ML20107E291

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Testimony of L Campo Re Lilco 850111 Proffered Evidence. Supporting Documentation Encl.Related Correspondence
ML20107E291
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 02/19/1985
From: Campo L
SUFFOLK COUNTY, NY
To:
Shared Package
ML20107E279 List:
References
OL-3, NUDOCS 8502250499
Download: ML20107E291 (17)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO'N'p-80CKETES USh8; e

Before the Atomic Safety and Licensing Bogrd FEB 22 n1 QS o>

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In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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~ dEeEyency Planning).

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(Shoreham Nuclear Power Station

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Unit 1)

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DIRECT TESTIMONY OF LEON CAMPO ON BEHALF OF SUFFOLK COUNTY REGARDING LILCO'S PROFFERED EVIDENCE OF JANUARY ll Q.

Please state your name, occupation, and professional background.

A.

My name is Leon Campo.

I am the Executive Assistant for j

Finance (Assi,stant Superintendent of Schools), East Meadow Union Free School District, Nassau County, Meu York.

I have been associated with the East Meadet. Union Free School District for approximately 10 years.

I hold the following educational degrees:

Master of Business Administration, Finance, June 1975, Adelphi Education, June 1972,

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University; Master of Science Degree, Education, Hofstra University; and a Bachelor of-Arts Degree, 1964, Adelphi University.

,0 What is the purpose of this testimony?

The purpose of this testimony is to express the position

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.of the East Meadow Union Free School District and to respond to

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LILCO's proffered evidence of January 11, 1985.

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6- 'J Are you familiar with the evidence proffered by LILCO?

Q.

I have reviewed LILCO's evidence, including the A.

Yes.

letter dated October 23, 1984 from Matthew C. Cordaro, Vice President, Long Island Lighting Company, to Frank M. Rasbury, Executive Director of the Nassau County Chapter of the American Among other things, the October 23 letter provides Red Cross.

'that Red Cross personnel will " direct evacuees (from the Nassau Coliseum] to congregate' care centers operated by the Red It is my understanding that the East Meadow Union Cross.

' Free School District is among the " congregate care centers" relied upon by the American Red Cross and LILCO for use as shelters during an emergency at Shoreh,am.

Q.

. When did you first learn about the Red Cross and LILCO proposal to use East Meadow Union Free School District buildings to shelter Shoreham evacuees?

I first became aware of the proposal by '.he Red Cross A.

and LILCO only recently,..following LILCO's proposal to use the

.Nassau Coliseum as a monitoring and decontamination center for i.

evacuees during an accident at Shoreham.

What'is the positio'n of the East Meadow Union-Free

-Q..

1 School District with respect to the evidence proffered by LILCO?.

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. Notwithstanding.the assertion of'the American Red Cross

-A.

and LILCO to_the contrary,'the East Meadow Union',ree' School F

District has not entered into any agreement with the Red Cross or-LILCO to provide lfacilitie's for sheltering 1evacueesiduring an l

iemergency;at the-Shoreham plant.

Any such agreement would'have t'

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to have been approved by the East Meadow Union Free School District Board of Education, upon the recommendation of the District Superintendent.

No such approval has been granted.

On 2

February 12, 1985, I wrote Frank M. Rasbury, Executive Director a

of the Nassau County Chapter of the American Red Cross, to inform him of this fact and to advise that there is therefore no basis for either the Red Cross or LILCO to assume that evacuees would be sheltered in our School District's buildings during an emergency at Shoreham.

A copy of my February 12 letter is Attachment 1 to this testimony.

In addition, on February 15, Dr. Howard M. Koenig, the District Superintendent of East Meadow School District, formally advised the Nuclear Regulatory Commission that notwithstanding there is no agree-the representations of the Red Cross and LILCO, ment between the East Meadow School District and the Red Cross or LILCO which permits the use of school facilities to shelter-evacuees in the event of a radiological emergency at Shoreham.

