ML20079F500
| ML20079F500 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/16/1984 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20079F461 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8401180288 | |
| Download: ML20079F500 (26) | |
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DOCHETED USNRC UNITED STATES OF AMERICA .g4 ]q j 7 p q g7
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NUCLEAR REGULATODY COMMISSION r
Before the Atomic Safety and Licensing Board
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In the Matter of .)
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LONG ISLAND LIGHTING COMPANY ') Docket No. 50-322 (OL)
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(Shoreham Nuclear Power Station, )
Unit 1). )
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Suffolk County Motion for Leave to File Amended and Supplemental Testimony on Certain Group I Issues In accordance with the Joint Motion for Adjustment of Schedule filed by LILCO and Suffolk County on January 3, 1984 and accepted by the Board during a conference of counsel held January 4, 1984, Suffolk County hereby moves the Board for leave to file the following Amended or Supplemental Testimony, copies.of which are attached hereto:
- 1. Amended Direct Testimony of Inspector Richard C. Roberts, Inspector Joseph L.
Monteith, Deputy Inspector Philip McGuire, Depu-ty Inspector Michael J. Turano, Jr., and Captain Edwin J. Michel (hereinafter "Suffolk County Police Department" or "SCPD") on Behalf of Suffolk County Regarding Emergency Planning Con-tentions 65 and 23.H (" Amended SCPD Testimony");
- 2. Supplemental Direct Testimony of Professor Bruce William Pigozzi on Behalf of Suffolk County Regarding Contention 65 (Evacua-tion Time Estimates) (" Supplemental Pigozzi Tes-timony");
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3.a. Supplemental Direct Testimony of Nick J. Muto and J. Thomas Smith on Behalf of the Middle Island Central School District and Suffolk County Regarding Contention 25 -- Role Conflict; 9
- b. Supplemental Direct Testimony of Robert W. Petrilak on Behalf of the Mt. Sinai Board of Education and Suffolk County Regarding Contentions 25.C and 25.D -- Role Conflict;
- c. Supplemental Direct Testimony of Dr.
George Jeffers and Anthony R. Rossi of Middle Country Central School District and Suffolk County in Support of Contentions 25.C and 25.D;
- d. Supplemental Direct Testimony of Leon J. Campo on Behalf of Suffolk County Concerning Emergency Planning Contentions 25.C and 25.D (collectively, " Supplemental School Administra-tors' Testimony").
This Motion is submitted pursuant to the Boa'rd's Memoran-dum and Order Regarding Motion for Change in Schedule, Request for Conference Call, and Motion to Compel Discovery, dated November 14, 1983, and its Order Granting in Part Fuffolk Coun-ty's Motion for Discovery and Response to Lieberman Testimony and to Revision 2 of the LILCO Plan dated December 23, 1983.
In these Orders, the Board informed the parties that in sub-mitting the anticipated Supplemental Testimony, they should explain why it was not filed at the time the rest of Group I testimony was filed, i.e. on November 18, 1983, and thus establish good cause for the filing of the additional testimony at this time.
g e In brief, the Amended SCPD Testimony filed herewith reflects changes made by LILCO in Revisions 2 and 3 of the LILCO Plan concerning traffic control and evacuation times.
Because Revision 2 became available only days before the filing of testimony on November 18, and Revision 3 became available in late December, the SCPD witnesses were unable to address the contents of these revisions in their testimony which was filed on November 18.
, The Supplemental Testimony of Professor Pigozzi addresses i
two documents of which the County first became aware with the filing of LILCO's November 18 testimony (KLD TM-139 and KLD TM-140). Pursuant to the Board's December 23, 1983 Order ref -
erenced above, the County conducted discovery concerning the two reports in early January, 1984. Because the two KLD documents were not known to the County until November 18 and discovery concerning them was not completed until early January, Professor Pigozzi was unable to address those studier in his testimony which was filed in November.
