ML20204B832
| ML20204B832 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/19/1987 |
| From: | Donegan D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2896 OL-5, NUDOCS 8703250159 | |
| Download: ML20204B832 (22) | |
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DOCKETED USNRC UNITED STATES OF AMERICA i
1 NUCLEAR REGULATORY COMMISSION m D R2i32 OFFICE OF IEP'I Y Before the Atomic Safety and Licensing BoardOCMEigfL M E In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-0L-5
) (EP Exercise)
(Shoreham Nuclear Power Station )
Unit 1) )
LILCO'S MOTION TO STRIKE PORTIONS OF THE TESTIMONY OF DAVID HARRIS AND MARTIN MAYER CONCERNING CONTENTION EX 47 (REGISTRATION, MONITORING, AND DECONTAMINATION OF SPECIAL FACILITY EVACUEES) AND CONTENTIONS EX 22.A AND 49 (MONITORING AT THE NASSAU COLISEUM)
Long Island Lighting Company ("LILCO") hereby moves to strike portions of the direct testimony of David Harris and Martin Mayer on behalf of Suffolk County regard-ing Contention EX 47, dealing with registration, monitoring, and decontamination of special facility evacuees, and regarding Contentions EX 22.A and EX 49, dealing with monitoring at Nassau Coliseum. (" Harris and Mayer Testimony"). The reasons why spe-cific portions of the testimony must be struck are set forth below.
I. CERTAIN PORTIONS OF THE HARRIS AND MAYER TESTIMONY ARE OUTSIDE THE SCOPE OF THE CONTENTION Pursuant to Section 2.743(c) of the NRC's Rules of Practice, LILCO moves to strike certain portions of the Harris and Mayer Testimony on the ground that it is not relevant to the issues in contention. Irrelevant testimony is the proper subject of a motion to strike.10 C.F.R. Part 2 Appendix A, V.(d)(7). The Licensing Board's author-ity to grant such motions is provided in 10 C.F.R. S 2.757(b), "[t]o prevent unnecessary delays or an unnecessarily large record. . . ." The exercise of this authority is i
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particularly appropriate where, as here, the proceeding is expedited, the issues in con-troversy are narrowly focused on one day's events, and collateral planning issues have been extensively litigated in a prior proceeding.
LILCO moves to strike the specific portions of testimony detailed below because they are outside the scope of Contention EX 47 and are therefore irrelevant. The only 4
' issues raised by Contention EX 47 are whether LILCO demonstrated the ability to regis-ter, monitor, and decontaminate special facility populations during the February 13, 1986 Exercise, and whether provisions of Revision 7 of the LILCO Plan are sufficient to
, protect the special facility population during an emergency. The objectionable portions of the Harris and Mayer Testimony shed no light on LILCO's ability during the February 13 Exercise to register, monitor, and decontaminate special facility evacuees. Instead, the testimony speculates on matters not fairly raised by the contention and raises plan-ning issues already resolved during the litigation of the LILCO Plan. Accordingly, the following references should be stricken:
Page and Line Reference Text to be Stricken -
page 16, line 9 page 17, line 4 "In general, LILCO proposes to recom-mend sheltering for hospital patients, even if an evacuation is recommended for all other individuals in the EPZ. If a decision is made to evacuate the hospi-tals, however, under the LILCO Plan LILCO would provide necessary trans-portation for such evacoation on an ad hoc basis, af ter all the other special facility residents and individuals requir-ing transportation assistance had been evacuated and the necessary vehicles had become available. See OPIPs 3.6.1; 3.6.5. Further, according to the Plan as exercised, patients evacuated from hos-pitals would be transported to reception hospitals. But, such hospitals are not identified in the Plan; instead the Plan merely contains the note "(filled in at time of emergency)" for the " reception centers" for hospitals. OPIP 3.6.5, At-tachment 2. SO, even though LILCO d
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1 Text to be Stricken. Cont'd acknowledges the potential need to evac-uate hospital patients, and the need, in the event of such an evacuation, to transport
-patient evacuees to reception hospitals, the LILCO Plan as exercised provides no basis to determine that such reception hos-.
pitals exist,' nor is there any provision for the registration, radiological: monitoring, or decontamination of patient evacuees at the unidentified reception facilities."