'Dr._Koenig's letter, which was expressly approved by the East Meadow Board of Education, is Attachment 2.to this testimony.

'Do you have any other concerns relating to LILCO's Q.

proffered evidence?

It appears that the Red Cross and LILCO have pro-A.

Yes.

posed using_the facilities of the East Meadow Union Free School

. District to shelter Shoreham evacuees based upon a 1978 agree-A copy of this agreement is Attachment 3 to this testimony, ment.

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s.

However, that agreement was limited to the use of School District buildings as shelters during natural disasters, and did not grant the Red Cross or LILCO permission to use such buildings as shelters pursuant to LILCO's proposed plan to deal with a radiological emergency at Shoreham.

In addition, the agreement has never been renewed or even discussed by the School Board, the District Superintendent or me since 1978, and, in my view, is not in effect To my knowledge, neither the Red Cross nor LILCO at this time.

has ever contacted the School Board or any School District official concerning their proposed use of the School District's buildings.

I am unable to understand how LILCO and the Red Cross Therefore, can presume that the buildings of the East Meadow Union Free School District would be available for their use during an emergency at Shoreham.

Given the complete lack of any attempt by LILCO or the Red Cross to contact the East Meadow School District concerning h ther their proposal to use School District property, I question w e available to them sufficient in fact, LILCO and the Red Cross have, All but a shelters for evacuees during a Shoreham emergency.

handful of the approximately 50 shelters or " congregate care r

build-centers" relied upon by LILCO and the Red Cross are school ings.b/

I have contacted officials and administrators for a A list of the facilities for which the Red Cross claims to have agreements for sheltering evacuees during an emergency 1/

It is my understanding is Attachment 4 to this testimony.

25, 1984 letter from that this list was attached to a JulyEven though I am named as a " con-the Red Cross to LILCO.

I first tact" person for the East Meadow School District,following LILCO's learned about this list only recently, (Footnote Continued on Next Page)

6 5-number of these schools and school districts and have learned that none has ever been contacted by LILCO or the Red Cross with respect to the use of school property to shelter evacuees during Moreover, without exception, the school a Shoreham emergency.

officials I have contacted informed me that any agreements they have entered into with the Red Cross do not mention, nor did they ever contemplate, a radiological emergency or the use of school buildings by LILCO or the Red Cross during a radiological emergency.1/

This is not surprising, since all the agreements relied upon by LILCO and the Red Cross pre-date the appearance of LILCO's --

or any -- proposed emergency plan for Shoreham, and clearly could (Footnote Continued From Previous Page) announcement that it intends to use the Nassau Coliseum to monitor and decontaminate evacuees.

I have since learned.that many other so-called " contact" people on the Red Cross' list are no longer even associated with their respective school districts.

In at least one case, the contact person has been deceased for four years.

In other cases, the contacts listed by the Red Cross have not been associated with their school districts for five years or more because, for example, of retirement.

I have personally reviewed the agreements which exist between 2/

the Red Cross and the approximately 50 shelters or " congregate care centers" which LILCO and the Red Cross claim would be used Most of these' agreements are to shelter Shoreham evacuees.

limited to natural disasters and none mentions Shoreham or a

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radiological omergency.

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e not have contemplated the use of school facilities for a Shoreham emergency pursuant to the plan first proposed by LILCO in 1983.

Thus, in the opinion of the school officials contacted by me, there are at this time no agreements between their schools and school districts and LILCO or the Red Cross to provide shelters to this testimony sets forth for Shoreham evacuees.

1!

a list of school officials and administrators contacted by me.

1985, I was advised by In addition,^on February 14, the District Superintendent of the East Meadow School District at a County-wide meeting of school district superintendents

that, the previous day, he had raised the issue of the LILCO and Red Cross proposal for using Nassau County school buildings to shelter evacuees during an emergency at Shoreham, and had dis-covered that none of the superintendents present at the meeting l

The super-had ever been contacted by LILCO or the Red Cross.

intendents,in attendance made clear that any agreements their schools had entered into with the Red Cross did not include use of school property by LILCO or the Red Cross during a Such a use of school property radiological emergency.at Shoreham.

won,d require the approval of the respective Boards of Educatio

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of the school districts, with the involvement of the district superintendents.

