ML20078R549
| ML20078R549 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/09/1983 |
| From: | Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL-3, NUDOCS 8311150194 | |
| Download: ML20078R549 (26) | |
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I SOCKETES USMRC UNITED STATES OF AMERICA -- . ... .
NUCLEAR REGULATORY CCPMISSION 13 MN 14 M0:42 Before the Atomic Safety and Licensing.. Board .., . , ,
)
In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) . Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit-1)- )
)
)
L'UFFOLK COUNTY MOTION FOR CHANGE IN SCHEDULE WITH RESPECT TO CONTENTIONS 65, 23.D AND 23.H AND FOR~ BOARD ORDER CLARIFYING WHICH REVISION OF THE LILCO PLAN IS TO BE LITIGATED Suffolk County hereby. moves the Licensing Board to change the schedule for submission of testimony on Contentions 65, 23.D, and 23.H. These contentions concern the' accuracy of LILCO's evacuation time estimates, the adequacy of LILCO's traffic control scheme at the perimeter of the EPZ, and the effect of the shadow phenomenon on evacuation time estimates.
Suffolk County makes this motion -- and requests expedited Board ruling on it -- because LILCO yesterday unexpectedly sub-mitted significant revisions (Revision 2 of the Plan) of its emergency response plan. The major revisioas are to Appendix A of the Plan. Appendix A describes the traffic control scheme E
upon which LILCO's evacuation time estimates are premised.
8311150194 831109 PDR ADDCK 05000322 O PDR
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1 Until yesterday, Suffolk County had been preparing its ,
testimony on Contentions 65, 23.D, and 23.H based on Revision 1 of the LILCO Plan. As demonstrated in this Motion, the new Re-vision 2 makes significant changes to Appendix A that render it impossible for the County to submit testimony on Contentions 65, 23.D and 23.H on November 18. In actuality, Revision 2 provides a new data base which must be analyzed by the County's experts before they can decide what to write in formal testimo-ny.
Although the County received Revision 2 only yesterday,
, the vast majority of the. Revision 2 pages (all except for a few procedures) are dated between October 7 and 19, 1983. The County was_ pot given or informed of the contents of these changes prior to this week, even though LILCO obviously knew of them and presumably its experts and counsel used them in ,
preparing LILCO's testimony.
This proceeding is designed to assess the adequacy of the plan which LILCO proposes to use in the event of a Shoreham emergency. That plan clearly now is Revision 2, not Revision 1 which all parties and the Board believed until yesterday would be the subject of the upcoming litigation. To address Revision 2, the County must have time for its experts to review the new materials, to have questions answered and new provisions
clarified, and to prepare testimony which is relevant to the new provisions in LILCO's plan. The County thus moves that its testimony on Contentions 65, 23.D, and 23.H be filed on January 18, 1984 with the Group II issues. Such a change in schedule would minimize disruption of arrangements for hearing i
that have already been made, since the hearing on Contention 25 and the rest of Contention 23 could still commence on December 6.
The unexpected receipt of Revision 2 on the eve of the filing of testimony compels Suffolk County also to move the Board to establish which revision of LILCO's Plan will be the subject of litigation. Such relief is essential, or else the County, other parties, and the Board may be faced with a con-tinually moving target of revised plans, which will necessitate j
continual. changes in testimony, supplemental filings, and a i seemingly interminable proceeding.
The details regarding this Motion are set forth below.
I. Receipt of Revision 2 of the LILCO Plan On November 7, 1983, Suffolk County learned from LILCO's i
counsel that a revised version of the LILCO Transition Plan had been prepared and would be distributed "within a week." See ,
Letter dated November 4 from Jessine Monaghan to John Birkenheier, Exhibit 1 hereto. Immediately upon receipt of t
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~this information, counsel for the County requested that a description of the changes in the Plan be provided, since the County's witnesses were nearing qmpletion of draft testimony
, onYthe Group I issues,'and such testimony, obviously, was based upen the contents of_the then current Revision 1 of the LILCO Plan. See Letter' dated November 7, 1983 from Karla J. Letsche i
sent by telecopier to LILCO's counsel Donald P. Irwin, Exhibit 2 hereto.
