ML20100L111
| ML20100L111 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/12/1985 |
| From: | Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-529 OL-3, NUDOCS 8504160379 | |
| Download: ML20100L111 (19) | |
Text
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April 12, 1985
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.o k: E,*T,ED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~35 ACR 15 A11:i9 Before the Atomic Safety and Licensing Board CFI C E Tr 'rcnE7/ : --
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In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket"No!"50232220L 3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
)
SUFFOLK COUNTY SUPPLEMENT TO DIRECT TESTIMONY OF LEON CAMPO REGARDING LILCO'S PROFFERED EVIDENCE OF JANUARY 11 On February 19, 1985, Suffolk County and the State of New York filed testimony, pursuant to the Board's January 28 Memorandum and Order Granting LILCO's Motion to Reopen Record, concerning LILCO's latest relocation center scheme. Such testimony included the Direct Testimony of Leon Campo on Behalf of Suffolk County Regarding LILCO's Proffered Evidence of January 11 (here-inafter " Campo Testimony"), which consisted of seven pages of testimony and five attachments. In his testimony Mr. Campo stated:
LILCO and the Red Cross have no basis for their claim that there exist agreements that provide assurance that there would be sufficient sheltering capacity for evacuees during a radiological emergency at Shoreham.
8504160379 850412 dh PDR ADOCK 05000322 G PDR
'*- There is certainly no agreement between the East Meadow Union Free School District and LILCO or the Red Cross to provide such shelters, and based on my conversations with other school officials and administrators, I be-lieve that is the case at many or all the other schools and districts relied upon by LILCO and the Red Cross.
Campo Testimony at 7.
Mr. Campo attached to his direct testimony a letter to Frank Rasbury (the Nassau County Red Cross Director whose representations concerning available school facilities are relied upon by LILCO) and one from the Superintendent of the East Meadow School District to Judge Margulies concerning the misrepresentations contained in LILCO's submitted evidence and the actual unavailability of East Meadow facilities. He also attached a list of certain Nassau County school officials and administrators whom Mr. Campo had personally contacted, none of whom had been contacted by LILCO or the Red Cross concerning the use of their school facilities during a Shoreham emergency, and none of whom had agreed to make their facilities available for LILCO's use. Mr. Campo also noted, however, the following:
The number of school officials and adminis-trators contacted by me was necessarily limited by the shortness of time between my learning of the LILCO and Red Cross proposal to use Nassau County school buildings to shelter evacuees during an emergency at Shoreham and the February 19 deadline for filing testimony concerning this proposal.
I am continuing my efforts to contact officials and administrators at other school districts, but, at this time, I am aware of no school or district which has entered into any agreement with LILCO or the Red Cross permitting the use of school property to shelter Shoreham evacuees.
Campo Testimony at 6, n.?.
- ] -
Since February 19, when Mr. Campo's testimony was filed, at least eight additional school districts, whose facilities were represented by LILCO's witnesses as being available for congregate care purposes in the event of a Shoreham emergency, have stated in writing that such representations are false. Attached hereto are copies of such statements. In addition, and also subsequent to February 19, the Superintendent of the East Meadow School District has written a further explanatory letter to Mr. Rasbury
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concerning the misrepresentations that have been made to this Board with respect to the purported " availability" of his school
' district's facilities. A copy of that letter is also attached hereto.
Suffolk County hereby supplements the attachments to the Campo Testimony with the attached letters. While it appears that all these documents have been sent to Judge Margulies personally, it is essential that they be made a part of the evidentiary record in this proceeding as well.
This Board cannot ignore the critical facts set forth in these documents. They make clear that the representations made by LILCO's witnesses, Mr. Rasbury and Ms. Robinson, concerning the alleged " availability" of school facilities and, even more significantly, the alleged " agreements" with school districts consenting to the use of their facilities to implement the LILCO Plan, are just plain false. In fact, as school district after school district has plainly stated, no such agreements exist and, indeed, contrary to LILCO's assertions, the facilities will not be made available for LILCO's use.
These documents directly challenge the veracity and credi-bility of LILCO's witnesses concerning relocation center issues.
In addition, they clearly reveal that LILCO's latest relocation center scheme, like each of its previous ones, cannot in fact be implemented. Accordingly, the attached documents should be in-cluded as attachments to the Campo Testimony and admitted into evidence with the other County and State testimony on LILCO's latest relocation center scheme.
Respectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 Y
/M Herb 6rf H. Brown N
j LawrenceCoeLanphfr Letsche Karla J.
