ML20206T271
| ML20206T271 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/13/1987 |
| From: | Zahnleuter R NEW YORK, STATE OF |
| To: | Kline J, Margulies M, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20206T041 | List: |
| References | |
| OL-3, NUDOCS 8704230150 | |
| Download: ML20206T271 (10) | |
Text
{{#Wiki_filter:,_. s Attachmsnt 1 s (A n ..... STATE oF New Yonx Extcutivt CHAMBER
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FASI AN PALOMINO Special Counsel to the Governo, April 13, 1987 By Telecopier Morton B. Margulies, Esq. Dr. Jerry R. Kline Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East-West Towers 4350 East-West Highway Bethesda, MD 20814 Re: Docket No. 50-322-OL-3 (Emergency Planning) Gentlemen: Today, under separate cover, the State of New York hand delivered the " Direct Testimony of David T. Hartgen and Robert C. Millspaugh on Behalf of the State of New York Regarding LILCO's Reception Centers." Attachments 3, 4, 5 and 6, consisting of aerial photographs, and attachment 25, consisting of a videotape, were also hand delivered in the same package but in a separate envelope. Please take note that this witness panel consists of Dr. Hartgen and Mr. Millspaugh. On March 25, 1987, the State of New York withdrew Messrs. Acquario and Kilduff. Today, under separate cover, the State of New York also hand delivered the " Direct Testimony of James Conrad Baranski, Lawrence Bruno Czech and James Dominic Papile on Behalf of the State of New York Regarding LILCO's Reception Centers." The State of New York hereby withdraws Langdon Marsh and Sarah Meyland as witnesses in this proceeding. This development also renders "LILCO's Motion to Compel State of New York to Produce Document" (April 3, 1987) moot. In a letter dated March 30, 1987, LILCO's counsel " alerted" the Board to several issues. Regarding scheduling, the Governments will respond in a separate pleading. Regarding the 8704230150 870417 PDR ADOCK 05000322 O PDR
r 4 other issues, LILCO's arguments are premature and the State of New York will respond when appropriate. However, the record must be set straight concerning one of LILCO's claims for a need for a rebuttal phase. LILCO bases its claim on, among other things, the fact that LILCO " received only this week (date of receipt was March 26, 1987] certain traffic signal data from the State." LILCO asked for this data on March 9, 1987, three days after the close of the original discovery period. The State of New York actually provided LILCO with responsive information and documents quite promptly, approximately two weeks ahead of the thirty-day period set forth in the regulations. LILCO's inability to discuss this data in its direct testimony is attributable to LILCO's own extensive delay in asking for the data. LILCO, therefore, is unable to show good cause for the need to submit rebuttal testimony based on certain traffic signal data; any such pleading by LILCO should be denied. Sincerely,
- pe '7 /7 /
(fg&) Ah U Richard J. h euter Deputy Specia Counsel to the Governor cc: Mr. Christman Mr. McMurray Mr. Bachman Mr. Cumming e
Attachm:nt 2 s STATC or Ncw YoRM Exccu'rivc CH AMBc A PABI AN PALOMINO Somas Counses to tme Governor
\1 arch 25,1987 By Federal Express Mary Jo Leugers, Esq.
Hunton & Williams 707 East Main Street Richmond, Virginia 23212 , Dear Mary Jo This is in response to "LILCO's Request to Inspect and Record Dial Settings on Certain Actuated Traffic Signal Controllers" (March 9,1987); your letter to me dated March 18,1987; your letters to me dated March 4,1987 and March 17, 1987; and the Board's Order of March 25,1987.
- 1. "LILCO's Request to inspect and Record Dial Settings on Certain Actuated Traffac signal Controllers".
The State of New York hereby provides iesponsive information and documents as follows:
"Inte rsec tion" Response Sunrise Highway & Babylon Turnpike
& Merrick Avenue
" & Newbridge Road
& Bellmore Road Merrick Road & NeWbridge Road Willis Avenue & North LIE Service Road
& South LIE Service Road
" & Northern State Parkway t
s 2-Roslyn Road & South LIE Service Road 107 & Scott Avenue
" & Lenox Avenue /Newbridge Road
" & John Street / Jerusalem Avenue
" & Old Country Road **
" & New South Road
" & South Oyster Bay Road .* .
" & Hempstead Turnpike
" & Stewart Avenue South Oyster Bay Road at North LIE Servica Road **
Woodbury Road Old Country Road Old Country Road & Round Swamp Road
" & Manetto Hill /Plainview Reads
" & Seaford Oyster Bay Expressway **
& New South Road
& Park Avenue One asterisk means that documents setting forth responsive information are attached hereto. Two asterisks mean that the State of New York does not possess or control the requested information.
II. Your Letter of $tarch 18,1987 Item Response
! Your letter states that Mr. Marsh is presenting
" legal testimony rather than factual testimony". To the contrary, Mr. Marsh is presenting factual
3 testimony, not " legal testimony" which in itself is a confusing phrase. M r. Gerstman, who is an attorney, prepared the analysis of environmental laws at my direction. The memorandum is protected by attorney-client privelege and attorney work product doctrine. LILCO may request its own attorneys to analyze environmental laws. 2 None exist. 3 Attached. 4 None exist. 5 None exist. . III. Your letters of March 4,1987 and March 19,1987 The State of New York will provide LILCO with videotapes, pictures or measurements which will be relied upon by the State's witnesses in testimony. Videotapes, pictures or measurements not relied upon in testimony, all of which were taken at the direction of counsel, are protected by attorney-client privelege and attorney work product doctrine. Pictures or measurements that were taken by the State caa be taken just as easily by LILCO since the reception centers are under LILCO's control and highways are in plain view to all. At this time, the State's witnesses intend to rely upon the following measurements in testimony:
. a gate directly in front of the gatehouse in the Roslyn reception center is approximately 20 feet wide.