The Supplemental School Administrators' Testimony addresses changes made in Revision 3 cf the LILCO Plan regarding proposed protective actions for schools. Because these gentlemen first learned of the changed LILCO proposals 1
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contained in Revision 3 in early January, 1984, they were unable to address in their November 18 testimony the effects of role conflict on the implementability of the new LILCO propos-als.
Each of these pieces of testimony is discussed in more de-tail below.
I. Amended SCPD Testimony The Amended SCPD Testimony is intended to replace, in its entirety, the SCPD Testimony which was filed on November 18, 1983. A comparison of the contents of the November 18 and the Amended SCPD Testimony, which explains and justifies the amend-ments, follows.
As was noted in the November 18 testimony and in the November 9, 1983 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 Lit-igated, Revision 2 of the LILCO Plan was received by the Coun-ty's attorneys on November 8, 1983. Revision 2 contained substantial changes to LILCO's proposed traffic control plan, which,is set forth primarily in Appendix A of the LILCO Plan.
There was insufficient time available between the appearance of I
l Revision 2 and the November 18 testimony filing date to permit the SCPD witnesses to receive, review and analyze Revision 2, revise their draft testimony, and have such testimony reviewed and finalized. Accordingly, the November 18 testimony filed by the SCPD witnesses addressed Revision 1 of the LILCO Plan, but included a statement that an Amendment to address pertinent portions of Revision 2 would be forthcoming following its review and analysis by the witnesses.
In early December, the Board and parties were informed by LILCO's counsel that Revision 3 of the LILCO Plan would be distributed in late December. It was received by the SCPD witnesses on January 3. Revision 3 contained further changes in the LILCO proposals for traffic control that were even more extensive than those in Revision 2. Thus, Revision 3 also ne-cessitated modifications to the November 18 SCPD testimony.
Because LILCO changed the factual data base upon which the lit-j igation concerning traffic control techniques and strategies, and evacuation time estimates, is premised, it is necessary to amend the testimony submitted on those topics to reflect such l new facts. Without such amendment, the testimony would be l
l useless and irrelevant, since it would address a traffic control scheme and other elements of the LILCO Plan which have now been superceded. Clearly, it was not possible to submit
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the Amended SCPD Testimony on November 18 since the LILCO changes embodied now in Revision 3 which necessitated the amendments to the testimony were not in existence at the time such testimony was prepared by the SCPD witnesses.
A. Testimony Not Amended Certain portions of the text of the November 18 SCPD tes-timony have been deleted, because they addressed matters that are no longer pertinent to the new LILCO traffic control pro-posals; therefore, such portions of the November 18 testimony have been withdrawn by the County. In addition, Revisions 2 and 3 to the LILCO Plan did not necessitate any modifications to certain other portions of the testimony submitted on November 18, 1983. Such portions are therefore merely repeat-ed, without change, in the Amended SCPD Testimony. These two categories are discussed below.
- 1. Deleted Portions of SCPD November 18 Testimony The following portions of the SCPD November 18 testimony have been deleted from the Amended SCPD Testimony because revi-sions to'the LILCO Plan made subsequent to the preparation of the November 18 testimony made these portions no longer appli-cable to the Plan now being submitted by LILCO:
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Footnote 1, pages 4-5 Footnote 5, page 8 Page 19, line 9 thru line 17 (sentence beginning "For example . . . " through end of paragraph)
Page 21, line 1 thru line 4 (beginning with "the strategies set forth . . . " through "In other in-stances," on line 4)
Page 22, line 1 thru line 16 (ending with "Ex-pressway, westbound" on line 16)
Footnote 6, page 23 Footnote 7, page 24 Footnote 8, page 25 Page 34, lines 1 thru line 8 Page 34, line 19 thru page 35, line 5 Page 36, line 12 thru page 37, line 10 Page 38, line 1 thru page 41 (including fn. 10)
Attachment 3 [ discussion regarding channelization treatments at links (13, 17), (22, 21), (23, 22), and (81, 24)]
Attachment 4 [ discussion regarding concurrent continuous flow treatment at intersection of Whiskey Road and Ridge Road (node 38)]
Attachment 5 [ discussion regarding one-way flow at links (7, 30) and (38, 40)]
The above portions of the November 18 testimony do not appear in the Amended SCPD Testimony.