KIRKPATRICK & LOCKHART 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County 4
April 12, 1985 l
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l Attachments I
Letter dated February 21, 1985 to Mr. Morton B.-Margulies !
from Garden City Public School.
Letter dated February 22, 1985 to Frank M. Rasbury from West Hempstead Union Free School District.
Letter dated February 20, 1985 to Mr. Morton B. Margulies from Oceanside Union Free School District.
Letter dated. February 26, 1985 to Mr. Morton B. Margulies from Lawrence Public Schools.
-- Letter dated April 1, 1985 to Mr. Morton B. Margulies from Laurence H. Johnson, Jr.
-- Letter dated March 7, 1985 to Mr. Frank M. Rasbury from Seaford Union Free School District.
--- Letter dated March 5, 1985 to Honorable Morton B. Margulies from North Merrick' Union Free School District.
-- Letter dated March 11, 1985 to Mr. Frank M. Rasbury from Farmingdale Public Schools.
Letter dated April 3, 1985 to Mr. Frank M. Rasbury from East Meadow Union Free School District.
4
1 Garden CityPublic Schools M CATHEDRAL AVENUE cARDEN CTTY. NEW YORK ltDe
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MCKETlhG & SElWici 8 RANCH February 21, 1985 SERVED FEB 271985 Mr. Morton B. Margulies Administrative Law Judge Atomic, Safety & Licensing Board Panel U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Judge Margulies:
I am surprised to learn that the American Red Cross and LILCO have designated the Garden City Schools as a relocation ceriter in the event of a radiological emergency at the Shoreham Nuclear Power Station. The Garden City School District has not entered into any agreement with the American . Red Cross-or LILCO to serve as a relocation center or as a decontamination and monitoring facility for a Shoreham emergency. Any such agreement would have to have been approved by the Garden City School District, and no such approval has been given.
Sincerel, yours.
. .i f U.hJ Robert M. G rdner Superintendent of Schools pgs
, WEST HEMPSTEAD UNION FREE SCHOOL DISTRICT 1 ADMINISTRATIVE OFFICES 252 Chestnut Street ,gk LSh ,C West Hernpstead, New York 11552
. '85 FEB 27 A10 03 DOCKET NUMBER
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5#5",tyt[,c,',se cots GCMETikG yg m . nun February 22, 1985BAAN Frank M. Rasbury N Executive Director of Nassau County .. .. N g g g O Chapter of the American Red Cross 2% Old Country Road Mineola, NY 11501
Dear Mr. Rasbury:
I have recently become aware that the American Red Cross.and the Long Island Lighting Company have designated West Hempstead High School as a relocation center in the event of a radiological emergency at the Shoreham Nuclear Power Station.
Please be advised that the West Hempstead Union Free School District has not entered into any agreement with the American Red Cross or LILCO to serve as a relocation center, or as a decontamination and monitoring facility, for a Shoreham emergency. Any such agreement would have to have been approved by the West Hempstead Union Free School District, and no such approval has been granted. West Hempstead has permitted the American Red Cross to list West Hempstead High School as a mass care shelter, but that listing does not grant the American Red Cross or LlLCO permission to use our high school as a relocation center, or as 4. decontamination and monitoring-facility, pursuant to LILCO's proposed plan to deal with a radiological emergency at Sho reham. '
in addition, the Governor of the State of New York has determined that the State of New York will not participate in the implementation of the offsite radio-logical emergency response plan for Shoreham proposed by LILCO. In accordance with the Governor's position, West Hempstead High School will not be available to the American Red Cross or LILCO for use in implementing the LILCO plan.
Consequently, as Superintendent of Schools and Chief Executive Officer of the West Hempstead Union Free School District, I am advising you that we have not entered into any agreement to serve as a relocation center, or as a decontamination and monitoring facility, in the event of a radiological emergency at Shoreham.
Sincerely,
/ . -- .
" Richard L. Varriale Superintendent of Schools cc: Morton B. Margulies, Adm. Law Judge Atomic, Safety t, Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Oceansi e Wnton 9 tee ScRooWistrict :.
