILCO plan does not provide protective action recommendations for persons for whom the full range of protective a.ctions may not be available, i.e.,
persons utilizing beaches (sheltering not possible),
bedridden persons, persons on boats, the handicapped, those in hospitals or other health care institutions, those in penal institutions,.the elderly or those without transportation of their own.
D. LILCO's decision to suggest (Plan at 4-2) that shel-tering is the immediate protective action to be taken at the general emergency action level until the fea-sibility of evacuation prior to a "significant" radiological release can be evaluated is inadequate because:
(1) It fails to provide for the population for which sheltering is not available (such as those indi-viduals on beaches or in transit).
(2) It is not based upon an analysis of the relative benefits and disadvantages of sheltering versus evacuation or other protective actions, nor hac e .
LILCO specifically analyzed the degree of sheltering offered by residential structures in the affected areas of Long Island.
(3) It does not define the term "significant,"
which, without definition, cannot be objectively judged as a standard or evaluated to determine whether it is a workable guideline. Moreover, such a subjective standard would provide no practical guidance to decisionmakers in an emer-gency.
(4) There-is no analysis of whether immediate shel-tering of all affected persons would cause com-plications if evacuation were later required.
Therefore, analysis of the affected population center and principal places of employment should be performed in order to determine whether immediate protective actions should be selective and different for various segments of the affec-ted public.
{t O EP6: OFFSITE RESPONSE ORGANIZATIONS l
Suffolk County contends that LILCO has failed to provide reasonable assurance that onsite assistance from offsite agen-cies will be forthcoming in the event of a radiological emer-gency at the Shoreham site. LILCO has therefore not met the requirements of 10 CFR SS50.47(b)(1),(2),(3),(8),(12) and (15),
10 CFR Part 50, Appendix E, and NUREG 0654. In particular:
A. It does not appear that LILCO has addressed or analy-zed the possibility that offsite personnel expected to report to the Shoreham site for emergency duty, many of whom are vol'unteers, would fail to report (or report in a timely manner) because of conflicting family (or other) duties that would arise in the event of a radiological emergency.
B. LILCO has not adequately demonstrated the possible effects of traffic congestion during evacuation of the population upon the ability of offsite personnel to respond promptly to the Shoreham site.
C. The LILCO plan does not contain up-to-date contracts with local fire and ambulance organizations or other offsite organizations concerning the services those organizations will provide in the event of a radio-logical emergency.
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. e EP7: TRAINING (SC, joined by NSC and SOC)
Suffolk County contends that LILCO has failed to meet the training requirements of 10 CFR SS50.47(b)(ll) and (15), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.K and O for all personnel who may be called upon to assist in an emergency. In particular:
A. LILCO has not provided adequate assurance that fire, ambulance, and other such personnel from offsite agencies expected to respond for emergency duty in -
the vicinity of the Shoreham plant have received ade-quate radiological emergency response training.
Without such training, the County contends that an adequate response as required by Section 50.47 cannot be assumed.
B. LILCO in Chapter 8 of the Plan, provides inadequate information regarding the training of its own person-nel. Accordingly, there is no assurance that their personnel will have adequate training to take the steps necessary in a radiological emergency.
EP8: PUBLIC EDUCATION (SC, joined by NSC and SOC)
Suffolk County contends that LILCO has not demonstrated that its public education program will adequately inform the population potentially affected by a radiological emergency of the initial and subsequent actions to be taken in the event of a radiological emergency, and such other information as re-quired by 10 CFR 550.47(b)(5),(6) and (7), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.E,F and G. In particular:
A. The plan at 8-17 through 8-20 does not satisfactorily describe the form and content of materials to be dis-tributed to residents or posted for transients, nor does it clearly define the frequency with which var-ious forms of information will be disseminated to the public.
B. There is no indication that LILCO has prepared its public education program with recognition of the par-ticular social and psychological profile of Suffolk County's residents, or that it has taken into account the probable response of particular groups, such as the economically disadvantaged, to its education pro-gram. Absent an evaluation of the social and psycho-logical profile of County residents, and integration of the evaluation into the LILCO public education I
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I program, there can be no basis to find that the LILCO education program satisfies regulatory requirements.
EP9: ONSITE RESPONSE ORGANIZATION AND AUGMENTATION (SC, joined by NSC and SOC)
Suffolk County contends that LILCO has not satisfactorily delineated the responsibilities of LILCO response personnel, nor has it demonstrated adequately that it will be able to aug-ment its emergency response staff in a timely manner. Thus, LILCO's emergency response plan is not in compliance with 10 CFR SS50.47(b)(1)(2)(3) and (8), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.A,B,C and H. In particular:
A. The LILCO plan at 5-4 through 5-8 does not clearly define and distinguish between the functions of the Emergency Director and the Response Manager; B. Table 5-1 does not clearly demonstrate LILCO's abi-lity to augment its staff within 30 minutes of decla-ration of an emergency and is not in compliance with Table B-1 of NUREG 0654.
