ML20154B702
| ML20154B702 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/27/1988 |
| From: | Lengers M LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6234 OL-3, NUDOCS 8805170286 | |
| Download: ML20154B702 (13) | |
Text
N (o 2/3 Y V'
LILCO, April 27,1988
\\
00CKETE0 UNITED STATES OF AMERICA USHRC NUCLEAR REGULATORY COMMISSION
'88 gy -9 P8 57 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,
) (School Bus Driver Issue)
Unit 1)
)
LILCO'S ANSWER OPPOSING INTERVENORS' MOTION TO STRIKE LILCO'S TESTIMONY LILCO responds here to the "Government's Motion to Strike a Portion of LILCO's Testimony Regarding Contention 25.C," dated April 20,1988 (hereinaf ter "Motion").
The Intervenors move to strike one question and answer of LILCO's testimony:
Q.
Do you know anything about how schools are evacuated in the counties around the other nuclear power plants <
in New York?
A.
(Crocker) Yes, I abed one of thLCO's consultants, Mr. Richard Watts, to call all of the counties within the 10-mile EPZ's of the other nuclear power plants in New York State to find out how they evacuate schools in their EPZ's. The planners he talked with are from Monroe, Oswego, Orange, Putnam, Rockland, Wayne, and Westchester counties. Mr. Watts discovered that all counties evacuate schools in a single wave using both the school districts' regular school bus drivers and other available bus drivers from other bus companies that do not normally serve those schools. Mr. Watts also asked the counties if the additional "non-school" bus drivers were approved by the school districts. Ba-sically, they responded that they had never heard of any requirement that tne extra drivers needed the school districts' approval before driving during a ra-dialogical emergency.
Testimony of Crocker e_t al. on the Remanded Issue of "Role Conflict" of School Bus Drivms ("LILCO Testimony") at 58 (April 13,1988). The Intervenors claim that this testimony is irrelevant and unreliable. The Intervenors' arguments have all been made before and rejected by the Board. For the reasons stated below, the Intervenors' motion should be denied and LILCO's testimony should be admitted.
D 8805170286 880427 PDR ADOCK 05000322 G
I. LILCO's Testimony About School Evacuation Plans at Other Nuclear Power Plants is Relevant The Intervenors' first argument goes to relevance. The Intervenors object to the testimony quoted above, claiming that it is not relevant to the issue of "role conflict" of school bus d71 vers or to the "assessment of the adequacy of LILCO's new auxiliary school bus driver proposal." Motion at 2-3. They also argue that the Board is precluded from considering other plans by the Commission's new emergency planning rule that governs utility-only plans. Id. at 3.
The Intervenors' argument that what happens at other nuclear facilities is irrele-vant has been rejected repeatedly in this proceeding. _See_, e_.L. Memorandum and Order (Ruling on Governments' Motion to Strike Portions of LILCO's Testimony on the Sultability of Reception Centers) at 8 (May 7,1987); Memorandum and Order (Ruling on LILCO's !.iarch 18, 1987 Motion to Compel) slip-op. at 4 (Mar. 25,1987); Memorandum Memorializing Ruling on Motion to Compel Response to LILCO's Interrogatories and to Produce Documents (Mar. '17,1987); Memorandum and Order (Ruling on LILCO's Mo-tions to Compel New York State to Answer LILCO's First Set of Interrogatories and for a Protective Order) at 5-6 (Dec.19,1986); Order Granting LILCO's Motion to Compel Expedited Production of the New York State Emergency Preparedness Plan at 4 (Feb.
28,1984); Tr. 3697-98, 7890-92. In f act, the Board heard extensive testimony during the 1987 Reception Centers remand proceeding about the emergency plans for the counties surrounding other nuclear power plants in the State. See Tr.18,066 et sea. (Baranski, Czech, Papile); Tr. 18,417-18 (Keller); Tr. 18,454-460 (Husar, Keller).