- 2. Testimony Not Affected by Plan Revisions The following portions of the November 18 SCPD testimony were not modified in any significant way in the Amended Testi-mony because Revisions 2 and 3 of .the LILCO Plan did not affect the. contents of the previously filed testimony (note that the page and line numbers below refer to the November 18 testimony; of course, the portions listed below now appear at new loca-tions in the Amended SCPD Testimony):
Page 1, line I thru page 19, line 61/
Page 19, line 18 thru page 202 /
Page 21, line 4 (beginning with "the strategies to be implemented . . . ") thru line 8 Page 21, lin 11 (beginning with Route 25A . . . ")
thru line 22_g/
Page 22, line 19 thru page 23, line 6 Page 26, line 1 thru page 27, line 11 Page 28, line 8 thru page 29, line 20 (ending with "For example,")
-1/ As noted above, footnotes 1 and 5 to the November 18, 1983 testimony have been deleted.
2/ However, a footnote (fn. 4 to the Amended Testimony) was added.
3/ A discussion regarding insufficient number of traffic guides was added following line 22 of the November 18 tes-timony. .
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Page 31, line 11 thru page 33, line 12 s Page 42, line 1 thru page 66, line 4d/
Page 66, line 11 (beginning with "If all the accident . . . ") thru page 67, line 17 Page 68, line 1 thru page 69, line 18 (ending with "in Suffolk County.")
Page 69, line 18 (beginning with " Road construction . . . ") thru page 70, line 16 Page 70, line 19 thru page 76, line 10 (ending with
" Appendix A, LILCO")
Page 77, line 6 (beginning with "On the South Fork . . . ") thru line 12 Attachment 1 Attachment 2 Attachment 6 Attachment 7 With the exception of some minor typographical corrections and other non-substantive changes (see Section B.3. below), the above portions of the Amended Testimony are identical to the November 18 testimony.
4/ Footnotes (fns. 8, 10 and 12 to the Amended Testimony) were slightly modified.
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B.- Amended Testimony The November 18 SCPD testimony was amended or modified for three reasons:
- 1) To reflect a chance in page or section numbers in the Plan;
- 2) To reflect a change in either the text or the substantive proposals contained in the Plan;
- 3) To correct non-substantive or typographical errors in the original testimony or to correct computational errors in the original testimony.
In many cases, if the modification was made for the second reason (to reflect a change in text or substantive proposal in the Plan), modifications were also necessary to reflect changed page or section numbers.
- 1. Changes in Plan Page or Section Numbers Some modifications were made in the November 18 testimony in order to reflect a change in page numbers or section numbers of the LILCO Plan, with no other modifications made to the text of the SCPD testimony. The reason these changes were made is obvious: the original testimony referenced a now-outmoded ver-sion of the Plan and the change merely corrects the citation so that the testimony, as amended, addresses the version of the Plan which the Board will in fact be considering.
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' . Chances in Plan Text or Proposals The following portions of the November 18 SCPD testimony were amended to reflect either changes in Plan text that had been quoted or referenced in the original testimony, or sub-stantive changes in the proposals contained in the Plan, or both (again, unless specifically noted, page and line refer-ences are to the November 18 testimony):
Page 19, line 7 thru line 8 Page 20, line 10 thru line 151/
Page 21, line 9 thru line 11 (ending with citation to Appendix A, Table IX, at IV-20)
Page 23, line 8 thru page 26, line 1 (ending with the word." flow")A/
Page 27, line 20 (after "For example,") thru page 28, line 7 Page 29, line 20 (after "For example,") thru page 31, line 10 Page 33, line 13 thru line 21 Page 34, line 9 thru line 181/
-5/ In addition, a new footnote was added (fn. 4 to Amended Testimony).