C. LILCO has not evaluated the effects upon its emer-gency response efforts of potential family (or other) role conflicts that may inhibit or even prevent LILCO 1
personnel from responding to a radiological emer-gency.
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D. LILCO has not evaluated the effects that extreme traffic conditions engendered by an evacuation, either ordered or voluntary, would have upon its abi-lity to augment its emergency response staff.
EP10: PUBLIC INFORMATION (SC, joined by NSC and SOC)
Suffolk County contends that LILCO has not adequately described in its plan, or made provision for, coordination with Suffolk County officials of public statements concerning events and actions occuring and to be taken during a radiological emergency. Suffolk County officials should take a major role in determining the form and substance of such statements, which role is not apparent from the face of the LILCO plan at 5-25 through 5-26. Therefore, LILCO is not in compliance with 10 CFR SS50.47(b)(1),(3),(5) and (7), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.A,C,E and G.
EPil: COMMUNICATIONS (SC, joined by NSC and SOC)
LILCO intends to maintain communications with hospitals, the U.S. Coast Guard and the U.S. Department of Energy during a radiological emergency using only commercial telephone lines (Plan at 7-79) which may become overloaded under emergency con-ditions. Thus, Suffolk County contends that LILCO has not pro-vided for adequate communications with those facilities as required by 10 CFR SS50.47(b)(1),(2),(3),(5) and (6), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.A,B,C,E and F.
EP12: EMERGENCY RESPONSE FACILITY (SC, joined by NSC and SOC)
Suffolk County contends that LILCO's plan and procedures for operation of its Emergency Response Facilities are not in conformance with the requirements of 10 CFR 550.47(b)(8), 10 CFR Part 50, Appendix E, and NUREG 0654, Item II.H. In parti-cular:
A. The LILCO plan at 7-3A states that the EOF shall a-chieve operational readiness within two hours of dec-laration of an emergency. Such an activation time violates the one hour requirement of NUREG 0696.
B. There is, as yet, no provision for obtaining at the EOF, or at any other LILCO emergency response facili-ty, information relating to seismic phenomena (Plan l
at 7-128).
C. LILCO proposes to activate its EOF only upon declara-tion of a Site Area or General Emergency (Plan at 7-3A). The EOF should be activated at an earlier time in an accident to ensure operational readiness in the l
I event that an accident escalates to a more severe classification level.
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EP13: NOTIFICATION OF RESPONSE ORGANIZATIONS AND EMERGENCY PERSONELL (SC, joined by NSC and SOC)
Suf folk County contends that LILCO has not developed noti-i fication procedures for offsite response organizations and onsite personnel (both those onsite at the time of an emergency and those called to report for duty after an emergency has com-menced) in a manner consistent with the required emergency classification and action level scheme. Rather the LILCO plan appears to utilize a non-systematic notification procedure bearing no relation to the Section 50.47(b)(4) planning stan-dard regarding action levels. Thus, LILCO has not ensured that sufficient trained personnel will be available when required.
Furthermore, the LILCO plan does not provide the contents of initial and followup messages to offsite authorities.
Therefore, LILCO does not meet the notification requirements of 10 CFR SS50.47(b)(1),(2),(3),(4) and (5), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.A,B,C,D and E.
EPl4: PUBLIC MESSAGES (SC, joined by NSC and SOC)
LILCO's plan does not include written messages intended for dissemination to the public through various media in the event of a radiological emergency, thus failing to meet the requirements of 10 CFR SS50.47(b)(5),(6) and (7), 10 CFR Part 50, Appendix E, Item IV.D, and NUREG 0654, Items II.E,F and G.
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EP15: OFFSITE PLANNING COORDINATION (SC, joined by NSC and SOC)
LILCO has failed to demonstrate radiological emergency planning and coordination with the State of Connecticut as re-quired by 10 CFR SS50.47(b)(1) and (3), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.A and C.
EP16: RADIOLOGICAL EXPOSURE (SC, joined by NSC and SOC)
LILCO has failed to demonstrate that it has established the means for controlling radiological exposures to emergency workers (both LILCO personnel and those from offsite agencies).
Thus, it has not met the requirements of 10 CFR SS50.47(b)(ll) and (15), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.K and O. In particular:
A. The plan inadequately describes provisions for moni-toring individuals evacuated from the site.
B. The plan does not describe action levels for deter-mining the need for decontamination of emergency re-sponse personnel.
C. The plan does not adequately delineate guidelines for emergency workers to follow to ensure that exposures received by such workers are not excessive.
EPl7: EXERCISES (SC, joined by NSC and SCC)
In discussing annual exercises (Plan 8-13), LILCO states that "the scenario will be rotated each year to ensure all major elements of the plan are tested over a five-year period."