In particular, the tastimony that the Intervenors seek to strike is relevant be-cause it refutes an argument they have made in their own testimony. The Intervenors claim that LILCO's plan is inadequate because LERO bus drivers have not been ap-proved by school districts. The LILCO testimony suggests that this alleged legal prob-lem is nonexistent, because it does not appear to exist at other nuclear plants in the same state.
e O The situation is reminiscent of the litigation over LILCO's reception centers, in I-l which the Intervenors at first claimed that there were various legal objections to LILCO's method of collecting contaminated washwater. They later withdrew their j;
claims in the face of evidence that the alleged legal problems were being asserted only with respect to Shoreham, Likewise, the Intervenors' reliance on the new NRC rule to support their motion i
to strike is misplaced. In their motion to strike the Intervenors only quote part of a sentence from the new rule (that part is hightlighted below) to support their claim that the rule prohibits comparisons with other plans. As the full passage from the rule shows, the Intervenors' characterization is incorrect:
The Commission, in its 1986 LILCO decision, stressed the need for flexibility in the evaluation of emergency plans. In 1
that decision, the Commission observed that it "might look fa-4 '
vorably" on a utility plan "if there was reasonable assurance j
that it was capable of achieving dose reductions in the event 2
of an accident that are generally is comparable to what might be accomplished with government cooperation." 24 NRC 22 j
- 30. We do not find that decision as requiring a finding of the ji precise dose reductions that would be accomplished either by 1
the utility's plan or by a hypothetical plan that Lad full state j
and local participation: such findings are never a require -
ment in the evaluation of emergency plans. The final rule
'l makes clear that every emergency plan is to be evaluated for adecuacy on its own merits, without reference to the specif-ict dose reductions which might be accomplished under the plan or to the capabilities of any other plan.
52 Fed. Reg. 42078, 42084 (Nov. 3,1987). The only issue addressed in this part of the new rule concerns whether a utility plan with f ull state and local participation snould l
be required to provide equivalent protection, that is, equivalent dose savings. It does l
not imply, as the Intervenors woJid have it, that procedures for implementing protec-l tive actions or measures in a utility plan cannot be compared to other plans in an effort l
to understand how acceptable emergency plans work. The Interrenors' argument is I
without merit.
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-i-II. LILCO's Testimony on How County's in New York State
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a4 e Evacuate Schools is Reliable Intervenors also argue that LILCO's testimony on how other EPZ counties evacu-ate schools is unreliable as "double hearsay."II Motion at 4. Intervenors' pleading does not tell the whole story.
The Intervenors' motion suggests that they are unable to conduct their own in-vestigation into the reliability of the data included in LILCO's testimony on the school evacuation plans for counties surrounding other nuclehr f acilities in the State. Howev-Wi. l.1 er, they have known for sometime that LILCO was collecting information on this sub-
, ject. In fact, LILCO promptly provided them with all the background material un-
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derlying the disputed testimony. Mr. Crocker told $2rvenorrpdurjghis depositipn..,
that one of LILCO's/do'nsultant.s Richar'd)$ hts"j as collecting data on how 'o rO c a.tb
- _-4 Q v t.
counties evacuate schools. Deposition transcript of Douglas M. Crocker (Feb. 2,1988) at 252-54. On March 22, LILCO provided the Intervenors with the written documenta-g 4the information collected by Mr. j'gus.g ThigdocumengQgluded} g y
and a final report. The letter transmitting the documents and'th&ddeuments thdb.d
.. 4) 2 41 y,.
we s%
selves are Attachment i to this pleading.rContrary to what the Intervenors want t,he Board to believe,U these documents list the names of the planners contacted and their y
This is not the first time the Intervenors have made this argument. For exam-ple,in 1984 they made the following argument:
The assertion (in LILCO's Testimony on Contentions 24.E.
24.F.2, 24.F.3, 24.M. 61.C and 68-71 (Schools)) that some unidentified school administrators made alleged determina-tions is double hearsay, based solely on an out-of-court writ-ten statement of an unidentified County employee, which purports to repeat out-of-court expressions of the opinions of unidentified school administrators. There is no basis for a finding that the statements by LILCO's witnesses are rell-able.
Suffolk County Motion to Strike Portions of LILCO's Group II-B Testimony at 19 (Mar.
28, 1984). This motion to strike was denied. Tr. 9145.
2/
In their motion to strike, Intervenors claim that Mr. Watts telephoned "unnamed
' and unidentified" planners for the counties surrounding the other nuclear f acilites. Mo-(footnote continued)
s.
positions with the counties surrounding the other nuclear facilities in the State. These two documents, in addition to conversations with Mr. Watts, form the basis for Mr.
Crocker's testimony. The Intervenors are plainly wrong that his testimony is based only on "a general and ambiguous summary of his recollection of what Mr. Watts told him."
Motion at 4.
Intervenors claim that the testimony should be stricken because Mr. Watts and the planners he contacted are not witnesses and are not subject to cross-examination.