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The number of school officials and administrators conta by me was necessarily limited by the shortness of time between 3/

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 I am continuing my efforts to con-concerning this proposal.

tact officials and administrators at other school districts, s

entered into any agreement with LILCO or the Red Cross _ permit-but, at this rime, ting the use of school property to shelter Shoreham evacuees.

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7-What conclusions have you made from your conversations 1

Q.

r with other school officials?

LILCO and the Red Cross have no basis for their claim A.

that there exist agreements that provide assurance that there would be sufficient sheltering capacity for evacuees during a There is certainly no agree-radiological emergency at Shoreham.

ment between the East Meadow Union Free School District and.LILCO or-the Red Cross to provide such shelters, and based upon my con-I versations with other school officials and administrators, believe that is the case at many or all the other-schools and districts relied upon by LILCO and the Red Cross.

Does that conclude your testimony?

Q.

A.

Yes.

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CARMAN AVENUE, EAST MEADOW, NEW YORK 11554 516-794-7000 OFFICE OF THE SUPERINTENDENT OF SCHOOLS February 12, 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:

It has recently come to my attention that, in official testimony before the Nuclear Regulatory Commission, you outlined a relationship which requires East Meadow Union Free School District to offer our facilities to the Red Cross in the event of an accident of the Shoreham Nuclear Plant which necessitates evacuation of the population.

As I understand it, the basis of your claim is an agreement signed by East Meadow in 1978 which in the indicates our willingness to cooperate with the Red Cross i

event of a natural disaster,.

Please be advised that East Meadow School District is under no obligation, contractual or otherwise, for the use of our schools in the wake of a radiological accident at Shoreham.

The original agreement with the Red Cross specifically omits

" man-made" disasters including those of a radiological nature.

Prudence, if not respect for the agreement which you referenced before the NRC, should have compelled you to contact me before describing the relationship between the Red Cross and the East Meadow Union Free School District.

O There are numerous reasons which make our school system inappropriate for use in the event of a radiological emergency; I will not elaborate as you have expressed no direct

however, interest in these factors.

For your information, in East Meadow a proposal to consider participation in an emergency response plan for Shoreham would be subject to a f act-finding, discussion and decision-making process which involves the Superintendent of 1

Schools and the Board of Education.

is troublesome that you list me and Claude Stringham, It a custodian in one of our buildings, as " contact" persons Mr.

regarding use of our schools in the event of an emergency.

Stringham has no districtwide responsibility nor administrative Mr. Stringham has authority regarding use of our schools.

indicated to me that he possesses no knowledge of you or this Have you ever contacted me regarding emergency matter.

Have you contacted me for any reason?

My records preparedness?

reflect an absence of conversation or communication with you or In the event of a the American Red Cross on these matters.

in the absence of contact between the Red Cross natural-disaster, I must question the readiness to respond and our school district, l

.to any emergency.

Upon telephoning a number of my colleagues in other it appears that you failed to specify that they school systems, to participate in a radiological have no contractual agreement emergency at Shoreham and that contact regarding this matter has never been initiated by the Red Cross.

You are requested to take immediate steps to modify your the reality of the

- testimony before the NRC to reflect relationship between the Red Cross and the East Meadow Union Free l'

School District.

Sincerely, I-f t'

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v' Leonf Campo #

Exec tive Assistant For Finance LJC:ms l

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ATTACHF.ENT 2

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CARMAN AVENUE, EAST MEADOW, NEW YORK 11554 516 794 7000 OFFICE OF THE SUPERINTENDENT OF SCHOOLS February 15, 1985 Mr. Morton B. Margulies Administrative Law Judge Atomic, Safety & Licensing Board Fanel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Margulies:

I have recently become aware of the fact that the American Red Cross and the Long Island Lighting Company have, in official testimony before the Nuclear Regulatory Commission, designated the facilities of East Meadow Union Free School District as a " congregate care center" in connection with the utility's evacuation plan for the Shoreham Nuclear Plant.