That statement is inconsistent with the requirement of 10 CFR Part 50, Appendix E, which specifies that each annual exercise shall test as much of the integrated plans "as is reasonably achievable...." LILCO's five-year program is short of this requirement. Thus, Suffolk County contends that LILCO has not met the regulatory requirements of 10 CFR 50.47(b)(14), 10 CFR Part 50, Appendix E and NUREG 0654, Item II.N.
EP18: EMERGENCY CLASSIFICATION SYSTEM (SC, joined by NSC and SOC)
LILCO has failed to establish an adequate Emergency Action Level (EAL) system as required by 10 CFR 550.47(b)(4), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.D 1 and 2.
Specifically:
A. LILCO has not established EALs for each initiating condition specified in Appendix 1 to NUREG 0654.
B. The initiating conditions do not include all of the postulated accidents in the FSAR.
C. Certain EALs are incomplete or under development as noted at pp. 4-4 and 4-8.
EP19: ACCIDENT ASSESSMENT AND MONITORING (SC, joined by NSC and SOC)
Suffolk County contends that LILCO's plan is inadequate with respect to its ability to assess and mitigate accidents and monitor radiological releases from the Shoreham facility in the event of a radiological emergency. Thus, LILCO has failed to comply with 10 CFR SS50.47(b)(2), (4), (8), (9) and (10), 10 CFR Part 50, Appendix E and NUREG 0654, Items II.B,D,H,I and J.
In particular:
A. LILCO's commitment to only three field monitoring teams is inadequate given the large area and popula-tion that will need to be covered in the event of an accident. Furthermore, LILCO's failure to require deployment of monitoring teams prior to the site emergency stage, and the time necessary (60 minutes) for such deployment, are inadequate for timely moni-toring of potential radiological releases.
B. LILCO does not intend to use real time monitors at i
fixed locations that can be remotely interrogated.
C. LILCO does not identify specific instruments to be used for classification of emergencies (NUREG 0654 l II.D.1).
l D. LILCO does not identify in sufficient detail the type and capability of specific process and radiological
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instruments and monitoring systems required for initiating emergency measures and conducting asses-sments (NUREG 0654 II.H.5.b and c).
E. The plan does not contain identification of fire and combustion product detection equipment (NUREG 0654 II.H.5.d).
F. The plan does not provide for a mobile radiological laboratory facility to cover the event when highways leading to the fixed laboratory sites may be obstruc-ted (NUREG 0654, II.H.6.c).
EP20: FAILURE OF SHOREHAM/LILCO'S EMERGENCY PLANS TO COMPLY WITH NRC/ FEMA REGULATIONS (NSC, joined by SOC. SC will participate as an interested County pursuant to 10 CFR S2.715)
As presented by the applicant, LILCO/Shoreham Nuclear Power Station, the Shoreham Annex to the New York State Plan, dated March 1982, and the Revision to the Shoreham Emergency Plan, dated January 1982, are inadequate to protect the health and safety of the public because the existing plans do not meet the mandatory standards established by the NRC/ FEMA in 10 CFR 50.47 and 10 CFR Part 50, Appendix E.
EP20(a): Notification procedures established by LILCO to com-municate with State and local response organizations do not meet the requirements of 10 CFR 50.47(b)(1),
(2), (3), (4), (5), and (6); 10 CFR Part 50, Appendix E.II.C, G, H and IV.E.9.
0 0 Bases for EP20(a):
(1) Notification by LILCO of the State and local response organizations involved in the response to a radiological emer-gency, as mandated by the Administrative Law Judges of the NRC in their Order of April 20, 1982, (Docket No. 50-322-OL) con-sistent with the provisions of S50.47 of the Rules and Regulations of the Nuclear Regulatory Commission as amended, is inadequate under either of the two basic communications systems upon which Shoreham's notification / communication network relies: the dedicated and commercial telephone lines or the low-powered UHF radio station.
(2) LILCO's reliance on or y two means of communication to notify the organizations from whom a thorough assessment of the radiological emergency and the implementation of protective actions for the health and safety of the public must issue pre-vents the likelihood of an adequate and timely notification given the significant probability that the telephone system will break down, suffer a power overload or be sabotaged by hostile forces, and that no specific backup power source has been devised, as mandated by 10 CFR Part 50, Appendix E.IV.E.9.
(3) LILCO has attempted to disguise the overall uniformi-ty of its communications / notifications system, which is actually only a sophisticated telephone system, by devising such nomenclature as: hotline, Radiological Emergency Communications System, dedicated lines, National Alert Warning System, emergency card dialer phone, private automatic exchange and sound powered telephone. (Shoreham Emergency Plan, Rev. I, January 1982 at S7.2.1-7.2.6.) These diverse terms belie the fact that all offsite organizations and the public are depend-ent upon the operability of telephone power lines to be noti-fled of a radiological accident and to receive the essential information with which to adequately respond to the emergency.