I will keep you apprised of further developments. IV. Board's Order of March 25,1987 The Board made the following finding on page four:
"LILCO's request was to determine whether an EIS or SPDES permit hy been required at other facilities not whether either u required... At the time of the request, had an EIS or SPDES permit been required by New York State at the other facilities. Applicant's inquiry was not whether a statement or permit is required. It is possible an EIS or SPDES permit is required by law but
s 4 may not have been required by the authorities at the time of the request." (Emphasis in last sentence added.) In accordance with the Board's interpretation, the State admits the statements propounded to it in LILCO's requests of March 3,1987. V. Miscellaneous 1he State of New York withdraws William Acquario and Charles Kilduff as witnesses. Sincerely, 3' / _: i s j- Vgk-}h' 'Ql ,,,/.
$d ?. .* bdsb<.-d a &
Richard J. 7.ahnnduter Deputy Special Counsel to the Governor s 0
Attachmsnt 3 Statement Of Material Facts As To Which LILCO Contends There Is No Genuine Issue To Be Heard
- 1. SEQRA requires an environmentalimpact statement for any action that state or local agencies, " propose or approve" which may have a significant offeet on the environment. ECL SS 8-0109.2. 8-0105.1 .3.
- 2. The reception centers are on private property owned by LILCO.
- 3. SPDES permits are required only for " discharges" of pollutants "Into the waters of (the] state." ECL SS 17-0701, 17-0505.
- 4. LILCO will collect the washwater in portable storage tanks.
- 5. No other reception center for any nuclear plant in New York State has been required to have SPDES permits or an environmental impact state-ment.
- 6. In a real emergency, New York State and the county governments would make a "best effort" response. CLI-86-13,24 NRC 22,31,33 (1986).
o l l
Attachment 4 TRAXSCRIFf OF PROCEEDIXGS 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 :
- (ASLBP No. 86-533-01-OL)
(Shoreham Nuclear Power Station, : Unit 1) : Y
- - - - - - - - - - - - - - - - - - - -x DEPOSITION OF CHARLES DAVERIO Hauppauge, New York Friday, March 13, 1987 ACE-FEDERAL REPORTERS, INC.
swweyre w 444 North Capitol Street Washineton. b.C. 20001 (202)347-3700 Nationwide Cowrage 800-336-6646
r 65 1 the sinks area accommodate at any one time? 2 A. I would guesstimate somewhere in the a range of 20, 30 people. That's Just a guess on my 4 part. 5 Q. Does that include-- 6 A. That would be total occupancy. 7 Q. How many people do the shower areas 8 accommodate? Do you know? 9 A. You can take ten showers in each side. 10 so there would be e total of 20. 11 Q.. Are there any toilet facilities in the 12 decontamination trailers? 13 A. I don't believe so. 14 Q. I assume these are going to have hot 15 water, the showers? 16 A. They are hot water showers and heated. 17 Q. I believe under tne draft the water from 18 the showers is going to be captured? 19 A. That's correct. 20 Q. How is that to be done? s' 21 A. In collapsible storose tanks. There is 22 e system that runs the water from here to the tank. COMPUTER AIDED TRANSCRIPTION / keyword index
e . 66 1 Q. Will those collapsible tanks be stored 2 on-site or off-site? 3 A. I believe they are stored on-site. They 4 fold up into a sort of nest little package. 5 Q. Do you know what the capacity of those 6 tanks are?
- 7 A. The ones we are looking at buying are 8 15,000 gallons.
9 C. They haven't been purchased yet? 10 A. No, they have not. 11 Q. What are they made out of? 12 A. I d o n ,' t remember the exact material, but 13 it's probably some kind of plastic or rubber type of 14 system. But I am not exactly sure which one. 15 Probably some high tech plastic, but I am not sure. 16 MR. CASE: We'll mark these as Deverio 17 exhibits in order. 18 (Daverio Exhibits 4 through 12 19 were so marked for 20 identification.) s' 21 Q. Looking at Exhibit 4, do you recognize 22 the document?
~
COMPUTER AIDED TRANSCRIPTION / keyword index
Attachment 5 LILCO, February 26, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATCRY CCMMISSICN Before the Atomic Safety and Licensinc Board In the Matter of )
)
LCNG ISLAND LIGHTING COMPANY J
)
Docket No. 50-322-OL-3 (Shoreham Nuclear Power Station, ) (Emergency Planning Unit 1) Proceeding)
)
AFFIDAVIT OF JOHN A. WEISMANTLE My name is John A. Weismantle. I am Manager of the Local Emergency Response Implementing Organization. 1. Based on discussions with planners involved in radiological emergency planning for the operating nuclear j plants in New York State (Indian Point, FitzPatrick, Nine Mile Point, and Ginna), LERIO believes (1) that no monitoring and decontamination center designated in the emergency plans for any of those facilities has been required to apply for an SPDES permit and (2) that no such center has been the subject of a state environmental impact statement under the State Environ-mental Quality Review Act. 2. In order<< to protect Long Island's groundwater resources, a study entitled "The Long Island Comprehensive Waste Treatment Management Plan" (or "the 208 Study"), was com-pleted by the Long Island Regional Planning Board under Section 26630662.!2 2p.