The hospital evacuation procedures discussed in this answer are in no way impli-cated by events occurring during the Exercise. On the day of the Exercise, the scenar-10 caHed for sheltering of hospital patients, not evacuation.
The LILCO Plan procedures for the sheltering and evacuation of hospital pa-tients were thoroughly reviewed in the Plan litigation. Without criticizing the evacua-tion procedures, the Licensing Board approved sheltering as a first-choice protective action and concluded:
LILCO's preference for sheltering of hospital patients is well-founded, both because of the likelihood that radiation levels near the 10-mile EPZ boundary will not be excessive in most accidents and because of the specially sensitive nature of hospital patients who re-quire special care. PID at 846.
' LILCO's evacuation procedures for hospitals have already been approved; they were not used on the day of the Exercise because the Exercise scenario did not call for it. Thus, LILCO's ability to evacuate hospitals and the procedures for accomplishing that evacu-I ation are unrelated to any fact in issue in this proceeding.
l Page and Line References Text to be Stricken page 19, line 14 page 20, line 4 The paragraph " Registration is essential for several reasons. First, f amilies and I
loved ones must be able to locate special
! facility residents af ter an accident.
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Text to be Stricken. Cont'd
, Second, records must be kept concerning the effects of the accident, the evacua-tion process, and subsequent care and treatment of special facility residents on preexisting health conditions. - Third, records must be kept on radiological exposures and contamination to permit the necessary medical follow-up on indi-viduals who have been contaminated. In addition, such records are an invaluable source for epidemiological evaluations conducted af ter a radiological accident to understand its consequences and make fu-ture policies."
This portion of the testimony purports to explain the reasons behind the regis-tration requirements of NUREG 0654. It assumes an elaborate system of medical recordkeeping requirements where none exists. The testimony then suggests that epidemiological evaluations be made on the basis of this data.
The assumption is erroneous as are the conclusions following from it. NRC regu-lations do not require LILCO to keep medical records. Further, medical records and ,
epidemiological studies bear no relation to events that occurred at the February 13 Exercise.
This portion of the testimony also seeks to raise planning issues. LILCO Plan procedures for the protection of special facility populations were extensively reviewed, and resolved, in the Plan litigation and therefore are outside the scope of this proceed-
! ing. See PID at 835.
Page and Line Reference Text to be Stricken page 20, lines 8-11 The sentence "Such fears and anxieties may be particularly great among indi-viduals with special needs and their iamilies."
s Without providing any factual basis, the testimony speculates that fears of con-tamination will be greater among the special facility populations and their families.
Nowhere does the testimony explain why this might be so. Nor does the testimony l
. relate to the issues raised by the contention: whether LILCO can in the future or did on February 13, 1986, register, monitor, and decontaminate special facility evacuees.
Therefore, this sentence is irrelevant and must be stricken.
Page and Line Reference Text to be Stricken page 21, lines 10-19 The sentences "First, in our professional opinion, responsible officials of special facilities - be they adult homes, nursing homes, facilities for the handicapped, or schools - would never permit their pa-tients to be evacuated absent a prior demonstration of adequate facilities and procedures for the registration, moni-toring, decontamination, housing and care of their patients or charges. Since LILCO failed to provide such a demon-stration, we conclude that LILCO lacks the capability- to implement the pro-tective action of evacuation of special l
facility residents."