Apparently, the basis of this claim is an agreement signed by East i

Meadow in 1978 which indicates our willingness to cooperate with l

the Red Cross in the event of a natural disaster.

l Please be advised that the East Meadow School District is under no obligation, contractual or otherwise, for the use of our schools in the event of a radiological accident at Shereham.

Neither the Red Cross nor Lilco has contacted us regarding this matter and their presentation to the NRC is, therefore, a misrepresentation of the truth.

l 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 Lilco designed and Red Cross sponsored evacuation plan and has characterized Lilco's plan as illegal in that the Corporation astumes powers norcally reserved to gove rnment..

On-behalf of the East Meadow Board of Education, which I am advising you commenced this letter through official vote, that the facilities of East Meadow Schools will not be available to the American Red Cross or Lilco for implementing the Lilco evacuation plan and that we have not entered into any agreement for the use of our schools for purposes of monitoring,

. decontamination, or relocat on in the event of an emergency at i

Shoreham.

Si.erely, zMi N

3 Howard M. Koen Superintendent o 1s Long Island Lighting Company cc:

American Red Cross e

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ATTACHMENT 3 3

STATEMENT OF AGREEMENT CONCERNING THE USE OF FACILITIES AS MASS CARE SHELT5'.RS BY THE AMERICAN NATIONAL RED CROSS This agreement is made and entered into between the governing board of the East Meadow UFSD and the Nassau County chapter of,the American National Red Cross, here in after refer to as " Red Cross."

RECITALS Pursuant to the terms of Federal statues, the Red Cross provides emergency services on behalf of individuals and family victims of disaster.

East Meadow UFSD Board of Education

' is authorized to permit Red Cross to use buildings, grounds, and equipment for mass care shel-ters required in the conduct to Red Cross Disaster Relief activities and wishes to cooperate with the Red Cross for such purposes.

The parties here to mutually desire to reach an understanding that will result in making the aforesaid facilities of East Meadow UFSD available to the Red Cross for the aforesaid~use.

l Now therefore, it is mutually agreed between'the parties as follows:

l 1.

East Meadow UFSD Board of Education agree (stihat, it will permit, to the extent of its ability, and upon request by Red Cross, the use of its physical facilities by Red Cross as mass shel-ters for the victims of natural disasters.

2.

Red Cross agrees that it shall exercise reasonable care in the conduct of'its activities in such facilities and further agrees to replace or reimburse East Meadow UFSD for supplies that may be used by Red Cross in the' conduct of its relief activities in said mass, shelters.

In witness thereof the governing board of the East Meadow UFSD l

has caused this agreement to be executed by the Presidenf. of the i

Governing Board, and the Red Cross has caused this agreement to be executed by the Nassau County chapter said agreement to become effective and operative upon the fixing of the last signa-ture hereto.

Signature'to the agreement East Meadow UFSD American Red Cross Chapter

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' XDiastmaN Executive Di otor President of Board of Education Dale A. Edwards

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ATTACHMENT 4

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SAU COUNTY CHAPTER AMERICAN RED CROS$

3101TER INFORMATEN 1982 1983 264 OLD COUNTRY ROAD MINEOLA NY 1150I nor$txt f, CAPtCITT sheldon Fuchs Contaet 223J100 ext. 207/208 an14 win Publia Seboels 1973 31gh Seboel Drive SCO Baldwin New 1erk 1220 Mr. Ellinger BellserMierrick Central E.3. Dist.

623 8900 1976 1691 Meadowbreek Road 20cc Merrisk. N.Y.

11566 -

Gerse Beyh1 Carlo Flase Union Free school 334.1900 art. 224 1976 Carlo Flace. N.I.