208 of the Clean Water Act Amendments of 1972. The 208 Study divides Long Island into eight hydrogeologic zones and makes specific recommendations pertaining to each zone. The 208 Study identified deep flow recharge areas on Long Island as consisting of hydrogeologic zones I, II, and III.
- 3. According to the 208 Study, Suffolk County Community College (Zone III), SUNY - Stony Brook (Zone I), and SUNY - Farmingdale (Zone II) are located in the primary groundwater recharge areas for Long Island, as shown on the map of hydrogeologic zones in the Nassau-Suffolk 208 Study Area (Figure 3-2 on page 43'of the 208 Study).
fin A. Weismantle t aSubscribed'and A11, 1985. sworn to before me this day af 6 My commission ~ expires: M 1L('lU lO N .
- c. = 4 rc....a act: j ec...:. r.m er I;:e, Yofk i:o.;. 7:11;J
( Qu:'.f::: ia t::::aa County Comm.s:.on e.t;;.rc: I.Mr.30,19d ' [, / d 0 i A ll+ L lb .9
/ Notary Public l
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Attachment 6
--- . . L . . * *. 3 :.. .t *e STATE bF NEW YORK DEPARTMENT OF HEALTH tows = swuciwo e Twt sevenwen = aLsow A. nocastskban awning svare cua: A e aceae.v. 8.v. taan !
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c ... ., l August 29, 1983 D @N) . -y m SEP 1 19J3 " OmC1if15t3818tf Pat?tAttaISE Mr. Geor'ge Brower ' Director
-{y Disaster / Emergency Preparedness 200 North Second Street Fulton, NY 13069 ,
f .
Dear Mr. Brower:
her Referring to your question today on 'the decontamin.atiert of vehicles leaving the 10 mile EPE as to what problems may arise from water us'ed to wash off a. vehicle that may become contaminated, we believe that this is not a problem that creates any major concern. It is believed that the'small amount of contamination h, that may settle on a car will be diluted to a great extent by washing and that this water can either seep into the ground or enter the sewer system. Care should be taken to see that the wash water does not enter the area where people gather. l The major concern with contamination is still with human l beings first and equipment second. I hope this information gives you 'enough .guidancee toe answer your questions. sincerely you , , , M A" nald D. Davidoff i Director Radiological Emergency l Preparedness Group cc: Mr. Rowieski, FF.MA l
Attachment 7
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- November 16, 1983 I?
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.f D C' 2330CT F?,:,al ::;,,g Mr. George Brower Dirac r t..
' Disas / Emergency Preparedness , q-g .% '
l 200 N th Second'atreet '- . ruito NY 13069 ' '
Dear . Brower:
- t The question of what to do with waste shower water , . . .
tMat a become contaminated due to the cleansing of a contapnatedindividualhasbeenasked. (* In consultation with Dr. Karim Rimawi, Director, Bures of Environmental Radiation Protection, it has been date ned that auch waste water should be allowed to flow ,I dirac y into the normal. sewer system since it would be ,. , , - gros diluted by the volume of water in the system and 0 #j~;p, - ther re pose no health problems. "A - . a , .. ,9 - h , sincerely yours, ; .
,[
t W g
-[
nald . Dav d 6,.
. irector *E. a. y .*
< adiological Emergency Preparedness Group 6
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Attachment 8 TIM. SCRW1
~
03 PROCEEDINGS i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of: :
- Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY : (Emergency Planning)
(Shoreham Nuclear Power Station, : Unit 1) :
- - - - - - - - - - - - - - - - - - -x DEPOSITION OF JAMES C. BARANSKI, JAMES D. PAPILE and LAWRENCE B. CZECH l
Albany, New York
, Wednesday, February 25, 1987 ACE-FEDERAL REPORTERS, INC.
Stenoture Re:vrters 444 Nonh Capitol Street Washington, D.C. 20001 (202) 347-3700 Nationwide Cowrage 800-336-6646
. l I
9941 02 02 98 r- ysimons 1 i can't remember the necessity for the cars offsite. 2 A (Witness Papile) I've never heard of anyone i 3 doing it for offsite personnel. Now offsite means outside i 4 the exclusion area. Whether it was in the exclusion area ' 1 5 , or not, that would be up to the licensee. l 6 (Pause while the witnesses confer.) 1 7
, O Do you know if they had to decontaminate any !
8l people from the Ginna incident? { 9l MR. LANPHER: I object to that question as ; I
- 10 l vague. Do you mean as "they" the licensee or the offsite 11 i people? -
l 12 MR. CHRISTMAN: Anyone. 13 l WITNESS CZECH: We had no problems offsite, and 14 t onsite I don't believe we would have that information 15 , readily available. I 16 ; BY MR. CHPISTMAN: 1 17 I O Under other radiological emergency plans in New 18 York State, that is other than Shoreham, I take it people 19 are decontaminated by washing with soap and water? Is that
/
20 generally right? - i 21 A (Witness Baranski) That's generally correct. i 22 l A (Witness Papile) That's what we teach them. , I l l
! ACE FEDERAL REPORTERS, INC.