Whether special facility administrators would allow their residents to be evacu-ated has nothing to do with the allegation in the contention that LERO workers can not register, monitor, and decontaminate those evacuees. Moreover, that precise issue was decided in the litigation of the LILCO Plan. There, the Licensing Board rejected the view that LILCO must coerce the cooperation of special facility administrators, and stated:
The only action expected of these organizations is to act in their own interest to protect themselves from radiation by either sheltering or evacuation. They re-quire assistance in determining whether to shelter or evacuate, and if evacuation is ordered, for the neces-sary transportation. LILCO has provided for trans-portation for these faellities. Furthermore, it has conducted discussions with these facilities to inform them about the options of sheltering or evacuation and it has provided adequately for notification of these facilities.
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LILCO's responsibility in this matter is to provide as-sistance and advice which would enable people with -
ordinary incentives for self-protection to take appro-priate actions. PID at 835.
Finally, there are to facts in the testimony that support this conclusion about attitudes of special facility administrators. For all of these reasons, these statements are irrelevant and must be stricken.
Page and Line Reference Text to be Stricken page 27, lines 4-8 The sentence "But, in general, the types of facilities which could be appropriate for this purpose are not set up or laid out to include sheltered areas either outside their buildings, or in- foyers,-
where monitoring of large numbers of persons with special needs could be per-formed."
Atter admitting that they have no identified f acility in mind, the witnesses spec-ulate as to why the unnamed facility will be flawed. Conjecture about facilities that LILCO does not use cannot assist the trier of fact in determining the adequacy of LILCO's February 13, 1986 performance or the efficacy of its Plan. The testimony is not probative of any material fact and must be stricken.
II. THE WITNESSES ARE NOT QUALIFIED TO RENDER CERTAIN OPINIONS LILCO moves to strike portions of the Harris and Mayer Testimony on the ground that Drs. Harris and Mayer are not qualified to testify as experts in the areas of l
j radiological monitoring and decontamination, or in the area of radiation health effects. ,
Health physics, the scientific rubric under which radiological monitoring, decontamina-tion, and radiation health effects fall, is a highly technical and well-defined specialty.
I It is not an area on which Drs. Harris and Mayer, as public health physicians, can reli-l l ably opine.
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4 The resume attached to Dr. Harris's testimony indicates that he has no education !
or experience in health physics. The description of his current position as Suffolk j County's Commissioner of Health Services lists no duties that require or make use of a health physics background. Nor do his past positions or professional activities include l this type of expertise. The focus of Dr. Harris' professional career has been public health and pediatrics.
Only one of Dr. Harris's publications, " Total Body Irradiation," published in 1961, has any relationship to radiological medicine. This paper discussed irradiation as a method for destroying leukemic bone marrow in order to substitute healthy bone mar-row. It has nothing to do with the potential health effects of radiation releases from nuclear power plants. A copy of that portion of Dr. Harris's 1983 deposition transcript from the litigation of the LILCO Plan which describes this paper is attached hereto (Attachment A).
Similarly, Dr. Mayer's resume lists no education or experience in the science of health physics. Af ter completing an internship in pathology, Dr. Mayer obtained a mas-ter's degree in public health in 1972. Since that time he has worked at the Suffolk County Department of Health Services.
These witnesses' lack of expertise is confirmed by their deposition testimony.
During Dr. Harris's deposition he testified:
, Q. Dr. Harris, do you consider yourself an expert in radiological monitoring or decontamination?
I A. No.
l l
Q. And you don't claim to be an expert in nuclear or radio-logical medicine?
I
! A. No, I do not.
Deposition of David Harris, M.D. and Martin David Mayer, M.D., February 6,1987, at
< 16. (The deposition pages cited throughout this motion are collected in Attachment B.)
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Dr. Harris further testified that he had never participated in any training related to radiological monitoring:
Q. Does the Department of Health Services conduct training of any of its employees in radiological monitoring?
A .' It does not conduct it, but it sends members of its staff to training programs that are held, for example, by the State and I believe sometimes by the Federal Government.
Q. Have you personally taken that training?
A. No.
- Deposition Transcript of David Harris, M.D. and Martin David Mayer, M.D., February 6, 1987 at 17 (Attachment 2).