Id. The Intervenors' position is incorrect for two reasons. First, hearsay is ordinarily admissable in administrative proceedings,E and has been admitted many times in this one. Tr.14,925 (Judge Laurenson). The County's objection goes to weight, not admissi-bility. The Board can decide to give the testimony little weight, if it wishes; but it should not exclude the testimony altogether.
Second, Mr. Crocker, who manages both the onsite and offsite emergency re-sponse organizations for LILCO, must be permthed to rely upon his staff and consul-tants to further.t.be operations he oversees. Thpis standard practice in NRC proceed-
. > c. ~
ings. It is Mt possible for Mr. Crocker personally to seek out all of the information he must rely upon to make decisions in his positYo as manager and to give testimony in this proceeding.
i (footnote continued) tion at 4. While it is true that LILCO did not identify the planners in its testimony, it did provide Suffolk County the names during discovery over a month ago.
3/
See Memorandum and Order (Ruling on Governments' Motion to Strike Portions of LILCO's Testimony on the Suitability of Reception Centers) at 8 (May 7, 1987)("Hearsay testimony is admissible in administrative proceedings where it is accompanied by sufficient indicia of reliability."); Philadelphia Electric Co. (Limmerick Generating Station, Units 1 and 2), ALAB-863,25 NRC 273,279 (1987); Cleveland Elec-i tric Illuminating Co. (Perry Nuclear Power Plants, Units 1 and 2),21 NRC 490,501 n. 61 (1985)("[T]he Commission's Rules of Practice do not prohibit the admission of hearsay evidence."); Duke Power Co. (Catawba Nuc! car Station, Units 1 and 2), ALAB-355, 4 NRC 397,411-12 (1976).
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Furthermore, the Intervenors have had this information for over a full month.
See Attachment 1. During that time, the Intervenors could have made their own inqui-ry into this matter and could have talked with the same people LILCO contacted. The Intervenors then could have presented their own testimony on the school evacuation plans of counties at other nuclear facilities in the State. The Intervenors chose not to do so.
LILCO's position is further supported by the Board's resolution of a similar dis-pute during the Reception Center remand proceeding. During that proceeding, LILCO presented evidence gathered by one of its consultants who was not a witness about the monitoring capabilities of counties surrounding other nuclear power plants in the State.
Since LILCO did not provide the Intervenors with the names of the county planners it had contacted, the Intervenors moved to compel the source of the data. See Suffolk County and State of New York Motien to Compel LILCO to Provide Sources of Data Rolled Upon in Test mony (April 13, 1987). When LILCO refused to provide the data, Suffolk County moved to strike the testimony. See Suffolk County, State of New Yo'rk and Town of Southampton Motion to Strike Portions of LILCO's Testimony on the Sultability of Reception Centers (April 20, 1987). The Board ruled on the Intervenors' motion to compel on April 30,1987 stating that LILCO should make available to the In-tervenors "the identitles of the individuals that furnished the data." Memorandum and Order (Ruling on County and State Motion to Compel, of April 13,1987) at 8 (April 30, 1987). The Board reasoned that "[t]he source of the data is critical to determining its reliability and validity.... If the testimony is to be part of the record Intervenors should be provided with the information as to who provided the data."3 Ld. at 6.
In 3/
The Board granted LILCO's request for a protective order ruling that there was "good cause for the entry of a protective order" due to the "acrimonious atmosphere" of the Shoreham litigation and because "(e]xtensive pressure has been brought upon indi-viduals, groups and organizations that cooperate and participate with LILCO in the emeregney plan. Participants have succumbed to such pressures to LILCO's detriment."
April 30 Memorandum and Order at 8. LILCO decided to withdraw the testimony rather than turn over the names of LILCO's contacts to the Intervenors.
ruling on the Intervenors' motion to strike, the Board decided that if LILCO produced the source of the data, the "Intervenors' cause for complaint" would be removed and that "(1]t should permit them 'the opportunity they desire to conduct an appropriate investigation of the basis of the (data) for effective cross-examiniation.'" Memoran-dum and Order (Ruling on Governments' Motion to Strike Portions of LILCO's Testimony on the Suitability of Reception Centers) at 8 (May 7,1987).
The Board's reasoning in the Reception Center remand proceeding is instructive here. During that proceeding, the Board found that the information would be admissi-ble if LILCO provided the Intervenors with the source of the data. Here, L!LCO pro-vided the Intervenors with the source of the data over a month ago. Therefore, they have the information they need "to conduct an appropriate investigation of the basis of the (data} for effective cross-examination." IA a,,
III. Conclusion
,For. the reasons cited above, the Intervenors' April 20,1987. motion to strike LILCO's testimony should be denied.