A history of power outages in Long Island, and LILCO's capacity vel non to respond to the ensuing confusion, demands the con-clusion that LILCO's communications / notification system is so inadequate as to render the entire LILCO Emergency Plan nonvia-ble.
(4) More specifically, the placement of the telephone lines overhead exposes the system to threats of sabotage and extreme weather conditions, neither of which is impossible, despite LILCO's attempts to minimize the possibility of such interferences. The applicant does not adequately prepare for such contingencies. Despite its sophisticated title, the sec-ondary backup to the " hotline," the National Alert Warning System, is just another kind of telephone and subject to the above limitations (Rev. I, 57.2.2, 7.2.1).
Even the use of " beepers," (Rev. I, S8.1.1) between key company personnel necessitates that they call in on phones after the beeper's initial alert to receive instructions and information.
(5) The breakdown of the telephone system in the event of an emergency shutdown at the plant or an overall system over-load would prevent LILCO from assigning and specifying primary responsibilities for emergency response between the applicant and State and local organizations, as required by 10 CFR 50.47(b)(1). Further, the availability of adequate " staff to respond and augment its initial response on a continuous basis," (10 CFR 50.47(b)(1)) depends entirely on this vulnera-ble telephone network. The likelihood that key plant personnel l
will be absent from the plant, from their homes, or even out-of-town, whenever the emergency occurs, has not been rea-listically considered in LILCO's plans. Too few personnel are connected to the " hotline" to satisfy the requirements of this regulation (Rev. I, S7.6). Even the maintenance of adequate staffing in key functional areas at all times, as required by 10 CFR 50.47(b)(2), depends upon contacting these personnel wherever offsite they may be at that time.
(6) LILCO is further negligent in addressing the issue of the human factor involved in response and notification. Not unlike the finely honed technical systems upon which LILCO rests so much confidence, people, too, can break down in the occurrence of a crisis previously unexperienced, especially one in the nature of a radiological emergency.
The weakness of the underlying communication network is further evidenced by its reliance on a very few designated com-municators to transmit the key information to offsite support and response organizations. LILCO has chosen only three or four onsite communicators and three at the Emergency Operations Facility to handle a task that in actuality requires a greater number of minds and voices to communicate to almost a dozen support and response organizations involved (Rev. I, S5.2.8).
While overemphasizing control of information leaks to the pub-lic and the various state and local organizations to justify the concentration of the communicators' functions in so few hands, LILCO is ignoring the possibility that stress and over-exertion acting upon those few communicators can undermine the efficacy of the overall communications with all offsite govern-mental, technical and support agencies. Such human factors expose an emergency plan workable only on paper.
(7) Until the communication / notification system is more reliable and effective, LILCO cannot meet 10 CFR 50.47 (b)(3):
arranging for, requesting, and effectively using assistance resources, because, again, these arrangements rely on a sound and viable communications network. Analysis of this network makes apparent that LILCO has not addressed the substantive points in the federal standard and evaluation criteria.
(Letter of 8/3/81 from John Myers of Battelle Laboratories to NRC Emergency Preparedness Division.)
(8) Nor can LILCO adequately assure State and local re-sponse organizations of its ability to provide them with infor-mation relevant "for determinations of minimum initial offsite response measures" as required by 10 CFR 50.47(b)(4), if there remains such a strong probability that its medium of informing, the telephone system, cannot withstand the demands put upon it.
Again, the unrealistic number of communicators that LILCO has given the full responsibility of transmitting information offsite and to the public further reveals the flaws in LILCO's information network. These flaws undermine the likelihood that the public will be adequately, accurately and timely informed of protective actions necessary, and that State and local acti-vities regarding assessment, monitoring and implemencing pro-tective responses will be sufficiently well-informed and organ-ized to ensure minimal health and property damange.
(9) For the above reasons, neither 10 CFR 50.47(b)(5) nor (b)(6), regarding notification and communications with princi-pal response organizations, emergency personnel and the public, can be met by LILCO's present plans. There is no competent evidence in LILCO's plans that " sufficient and diverse communi-cations capabilities exist between and among the emergency re-sponse organizations to assure effective emergency response under a range of conditions, including heavy traffic on commer-cial communications, adverse weather and loss of normal power o .
sources." (USC/NYPIRG Contentions before ASLB in the Matter of Indian Point Units 2 and 3, p. 12, January 1982, referring to Post Exercise Assessment--Exercise of the New York State and Oswego County Radiological Emergency Plans for Nine Mile Point Nuclear Power Station, September 1981).