l 202 347 3700 Nationwide Coverage 300 336-6M6
I 9941 02 02 99 ' r ysimons 1 j 0 Where does the wash water go typically at those i 2 other plants once it's been used to wash people off? 3 A Down the drain. I 4 f 0 Into the normal sewer systems or where? I 5 , MR. ZAHNLEUTER: If you know. 6l WITNESS PAPILE: Yes. , 7 BY MR. CHRISTMAN: 8 ; O Do you monitor it after it leaves the people? i I h 9 A (Witness Papile) Yes, we teach to monitor if it {
! l 10 goes either into the sewer system or goes into the earth 11 'itself, to keep monitoring that and keep monitoring.it.
l 12 0 Let's take the sewer system first. How do you f 1 13 monitor the sewer system once the water has gone down the 14 i drain? i 15 A (Witness Czech) The sewer system itself you
~
16 wouldn't be able to monitor. You would go into a catch l 17 l basin or a trap or something, but what you would be doing l 18 there is monitoring the --- 19 (Pause due to telephone interruption.) o 20 MR. CHRISTMAN: Back on the record. l 21 , BY MP. CHRISTMAN-i I I 22 i 0 Mr. Czech, I was asking you how you go about i { l ACE. FEDERAL REPORTERS. INC. ] 202 347 3700 Nationwide Coserage 800 336 6646
9941 02 02 100 m ysimons 1 monitoring wash water after people have been 2 decontaminated, people now. Could you explain how you do i 3 that at other sites? I 4 A (Witness Czech) Typically, without being able ' l 5 to take a grab sample, you couldn't do it. You would have I i 6 to go and monitor the traps or something like that l 7I af terwards, unless there were a holding tank. t 8l , There are a couple of facilities that do use a i 9l hold tank type of approach for the water. There is one in 10 the Ginna area. Other than that it would go into the ! i 11 l - sanitary sort. ; l 12 O Are there provisions in other radiological j I 13 emergency plans for monitoring the water if it is taken to 14 a holding tank? 15 A That's one of the things they should do before 16 i they dispose of it; that's correct. 17 0 But do they do that in exercises? 18 A I honestly don't know at this time. 19 0 Are there provisions in the plans that tell them l e 20 they should do that? I I I 21 A It's part of their training. l 22 { O Ch, it's in the training. I l t
! ACE FEDERAL REPORTERS, INC.
l 202 347 3?00 Nationwide Coverage 90043&6M6
l 9941 02 02 101 r ysimons 1 A I can't speak to the individual plans as to 2 I whether that's included or not. That's information that I ' I 3 l just don't carry in my head. l 4 0 But if there is not a holding tank and it goes ; I 5 l into the ordinary sanitary sewer, then 'it's just not l 6 feasible I take it to monitor the water? ! 7j A That's correct.
- 8 0 General Papile, you mentioned the water seeping l 9l into the ground . I take it that would be water from i l ;
10 I vehicles rather than people? I 11 A (Witness Papile) Yes, absolutely. l I i 12 l 0 Are there reception centers under New York State. i i I 13 ; emergency plans where the wash water frem the vehicles does , 14 go to the ground? ; i 15 i A There is one that I know of specifically, yes. 4 i 16 l 0 Is there more than one? i 17 A There is one, and FEMA has approved that area. l l ! 18 We've had FEMA look at that area, their health physicists t 19 or whatever, and there are rocks and stones and so forth, :' o' 20 and we can take readings there, periodic readings to see if 21 l it's getting beyond the point where we shouldn't do it. - t ! 22 l 0 What is that area? ,
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l r ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nanonwide Coverage 300 336 6646 i
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$9410202 102 m .ycimons 1 A It's in Westchester.
i 2 j 0 And that's the only one you know of? : t 3 i A No. I'n just saying it's the only one I I ' 4 personally know of because I was there watching it one day, ! I i 5 but there are others because I know this is what we teach ! i 6J them. I i t 7 t O And what you teach them is you monitor the area {
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8 . where the water has been dumped? I 9! ' A Pericdic monitoring, yes. j 10 l 0 Periodic means how of ten and for how long l 11 l a f terward s ? 12 A I say period, but we tell them to do it. 13 ! O And you leave it up to them. Does their 14 training tell them how long or how often? 15 (Pause while the witnesses confer.) j i 16 A (Witness Baranski) I know of two other sites 17 ; that just dump it down the drain. One of them is up in 1 18 Rochester from Monroe County and another one is in Orange i 19 County. The training is not specific in saying that every
; 20 15 minutes you shall monitor the ground or every hour or i 21 , half hour or whatever, but after the fact obviously samples I
l 22 l would be taken to see the degree of contamination that i l I l ACE. FEDERAL REPORTERS, INC. I 202 347 3700 Nationwide Coverage 800 336-6M6 I
I a 9941 02 02 103 tr ysimons 1 exists. I 2 0 When you said they dump it down the drain, did 3 you mean the storm drains? I thought we were talking about 4 dumping it on the ground and you said they dumped it down 5 , the drain and I wondered if you mean storm drains? l 6l I A Well, eventually in some of these places it will 7 l end up in storm drains. It's being filtered through the 8 ground. 9 A (Witness Czech) In sanitary sewers usually. 10 A (Witness Papile) Yes. 11 0 But you're saying in at least three cases that 12 you know of the wash water from the cars goes where wash i 13 l water from washing cars usually goes which is onto the 14 ground and runs off wherever it runs off? l 15 A (Witness Czech) Yes. !' 16 I A (Witness Baranski) Yes. 17 0 And of those three, you know of one place at 18 least where the people doing the monitoring are taught to 19 monitor the ground --- 20 A (Witness Papile) To monitor the ground around 21 it. I 22 l 0 And that's how you handled th.-t problem I guess I ACE FEDERAL REPORTERS. INC. I 202 347 3700 Nationwide Coverage 800 336 6M6
l
, i.