6/ A discussion regarding school bds traffic was added after the word " flow" on page 26, line 1 of the November 18 tes-timony.
7/ In addition, a discussion reoarding insufficient number of traffic guides and a footnote were added (fn. 6 to Amended .
Testimony), as was a discussion regarding traffic control posts #10 and 411.
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Page 35, line 17 thru page 36, line 11 Page 37, line 11 thru line 208 /
Footnote 12, page 44 (fn. 8 in the Amended Testimony)
Footnote 16, page 165 (fn. 12 in the Amended Testimo-ny)
Page 66, line 5 thru line 10 Pae 67, line 18 thru line 19 Page 69, line 18 (discussion of new Attachment 11 to the Amended Testimony added after sentence ending "in Suffolk County.")
Page 70, line 16 thru line 18 Page 76, line 10 th'ru page 77, ifne 6 Attachment 3 Attachment 4 Attachment 5 Attachment 8 Attachment 9 Attachment 10 Attachment 11 (new attachment to Amended Testimony)
Attachment 12 Attachment 13. s
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In many instances, the modifications contained in the Amended Testimony are relatively minor. For example, some
-8/ In addition, a discussion regarding traffic control post
- 140 was added in the-Amended Testimony.
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merely involve the addition or deletion of a few words to make the testimony conform to the Plan now before the Board. These amendments, therefore, were necessary to rerlect changes made by LILCO in its Plan. See, for example, Attachments 8, 9, 12 and 3 3, which all were amended to reflect change s made by LILCO in the designation and placement of traffic contzol posts.1/
Attachment 10 was amended to reflect LILCO's changed descrip-tions of roadway sections. Attachment 10, as amended, also reflects adequacy or inadequacy of shoulders along some roadway links not previously reported by LILCO. The following are in-stances where the modifications made in the Amended SCPD Testi-mony are relatively minor in nature:
Page 19, line 7 thru line 8 Page 20, line 10 thru line 15 Page 21, line 9 tnru line 11 (ending with citation to Appendix A, Table IX, at IV-20)
Page 21 [ discussion added following line 22 (see n. 3 above)]
Page 33, line 13 thru line 21 Page 34, line 9 thru line 18 Page 35, line 17 thru page 36, line 11 9/ Attachment 9 was also amended to correct some inadvertent errors in tabulation of the number of accidents along selected roadway sections. See discussion in Section B.3.
below. .
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Page 37, line 11 thru line 20 Footnote 12, pace 44 (fn. 8 in the Amended Testimony)
Footnote 16, page 65 (fn. 12 in the Amended Testimo-ny)
Page 66, line 5 thru line 10 Page 70, line 16 thru line 18 Page 76, line 10 thru page 77, line 6 Attachment 8 ,
Attachment 9 Attachment 10 Attachment 12 Attachment 13 with respect to the above portions of testimony, the reasons for the amendments are, in the County's view, self-explanatory. For example, in Revision 1 of the LILCO Plan, which was the basis for the November 18 SCPD testimony, four of the intersections discussed in Attachment 8 were not designated as manned traffic posts in the LILCO Plan. In its subsequent Plan revisions, however, LILCO has added a traffic post at one of the intersections -- County Road 83 and Old Town Road. This ,
change by LILCO obviously affected the November 18 SCPD testi-mony and is reflected in the Amended Testimony. The changes made, however, do not change the meaning or thrust of the original testimony -- i.e., that the LILCO Plan fails to
provide traffic guides at intersections where, historically, traffic accidents have occurred with some frequency.
In other instances, the amendments made to the November 18 SCPD testimony appear more extensive. However, as with the ex-ample discussed above, none of these changes alters the basic thrust of the November 18 testimony; rather, the thrust of the testimony remains the same, with the underlying facts changed to reflect changes in LILCO's Plan.