Similarly, at deposition Dr. Mayer testified:
Q. Do you consider yourself an expert in radiological moni-toring?
A. No.
Q. In radiological decontamination?
A. No.
Q. Have you been trained in either area?
A. No.
Q. Have you taken any courses on radiation sources or measure-ment or monitoring?
A. I'm an engineer by original training in an engineering school.
I'm a chemical engineer. I may have had a course, and I would have to go back and look at a transcript, on radiation as part of a chem.ical engineering course back in the late 50's. I can't recall specifically, but otherwise, nothing.
Deposition Transcript of David Harris, M.D. and Martin David Mayer, M.D., February 6, 1987, at 24-25 (Attachment 2).
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.Drs. Harris and Mayer's lack of training, knowledge, or experience in health physics renders them incompetent to testify on such issues. Their medical knowledge of the detection and spread of disease is in no way comparable to the health physics principles that explain the detection and spread of contamination. Consequently, the portions of the testimony specifically identified below are incompetent and unreliable and should be stricken on that basis.
Page and Line References Text to be Stricken page 31, lines 14-17 The sentence " Depending upon the type of contamination involved, a delay in decon-tamination procedures could increase the exposure of the individual, and thereby in-crease the potential for harmful health ef- '
fects."
page 31, line 18 page 32, line 1 The sentence "Furthermore, from a medical point of view, the decontamination process should be initiated as soon as possible not only to minimize the health threat to the exposed individual, but also to minimize the potential of exposing others, such as those whom LILCO proposes to be in the buses or other vehicles with the contaminated per-sons, those who would be in those vehicles subsequently, and others who may come in contact with the contaminated individual."
page 33, lines 26 page 34, lines 1-4 The sentence "Accordingly, it is essential 4 that they be monitored as soon as possible
. not only for their own protection, but to re .
duce the likelihood that any contamination they might have would be spread or dis-persed, thereby endangering others."
l l page 49, lines 6-19 The sentences "If the pressure of knowing i there has been a real radiological accident, 1 or the " pressure" caused by knowing there i are thousands of individuals in line de-manding to be monitored, made LILCO mon-itors go faster, we would be very concerned 1 about the accuracy and adequacy of the
- monitoring. If anything, knowing that peo-l ple really were contaminated should make
! monitors be more careful, and take longer, rather than causing them to speed up."
P
e III. CONCLUSION For the reasons stated above, LILCO respectfully requests that this Board strike:
- 1) Page 16,11ne 9 - Page 17, line 4;
- 2) Page 19, line 14 - Page 20, line 4;
- 3) Page 20, lines 8 - 11;
- 4) Page 21, lines 10 - 19;
- 5) Page 27, lines 4 - 8;
- 6) Page 31, lines 14-17;
- 7) Page 31, line 18 - Page 32, line 1;
- 8) Page 33, line 22 Page 34, lines 1 - 4; and
- 9) Page 49, line 16-19 of the " Testimony of David Harris and Martin Mayer on Behalf of Suffolk County Con-cerning Contention EX 47."
Respectfully submitted, LONG ISLAND LIGHTING COMPANY LCA A Dorfald P. Irwin Kathy E.B. McCleskey Karen L. Donegan Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 s
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. Attachment A 1
1 UNITED STATES OF AMEFICA
.40 CLEAR REGUL ATOPY COMMTSSIch 1 2 1112ge the Atomic Safety and Licensinc_Ro.gni l
, , 1 3 ----------------------------------x In the matter of:
4 LOliG ISL AND LIGHTING CCHPAliY Docket No.
.(Shcreham Nuclear Power Station, 50-322-01-3 5 Unit 1) (Emergency
. Planning) 6 ----------------------------------x 7 Hauppa uge, N.Y.