No answer or phone call'was received from LILCO in re-sponse to Ms. Letsche's letter. Instead, at approximately noon on November 8, 1983, counsel for the County received one copy of Revision 2 to the LILCO Plan. Revision 2 includes a total of 823 now pages, to be -inserted into the Plan, Appendix A, and the.two volumes of implementing procedures (OPIPs). The revi-sions. were divided by LILCO into four groups a'id characterized as follows:
'l . Those purportedly responding to FEMA comments;
- 2. Those which in LILCO's view relate to Contentions 23, 25 and 65;
- 3. Those which, .in LILCO's view, constitute " improve-ments" in the Plan; and
- 4. Those which, in LILCO's view, constitute " minor changes."
Having received only one copy of Revision 2 yesterday, the County has not completed a detailed review and analysis of its
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contents. Not surprisingly, none of the County's experts has even seen Revision 2; nor will they be able to until additional copies can be obtained from LILCO. However, four lawyers and one paralegal spent approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> yesterday afternoon and evening reviewing the portions of Revision 2 that appear to be relevant to the Group I issues in an effort to determine the effect of the revision on the draft testimony that has already been prepared by County experts on those issues.1/ This pre-liminary review indicates that although Revision 2 affects the County's testimony on Contentions 23.A-C (evacuation shadow) and 25 (role conflict), that testimony can be revised as neces-sary to reflect the Revision 2 changes in time to meet the November 18 filing deadline.
The same is not true with respect to Contentions 65, 23.D, and 23.H, which concern evacuation time estimates and the traf-fic control scheme for the EPZ perimeter. The changes in 1/ Of necessity, the County's preliminary review included al-most all of. Revision 2, not just the portions categorized by LILCO as relating to Contentions 23, 25 and 65. The review revealed that many of the changes labeled by LILCO as " improvements" and "in response to FEMA comments" also related to the County's testimony on the Group I issues.
The County notes that this need to review LILCO's unex-pected revision cost at least two days of attorney time which otherwise would have been devoted to completion of the draft Group I testimony. This does not include the additional time required to prepare this Motion.
Revision 2 are significant insofar as these contentions are concerned. Indeed, major portions of the County's testimony on Contentions 65, 23.D, and 23.H, which at this time are essen-tially complete (albeit in draft form), must now be substan-tially revised and, in many cases, scrapped. To prepare new testimony on these contentions, particularly.the portions on traffic control, congestion, and the extent of inaccuracy in the LILCO evacuation time estimates, the County's experts must carefully review and interpret the changes and rewrite their testimony. This is no small task.
Accordingly, the County submits that the filing date for its testimony on Contentions 65, 23.D, and 23.H should be changed to January 18, 1984.
II. Discussion The sudden appearance of Revision 2 yesterday afternoon has substantially altered the data base upon which this entire proceeding is premised. Whereas the County (and presumably the Board and all other parties but LILCO) had been acting in reli-ance on Revision 1, we now are confronted with a major new re-vision, particularly insofar as Contentions 65, 23.D, and 23.H l are concerned. This means that major portions of the analyses, evaluations, discovery, and testimony that the County, its witnesses and consultants have been conducting and preparing over the past few months are now completely irrelevant.2/ The 2/ The data base also changed with Revision 1 of the Plan (which was provided to the County in mid-August), making (Footnote cont'd next page) i -
County has been severely -- and most unfairly -- prejudiced by LILCO's submittal of a new Plan literally on the eve of the deadline for filing testimony.
First, although Revision 2 was only provided to the County yesterday, November 8, the vast majority of the pages contained in Revision 2 are dated from October 7 to October 19.3/ This means that for at least a month the LILCO witnesses and attorneys have known of significant changes in the Plan, and presumably have been preparing testimony based on the Revision 2 facts rather than the now irrelevant Revision 1 facts.
Nonetheless, LILCO and its counsel sat silently by, letting the County waste its time and resources by preparing testimony in reliance on the obsolete facts contained in Revision 1. In-deed, LILCO and its counsel encouraged the County to expend its resources in that wasteful process by repeatedly asserting that (Footnote cont'd from previous page) certain contentions, which had been based on Revision 0 (distributed in May), somewhat inaccurate. However, the Revision 1 changes were minor compared to those contained in Revision 2. Moreover, with three months to review, an-
, alyze and conduct discovery on Revision 1, it was reason-i able to expect that testimony could reflect the Revision 1 facts that were not known at the time the contentions were written.