For the most part, the areas of more extensive amendments involve LILCO's proposed traffic control techniques and stategies. For example, the amendments to pages 23-25, 27-28, and Attachments 3, 4, and 5 of the November 18 testimony in-volve LILCO's changed proposals to control traffic, increase roadway capacity, and reduce traffic times, by such means as concurrent continuous flow treatments, one-way flow, mandating turn movements, and channelizing traffic flow. Similarly, the amendments to pages 29-31 of the November 18 testimony involve inconsistencies which exist between the revised traffic control strategies now proposed to be implemented by LILCO's traf fic guides and the turn movements now prescribed for and expected of evacuating traffic at traffic node locations.
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l In its recent Plan revisions, LILCO apparently attempted to moot meny of the criticisms made by the SCPD witnesses in their November 18 testimony. Thus, for example, inconsistencies noted by the SCPD witnesses between concurrent continuous flow treatments and other LILCO proposed traffic control strategies were purportedly " fixed" by LILCO in Revi-sions 2 and 3. However, deficiencies in the LILCO traffic control plan still exist in Revision 3 of the Plan. Some of these deficiencies are discussed in the Amended SCPD Testimony.
Several of these deficiencies, of course, were not specifically addressed in the November 18 testimony, nor could they have been, since LILCO's own changes in Revisions 2 and 3 for the first time raised the concerns expressed in the Amended Testi-mony. Again, however, and despite the amendments necessary to reflect the changes in the LILCO proposals, it must be empha-sized that the thrust of the SCPD testimony has not changed.
As stated in the November 18 testimony, the SCPD witnesses find LILCO's traffic control plan to be unworkable and incapable of successful implementation.
The other instance of an amendment which may appear to be extensive in scope involves new Attachment 11 to the Amended Testimony. Attachment 11 presents data regarding proposed con-struction and road repair projects in Suffolk County during the
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next five years. The November 18 SCPD testimony discussed the impact of construction / repair work on traffic congestion and flow. See pages 69-70 of November 18 testimony. The factual data contained in Attachment 11, which provide additional de-tail on the subject, were unavailable to the County at the time the November 18 testimony was filed. Since these data now have became available and provide further information on a topic al-ready before the Board for consideration, it is appropriate to amend the testimony to present these data.
- 3. Typographical and other Minor Corrections Some minor amendments were made in order to correct non-substantive typographical errors or to make other minor changes in the November 18 testimony (e.g., addition of the word "LILCO" before the words " traffic guide (s)"). In addition, At-tachments 8 and 9, and the testimony at pages 66-67 of the November 18 testimony were amended in order to clarify and correct inadvertent errors in the original testimony. Attach-ment 8 previously listed one intersection (Rocky Point Road and Route 25) twice. This error was corrected and the number of reported accidents at the intersection was changed to reflect this correction. Similarly, Attachments 8 and 9 as filed on November 18 contained certain inconsistencies in the reported 17 -
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number of accidents for certain intersections listed in both Attachments. These inconsistencies were noticed after the tes-timony had been filed and were corrected in the Amended Testi-mony. This correction, in turn, required an amendment to the total number of intersections and reported accidents listed in Attachment 9 and the portion of the testimony text applicable to that Attachment. The County has made all of these correc-tions in the Amended SCPD Testimony rather than waste hearing time going through such corrections orally.
The County submits that the foregoing discussion establishes good cause for the filing at this time of the Amended SCPD Testimony.
II. Supplemental Picozzi Testimony The Supplemental Pigozzi Testimony addresses two studies (KLD TM-1391S/ and KLD TM-14011/) which were attached to the testimony submitted by Dr. Matthew Cordaro, et al. on November 18, 1983 on behalf of LILCO regarding Contention 65 (Evacuation 10/ " Development of Time Distributions for Evacuation Events and Activities," November 14, 1983.
--11/ " Determination Of Varying Route Compliance Levels and of a Proposed New Roadway on Evacuation Travel Times Within the Shoreham EPZ," November 16, 1983.
Time Estimates). The need for this supplemental testimony, and the justification for filing it at this time is clear.