In satisfaction of the requirement of a backup power source, LILCO makes a vague reference to some kind of Electrical Emergency Restoration Procedure (Rev. I, S2.1), but the applicant neither defines nor explains precisely how this procedure can deal with a power loss that would paralyze all communications and response capabilities.
(10) The second basic notification / communication system, a low-powered UHF base radio station (Rev. B to the New York State Plan, Shoreham Annex, March 1982, 55.7.10), is only briefly referred to and does not contain information on its coverage and load capacities, especially when confronted with a breakdown in the primary telephone systems. No adequate ana-lysis or approval of this aspect of LILCO's system can be made until more specific data is provided. The possibilities of the radio system jamming from the multitude of calls coming into it from the mobile units, offsite locations and police departments that are connected to the Control Room Communications Center by means of the radio are great, and pose the same problems that a vulnerable telephone system does for the overall response capabilities at Shoreham.
d O EP20(b): Communications between LILCO and State and local re-sponse organizations do not meet the federal stan-dards in 10 CFR 50.47(b)(1), (3), (5), (6), (7) and (8), 10 CFR Part 50, Appendix E.II.G and Appendix E.IV.D.1, D.3, and Appendix E.IV.E.9.
Bases for EP20(b):
(11) The bases for NSC's contentions regarding communica-tions between LILCO and the state and local response organiza-tions is partially encompassed by the discussion on Notification in EP20(a). Because of the reliance of the .two V
interrelated functions on the telephone and radio systems', a separate discussion of the two aspects is redundant. Note, however, the following addition:
(12) Communications with the outside governmental agen-cies, the Media and the public are inadequately staffed, briefed and technically equipped to ensure a coordinated dis-semination of vital information to these offsite sources. Thus
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10 CFR 50.47(b)(7) is not met.
(13) Lacking more specific data on the two-way UHF radio system which links the control room of the plant with the ENS, \
we cannot conclude that this radio will not overload, be inter-fered with by a competing carrier or technically malfunction.
For these reasons, which have been stated above as well, LILCO's assertion that their " communication systems operate on an around-the-clock basis" (Rev. B, Shoreham Annex, S5.5.1), is not sufficiently explanatory to satisfy the requirements of the 0 D NRC for a " reasonable assurance" of safety and protective measures (See 10 CFR 50.47(a)).
(14) Likewise, by promising some kind of "uninterruptible power source" to back up their party line system (Rev. B, Shoreham Annex, 55.7.7), LILCO cannot bypass the federal re-quirement that the applicant's elaborate technical plans are not only " adequate," but also " capable of being implemented" (10 CFR 50.47(a)(2)). These examples of simplified resolutions of major communications difficulties at Shoreham underscore the NSC's contention that LILCO has not adequately planned for steps to be taken in the event of a radiological emergency, which will assure the public that health and safety are LILCO's priorities.
(15) In addition to alleging mysterious "uninterruptible power sources," LILCO does not meet federal requirements by understaffing key personnel positions at the plant. The cs-signment of the Health Physics Engineer to sole responsibility for ensuring the availability of the communication equipment during emergency conditions does not consider the possibility that this one person will be unavailable, and that alternatives to the coordination and functioning of vital communications equipment must be provided (See Rev. B, Shoreham Annex, 52.0).
The applicant does admit that communication is the key to the operability of all scientific, technical and administrative a .
responses: ...where the same response activities are being carried out by two or more organizations, close coordination will be necessary. On-going communication and coordination will be maintained among all organizations with a response operational responsibility" (Rev. B, Shoreham Annex, S4.0).
Despite this admission about the necessity for operable links between the plant and various critical offsite response and support organizations, LILCO has submitted a faulty communica-tions system.
(16) The applicant has placed an inordinate amount of responsibility in the role of one individual: the Emergency Director. Yet the applicant has omitted the Emergency Director's private home from the network of those accessible to the Private Automatic Exchange. The possibility that one per-son may not be able, under the stress of a radiological emer-gency, to perform all the tasks strictly assigned to him/her, has not been considered. Instead, LILCO concludes that "The responsibilities associated with this position are non-delegatable" (Rev. I, S5.2.1).
Nor has LILCO considered the possibility that the Emergency Director or his close associate, the Response Manager, may make decisions regarding protective measures or the allocations of scant communications resources, that con-flict with the county or state's decisions about what is in the public's best safety and health interests. This argument is another aspect of the NSC's critique that LILCO has not inte-grated its plans with those of the County, which are as yet unsubmitted. The possibility of great confusion ensuing from such unresolved tensions is obvious.
This inflexible and unrealistic attitude about the posi-tion of the Emergency Director, and his ability to assume many functions in a crisis situation without delegating them, con-flicts with psychclogical studies of the combination of a stressful situation and overburdening pressures upon an indivi-dual's response capabilities. Because the Shoreham Plan does not provide a priority list of the Emergency Director's many functions, severe consequences could result in the event that he is unable to decide where to put the emphasis of his limited energies in a time of crisis to minimize the deleterious conse-quences for the public at large.