8 Friday , O ctober 14, 1983 9
10 DEPOSITION OF DAVID HARRIS, called for 11 examin ation by counsel for LILCO in the above-entitled 12 action , pursuan t to notice, the witness having been duly -
, 13 sworn by NICHOL AS J. TORRE, s Notary Public in and for 14 the State of New York, at the cffices of the.Suffolk 15 County Exec u tive ; H. Lee Dannison Building, Veterans 16 Hig hwa y , Hauppauge, New York, at 1:35 p.a., the 17 proceedings being taken down by Stenotype by NICHCLAS J.
18 TORRE, and transcribed under his direction.
19 I 20 21 22 i
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A 14 1 enforcement and set?tng of standards are clearly sta te.
1 There was a time, during my tenure, when the department 3 was delegated the responsibility for doing the 4 inspections, but that delegation was withdrawn several 5 years ago.
e In that case, the. state took on the 7 ressonsibility for the inspections in the hospitals, 8 which we used to'do. ,
e , Q In your resume, sir, I have noticed a 10 nuater of papers and presentations in each of the 11 pediatric and public health areas, generally.
12 A All right.
13 Q There are literally dozens of then I
- 14. did n't notice any, though, that related particularly 15 either te nuclear medicine or radioactive areas of 1s interest, or to any kinds of, call it, disaster or 17 contin gency planning, to the extent that is a public is health phenomenon.
Is Are there sNy such entries in your resume a
20 that come to aind, .immediately?
21 A Well, ycu are quite correct, when ycu say 22 that you don 't notice many, if you said tha t. There is i
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15 which I wrote in my youth, when I was in 1 just one paper, 2 Washin g ton , D.C.
This was done at the National Naval 4 Redical Center, entitled "Tctal Body Irradiation."
That is part of a report that my
. 5 a colleagues and I made on our experience with total bcdy 7 irradia tion .
8 It was used then on an experimental e basis, for the treatment of desperately ill children to with leukemia.
11 Our work had to do with the use of total 1
12 body irradiation in what would have been lethal doses, 13 to destroy leukemic cells and leukemic bone marrow, so
- 14 that thd' person would be receptive to hone marrow l 15 transplantation. _
l 1e That is the only part of my published 17 work that bears on radiation and radiation biology, tha t is I recall, and I don 't recall an y other pape rs or
! 19 presentations not here, that bear on it.
20 ' That is with the exception , say, of my 21 association of my name with the final report of the 22 Sandia labs on the transportation of the wastes.
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Attachment B TRAXSCluP1 OF PROCEED: XGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of: :
- Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY : (EP Exercise)
(Shoreham Nuclear Power Station, : (ASLBP No. 86-533-01-OL)
Unit 1) :
x DEPOSITION OF DAVID HARRIS, M.D. and MARTIN' DAVID MAYER, M.D.
Long Island, New York Friday, February 6, 1987 ACE-FEDERAL REPORTERS, INC.
Stenctuy14porten 44 North Capitol Sneet i
' Washin n. b.C. 20001 (20.)34 -3 00 l Nationwide Coverage
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7360 01 01 16 marysimons 1 see on page 3. I very recently resigned from the New York 2 State Advisory Council on Mental Petardation and 3
Developmental Disabilities because of -- I just had too much 4 work to do and was unable to unable to keep up with the 5 press of work and that still shows me as being a member.
6 l
What is missing from the professional activities 7 -- that's correct. I thought I saw something wrong. No, 8l it's correct. Other than that, it's correct.
l 9' O Dr. Harris, do you consider yourself an expert in 10 radiological monitoring or decontamination?
~
11 A (Witness Harris) No.
12 0 And you don't claim to be an expert in nuclear or 13 ! radiological medicine?
l 14 i A (Witness Harris) No, I do not.
i 15 { 0 I have just a few questions about your duties as 16 ; a Health Commissioner. I see in the first paragraph, the 17 first big paragraph under Commissioner of Health Services 18 ' that you've listed environmental health services. What do 19 ' you mean when you refer to that? Do you see that?
20 A (Witness Harris) Where do you see that?
21 ! O It's in about the middle of the paragraph.