Contentions 65.A and 65.B address the County's concern that LILCO has not adequately estimated mobilization times for the public, or the effect of extended mobilization times on overall evacuation times. In Contention 65.C.4, the County takes issue with LILCO's use of prescribed routes and the effect of non-compliance with those routes on evacuation times.
KLD TM-139 is directly related to Contentions 65.A and 65.B, and was cited in and attached to LILCO's own November 18 testi-mony on those Contentions. It provides an analysis by KLD of the time estimated for the pub 2ic to gather at home, wait for school children, prepare to leave and then load onto the evacu-ation network. Likewise, KLD TM-140 addresses the concern raised in Contention 65.C.4 by providing estimates of the effect of non-compliance with prescribed routes on evacuation time estimates. That study was also cited in and attached to LILCO's November 18 testimony.
The County was provided with neither of these analyses nor any draf ts thereof during discovery or at any time prior to
1 November 18, 1983. Consecuently, the County moved this Board on December 8, 1983 for, among other things, discovery on KLD TM-139 and KLD TM-140.12/ The Board granted that portion of the County's motion on December 23, 198313/ and on January 5, 1984, the County deposed Mr. Lieberman concerning the two studies.
The Supplemental Pigozzi Testimony attached hereto is nar- ,
rowly focused on KLD TM-139 and KLD TM-140 and is based upcn Professor Pigozzi's review of those analyses as well as the results of Mr. Lieberman's deposition. This testimony could not nave been submitted on November 18, 1983 b9cause, despite due diligence, the County was not aware of the contents of the two studies at issue prior to their appearance on November 18 in LILCO's testimony on Contention 65. Since the time of the '
Board's December 23, 1983 Order, the County has acted expedi-tiously to pursue the discovery permitt'ed by the Board and to prepare this Supplemental Testimony. Thus, the County has 12/ Suffolk County's Response To LILCO's Motion For Discovery and Response To Polk Testimony; or, in the Alternative, Suffolk County's Motion for Discovery and Response to Lieberman Testimony and to Revision 2 of the LILCO Plan, December 8, 1983.
13/ Order Granting in Part Suffolk County's Motion for Discov-ery and Response to Lieberman Testimony and to Revision 2 of the LILCO Plan (December 23, 1983).
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demonstrated good cause for the Board to permit the filing of Professor Pigozzi's Supplemental Testimony at this time.
III. Supplemental School Administrators' Testimony The November 18 testimony of Messrs. Muto, Smith, Pe .
trilak, Jeffers, Rossi, and Campo addressed Contentions 25.C and 25.D. The testimony discussed the problem of role conflict among school personnel and school bus drivers, and its likely effect upon implementation of LILCO's proposed protective actions for school children contained in Revisions 0, 1 and 2 of the LILCO Plan. Each of those versions of the Plan proposed that in the event of "a Shoreham emergency, all schools (with the exception, under some circumstances, of the Shoreham-Wading River School District) would be expected to implement an early dismissal so children would be returned home and could, if nec-essary, shelter or evacuate with their parents. In their November 18 testimony, the School Administrator witnesses discussed the likelihood and effect of role conflict only in the context of the then current LILCO proposal that schools im-plement an early dismissa).
Revision 3 of the LILCO Plan, which the School Administra-tor witnesses received in early January, 1984, adds several new proposals concerning protective actions for school children.
The Plan now provides, for example, that if the public is advised to shelter, schools are expected to shelter their stu-dents. Similarly, if the public is ordered to evacuate, or to shelter and evacuate, schools are now expected to evacuate their students and relocate them to unidentified locations I
outside the EPZ. The Plan now also provides, for the first time, that schools located outside the EPZ, but having children who live inside the EPZ, are expected to retain those children at school after the end of the school day if protective actions are recommended for the public.