This illustrates well LILCO's failure throughout the plans to provide for alternative protective responses, should human resources and technical facilities become unavailable, inade-quate or useless. A rigidity about the procedures and the per-sonnel to be utilized _n the face of an unknown and possibly unprecedented radiological emergency does not meet the stan-dards set forth by the Nuclear Regulatory Commision.
EP20(c): Arrangements for assistance resources needed onsite, particularly medical and emergency transportation assistance, do not meet 10 CFR 50.47(b)(3), (b)(5),
(b)(6), (b)(8), (b)(10), (b)(ll), and (b)(12), as mandated by the NRC.
Bases for EP20(c):
(17) There is a strong likelihood that medical personnel will not be available or cannot be notified in sufficient time to provide urgent medical assistance, given the communications problems, and the human factors, discussed above. LILCO has not dealt with the question of whether those with whom trans-portation and medical assistance arrangements have been made will be able and willing to travel to an irradiated area in order to transport contaminated and/or injured persons to a
" nearby hospital" that may, in fact, turn them down for reasons such as unpreparedness, overcrowding, refusal to contaminate other patients and workers, and the like. This is another dimension of the ' human problem' which LILCO persistently ignores, and which threatens to expose the overall emergency plan as inoperable in the event of an actual radiological crisis. As a result, 10 CFR 50.47(b)(8), the provision and maintenance of adequate emergency facilities and equipment to support the emergency response has not been met.
(18) LILCO's plans do not adequately specify what proce-dures have been established to accommodate the variety of forms that the emergency can take, and the relation of that particular classification to emergency medical assistance needs. By not providing reasonably specific indicia of the content of the applicant's messages to the emergency assistance workers and agencies, and its adaptability to the above-noted variety of kinds of emergency, LILCO fails to comply with 10 CFR 50.47(b)(5) and (6). By simply requiring that offsite sup-port agencies verify the information they have been given by the applicant's communicatars by calling a certain phone number at Shoreham, LILCO reveals its removal from the real conditions that are likely to exist at Shoreham (Rev. B of Shoreham Annex to NYS Plan, S6.4) during a crisis.
(19) Another critical omissiori in the Shoreham plans is the absence of provisions for back-up medical assistance with the requisite training, facilities and preparation to respond to an emergency at the Shoreham plant. Because of the particu-lar natute of a radiological emergency, LILCO cannot assume that the other medical facilities within either the 10-mile plume EPZ or within Suffolk County will be able to timely and i
! adequately respond to LILCO's request for assistance on a j moment's notice. The failure to have letters of agreement with any of these facilities but Central Suffolk Hospital epitomizes this negligence. It is more than likely that these hospitals and clinics will have limited facilities and staff, perhaps already overburdened, and untrained for the specific I
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contingencies present in a radiological emergency. This deficiency in the protective actions planned by LILCO violates 10 CFR 50.47(b)(10).
(20) Furthermore, a cursory mention of arrangements with laboratories and nuclear plants without specifying the identity and roles of these facilities does not meet the explicit re-quirement of 10 CFR 50.47(b)(3) that these support agencies be capable of augmenting the emergency response. The letters of agreement supplied by LILCO in the Emergency Plan Revision I, January 1982, are almost four years old and have not, it can be assumed, been updated to allow for changes in plans or addi-tional information. These letters suggest vague arrangements with the Coast Guard, the Department of Energy at Brookhaven, and for Emergency Medical Assistance with Radiation Management Corporation in Philadelphia (which provides for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> access to one medical team of one physician, one certified health physicist, and technicians. See letter of November 20, 1978, Rev. I, Appendix A, References). For assistance from other nuclear plants, there is a form contract entitled the Fixed Facility Emergency Response Voluntary Assistance Program, but no parties are identified as party to the contract (All letters are in Revision I, Shoreham Emergency Plan, January 1982).
(21) Finally, by failing to provide for the necessary volume and variety of medical and laboratory assistance, LILCO cannot reasonably assure its customers and the population of Long Island that arrangements have actually been made for medi-cal services for the contaminated and irradiated. This vio-lates 10 CFR 50.47(b)(ll), and may be one of the most pressing concerns of all persons within the plume and ingestion pathways of the Shoreham Nuclear Power Station.
EP20(d): Because adequate assessment and monitoring methods, systems and equipment are not provided by the appli-cant's Emergency Plans, 10 CFR 50.47(b)(4) and (b)(9) are not met, and the plant cannot adequa'tely deal with the potential and actual consequences of its own malfunctions and emergencies.