Respectfully submitted, 4('
Jatfes t'm'a
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MaPy-J ers Counsel for Long Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: April 27,1988
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...... 7278 BY TELECOPY Michael S.
Miller, Esq.
Kirkpatrick & Lockhart South Lobby - 9th Floor 1800 M Street, N.W.
Wa s hing ton,.. D. C.
20036-5891 I
School Bus Driver Discovery Dear Miket a....
, 'Not withstanding the fact that the enclosed information is s
protected by the attorney client privilege and the work product doctrine, I am providing you with Richard Watt's documentation of the data he collected about how counties evacuate schools at other nuclear power plants in New York State.
As you know, the data was collected by Mr. Watts at the direction of Doug Crocker and LILCO's attorneys in preparation of LILCO's case concerning "role conflict" of school bus drivers.
By providing the enclosed documents, LILCO does not waive its claim of privilege.
Sincerely y urs, Mary J Leugers MJL/dl
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Work Product Prepared in Anticipation ^* Litigatica SCHOOL BUS EVACUATION SURVEY REY. 1
~
County Evacuation Mode Source of Buses Equipment.
Training Contact Monroe Single Wave Webster S.D.
School district drivers Annual 2-hr class Jim Reinhold Nat'l School Bus (Contract) issued TLDs, dosimeters,
-on emergency (Monroe Ebelter Fairport S.D.
KI, seps at bus garage; worker aspects
& Evac Officer);
bus co. drivers pick up kits at assigned schools.
Ms. O' Dell Each bus has radio.
(Webster, S.D.
Transp. Dir)
(2/r+,OS) myno Single hve W yne Central S.D.
Drivers pick up kits Annual em rgency Thelma Wideman Marion S.D.
at schools; some buses worker training (Director, Wayne Williamson S.D.
have radios, others are Beerg Ngat Office)
Penfield S.D. (Alternate) escorted by police.
(2/25/88)
Oswego Single hve Oswego S.D.
Bus driver kit 'at bus Annual emergency Geo. Brower Mealco S.0.
garages, some buses
. orker training (Director, Oswego w
Golden Sun have radios others, (approa. 8 hrs)
Energ Meet Office)
Centro f
. assisted by; R.A.C.E.S.,
(2/29/88)
Gibson Bus Service 2
i Oswego Co. BOCES 2
Putnam Single hve Putnam Valley S.D.
Bus kits available at Annual emergency Mario Rampola Hudson Valley Bus Co.
bus co. or at bus worker training (Dep. Director Mahopac S.D.
garage.
(2-3 hours)
Putnam Co. CD)
Haldane S.D.
Buses have radio contact (3/9/88)
Garrison S.D.
to bus garages.
~ Orange Single hve West Point Tours Bus kits at bus co.
Annual emergency Phil Scheer Bosch Bus Co.
Buses have radios, worker training (Asst Dir, Orange Carroll Bus Co.
I provided by W. Point Ennerg Night Office);
tours & county (3/11/88)
Jerry Brisman (West Pt Tours) s
s v
Couacy Evacuation Mode Source of Buses Equipment Training Contact mockland Single usve School Districts Bus kits TLDs, Annual 4-br class Susan Ehstledge and other bus companies; dosimeters, KI, maps; on emergency isorker (Public Info coordinated through dept. kept at EOC.
aspects Coord-also does of public transportation.
j school plasming) l (2/17/98)
We:t-Single Wave School districts and Kits distributed at Annual 3-hr class Ed Nullett (Dir.
chester other bus companies; 5.D. garages emd bus on emergency worker of Co. Office of coordinated through Co.
companies. Some buses aspects Energency Services)
EOC; county does not have radios; those with-(2/17/98) check out bus drivers.
out travel with buses that do.
Use R.A.C.E.S.
William Murphy (Radiological i
Preparedness Coordinator)
(2/18/08)
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LILCO, April 27,1988 i~
COL KE if.D t
U5NPC
^
- 88 MAY -9 P8 :37 CERTIFICATE OF SERVICE OFFICE ZJ n*f o
00CKETOG A 'MVICI BRAHLH
?