11514 C2&ude Stringhan goo East Meadow Union Free school Dist.

Mr. Cas;n 754-7000 ext. 206 1978 Carman Ave.

500 East Meadow..New Tark 1159 Edward lattare i

East Rochammy Publia Schools 599-7589

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le78 East Roekaumy E.3.

Robert horse 1100 599 7589 Ceean Ave.

East Rockaway. N.T.

H518 33b.8020 East Winisten School District 1981 no E. Winisten Ave.

900 Esst Willistan. N.Y.

11596 354.4917 E2mont Publia schools

' 1978 Elmont Road 1400 Elment. N.Y.

11003 752.6512 Farmingdale Pubisa schools 249 7680 1975 Van Cott & Grant Ave.

1500 Farmingdale. N.Y.

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Mr. Russen y2mral Park.5enrose Union Free Sebl Dist.

352.0768 1981 1 FeFFy Flase I

4co F3aral Park. 3.T.

11001 George Reyrelds Franklin Square Union Free School Dist.

354 1045 1961 Vashington Street 600 Franklin Square, N.Y.

n010 Robert Swanssa Freepet Publia Schools 6232100 1976 235 North ooenn Ave.

2000 Freeprt. N.Y.

11520 Mr. Ioisisch Garden City Publis Schools 248 7700

-1980 Garden City, N.I.

1153o Anthony Pristials 1500 Glen Cove P011a Schools 671 3272 l

1978 1500 hieria lane Glen Cove. N.Y.

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contact: 741 7800 Eastiaks Publia schools l'

gd shelter Rosk Road 11040 isoo New Eyde Park, N.I.

j Fred DePa3aa Reviett'Eigh School 374 5200 i

i 1981 Gus Bruno,

60 Bearit Ave.

14o0 Eawlett, N.Y.

11537 Barry Richter l

Rowlett.Wedmare Union Free School Dist. 374 5200 azt. 213 l

1974 800 1 Johnson Place i

%edmare;,N.Y. 11598 733 2100 Hieksv111e Puhlia schools Kathleen Sogna 1975 j

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Division Ave.

Eisksville, N.Y.

11801 432.8933 f

1980 v.1..a Park Schools 431.8100 T.' =.4 Park, N.I.'

11558 400 Mr. Fred Neist Island Trees Un$an Free school Dist.

7%4010 1975 owl Flaea & Condor Road Stella Clark 1400 Levittaa, N.Y.

11756 731-7247 l

Bertaa Nrp 14wenee Jr. B.S.

295 2700 est. 283/253 1973 lawenee, N.Y.

300 James D30$snamel Incust Valley Central Scheel Richard Smith 11560 676=bb)0 1975 Iscust Valley, N.I.

14o0 Willian soldan lang Beach N.S.

8892410 1981 Lide Blvd. & A11evard street Larry Bourger 800 Iong Beach, N.Y.

88S.2167 Imuis Pearsall Lynnbmek Union Free school Dist.

I.T 3 4861 1974 1000 Wavely Ave.

East Rookaway, N.I.

11518 Fathe John Jobson l

1978 Massapequa Grace Episcopal Church 7 g n 22 100 4750 Marrisk Read Massapegua, N.Y.

11758

. William A. Eldard Massapequa R$sh school

$416600 1975 49 5 Merriak Road ty;o Massapegua, N.Y.

11358 I4wer.ee Chapaan s

.Malverne U.F.3.D.

887 7733 193o Wedfis1d Road 300 Reakville Centre, N.T.

11570 Dr. Owen till raahasset Publie schools 627M 00 Donald Gaute

'1975 Memorial Flaos Dr. A 00 30o hanhasset, N.Y.

11030 627 G

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Contact:

F.ayor Smith l

g976 Mhm2a Tawn Ball

$72232 l

1cd' Jessho Turnpiko Miam3a,N.Y. 215E l ',

$7 6700 Miam3a % don Free sehool Dist.