3/ There are a few pages in the OPIPs dated October 5 and October 20-25.
the submittal of testimony on the Group I issues could go forward on November 18. This was done with LILCO's full knowledge that the County's testimony on those issues, in con-trast to LILCO's, would not be relevant to the changed facts contained in Revision 2 of the Plan.
The County is outraged by LILCO's conduct, particularly because LILCO'never even gave the County an inkling either that such a major Plan revision was forthcoming at the eleventh hour, or the actual substance of the changes that would be contained in such a revision.1/ LILCO clearly had ample oppor-tunity to do so, since its counsel and the County's counsel spent many hours discussing the division of issues into Group I and II during late October and early November. Prior to this week, there never was a hint from LILCO regarding the substance of the revisions we received yesterday.
Lecond, in order to submit meaningrul testimony on conten-tions 65, 23.D, and 23.H, which takes into account the new l
facts upon which LILCO's plan is now predicated, the County l
4/ Although the County learned during discovery that certain minor Plan revisions were being considered by LILCO, there I
was absolutely no indication given that the scope of any such revisions would even approach the magnitude of Revi-sion 2; nor was the County able to learn during discovery the contents of any of the anticipated revisions to Appen-l dix A that are discussed in this Motion.
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needs time (a) to review and analyze Revision 2; (b) to obtain
' information from LILCO that is necessary to comprehend the ,
meaning and significance of many of the changes contained in Revision 2; and -(c) to revise, and in many instances completely rewrite, draft. testimony that.has already been prepared on those contentions. Such additional time is needed because Re-vision 2 includes extensive changes in the traffic control scheme proposed by LILCO in Appendix A and the OPIPs, which significantly affect the issues addressed in Contentions 65, 23.D, and 23.H. Several of the significant revisions, which the County was able to identify during its preliminary review yesterday afternoon, and their impact on the County's testimo-ny, are described below.
Contention 65 as a whole concerns LILCO's evacuation time estimates, which the Intervenors allege are inaccurate and unreliable. Major subparts of Contention 65 focus on:
i (a) LILCO's traffic control scheme, its adequacy, workability and effect upon_ congestion and, ultimately, evacuation times i
_( Contentions 65.C.1-3, 65.H); (b) the evacuation routes pre-scribed by LILCO, their logic and practicality, whether L .
evacuees would follow them, whether they could be enforced by y
LILCO, and their ef fect on evacuation times and LILCO's evacua-tions- time estimates (Contentions 65.F, 65.C.4); and (c) the i
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assumptions underlying LILCO's evacuation time estimates, I
including the effect of road blockages, roadway capacities, 1
conformance with prescribed routes, driver behavior, and likely l 4
driving speeds, among other things (Contentions 65.A, 65.B, 65.C, 65.D, 65.E, 65.F). Contention 23.D relates closely to Contention 65 since it focuses on the effect of the shadow phe-nomenon on-LILCO's time estimates. Contention 23.H, although related to the evacuation shadow phenomenon because it in part concerns evacuees from outside the EPZ, in fact focuses also on the inadequacy of the traffic control measures at the perimeter of the EPZ, and the effect of such measures upon traffic con-gestion -- and therefore evacuation time estimates -- within the EPZ.
LILCO has assigned prescribed routes to the evacuating population, and its evacuation time estimates assume that 100 percent of t;. population will comply with those routes. The LILCO Plan has a detailed system of traffic control " posts," at which LILCO traffic guides will attempt to enforce the LILCO prescribed evacuation routes by directing drivers to turn a particular way, preventing them from going a particular way, or directing them to perform some maneuver such as making a "U" turn. The traffic control posts, traffic strategies, and pre-scribed turn movements are set forth in Figure 8 and Table XII l'
of Appendix A.
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As stated in Contention 65, in particular subpart C.4, the County believes there will be great deviation from the LILCO-prescribed routes, resulting in significantly increased congestion and evacuation times. In order to determine and be able to discuss in testimony the degree of expected deviation, experts from the Suffolk County Police Department have examined all traffic control posts and all prescribed turn movement strategies contained in Figure 8 and Table XII of Appendix A, and have developed detailed draft testimony on the adequacy, workability and likely driver reaction to the routes and turn movements prescribed by LILCO. A description of a portion of that draft testimony is Exhibit 3 hereto, which is submitted to the Board only for in camera inspection to provide a demonstra-tive example of the detailed evaluation which has been performed by the County's witnesses based on the facts contained in Revision 1. (See Exhibit 3, in camera).5/
Revision 2 of Figure 8, however, has substantially changed LILCO's entire routing scheme. Based on the County's initial review of the Revision 2 version of Figure 8, it appears that the locations of approximately 30 to 50 out of 138 traffic 5/ Exhibit 3 is submitted to the Board in a separate sealed envelope. If the Board decides that it does not need to review Exhibit 3, the County requests that it be returned to the County's counsel.