9941_02 02 104 l r ysimons 1 in that one place? 2 A (Witness Papile) Yes. i 3 A (Witness Czech) Part of the layout of reception I , 4 centers would be looking ahead of time to see what's in 5 that area, what sort of soils and where the runoff could 6 potentially go so we don't run into a problem where if you I 7 did have a runoff that it would be feeding into some sort 8 of stream or place where it could eventually wind up in the , I 9! drinking water supply. That's part of the layout initially 10 of the reception centers, too, to look at that. i
. 11 0 I was going to ask you about that because at l
12 l your last deposition on February 3rd you said that the l l 13 State had procedures for looking at what happens to the 14 runoff water. 15 , A (Witness Papile) That's right. 16 < 0 I was going to ask you where are those , 17 ! procedures? l 18 A (Witness Czech) Maybe it should be just the I f 19 practice of actually going out with them, and I myself have
/
20 gone out with some of the State emergency worker PMC's to 21 look at the setup and appropriate places to put those along , l 22 l with the appropriate county and State officials. !
- i l I ,
i i ACE FEDERAL REPORTERS, INC. j l 202 347.)?00 Nationwide Coverage 800 136 6646
l
'9941 02 02 i
105 . r ysimons 1 i 0 Mr. Czech, also at that last deposition you said i 2 } that procedures that allow wash water to seep into the l 3 ground or enter the normal sewer system are consistent with I 4 EPA policy from the EPA PAC Chairman. l It was at page 180 )
! 5 !' of that last deposition for what that's worth.
6 l t Co you recall saying something to that effect? 7 : A I don't remember saying quite that, but I do ! 8 , believe tha t -- okay, EPA, which has a representative on i 9 the RAC review committee for New York State has reviewed 10 I these procedures in terms of the water from monitoring and i j. j 11 decontaminating personnel as well as vehicles either going , I i 12 l to sanitary sewers and/or into areas of the soil which are L / ,' 4 13 ! not going to impact upon public water supplies and found it 14 perfectly acceptable. j 15 , Apparently we do have something, I had 4
- 16 forgotten, in our Emergency Worker Booklet which talks I
17 about letting the contaminated runoff water from f 18 [i decontamination of cars to go into soil could be easily l 19 contained or removed at a later date and taken to locations ; i e 20 i away from streams, rivers, et cetera. I 21 0 i You are referring I think,to page 70 of that , ! 22 ; manual? l I i i ! ACE. FEDERAL REPORTERS, INC. I 202 347.)?00 Nationwide Coserage 300 33 M 446 I l
9941 02 02 106 i e ysimons 1 A Page 78, at least that's what I'm 1 coking at 2 right here. 3 , 0 78, and that's Panel Exhibit No. 2 that is being ;
! l 4 referred to t is that right? i 5 l A That is correct. i i
6l 0 Well, when you say that the Federal EPA has i i 7 l looked at that and found it acceptable, have you documented l I ! 8 that acceptance? 1 9 A Not in a letter form. The only areas -- and I'm l i 10 ; trying to think now -- would be they have reviewed, and i f 11 when I say "they" the RAC has reviewed and made comments on l 12 the Emergency Worker Booklet originally and do review the f i 13 ; appropriate parts of the plan. So EPA would look at the 14 parts of the plan dealing with contamination and i i 15 decontamination and handling the waste waters, and I don't l 16 believe we have any outstanding items that were raised by i 17 that. 18 A (Witness Papile) It is our understanding that 19 the EPA representative on the RAC has stated that that i 20 procedure is okay, but he would have to get approval from 21 the Super PAC which is located in -- all the federal 22 j agencies are located in Washington. That's our last l 1 i ace. FEDERAL REPORTERS. INC. l l '02 14 % )*00 Nationwide Coverage 400 136 6644 I
__ . . _ _ . - .. _.. . ~ _ _ - _ _ _ _ . . - . _ .__ l 7 e
! 9941 02 02 107 *
. I m ysimens 1 understanding of it. ! 2 0 And when was that understanding derived or when 3 d id tha t --- I i j 4 A Ch, quite a while ago, three or four years ago. 5 ' I 5 0 So you understood that the EPA PAC ' i ! )
, 6 representative is going to go to Washington and get --- .
1 i l j 7 ) A He said he had to go to Washington to get i i
- 8 ! written approval because we wanted it in writing. ,
l 4 I 9 0 But you never saw the writing. , f 10 I A No, we haven't, but we've got his approval and 11 he is our RAC member. l 12 0 But his approval is either oral, I take it --- j i 13 A Well, it was oral. There was a letter back i i
- 14 l there, way back and we can't find it, and so forth and so .
i ! l ! 15 ' on, written by Joyce. ' I; I i i 16 0 Written by whom? ' - 1 17 i A By a member of the EPA. [ i 18 0 What was the name? l L 19 A She's no longer there. The gentleman I'm t ,, 20 talking about, the RAC man, took her place. t 21 0 What was her name? !