(22) The fundamental deficiency in Shoreham's assessment and monitoring devices is that they do not encompass a suf-ficiently broad area because LILCO has cut off the plume expo-sure pathway at 10 miles, despite its knowledge that the parti-cular topography of Long Island mandates a broader plume EPZ to cover the eastern end. The applicant is required by federal law to take the specific geographical, topographical, jurisdic-tional and meterological factors of Long Island into considera-tion prior to concluding that the suggested 10-mile plume EPZ is sufficient in this particular case (See 10 CFR 50.47(c)(2) and the NRC's Order of April 20, 1982, p. 7, no. 6). Because of the unusual layout of Long Island, the eastern end must be included within the plume pathway to reasonably assure that the necessary public notification and medical assistance can be 38 -
e e e extended to this area, which must travel through the contaminated area of the plant in the event of a radiological emergency. "he omission of the eastern end of the Island, which is populated by large numbers of vacationers and tran-sients who are in a unique position in terms of their unaware-ness of whatever protective actions LILCO may suggest for the resident!.al populace, threatens the health and safety of these thousands of people.
(23) Another reason that the plume EPZ should be broader than 10 miles is that the public in eastern and southern Long Island runs the risk that contaminated workers from the plant, if prematurely released to their homes, may contaminate those residential areas where they live. Thus, LILCO's personnel monitoring equipment onsite is critical to the health of these thousands of residents and vacationers. There are no specific alternative monitoring devices in the plans in the event that the primary equipment becomes inoperable or insufficient, espe-cially if the plume EPZ is extended. Local assessment and mon-itoring groups must be activated, and in close communication with Shoreham and the offsite support agencies. The public and the offsite support agencies and governmental agencies must be assured of accurate actual release rates and projected, doses of radiation in particular areas so that the precise protective action necessary can be timely and fully implemented. Until -
. i LILCO more particularly specifies assessment and monitoring plans and allocation of responsibility among the many groups involved in these critical functions, the next phase of its response -- the recommendation of protective actions -- will be so impaired as to render all preventive measures and arrange-ments with offsite facilities futile.
(24) The Department of Health, for example, is responsi-ble for providing technical guidance, assessment and evaluation of the emergency once Shoreham has apprised it of the emer-gency's specific nature. Given the unreliability of the com-munications/ notification network between the plant and offsite organizations, the overall assessment, monitoring and protec-tive action continuum can break down should the network break down. Given the above vulnerabilities in that network as pro-posed, this is a very real possibility.
(25) The inordinate faith that LILCO places in its Radiation Monitoring System Computer (Rev. B, Shoreham Annex, S6.5) illustrates the basic flaw in its monitoring plans. Like the Prompt Notification System, the ' hotline" and the National Alert Warning System, the RMS computer can become inoperable or overloaded. The applicant admits that the Computer can become inoperable: "In the event the Radiological Monitoring System Computer is not operational...an emergency procedure exists...to establish offsite doses" (Rev. B, Shoreham Annex, e e 56.5). LILCO does not identify the nature and capabilities of this ' emergency procedure,' thus diminishing one's confidence in their ability to monitor the doses of radiation released in the event that this main computer, like the PNS, the NAWAS, or the entire telephone communication system breaks down.
(26) Should the RMS computer become inoperable, the com-mercial telephone system is the only communication link between the Department of Health, the major offsite assessment and mon-itoring support organization. This critical agency, the DOH, has been excluded from the select group of agencies and offices within the compass of the " hotline" (Rev. B, Shoreham Annex, 55.7.1).
(27) Likewise, the network of communication between the State Office of Disaster Preparedness and the county and State Warning Points regarding conditions affecting the ingestion pathway EPZ is the commercial telephone system (Rev. I, 55.4-Rev. B, 56.2.7). Coordination of information and protective actions between these groups is essential to the health and safety of over one million people within the six county inges-tion EPZ; yet their coordination is dependent on this vulnera-ble ccmmunications network.
Similarly, coordination between the State Emergency l
Operations Center, the southern district and counties' ope'ra-1 tions centers, and the Shoreham EOF depends upon another l
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e e variation of the telephone: The New York State Nuclear Emergency Hotline. This system is undefined, as is its backup system, which is only mysteriously referred to as an " alternate system" (Rev. B, Shoreham Annex, 56.4).
The further one's distance from the Shoreham Nuclear Power Station, the greater the uneasiness one feels about LILCO's ability and willingness to control the consequences of an emer-gency breakdown at its own facility, whether the site of their response be the plant itself, the 10-mile plume EPZ, Suffolk County, or the six town ingestion pathway. Such deficiencies not only fail to meet federal regulations; they threaten the safety, health and survival of at least one million human beings...if not more.
EP21: RECOVERY AND REENTRY (SOC, joined by SC and NSC)
The applicant has failed to develop adequate procedures pursuant to 10 CFR 550.47(b)(13) and NUREG 0654 criteria that address plant recovery and the determination of population l doses, including procedures that describe when, how, under what conditions, and at what risk to the public, recovery will take t
l Place.