ADMINISTIT ATlON CFFICE SOCK IEI 145 M ERI.E AVENU E. OCE AN51D E. N. Y.18 572 515 OR 81200 115 FEB 27 NO 03 erries or twa socKrT MUMBER f~)
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February 20, 1985 3 ,
I Mr. Morton B. Margulies . ...,. SERVED FEB 2y 1985 7dninistrative Law Judge Atcraic, Safety & Licensing Board Panel U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555
Dear Mr. Margulies:
This is to inform you that, as executive officer of the Oceanside Public Schools, I have not had the w g tunity to discuss with, nor gain
. approval frcrn, the Board of Education regarding the matter of " congregate care centers" for evacuation in a shoreham nuclear plant emergency.
Accordingly, please be advised that there is no agrement be-tween the Oceanside Schools, the American Red Cross, or Lilco on this Iratter.
Should either of the two organizations wish to cantact us regarding this topic,we shall be pleased to discuss it with them.
Sincerely,T
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g\ k 'e-VAL:dn Victor A. Leccese Superintendent of Schools
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'.;awrence Public Schools dwin J. Baron 3
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'h j9:44 s.., :.: e Mr. Norton B. Margulies c/, -y, "c. :
Administrative Law Judge . . .
Atomic, Safety & Licensing Board Panel #M'
U.S. Nuclear Regulatory Cormiission Washington, D.C. 20555 SERyg g g
Dear Mr. Margulies:
I have.recently become aware that the American Red Cross and the Long Island Lighting Company have designated the campus of the Lawrence Junior High School as a relocation center in the event of a radiological emergency at the Shoreham Nuclear Power Station.
Please be advised that the Lawrence Public Schools have not entered into any agreement with the American Red Cross or LILCO to serve as a relocation center, or as a decontamination and monitoring facility, for a Shoreham emergency. Any such agreement would have to have been approved by us, and no such approval has been granted. The Lawrence School District has entered into an agreement with the American Red. Cross concerning the use of the district schools as mass care shelters, but that agreement does not grant the American Red Cross or LILCO perriission to use our campuses as relocation centers, or as decontamination and monitoring facilities, pursuant to LILCO's proposed plan to deal with a radiological emergency at Shoreham.
In addition, the Governor of the State of New York has determined that the State of New York will not participate in the implementation of the off-site radiological emergency response plan for Shoreha= proposed by LILCO. In accordance with the Governor's position, the campuses of the Lawrence Public Schools will not be available to the American Red Cross or LILCO for use in implementing the LILCO Plan.
As Superintendent of the Lawrence Public Schools, I am advising
. you that we have not entered into any agreement to serve as a r'elocation center, or as a decontamination and monitoring facility, in the event of a radiological emergency at Shorehati.
Very truly " urs, Alvin J. faron Superintendent AJB:JB c.c. Members of the Board of Education .,,s Mr. Carson i
NORTH BELLMORE" ""E UNION FREE SCHOOL DISTRICT 2616 MAATIN AVENUE NORTH BELLMORE. NEW YORX 11710 ,_,
(516) 221 2200 }* ~,g ,} '-
BoAAD OF EDUCATION BOAAD OFFICERS ADMINISTFiATION JAMES D AOC' EY Presicent WILLIAM ENGLANDER $nss- - 9 P 3 :26 LAUAENCE 1 JOHNSON. JR JOSEDMNE o GAOEN Vice presicent STEPHEN KOSHEAS. Treasurer SuDehntencent of Schools v4NCENT MAIELI MORTIMER DEARLSToNE. Distnct Cler" ANITA W 8AEY Cr AALES n AEINH AADT ( 42 .<t , Director of Special Services inM A KASS CU .' r'.C !, 'p i $ b i - DOMINIC J SAVINo D
Business Manager SERVED APR 91985 April 1, 1985 Mr. Morton B. Margulies Administrative Law Judge Atomic, Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Sir:
Please be advised that in the event of a radiological accident at the Shoreham Nuclear Plant, the North Bellmore Union Free School District.would not make its facilities available as part of a LILCO plan of evacuation.
Many years ago, our district agreed to cooperate in the event of natural disasters. However, we do not consider a Shoreham emergency to be a " natural" disaster; therefore, we would not participate in any evacuation plan that involved the use of our school property.
Sincerely yourse.
, m: ; .
.. . / ' . , sv: "r Laurence H. Johnson, Jr.
Superintendent of Schools LHJ:eh cc: Bd. of Ed.
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((-'d PR00. Si ImL GC... 2 i SEAFORD UNION FREE SCHOOL DISTRICT CENTR AL ADMINISTR ATIO N O FFICES ' ." .... i,. E -
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1600 WASHINGTON AVENUE SEAFORD. NEW YORK-11783 DWAYNE C. POLL, Ed.D.
suernenvrNotNT or scMoot.s t' :: . :.