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E control posts (Revision 1 had 143 posts) have been changed.
Furthermore, of those traffic posts-remaining at the same loca-tions, from-a preliminary review it is apparent that LILCO has' in many instancesLchanged the: planned traffic control 1-
. strategies by routing traffic in different ways than had been prescribed in Revision 1. While the County has not had' time to review all.138 of LILCO's traffic posts in Revision 2, a random sampling of 10 posts revealed that-8 of them included new 4
routing schemes. In addition, the number of. traffic guides to be stationed at traffic control posts appears to have been changed for at least 21 posts.
Clearly, the County's experts must now reanalyze all of LILCO's traffic posts as they appear in Revision 2 and must de-termine all over again the validity, workability, and effect upon congestion and evacuation times of LILCO's traffic routing scheme. This review must also include an analysis of the traf-fic control posts existing along the perimeter of the EPZ, which is directly relevant to Contention 23.H.
The County's reanalysis of LILCO's prescribed turn move-ments and' traffic posts will be a time-consuming effort, made j more difficult by the fact that in Revision 2, LILCO has total-ly reformatted Figure 8. Where.'s 'the Revision 1 version of
! Figure-8 had a narrative description of each traffic control L
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4 strategy (e.g. for a particular intersection " establish i roadblock to prevent traffic from proceeding north on Terryville Road...."), the version in Revision 2 has a six column chart, listing only compass directions, for " movements
- .to be facilitated," " movements to be discouraged" and "non-evacuation movements to be accommodated" (e.g. "From NE" "To S," "From All" tc "NE"). -
Copies of corresponding pages of Figure 8 from Revision 1 (Exhibit 4) and Revision 2 (Exhibit 5) are attached hereto.to demonstrate the change in format.
Compare Exhibits 4 and 5. In Revision 2, Figure 8 consists of 16 pages; in Revision 1 it was 27. It is clear from a glance at the trevised Figure 8 that simply interpreting the skeleton-like content of the new Figure 8 represents a major undertak-ing, separate and apart from comparing it to the original Figure 8 which has already been analyzed by the County's witnesses, and then analyzing all the changes. The changes in traffic control posts, prescribed turn movements and traffic
- control stategies affect the adequacy and workability of the LILCO traffic control scheme, the likelihood of driver devia-tion from LILCO's prescribed routes, and the resulting degree j of. inaccuracy of the~LILCO time estimates, all of which go to the whole of Contention 65 and Contentions 23.D and 23.H.
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v Revision 2 will also have an impact on the County's testi-mony concerning LILCO's ability to enforce compliance with its prescribed routes and traffic control strategies and the re-sulting effect on traffi,c congestion and evacuation times. Re-vision 1 of Appendix A called for traffic guides to " control" and " enforce" traffic movements by various means, including the use of roadblocks, " directing" traffic " preventing" traffic from going in certain directions, and forcing traffic to make "U" turns and the like at particular intersecticnc. A screening procedure was also included in Revision 1, according to which the traffic guides would make sure that persons seeking to deviate from prescribed routes had " good reason" to do so. Contentions 65.C.1 and 65.C.2 expl.icitly challenge such control and enforcement mechanisms.
In Revision'2, LILCO appears to have attempted to alter the traffic guide function by stating that undesirable turn movements by evacuees are now to be " discouraged" or "accommo-dated." The explicit screening procedure of Revision 1 has ap-1 parently been dropped. Thus, Appendix A now contains the fol-lowing inscrutable statement purportedly " defining" the column headings (i.e., the traffic control strategies) in Figure 8:
Evacuation Movements to be Facilitated -
Represents major evacuating traffic movements as -
specified in the evacuation plan which should be assisted to the greatest' extent possible.
Movements to b? Discouraged - Represents movements which if made, will move traffic to-ward Shoreham Nuclear Power Station and/or is counterflow relative to the major evacuation traffic flow.