O In the Matter of b
LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) i Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's ANSWER OPPOSING INTERVENROS' MO-TION TO STRIKE LILCO'S TESTIMONY were served this date upon the following by Federal Express as indicated by one asterisk, or by first-class mail, postage prepaid.
James P. Gleason, Chairman
- AdjudicLtory File Atomic Safety and Licensing Board Atomic Safety and Licensing 513 Gilmoure Drive Board Panel' Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D C. 20555-u Dr. Jerry R. Kline
- Atomic Safety and Licensing Richard G. Bachmann, Esq.
- Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission-
'" One White Flint North -
East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy.
Rockville, MD 20852 Bethesda, MD 20814 f
Herbert H. Brown, Esq.
- l Mr. Frederick J. Shon
- Lawrence Coe Lanpher, Esq.
1 Atomic Safety and Licensing Karla J. Letsche, Esq.
i Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.
4350 East-West Hwy.
Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Secretary of the Commission Richard J. Zahnleuter, Esq.
Attention Docketing and Service Special Counsel to the Governor Section Executive Chamtm U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W.
State Capitol Washington, D.C. 20555 Albany, New York 12224 l
Atomic Safety and Licensing Alfred L. Nardelli, Esq.
Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission 120 Broadway Washington, D.C. 20555 Room 3-118 New York, New York 10271
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LILCO, April 27,1988 l
00LKEiE0 USNRC 88 MY -9 P8 37 CERTIFICATE OF SERVICE OCbli 4G NI BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO's ANSWER OPPOSING INTERVENROS' MO-TION TO STRIKE LILCO'S TESTIMONY were served this date upon the following by Federal Express as indicated by one asterisk, or by first-class mail, postage prepaid.
James P. Gleason, Chairman
- Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission.
Washington, D.C. 20555-
~>
Dr. Jerry R. Kline
- Atomic Safety and Licensing Richard G. Bachmann, Esq.
- Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
" - One White Flint North u East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy.
Rockville, MD 20852 -
Bethesda, MD 20814 Herbert H. Brown, Esq.
- Mr. Frederick J. Shon
- Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.
4350 East-West Hwy.
Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Secretary of the Commission Richard J. Zahnleuter, Esq.
Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W.
State Capitol Washington, D.C. 20555 Albany, New York 12224 Atomic Safety and Licensing Alfred L. Nardelli, Esq.
Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission 120 Broadway Washington, D.C. 20555 Room 3-118 New York, New York 10271 y-r-
LILCO, April 27 1988 0
000KCIE0 USNRC
'88 my -9 P8 37 CERTIFICATE OF SERVICE OFFICE F f f
- An f 00CKEimG & SUtvlCL BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of ULCO's ANSWER OPPOSING INTERVENROS' MO-TION TO STRIKE LILCO'S TESTIMONY were served this date upon the following by Federal Express as indicated by one asterisk, or by first-class mall, postage prepaid.
James P. Gleason, Chairman
- Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and Licensing 513 Gilmoure Drive Board Panel' Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-H
++
Dr. Jerry R. Kline
- Atomic Safety and Licensing Richard G. Bachmann, Esq. *
"~
Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission '"
"" One White Flint North East-West Towers, Rm. 427 11555 Rockville Pike 4350 East-West Hwy.
Rockville, MD 20852 -
Bethesda, MD 20814 Herbert H. Brown, Esq.
- Mr. Frederick J. Shon
- Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
Board Kirkpatrick & Lockhart U.S. Nuclear Regulatory Commission South Lobby - 9th Floor East-West Towers, Rm. 430 1800 M Street, N.W.
4350 East-West Hwy.
Washington, D.C. 20036-5891 Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Secretary of the Commission Richard J. Zahnleuter, Esq.
Attention Docketing and Service Special Counsel to the Governor Section Executive Chamber U.S. Nuclear Regulatory Commission Room 229 1717 H Street, N.W.
State Capitol Washington, D.C. 20555 Albany, New York 12224 l
Atomic Safety and Licensing Alfred L. Nardelli, Esq.
Appeal Board Panel Assistant Attorney General l
U.S. Nuclear Regulatory Commission 120 Broadway l
Washington, D.C. 20555 Room 3-118 New York, New York 10271 l
l
s George W. Watson, Esq.
- Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.
Stephen B. Latham, Esq.
- Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NYo11792-s ~
+. +.. - + -
26 Federal Plaza New York, New York 10278
.c "i
.o-Jonathan D. Feinberg, Esq.4 New York State Department of Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 Add /
h Mary \\l.p Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: A pril 27,1988 I
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