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!.tasch 7, 1985 SEMED MR 9%
Mt. Frank !.1. Rasbuty, Execu.tive Direc.tcr l Nassau Ccunta Chaptet of the American Red Cross l 264 Old Ccunttu Read j
!.linccla, NY 11501 l Dext !f:. Ra.sbu1y:
Recenttu I teceived a copy of ucar Jala 25, 1984, lettet to !.Lu. Elainc C. Robistson of die Long Island Ligitting Ccmpanu. In dat lettet uca cut-lined an agtcement be,tecen the Nassau County Chaptch of the American Red C css and Lilco lot the u.se of certain public schect buildinas in Nassau CcuMy a.s evacuation centets in case of an emetgency M die S!1creham Nucleat Pcteet Station.
Fatthetmcre, in tl tat lettet aca indicate to Lilcc .that the.1e is in existence an agreement betecen the Nassau CcuMu Chaptet of die American Red C css and the .schocLs cf the Scaford Urtion Free Scheel District to use cut facilitics fot sheltet daring an cmetgency. Titis ccmed uns m.ade based cn a sheltet information Lbting in 1982-83 tehich acu attached tc ucur lettet tc.
!.lts. Rcbinsen.
At the time of 6 tat 1982-83 agteerent, tite Scafo d Public Schcols teete not infc med tha.t ycu teculd wish to u.se out facilities in case of a nucleat accident. Plcase be advised dat cu,1 Sca. d of Education takes exceptica tc ucu.t tcttet to Mrs. Robinson in uc st,tongest cessible tetms. Unless uou a.te first teilling to apply to cat 5011d of Education in tetiting for ute u.se of cut facilities during a nuclear evacuaticn and have their acceptance re-sportse 131 letiting on file in ucur cffice, die disttict teill not petmit die use of cur faciitties a.s patt of die Sitarcham evacuation plan.
k'e a,te completely ama:ed that you teould attempt to take the kind cf uniLMetal action that has been exitibited bu the ccuttents cf acut lettet to Litcc.
The lettet certainly dces nodzing to maintain cccpetative tetMicas betecen the Ametican Red Ctoss and the Scafcrd Public Schects. I ttast diat aca teilt respond in ec11 tina teldt a reques.t for t.he u.se of cu.1 bu.ildings if ucu feel
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this is essentiat to die implementaticn cf the Shareham evacuation plan.
Vety ttaly yours,
/km Ck Dhuune C. Poll Superintendent of Schools DCP:8G
/
cc to Morton !L au.lis, Administrative Leae Judae, Atenic Salcty and Licensing
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Bea. d Pancl, U.S. Nucleat Regulatcru Cemmission, k'asizingten, D.C.
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20555
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[UF M ?C XORTH MERRICI UNION FREE SCHOOL DIST.8tCT
-. . . - . - - . . . _ . - . - . . . - . - - .. .2.
(J;)/ 1775 OLD MILL ROAD
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MERRICK, N.Y.11566 soARo oF EDUCADoN
'85 AP -9 P3:296)379-4070 vincent J Parades.
3 Margare, R tasan. March 5, g. pE.g g.A,J v.e, .
No,e.n s.u.o Honorable Morton B. Margulies
[*,','J,' ^ j7 Administrative Law Judge SED APR gggp sonni. siaaion Atomic, Safety & Lincensing Board Panel Pas A stemno U.S. Nuclear Regulatory Commission sun. N in,,n.Ea o Washington, D.C. 20555 s w.ai.,o.e. scnoo,.
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Dear Honorable Margulies:
T,.u .,
Ter.ac. EI Smowv. Eso I recently became aware that in official testimony C="" before the Nuclear Regulatory Commission, LILCO and the rien E,nnom Nassau Chapter of the American Red Cross have committed Da c*a the North Merrick school facilities, along with 52 other school districts in Nassau County, to a LILCO plan of evacuation in the event of a radiological accident at the Shoreham Nuclear Plant.
The North Merrick School District has not been contacted regarding this matter by either the Red Cross or LILCO.
Please be advised that the North Merrick Union Free School District has not entered into any agreement with the American Red Cross or LILCO to serve as a relocation center, or as a decontamination and monitoring facility for a Shoreham emergency. Any such agreement would have
.to have been approved by the North Merrick Board of Ed-ucation, and no such approval has been granted.