Clearly, the school administrator witnesses had not, and could not have addressed these new LILCO proposals in their November 18 testimony. They do so,in the Supplemental Testimo-ny which is attached. The Supplemental Testimony is limited in scope -- it addresses the impact of role conflict on the imple-mentability of the new LILCO proposals concerning the protection of school children. Thus, other than to address those facts that were not in existence as of November 18, the Supplemental School Administrators' Testimony does not expand the scope of the November 18 testimony by the School Adminis-trators. The County submits that it has shown good cause for the filing of the Supplemental School Administrators' Testimony at this time.
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IV. Conclusion For the foregoing reasons, the Board should grant Suffolk County leave to file the attached Supplemental and Amended Tes-timony.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Suffolk County Department of Law H. Lee Dennison Building Veterans Memorial Highway Hauppauge, New York 11788
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LawrenceCoeLanppdr Karla J. Letsche Michael S. Miller
! Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL CHRISTOPHER & PHILLIPS 1900 M Street, N.W.
Washington, D.C. 20036 Attorneys for Suffolk County Dated: January 16, 1984 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .gg y 7 Before the Atomic Safety and Licensing Board sI f .
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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) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County Motion for Leave To File Amended and Supplemental Testimony on Certain Group I Issues, with attached testimony submitted by Inspector Richard C. Roberts, et al., Bruce W. Pigozzi, Robert W. Petrilak, Leon J. Campo, and George J. Jeffers and Anthony R. Rossi have been served on the following by U.S. mail, first class, except where noted, this 16th day of January, 1984.
Supplemental testimony submitted by Nick J. Muto and J. Thomas Smith will be served later on January 16 or on January 17, 1984.
- James A. Laurenson, Chairman ** Ralph Shapiro, Esq.
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. Mr. Jay Dunkleberger General Counsel New York State Energy Office-Long Island Lighting Company Agency Building 2 250 Old Country Road Empire State Plaza Mineola, New York 11501 Albany, New York 12223
- By Hand
- By Federal Express
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Mr. Brian McCaffrey ** Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea 175 East Old Country Road 33 West Second Street Hicksville, New York 11801 Riverhead, New York 11901 Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition -
U.S. Nuclear Pegulatory Comm.
195 East Main Street Washington, D.C. 20555 Smithtown, New York 11787
- Hon. Peter Cohalan Marc W. Goldsmith Suffolk County Executive Energy Research Group, Inc. H. Lee Dennison Building 400-1 Totten Pond Road Veterans Memorial Highway Waltham, Massachusetts 02154 Hauppauge, New York 11788 MHB Technical Associates
- Eleanor L. Frucci, Esq.
1723 Hamilton Avenue Atomic Safety and Licensing Suite K Hoard Panel San Jose, California 95125 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Joel Blau, Esq.
New York Public Service Comm. Ezra I. Bialik, Esq.
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
- Martin Bradley Ashare, Esq.
Suffolk County Attorney Atomic Safety and Licensing H. Lee Dennison Building Appeal Board 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, Esc.
David A. Repka, Esc. ** Stewart M. Glass, Esq.
U.S. Nuclear Regulatory Commission Regional Counsel .
Washington, D.C. 20555 Federal Emergency Management Agency 26 Federal Plaza, Room 1349 New York, New York 10278 l
__________________j
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Stuart Diamond
- James B. Dougherty, Esq.
Environment / Energy Writer 3045 Porter Street, N.W.
NEWSDAY Washington, D.C. 20008 Long Island, New York 11747 Gerald C. Crotty Spence Perry, Esq.
, Counsel to the Governor Associate General Counsel Executive Chamber Federal. Emergency Management Age State Capital Washington, D.C. 20472 Albany, New York 12224 Ben Wiles, Esq. Mr. Jeff Smith Assistant Counsel to the Governor Shoreham Nuclear Power Station Executive Chamber P.O. Box 618 State Capital North Country Road Albany, New York 12224 Wading River, New York 11792
- Fabian Palomino, Esq.
Special Counsel to the Governor Executive Chamber Room 229 State Capitol Albany, New York 12224 nLF Jof E. Birkenheier .
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 DATED: January 16', 1984 e
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