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. s EP22: Interim Safety Parameter Display System (SPDS)
Suffolk County contends that the interim SPDS that LILCO
' proposes to utilize until the installation of a permanent SPDS is deficient because it does not meet minimum requirements for such a system. Specifically, the interim SPDS does not:
A. provide all required parameters; P. provide for data verification; C. provide trending capability; D. provide information to the TSC and EOF; E. provide a data source and display that will operate during and following an accident or transient result-ing from an earthquake; F. meet human factor requirements; G. meet the requirement that it be capable of operation during and following an accident.
Thus, the interim SPDS does not meet the requirements of 10 CFR SS50.47(b)(4), (8), and (9), 10 CFR Part 50, Appendix E, 10 CFR Part 50, Appendix A, GDC 13, and NUREGs 0696, 0737 and i 0654.
m e
EP23: Permanent Safety Parameter Display System (SC, joined by SOC and NSC)
LILCO has not demonstrated that its proposed " permanent" SPDS will meet the requirements of NUREG 0696. Thus, the per-manent SPDS does not meet the requirements of 10 CFR SS50.47 (b)(4),(8), and (9), 10 CFR Part 50, Appendix E, 10 CFR Part 50, Appendix A, GDC 13, and NUREGs 0696, 0737 and 0654.
EP24: Emergency Operating Procedures (SC, joined by SOC and NSC)
Suffolk County contends that LILCO's emergency operating procedures (EOPs) are not complete and approved as required by 10 CFR 550.47(b), 10 CFR Part 50, Appendix E and NUREG 0654, Item II.P.7.
EP25: Accident Assessment Equipment (SC, joined by SOC and MSC)
Suffolk County contends that neither the LILCO plan, nor its EOPs include information necessary to identify the class-ification or qualification of equipment to be used in assessing an accident condition or mitigating the results of an accident.
Thus, LILCO has not met the requirements of 10 CFR SS50.47(b)(8) and (9), 10 CFR Part 50, Appendix E and NUREG 0654, Items II.I and P.
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EP26: Human Factors (SC, joined by SOC and NSC)
LILCO's radiological emergency response plan and EOPs have not been demonstrated to incorporate necessary human factors principles and analyses. Thus, Suffolk County contends that LILCO has failed to meet the requirements of 10 CFR 550.47(b),
10 CFR Part 50, Appendix E and NUREG 0654.
EP27: PRA Consequence Analysis (SC, joined by SOC and NSC)
LILCO has not completed, nor has the NRC reviewed, a PRA consequence analysis to provide the basis for the accident assessment and dose assessment models. Thus, Suffolk County contends that there is no assurance that LILCO has met the re-quirements of 10 CFR SS50.47(b)(9) and.(10), 10 CFR Part 50, Appendix E and the planning criteria of NUREG 0654.
i.
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Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 f l h? c' ,l
( ,. f % /., r .r o i . .- tc +io -
' 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 Attorneys for Suffolk County l(/,l/ l f,, w e gy y /> / (r.,n,n Ralph Shapiro /' ,
CAMMER & SHAPIRO 9 East 40th Street New York, New York 10016 Attorney for the North Shore Committee Against Nuclear and Thermal Pollution.
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.Jtihn F . Shea, III -
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' Stephen B. Latham TWOMEY, LATHAM & SHEA P.O. Box 398 Riverhead, N.Y. 11901 l
Attorney for the Shoreham opponents Coalition Dated: June 22, 1982 46 -
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a UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION
'EFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322 (0.L.)
(Shoreham Nuclear Power Station, ) (Emergency Planning Proceedings)
Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of the Consolidated Emergency Planning Contentions were served to the following on June 22, 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 Howard L. Blau, Esq.
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 707 East Main St.
Mr. Peter A. Morris
- Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger-Washington, D.C. 20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Mineola, New York 11501 Stephen B. Latham, Esq.*
Twomey, Latham & Shea Mr. Brian McCaffrey Attorneys at Law Long Island Lighting Company P.O. Box 398 175 East Old Country Road 33 West Second Street Hicksville, New York 11801 Riverhead, New York 11901
- By Hand
- By Federal Express
?
f Marc W. Goldsmith Mr. Jeff Smith Energ'j 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. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David H. Gilmartin, Esq. County Executive / Legislative Suffolk County Attorney Building County Executive / Legislative Bldg. Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D.C. 20555 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 Bernard M. Bordenick, Esq.* Commission David A. Repka, Esq. Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Matthew J. Kelly, Esq.
Staff Counsel, New York State Public Service Comm.
3 Rockefeller Plaza Albany, New York 12223
- By Hand
. n . c Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: (C!? O / " E- 1900 M Street, N.W., 8th Floor Washington, D.C. 20036