Movements to be Accommodated - Represents the preferred direction of movement for minor traffic flows, not specified on the evacuation plan, at controlled intersections. The indi-cated movement will direct this traffic to an-other evacuation route while maintaining smooth traffic flow. (Revision 2, at IV-23).
How turn movements are to be " discouraged," " facilitated," "as-sisted" or " accommodated" is unexplained, as is the difference
-- if any -- between " discouraging" traffic and attempting to control, direct, or guide it. It is evident that further dis-covery or clarification is necessary to determine the precise significance of these changes. In short, no one reading this new Revision 2 language could have the slightest idea of what it means in the context of LILCO's Plan.
The County's testimony on Contention 65.C.3 also appears to be affected by changes contained in Revision 2. This por-(
tion of the contention alleges that confusion will be caused by l
LILCO's personnel attempting to direct traffic in directions that conflict with operating traffic signal lights. In Revi-sion 2, it is revealed for the first time that some LILCO traf-fic guides will have " flashing lights." (Revision 2, Figure 8). This appears to constitute a control strategy different
from that contemplated in Revision 1, the adequacy and effect of which will have to be assessed after discovery or other means-to-clarify precisely what LILCO believes or intends that these flashing. lights will accomplish.
As'noted above, roadway capacities are a major issue in Contention 65, in particular in subpart D. Indeed, roadway capacities are a major factor used in deriving evacuation time i
estimates. Revision 2 (Appendix A, Table 4) substantially re-vises several of the roadway capacities which LILCO had assumed in deriving its time estimates. In some cases, LILCO has more than tripled those capacities. The County's experts, knowing that there-has been no physical change in the size of such roadways since Revision 1 was published, must now analyze these newly established roadway capacities in order to understand their bases, let alone-to-evaluate their accuracy and their effect on evacuation time estimates and.the County's testimony Lon Contentions 65,'23.D and 23.H.
f Finally, LILCO's traffic control procedure, OPIP 3.6.3, has been substantially rewritten in Revision 2. That procedure explains the functions of the various personnel (including 1
evaucation route spotters and traffic guides) assigned to control or assist the flow of traffic from the EPZ. The revi-sions in OPIP 3.6.3 were too numerous for the County's counsel
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l to analyze in detail last evening; however, it is clear these revisions will likely affect the County's testimony on Conten- ,
- tions 65.H and 65.C, which concern the duties of evacuation route spotters and traffic guides, their ability to perform their assigned duties, and the effect of their actions on con-gestion and evacuation times. County witnesses must also ana-lyze the impact of LILCO's new proposal to use helicopter sur-veillance in connection with traffic control. (Revision 2, Ap-pendix A at IV-70).
The County emphasizes that the foregoing discussion and the examples provided by the in camera exhibit are only a pre-liminary and incomplete set of examples of significant Revision 2 changes. It is the best that could be done in the short time available to County counsel. There is every reason to believe that many additional matters having an impact on the County's testimony will be identified when the County's experts are given the opportunity to review Revision 2. Just the foregoing examples make clear, however, that the changes which pertain to Contentions 65, 23.D and 23.H are major. The County thus needs an opportunity to review Revision 2 with care before testimony on these contentions can be filed.
It is impossible for the County to state precisely at this time when it will be possible to file testimony on Contentions 17 -
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65, 23.D and H. The November 18 date is clearly not feasible, particularly since the County's experts have not even received Revision 2 as yet from LILCO.
Under these circumstances, in the County's view only one option is available: an Order of the Board that testimony on Contentions 65, 23.D, and 23.H be filed as part of Group II on January 18, 1984. The County has considered whether some ear-litr date might be possible (i.e., establish a Group III for submission between November 18 and January 18). That is not feasible, since substantial time will be required for the new work caused by Revision 2 and since many of the experts will be involved in the trial of remaining Group I issues which presum-ably will still proceed on December 6.
LILCO has no basis on which to complain about this new testimony filing date, having created the present situation by its own doing. The fact that LILCO had completed major changes to its plan while permitting the County to prepare testimony on an obsolete plan has caused the County to waste a great deal of time and resources. Accordingly, to prevent LILCO from un-fairly profiting from its actions by having even more addition-al time (as compared to the County) within which to prepare testimony on Fevision 2, the County asks that LILCO be required to file its testimony on Contentions 65, 23.D, and 23.H. in
camera with the Board on November 18, and that LILCO distribute such testimony to the other parties on January 18, the filing date for Group II testimony.