The North Merrick School District did agree to allow the American Red Cross to use school district facilities for a mass care shelter in the event of a natural disaster, but that agreement does not grant the American Red Cross or LILCO permission to use our facilities as a relocation center, or as a decontamination and monitoring facility, pursuant to LILCO's proposed plan to deal with a radio-logical emergency at Shoreham.
- I am appalled and outraged at the misrepresentation of the Red Cross and LILCO.
S cerely, .
24/>24J -
June N. Irv n, Ed.D.
JNI:ce Superintendent of Schools
+ 00 BET NU5Est - 4-[
PR30. & 11T1L FAC __
FARMINGDALE PUBLIC SCHO.OLS Van Cott and Grant Avenues, Farmingdale, .11735 t ot
- 1516,) 752.S!y 0r 3 26 Office of the Superintend o3 .
FRED BROCKMANN Sup:rintencent of Schools c~ .: . :.. -
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March 11, 1985 Mr. Frank M. Rasbury Executive Director Nassau County Chapter A=erican Red Cross 264 Old County Road Mineola, NY 11501
Dear Mr. Rasbury:
The Farmingdale Board of Education has directed me to communicate our distress to you about the American Red Cross' involvement of the Farmingdale Public Schools in the LILCO plan for evacuation in the event of a radiological accident at the Shoreham Nuclear Plant.
We wish to ~ go on record that we are not participants in this program. I am seriously concerned with the fact that earlier communications from your organization to the Farmingdale Public Schools made absolutely no mention of this new dimension to your needs or plans in this regard.
A letter of October 19, 1984, from Mr. Paul Foley, indicated "Your school could be called on at any time to shelter people during a diaster. The hurricane season is now upon us, so we take this opportunity to ask you to inform your staff, of our disaster shelter program." Your letter implies' that you would like to " update your records" and although we nave done that in good faith, we do not feel this obligates us at all to the LILCO program.
We are seriously concerned about information that we have received that emergency centers in the local plan would carry on decontamination activities.
Please be advised , therefore, that the Farmingdale Public School District has not entered into any agreement with you or LILCO to serve as a relocation center or as a decontamination and monitoring facility for Shoreman emergency. Any such agreement would have to be approved by the Farmingdale Board of Education, and no such approval has been granted.
Mr. Frtnk M.'Rnsbury March 11, 1985 We have entered into an agreement with you to serve as a mass-care shelter, but that permission agreement does not grant the American Red Cross or LILCO to use our buildings as a relocation center, or as a decontamination or monitoring facility, pursuant to LILCO's proposed plan to deal with a radiological emergency at Shoreham.
Sincerely yours,
-2:=-
Fred Brockmann Superintendent of Schools
/dm cc: Board of Education Morton Margulies .
Administrative Law Judge U.S. Nuclear Regulatory Coc: mission [.~
W. Howa rd M. Koenig Superintendent of Schools ,
e East Meadow U.F.S.D.
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~ CARMAN AVENUE, EAST MEADOW, NEW YORK 11554 i
516 794 7000 1
OFFICE OF THE SUPERINTENDENT OF SCHOOLS April 3, 1985 Mr. Frank M. Rasbury, Executive Director Nassau County Chapter of the American Red Cross '
264 Old Country Road Mineola, New York 11501
Dear Mr. Rasbury:
In your letter of March 11, 1985 you " clarified" the basis of your testimony before the Nuclear Regulatory Commission with respect to the participation of local school districts in an evacuation plan developed, sponsored and implemented by the Lilco Corporation.
Unfortunately, your letter failed to address many of the substan-tive issues which Leon Campo, Executive Assistant for Finance, raised in his letter to you of February 12, 1985.
First of all, your failure to contact school districts with regard to your testimony is inexcusable. School Boards, under the law, not the Red Cross, possess not only the authority, but the respon-sibility to determine whether or not the public buildings in their charge are to be used as " congregate care centers" during a radio-logical emergency. Your testimony before the Nuclear Regulatory Commission specifically implied that school buildings would be available for such purposes and you submitted letters of agreement to substantiate this claim.
While your recent letter indicates that your total testimony simply represents your " opinion," this point was obscured by your testimony and that_of Lilco which causes reasonable people to con-clude that the Red Cross has pledged, by a contract with Lilco, to
~
provide congregate care centers through the use of the public schools of Nassau County.