22 , A (Witness Harris) Oh, it's not the first thing I
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7360 01 01 17 marysimons 1- listed. You threw me off with that. It's one of a number 2 of things listed.
3 Environmental health services refers to those 4
activities in the Department of Health. Services in Suffolk l
5 j County which protective individuals in the population from I
6 hazards, polluted water, polluted air, bad housing, 1
7 unsanitary food and the like.
8 0 Does the Department of Health Services conduct 9
training of any of its employees in radiological monitoring?
10 A (Witness Harris) It does not conduct it, but it
~
11 sends members of its staff to training programs that are 12 I held, for example, by the State and I believe sometimes by i
13 l the Federal Government.
wA f 14 l 0 What would you say that the Health Department 15 sends its employees for that kind of training?
16 A (Witness Harris) One, because that kind of 17 ! training is made available, it's of high quality, and we do i
18 not have the kind of staff who can train themselves. They 19 require a little expertise which is not available within the 20 ' Department. Those are the reasons.
21 ' O Have y u personally taken that training?
22 ; A (Witness Harris) No.
i l
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7360 01 01 18 marysimons 1 0 And I take it you have never personally trained 2 any of your employees?
3 A (Witness Harris) No, not in that aspect.
4 0 Let's take a jump over to the second page, 5 Academic Appointments. Could you tell me what the New 6
School for Social Research is?
7 A i
(Witness Harris) The New School for Social 8
Research is an institution of higher education licensed in 9
the State of New York to. confer undergraduate and graduate 10 degrees. It's headquarters is in the City of New York, but 11 it operates on many campuses throughout' the State, Suffolk 12 County being one.
I 13 ! O What do you teach there?
i 14 A (Witness Harris) I teach two courses from time 15 c
to time. One is called health in the community, which is a
) 16 l
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basic course for master's candidates on the essentials of 17 epidemiology and on the basic principles and approaches of 18 l public health.
19 The other course that I teach is an entry level 20 ' survey course of United States health care institutions. I 21 think it's called the United States Health Care System or I
22 something like that.
1 The name of the course varies.
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f7360 01 01- 24 marysimons 1 [ What about the last paper listed there? Can you 1-2 tell me the gist of what that's about?
3 A (Witness Harris) That was along the same lines.
4 Paople who had read my editorial asked me if I would go to 7
5 the preventive medicine meeting called Prevention '85 to 6 , give an expansion of some of the things I expressed in the 7 editorial, and I said I would be glad to. So it was along 8- the same lines.
9 f
Q Dr. Mayer, I'm going to spare you questions on
,10 your resume. I just have a few general questions.
11- Do you consider yourself an expert in 12' radiological monitoring?
13 A (Witness Mayer) No.
14 Q In radiological decontamination?
15 A (Witness Mayer) No.
r 16 Q Have you been trained in either area?
17 ' A (Witness Mayer) No.
18 Q Have you taken any courses on radiation sources i
19 l or measurement or monitoring?
3
< 0 A (Witness Mayer) I'm an engineer by original I
21 training in an engineering school. I'm a chemical
, 22 ' kngineer. I may have had a course, and I would have to go
- /
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marysimons l back and look at a transcript, on radiation as part of a 2 chemical engineering course back_in'the late 50's.. I can't 3 recall specifically, but otherwise, nothing.
4 Q The rest of these questions are to both of you.
5l When did you first see the contentions that were 6 filed in this proceeding?
'7 A (Witness Harris) Let me think. I believe the 8 first time I saw them was when they were mailed to me, but 9
them I.put them aside, and though I saw them, I didn't pick 10 them up really and look at them carefully until that week or 11 10 days or so ago that I'mentione'd before. They sat in my 12 , bedroom near my arm chair.
13 A (Witness Mayer) In my case that sat on a 14 bookcase in my office until about approximately the same 15 time. When I noticed on my calendar tha this was coming l
16 up, I picked them up off the bookesse Lout 10 days or two 17 ; weeks ago, approximately that time, and started reading.