III. The Board Should Specify the Version of the LILCO Plan Which Will Be Litigated The foregoing circumstances relating to Revision 2 of the LILCO Plan compel the County to ask the Board to define as pre-cisely-as possible what the data base is -- that is the Plan --
which is to be litigated in this proceeding. Such definition is essential if we are to avoid having a constantly moving tar-get which affects not only the analyses and testimony which are being prepared by the parties, but also the record upon which the Board will base its findings.
Respectfully submitted, David J. Gilmartin i
Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppa,pge, New York 11788 1 . / --
l Herbert H. Brown W 0014 Lawrence Coe L W her i
Karla J. Letsche l
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County November 9, 1983 i
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- Exhibit 1 Hu xT ow & WILLIAM S 707 EAST MA4N STREET P. o. Box 1535 o o a e evisse=o Rzcatasown,VratorwxA 23212 .. . ...vov.~,. c uu c, u. w. l
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John E. Birkenheier, Esq.
Kirkpatrick, Lockhart, Hill, BY FEDERAL EXPRESS Christopher &~Phillips 1900 M Street, NW Eighth Floor Washington, DC 20036
Dear John:
In response to Suffolk County's Informal Discovery Request 31 of June 14, 1983, LILCO defined the term " good reason" as it was used in the context of a quoted passage from page IV-23 of Appendix A to the Plan. To avoid misunderstanding and sur-prise, LILCO amends its prior response and states that Revision 2 'of the. Plan, which is scheduled to be sent to all holders of the Plan within the week, amends Appendix A at page'IV-23 and deletes the passage that provides for personnel to screen ve-hicular access to the EPZ. Due to the fact that the Group I ,
issues include the issue.of control of the EPZ perimeter, LILCO has chosen to inform suffolk County of the amendment now so that the change may be taken into consideration in your written testimony, rather than to await the issuance of Revision 2.
If you have any questions regarding this matter, please do not hesitate to give me a call.
Sincerely yours, essine A. Monaghan 283/730 .
cc: David A. Repka, Esq.
Stephen B. Latham, Esq.
James B. Dougherty, Esq.
Ralph Shapiro, Esq.
Stewart M. Glass, Esq.
Exhibit 2 ,
hr,pWCIC, WAWT, Err.T , CHRISTOPHER Se PwrrT_rvs A Panersmaussy Incsesswo A P- -'i Companarson a
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BY TELECOPIER Donald P. Irwin, Esquire Hunton & Williams -
707 East Main Street Richmond, Virginia 23212
Dear Don:
. We received this morning a letter from Jessine Monaghan -
dated November 4, 1983, in which she states that Revision 2 of the LILCO Plan "is scheduled to be sent to all holders of i the Plan within the week." We did not know such a revision was forthcoming and have been preparing testimony, to be filed November 18, based on the contents of Revision 1. Since revisions to the Plan will undoubtedly affect the testimony ~
we are currently preparing, and since we have no,t yet received the new version of the Plan, please provide us, as soon as possible, with a description of all the changes in the Plan that are reflected in Revision 2.
Sincerelr,
/
l Kar a J. Letsche KJL:so ,
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l l l 1 I i l l l 0 1 All llN 1 --
I 51 1 Terryville Road l At Terryville Elementary Port Jefferson l 1 l 0 l l -- l -- l --
l School l l l l l l l l .l l l l I i .I mi I l l l 4 l l 0 0 l E. lW l All iE l -- 1 --
1 l 52 llNesconsetRoaq Joyne Boulevard l Fort Jefferson 1 l i l I l l l l l I l l 1 i I l ,
I l i I l J l ' 53 l Hiddle 1 eland - l E. Bartlett Road Fatchogue 1 3 l 1 l NE lS l All l NE lW lS-l l l l l l l l l Yaphank Road l I, 1
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i I i l l l.All l NE l 54 l Middle 1 eland -
l Longwood Road l Fatchogue l 1 'l 3 ll 1 l -- l -- l SW lE l Yaphank Road l
l l l l l l .l l l NE l SW l 11E I SW l l l l l l l l l l l l 1- l I
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i Route 25A Mt. Sinal - Corse Road ,1 Port Jef(erson i 1 81 1 2 lE W l All l N lN lW l 55 lS IE l 1 l IW S I l l l l l 1
l 56 l Route 25A Route 83 (Patchogue - Port Jefferson l 2 l 4 ! 1 E lW l All lE lN W l Mt. Sinal Road) l l l l E lS I l lW IS l l l l 1 l- I l l l l l l l 1 Re v. 2 10/18/a
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
) -
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
). (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County Motion for ~
Change in Schedule with Respect to Contentions 65, 23.D and 23.H and for Board Order Clarifying which Revision of the LILCO Plan is to be Litigated have been sent to the following this 9th day of November, 1983 by U.S. mail, first class, except as otherwise noted:
- Ralph Shapiro, Esq.