, r 22 A Joyce Feldman.
i ! l ! l I
/\CE. FEDERAL REPORTERS, INC. E l 202 147 3700 Nationwide Coverage 800.))&%4 -
l I
. 9941 02 02 108 i
m vsimons 1 , O And you think there was at one time a letter 2 lfromheronthissubject? i I 3 ; A Yes, I do. l 4 0 But it can't be located any more? l 1 5 A I can't locate it. l l 6 0 Was there a letter, either that one or another 1 7 l in the context of a Nine Mile Point facility involving the i 8 release of wash water to the ground? t 9 (Pause while the witnesses confer.) f t 10 A Yes. It's a letter that you produced at our { I
, 11 last meeting, or a couple of letters that your partner 12 i p rod uced .
- 13 i O So the only letters you know, EPA correspondence l
; 14 on this subject are the two letters you saw at the last l
15 deposition plus this no longer existing letter from Ms. l 16 Feldman. 1 j 17 A Right. 1 18 A (Witness Czech) One additional comment that 19 comes to mind is that again at times when we have gone i / 20 through the offsite plan review with the RAC committee, 21 both members of REPG and the appropriate county or i ! l i 22 f counties, we went through the plan element by element. l l ACE. FEDERAL REPORTERS, INC. { l 202 147.)?00 . Nationwide Coserage 300 336 M46 I
9941 02 02 109 g r ysimons 1 This is NUPEG 0654 and it's a rather painful experience to 2 sit there for that long, and I do remember that at the 3 various FAC reviews that was one of the elements, the 1 4 dealing with the handling of contaminated waste water was 5 covered. And apparently from my recollection of those 6 various meetings, our procedures were satisf actory. 7 0 Is it the practice under any radiological l 8 emergency plan in New York State at any reception center in t 9 l New York State to catch the wash water from people and hold ( 10 it for monitoring and ultimate disposal? 11 A There are a couple locations where that is 12 possible and is done. There is one location in Westchester 13 l County where that's done, Valhalla, and I believe in the 14 Pochester area at Eastview, the State Emergency Worker PMC. 15 , (Pause while the witnesses confer.) , t 16 : I believe it's Eastview. It's the one with the , 17 ccT maintenance facility.
\ ,
18 A (Witness Papile) I don ' t know. I 19 0 The one at Eastview is a PMC for emergency
/
l t 20 workers? I i ! 21 l A (Witness Czech) Yes. 22 0 l And the Westchester County one was -- did you i l ,
! /\CE. FEDERAL REPORTERS, INC.
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9941 02 02 ; 110 r ysimons 1 l say valhalla? l 2 , A I believe it's Valhalla. 3 A (Witness Papile) That's for emergency workers 4 also. 5 l A (Witness Czech) Is it? Okay. I 6 , A (Witness Papile) That's for emergency workers. l l . 7 0 And in both those places they contain the water? , 8 , A (Witness Czech) They have provisions for [ 6 9 containing the watert that's correct? 10 0 What are, the provisions, do you know? 11 A They have underground tanks. I don't know I . i 12 l offhand what the dimension are, but they are large 13 underground tanks for holding water that could be monitored 14 i and then dumped into the sanitary system. 15 0 I see. So the plan is to hold it in the tanks 16 until it can be monitored? 17 A Right. , 18 0 What if the activity in tne water is too high to 19 release to the sanitary system?
/ I 20 A In at least one of the cases they have tankers 21 there that could actually pump it up and haul it 22 elsewhere. So there is more storage capability.
ACE.FeoeRat REPORTERS, INC. I
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I 9941 02 02 +?I l r ysimons 1 0 For the reception centers, not congregate care 2 . now, but reception centers at other power plants than I i i ; 3 Shoreham in New York State, what State permits are recuired ' l 4 ; before those facilities can be designated as reception > l 5! centers? i 6 MP. ZAHNLEUTER: I object. It calls for a legal I 7 conclusion. I , 8 ; MP. CHRISTMAN: You can answer it if you can. 9 WITNESS CZECH: To my knowledge today, we have 10 not needed any State permits.
! q 11 l WITNESS PAPILE: I don't know because that's
*I 12 l usually at the county level. I don't know. .
13 WITNESS BAPANSKI I'm not aware of any State 14 permits required to date for our reception center 15 operations. 16 ; BY MR. CHRISTMAN: ; i ! 17 O How about county permits of any kind, are you 18 aware of any of those that are required for reception i 19 centers? j i t 20 A (Witness Baranski) I'm not aware of any county I I 21 pe rmi t . l 22 A (Witness Papile) I'm not aware of any. l l l ! l ACE. FEDERAL REPORTERS. INC. ( l 202 347.)?00 Nanonwide Cosetage 800 136 4 4 l l
Attachm:nt 9
'IRANSCluP1 OF PRCCHEDIXGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-------------------.x In the Matter of: s
* ~ ~
~$
LONG ISLAND LIGHTING COMPANY :
* ~ ~
(Shoreham Nuclear Power Station, : Unit 1) , s DEPOSITION OF JOSEPH H. KELLER, PHILIP McINTIRE, IGOR W. KUZAR, and T!!OMAS E. BALDWIN New York, New York l
}
Friday, March 6, 1987 5 ACE-FEDERAL REPORTERS, INC. Stenotviv Rewtm 44 Nonh Capitol Street Wuhington. D.C. 20001 (202) 347 3700 Mtionwide Coverage 800 336 6646
. CR30089.0 ARTI/sjg i 1
__ UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 31 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- - - -x 4
lIn the Matter oft 5 : Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY : 6 (Shoreham Nuclear Power Station, a (ASLBP No. 86-533-01-OL a j Unit 1) : 7 8 i
, New York, New York 9i -
Friday, March 6, 1987 10 t 11 ; Deposition of JOSEPH H. KELLER, PHILIP McINTIRE, IGOR ti.