3973 2M bry*Esad 1600 Mines 2a, E.T.

31501 1

997J700 1981*

Nassau Osunty B.C.C.E.s.

Salisbury Canter 1cco Valentines Rd. & The min ad.

4 l

Westbury, N.Y.

uS90 SS' 9900 se. Baumore U.F.3.D.

1975 2616 xartin Ave.

1600 No. Sensore, N.I.

u710 379.A070 North Merrick U.F.5.D.

Id 1775 Old Mill Road Y

No. Merisk N.Y.

n566 671 5500

'1980 North Shore Sebools 300 sea cliff, N.Y.

678.1200 Cesanside Marie Ave. School 1982 Marie Ave.

500 Oceanside N.Y.

11572 922 3170 1978 Oyster Bay East Morwich School Dist.

1200 Cyster Bay, M.I.

11771 Norman Black minedge Publia Sobels 735J100 art.'%

1981 Hickville Road 1600 Bethpage, N.Y.

11714 938 38600 minview 01d Bethpage Central School 1978 minview, N.Y.

11803 l

Soo Harold Champel Port Washington U.F.3.D.

886.2517 l

1978 l

2100 27 Iangview Road Francis Ianta Port Washington, N.T.

2 050 B8 9 000 l

378 7301 1

l 1978 Roosevelt Publia Sebools 100 288 Nassau Road Roosevelt. N.Y.

621.J+900 l

1981 Reslyn Publia Schools l

1800 1eenst Iane Roslyn New Isrk' l

rat.her Harrer

  • 1981 St.' Isnatteus Restory 931 0056 300 129 Broaduny l

Misksville, N.T.

11801 l

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Edward Voorhees

.y Seaford Union Free School Dist.

CA 1.0700

  • 970 1

l 1600.

2147 Jaakm n Avo.

seafard,N.Y. 11783 N

seanhaha Central I.S. Dist.

1978 555 midse aA 5o0 sament,n.r. 11003 Joseph Singleton l

1975' Spseet Central Solnol Dist.

921 5500 Fell Iane 500 Sp sset, N.Y.

11791 485.%Cb Undondale Publia Sahools 1978 Goodriah Street 2300 Un$sadale,N.Y. 11553 Rey. George Czar United Methodist Charek 485 6363

1 40 Washington Street.

1 Neapstead, N.Y.

11550 George tilton 1978 United Methodist Church WE 2.A>5

100 ist amaduny IS 2.2977 sethpaso M.T.

11714 eas.ap5 1975 Vaney stream U.F.s.D.

600 corona Ave.

Valley Stream, N.Y.

11580 Dos cierse 1900 Valley stream U.F.3.D. f30 4653Wp Valley Stream, N.T.

21580 Elwood Webster.

Westbury U.r.3.D.

876.2016 Jerisho Tphs. & Hitchasek Lane Westbury, M.T.

11590 Barry Natow West Banpstead U.F.3.D.

449 841$

1975 450 Nassau Blvd.

1200 W. Bempstead, N.Y.

11552 Arcnzu n f!3Ar.sx2 516 876 3146 Sus lt VESTRURY CAMPUS

  • 16 4 $$9

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ATTACHMENT 5 s-NASSAU COUNTY SCHOOL OFFICIALS AND ADMINISTRATORS CONTACTED Person Contacted School Bellmore-Merrick Central George W. Littman, III .High School District Assistant Superintendent for Business Carle Place Union Free School Donald F. Connor Assistant Superintendent for Business East Rockaway Public Schools Ed Vorhees Business Administrator Elmont Public Schools Thomas Galante Business Manager Garden City Public Schools Robert J. Dema Assistant Superintendent for Business Herricks Public Schools Haskell E. Paige Assistant Superintendent for Business Hicksville Public Schools William H. Hall School Business Administrator North Bellmore Union Free Dominic Savino School District Business Manager Oceanside Merle Avenue -Herb Brown Business Administrator School R}}