James A. Laurenson, Chairman Atomic Safety and Licensing Board Cammer.and Shapiro .
. . U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D.C. 20555 New York, New York 10016 Dr. Jerry R. Kline Howard L. Blau, Esq.
Atomic Safety and Licensing Board 217 Newbridge Road U.S. Nuclear Regulatory Commission Hicksville, New York 11801 Washington, D.C. 20555
- W. Taylor Reveley, III, Esq.
Mr. Frederick J. Shon Hunton & Williams Atomic Safety and Licensing Board P.O. Box 1535 U.S. Nuclear Regulatory Commission 707 East Main Street
. Washington, D.C. 20555 Richmond, Virginia 23212 Edward M. Barrett, Esq.
General Counsel Mr. Jay Dunkleberger Long Island Lighting Company New York State Energy Office
. ,250 Old Country Road Agency Building 2 Mineola, New York 11501 Empire State Plaza Albany, New York 12223 Mr. Brian McCaffrey **
Long Island Lighting Company Stephen B. Latham, Esq.
175 East Old Country Road Twomey, Latham & Shea Hicksville, New York 11801 33 West Second-Street .
Riverhead,.New York 11901
- By Hand
- By Federal Express ymy-,y-, , , ,,yy , , , . , . _ , _ . . _ _ , , - - - - , , _ , ._.eC ---T-NT - = ' " ' - - -*w--w
l l
Nora.Bredes Docketing and Service Sect' ion i
Executive Director Office of the Secretary l Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm. l 195 East Main Street Washington, D.C. 20555 !
Smithtown, New York 11787 Hon. Peter Cohalan Marc W. Goldsmith Suffolk County Executive j Energy Research Group, Inc. H. Lee Dennison Building i 400-1 Totten Pond Road Veterans Memorial Highway l Waltham, Massachusetts 02154 Hauppauge, New York '11788 MBB Technical Associates
- Eleanor L.
Frucci, Esq.
1723 Hamilton Avenue '
Atomic Safety and Licensing Suite K Board Panel San Jose, California 95125 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 ,
Joel Blau, Esq. 1 New York Public Service Comm. Ezra I. Bialik, Esq.
l The Governor Nelson A. Rockefeller Assistant Attorney General Building Environmental Protection Bur.
Empire State Plaza New York State Dept. of Law Albany, New York 12223 2 World Trade Center .
New York, New York 10047 David J. Gilmartin, Esq.
Suffolk County Attorney Atomic Safety and Licensing I H. Lee Dennison Building Appeal Board l Veterans Memorial Highway U.S.. Nuclear Regulatory Comm.
Hauppauge, New York 11788 Washington, D.C. 20555 Atomic Safety and Licensing Jonathan D. Feinberg, Esq.
Board Panel Staff Counsel, New York State U.S. Nuclear Regulatory Commission Public Service Commission Washington, D.C. 20555 3 Rockefeller Plaza Albany, New York 12223 Bernard M. Bordenick, Esq.
David A. Repka, Esq. *
- Stewar t M. Glass, Esq. ,
U.S. Nuclear Regulatory Commission Regional Counsel I
. Washington, D.C. 20555 Federal Emergency Management l Agency 1 Stuart Diamond 26 Federal Plaza, Room 1349 Environment / Energy Writer New York, New York 10278 i NEWSDAY i Long Island , 'New -York 11747
- James B. Dougherty,.Esq. l 3045 Porter Street, N.W. l Washington, D.C. 20008 l l
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s r
t Spence Perry, Esq.
Associate General Counsel -
Federal Emergency Management Agency Washington, D.C. 20472 ,
Mr. Jeff Smith Shoreham Nuclear Power Station P.O. Box 618 North Country Road Wading River,'New York 11792 N
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KarlaJ..Let/che KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 DATED: November 9, 1983 O
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