; KUIAR, and THOMAS E. BALDWIN, witnesses herein, held at the 12 O of fices of the Federal Emergency Management Agency; 26 Federal 13 Plaza, New York, New York, on Friday, March 6, 1987 at 10:00 a.m.
14 before Debra Stevens, a shorthand reporter and notary public, within and for the State of New York. u - 17 la . 19 . I 20 ;
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21 22 -- e ntinued -- ACE-FEDERAL w . w .,.,. REPORTERS, $.C.
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miJnt :3 d d one morer thinJ* *he 1v ! r o rP* m t 21 A o t: ar: t; i on A g r,nt y is t n .. f r t e! * ** t l og *ac < 4 which is charged with promulgating protective action
') ;u l dit u innd oromul J at ing f .? d o r:21 gu i dant;e on t: hit 6 acceptability of contamination, et c e t e r* a , 'In d doses.
And my r* e c o L l e c C i o n s' u l 14 me t)ers:.su a e f so)' *
* - m e. f ri b e* <- w h o t h e r* it is in t .", e O r i g i n t3 1 EPA
.a 7 nanunl i s r- in ene rira a f t ver sions of three chaptero 10 which .1 r e < u ra r e n t l y out for review, but t h e i r*
11
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.a m- 12 a t 2 t +9 9 ': n u t in terma of decontaminatton, no x, '
t .', rn e t h o rt s - - y o u shouldn't go to any grent omins to L *. a on n:s in e n >< w a r: < p r' . 15 1 A,n .ny t3 thic?
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1 "' -~ document ts nd t h a r ,. ta n o t: a o i J- <tiscourse on 'nv. t '. h i n k = ** n n <J O d u m O U l o n on my O /le' h . Uhot Un11 19 conservation of mass thing getu into it. 20 when you detcontamina t at , you <fon't creato
?l radioujtivity. VoiJ may have moved it, cleurly. You
.v u h svo movod it on<1 i n m:si or' m ai no t* our aood ar'
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2 i We may h ii v a = i n t e r + . My mrqa ' t :re t L ort w iy a .. t' p.4 L i: / ! 0 7. ..e a .n a r r . r' od esca, fau N., n ' : anew ! b 3 . n .. t n .. r e n e r ., re rrl i / 1> eo,ni.nc t !. .p; 0' r. w ., p o i., n ,3 4 s u t e r-catween Nas:nau Count / ond Suffolk Countfi 3 c oer ,50 e ? ' 6 WITNESS KELLER: That is corract. l 7 4. Ia it y our- t; er s t; f. m ein / t; no t e n , p o c '< c; >r ; P s,
<it'ientra.* ton of t h e.
or~ourirt w n t e r- I.i ,*J. 3 i r. c u , Cr r e '. 9 J .: e L v l.3 . 110 t t:itr* / 1 10 WITNESS KELLER: That in not what I LL acid. Whea t: I 2nid woa--what: I hoper I 10 1,1 wa1 P:h u t 12 l
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in comoorir.on with the orceletn that i t. going to no 7 r 1,1 3 4 40c f. a t ors w i t; h c on t am inta t:lon f r'om ther r) l ume , that 14 > t riw* **inen t u t Dr'nD19m anhocittted with the c o f" vi t i a l 1-~ 1% oc o o. it) 1. $ ftv t orit am I n.1 #: i. o n oe *: n . ; jc-p init , a !: er n . o. p . ... ; IL / v._ 4 In o vn'j G r* (it t 1 (_e f* < t 't . ll d l' ar t" v' n t M r' e ',
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\ f. fir o c t e m you had where the c l utn e went. Now, the plumv l LO ours go nil h h rt way t;o Nnssnu Courtcy aino.
20 C. Without cher acter izing the problem a t, L
'.' i t r' i v i ci e t or not trtvial, do you dor *eto t ha t; '
!!2 'e cr.t am i nn e i ein teor. efur a n e nu l ci tenes to i
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3 WI' NESS KELLE': Djoin. I <fo rot mova i 4 ,an y ttennicet knowleoge enout ene a < lu t f -t r . I e'a 5 uwure of the fact that r :sdio nuc liden in soils are 6 et s i:n.sngerd by the solla. I tjon ' t n.s v es any w rt o'c l et o g,s 7 that dacontaminution effort 3 in Nassau County at 1 e n . p, t h r .. .s a t t ,s.> c'au l d ,:on t.pn f.n s t ad tha P >un<t o water. ' 10 C. Do you disagree with the statement thac LL d esc on t;.;sm i n o t i on pr ocerour en could c on t in i n n t er tho 12 ground water? 13 WITNESS KELLER: Anything could muco*n. 14 Q. Do you na v er an/ on i rii ori ort t. h .i t th r
\5 tove1a 3* c.antomino i9n would be?
13 W I T N C 1:1 .< C L L *'..*t. ! I #- ;,i s i e f !)n m rortro. 17 .triette on the amount of r L - u a ++ d .s c, t i v i : e (a rne ll) 0 0 0 i dst n t . to Q. Do you have any coinion on whethar there 20 woiald t)e a hea l th t hraeat f r'o m contaminated w a t et t- o r-21 othera mat eraia l a running into ;, h e aewage s y n t ** r.1 an a or
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e - e 1 W ? N C 'S'i XCLL2R: I dort ' t urider J':and y. . , , , - 2 question, I*m sorry.