Specifically, question 24 which was directed to you,as well as other representatives of the Lilco Corporation, asked if a "means of relocation would be provided for evacuees from an emergency at Shoreham?" Your response, in conjunction with that of Lilco rep-resentatives, was "yes, relocation centers will be available for those who require shelter should there be an emergency at Shoreham." On that matter of fact, as your testimony related to the use of Nassau County school buildings, I believe your testi-mony was not true.
- Mr. Frank M. Rasbury 4-3-85 Furthermore , your references to " emotionalism" and " politics ,"
are totally irrelevant to the issues at hand. You have ignored the fact that Lilco's evacuation program, as it has been presented to the Nuclear Regulatory Commission, is illegal in the-State of New York. Certainly,public schools and the Red Cross, in my opinion, may not participate in a program which contradicts the law.
Finally, you did not tell the Nuclear Regulatory Commission that you haven't had contacts with school districts in Nassau County for many years regarding emergency planning for natural disasters
'and have had absolutely no contact with these school systems re-garding a radiological emergency at Shoreham. It is rather impru-dent for the Red Cross, working in coniunction with Lilco, to pre-sent a program that is untrue regarding use of public school buildings. At the same time, you failed to notify our schools of your intent or your testimony.
Once again, on behalf of East Meadow Schools, I would ask that you remedy your testimony before the Nuclear Regulatory Commission as it relates to public school buildings in Nassau County and, more specifically, as it pertains to the use of East Meadow Schools in any radiological emergency evacuation program.
Sinc rely,
% d4 Howard M. Koenig, .
Superintendent of Schools HMK:mes cc: Morton B. Margulies,. Administrative Law Judge
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WiLATED UNITED STATES OF AMERICA CX"ETED NUCLEAR REGULATORY COMMISSION USRC Before the Atomic Safety and Licensing Boar 4 e5 /52 15 A11:19
) L U ICE Tr :E v<t T;.6
'In the Matter of ) 00CdEIN 4 SE6VfCf'
) BANCH 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 SUPPLEMENT TO DIRECT TESTIMONY OF LEON CAMPO REGARDING LILCO'S PROFFERED EVIDENCE OF JANUARY ll, dated April 12, 1985, have been served on the following this 12th day of April, 1985 by U.S. mail, first class.
- Morton B. Margulies, Chairman
- Edwin J . Reis, Esq.
Atomic Safety and Licensing Board Bernard M. Bordenick, Esq.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Com.
Washington, D.C. 20555 Washington, D.C. 20555
- Dr. Jerry R. Kline **W. Taylor Reveley, III,'Esq.
Administrative Judge 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
- Mr. Frederick J. Shon Ms. Donna D. Duer Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 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
a 0
Spence Perry, Esq. Stephen B. Latham, Esq.
Associate General Counsel Twomey, Latham & Shea Federal Emergency Management Agency P.O. Box 398 Washington, D.C. 20472 33 West Second Street Riverhead, New York 11901 Mr. L. F. Britt Long Island Lighting Company Ms. Nora Bredes Shoreham Nuclear Power Station Executive Director P.O. Box 628 Shoreham Opponents Coalition North Country Road 195 Ea'st Main Street Wading River, New York 11792 Smithtown, New York 11787 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 F. Cohalan Suffolk County Executive Martin Bradley Ashare, Esq. H. Lee Dennison Building Suffolk County Attorney Veterans Memorial Highway H. Lee Dennison Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Fabian Palomino, Esq.
Special Counsel to the Atomic Safety and Licensing Board Governor Panel Executive Chamber U.S. Nuclear Regulatory Commission Room 229 Washington, D.C. 20555 State Capitol Albany, New York 12224 Docketing and Service Section Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board 1717 H Street, N.W. U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 James B. Dougherty, Esq.
3045 Porter Street, N.W. Jonathan D. Feinberg, Esq.
Washington, D.C. 20008 Staff Counsel New York State Public Mr. Stuart Diamond Service Commission Business / Financial 3 Rockefeller Plaza NEW YORK TIMES Albany, New York 12223 229 W. 43rd Street New York, New York 10036 me n
r: ,
e' Stewart M. Glass, Esq.
Regional Counsel Federal Emergency Management Agency .
26 Federal Plaza, Room 1349 New York, New York 10278 Mary Gundrum,-Esq.
New York State Department of Law 2 World Trade Center, Room 4614 New York, New York 10047
/ 1is RARLA J. LETS KIRKPATRICK LOCKHART 1900 M Stree , N.W., Suite 800 Washington, D.C. 20036 DATE: April 12, 1985
- By Hand
- By Federal Express i
1