, 18 .them.
I 19 0 You said you were mailed the contentions. Were l
20 l you mailed the whole set or just the few that you might 21 testify or what?
22 l A (Witness Harris) I was mailed two certainly of i
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'7360'01 01 I marysimons 1 I have read tne foregoing pages 2
through , inclusive, wnien 3
contain a correct transcript of l
4j the answers made by me to the 1
5 questions therein recorded.
6 Signature is subject to 7l corrections.
4 8 DAVID HARRIS, M.D.
9 MARTIN DAVID MAYER, M.D.
10~ * *** **
I 11 I,
, Notary Public in anc
~12 for the 1
, do hereby certify that I am 13 , notarizing and witnessing signatures for the Deposition of 14 DAVID HARRIS, M.D. and MARTIN DAVID MAYER, M.D. on 15 l i
.this day of , 19 .
16 .
Notary Public in and for the l17 My Ccmmission expires i 18 19 20 i
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22 l
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LILCO,' March 19,1987 DO(,KE TED t15HBC CERTIFICATE OF SERVICE 1r/ mR 23 Pl2:32 In the Matter of LONG ISLAND LIGHTING COMPA i g gp gatige y (Shoreham Nuclear Power Station, U TING A SEPVICI Docket No. 50-322-OL-5 BRANCH I hereby' certify that copies of LILCO'S MOTION TO STRIKE PORTIONS OF THE TESTIMONY OF DAVID HARRIS AND MARTIN MAYER CONCERNING CONTENTION EX 47 (REGISTRATION, MONITORING, AND DECONTAMINATION OF SPECIAL FA-
~CILITY EVACUEES) AND CONTENTIONS EX 22.A AND 49 (MONITORING AT THE NASSAU COLISEUM) were served this date upon the following by Federal Express as in-
- dicated by an asterisk, or by first-class mail, postage prepaid.
John H. Frye, III, Chairman
- Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board .
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers 4350 East-West Hwy. Oreste Russ Pirfo, Esq. *
- Bethesda, MD 20814 Edwin J. Reis, Esq.
U.S. Nuclear Regulatory Commission t
Dr. Oscar H. Paris
- 7735 Old Georgetown Road Atomic Safety and Licensing (to mallroom)
Board Bethesda, MD 20814
- U.S. Nuclear Regulatory Commission East-West Towers Herbert H. Brown, Esq.
- 4350 East-West Hwy. Lawrence Coe Lanpher, Esq.
Bethesda, MD 20814 Karla J. Letsche, Esq.
Kirkpatrick & Lockhart Mr. Frederick J. Shon
- South Lobby - 9th Floor i
Atomic Safety and Licensing 1800 M Street, N.W.
Board Washington, D.C. 20036-5891-
, U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 Fabian G. Palomino, Esq.
- 4350 East-West Hwy. Richard J. Zahnleuter, Esq.
L Bethesda, MD 20814 Special Counsel to the Governor Executive Chamber Sacretary of the Commission Room 229 Attention Docketing and Service State Capitol
. Section Albany, New York 12224 U.S. Nuclear Regulatory Commission 1717 H Street, N.W. Mary Gundrum, Esq.
Washington, D.C. 20555 Assistant Attorney General 120 Broadway
- Atomic Safety and Licensing Third Floor. Room 3-116 Appeal Board Panel New York, New York 10271 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
4' r,- Spence W. Perry, 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 Gerald C. Crotty, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber l_ Agency Building 2 State Capitol Empire State Plaza - _ Albany, New York 12224 Albany, New York 12223
- Martin Bradley Ashare, Esq.
Stephen B. Latham, Esq.
- Eugene R. Kelly, Esq.
Twomey, Latham & Shea - Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 ,
Jonathan D. Feinberg, Esq.
New York State Department of
. Public Service, Staff Counsel i Three Rockefeller Plaza i Albany, New York 12223 L
Kafsn L. Donegan Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 l
DATED: March 19,1987 i
4
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