$ Q, You under S t;orid P' h . 3 0 t h e *' et S r' e - - t h -J C 4
recection centers and in und around the receotion 1 c a ri t: etr 1, ther t $2 r et l e* w.19 s t 3 / 3 t atm a5 y oe s would t' i ri d l,i 6 most semi-uroon areas.
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W C TNC'.30 XELLER : I c et ra t ra t ri l, y hono 30. 1 0, no you have a auffic':ent u n ete.r n t; a. m i.. ;
't o t' the LtLCO d.toon t ain i na t i ort pr ooouurita to kriow 10 whether or not contaminated wuter or other LL o oti t am i na t itd inn t atra la t a m igh t get t into the nowa'Jo 10 syt. tem?
(. '. 13 WITNESS KELLERf An I ntated, my Lt recollection of t h et o l cJ n 'v o l t h.3 0 tho Liquld ur'oduc*d i* wio t d oe cdu Jnc a n ct c artt a i n m f aret " 'i '* r1 t r un c o or* r t?rf
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10 run into surface water. 20 All of the othura 1,1 c e n a ct ef p i nrit s i ti FEMA 21 ccolon /II unct ino n e o f the other rerJionn in the
~92
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e .e I r un o t' f of that decontaninution g o et a to S t in d a r' d .1 2 sewage syst-ms, as does the r adioac t ive con amina::,,n 9 2
- am nosoitals that u s e- nonlear medicine in emeir 4 treatment. It is standar d practice that thi1 5 material go to the standard sewage system.
6 MR. McMURRAY: Would you read that 7 answer. please? 3 (R: cord MaJd.) 9 MR. CUMMING: Would it 39ertean this line LO of Questioning Lf we stipulated that Mr. Xoller L:1 11 not a geologist or sanitary engineer? r . 12 . MR. McMURRAY: Pr* o b a b l y not. ( 13 MR. CUMMING: In that case, could 14 c o u n a.t 1 t' o r Inter venors give ua a o m er auggeation h o .s t5 lon> m- .it3 c o n t i n u ** ? t> MR. McMtJRRAY.- I don *t 4 % 1 c!< 1O s(1l be 17 more than half hour. I don't know i t' anynna 4 13e nas 13 q u e as t L o n n . 19 MR. CHRISTMAN: I have five or ten 20 minutes. 21 MR. McMURRAY:
, Let's take a two or T' three ,n inu t o bro w .
COMPUTER AIDED TRANSCRIPTION / keyword index
7, Attachm:nt 10
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._ L J_.
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 JAMES CONRAD BARANSKI, JAMES DOMINIC PAPILE and LAWRENCE BRUNO CZECH Albany, New York
/ Tuesday, February 3, 1987 ACE-FEDERAL REPORTERS INC.
Stenotyw Mvrten W North Caettel stree: Wasiuneeon. b.C. 20001 (202) 34T 3700 Nationwide Coverage 800-336-6646
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c 01 01 I I 179 t marysimons 1 : MR. IRWIN: Just real quickly before we take a 2 : break, let me ask you if you have ever seen a letter dated 3 August 29, 1983, from Donald B. Davidoff to Mr. George 4l i Brower. 5 MR. LANPHER: You mean EF-77 6 MR. IRWIN: Yes. It has a label an top of it, 7l " Attachment 3," but I don't know what that relates to. I 8 would like it labeled as Exhibit 7. 9 (The document referred to was i 10 I marked reposition Exhibit f 11 l N'o . 7 for identification and b 12 i submitted for the record.) i: 13 (Pause while the witnesses examine document.) I 14 ' BY MR. IRWIN:
}
15 I O Mr. Czech, are you familiar with this letter? l 16 A (Witness Czech) Not this particular letter. 17 0 Are any of you familiar with it? I 18 ' A (Witness Baranski) No, not with this letter, no. i 19 A (Witness Papile) No. 20 0 Is the statement of policy in this letter 21 cansistent with New York State's policy as a whole 22 concerning disposition of contaminated water from vehicles .____._______________.3_
o , I l I s
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?
'. 01 01 ; o
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180 l merysimons 1 -at reception centers? 6 2 MR. ZAHNLEUTER: I object to the characterization 1
~
3l that it is a statement of policy. I ~r 4! BY MR. IPWIN: 1 5l 0 Is this letter consistent, Mr. Czech, with your L f 6i understanding of the procedures, with the substantive values i 7 embedied in the procedures to which,you were referring in J 8f our earlier question? 9 MR. LANPHER: Subs tar.ti e value? I i I BY MR. IRWIN: ' ' ' 10 l ~ 11 O Is it consistent with the procedures? I 12 ! A (fitness Czech) I would say yes. And not only 13 I that, this procedure -- and this goes b'ack now to '83, and a 14 lot has gone on since that time -- this has been consistent , i 15 ' with EPA policy from the EPA RAC chairman. 16 l MR. IRWIN: This would be a good time to take a i 17 break. I l 18 (Brief recess was taken.) i 19 j MR. IRWIN: Let's go back on the record. . 20 BY MR. IRWIN: i 21 ) , O In any of the exercises conducted in the New York i 22 State plants during the period of interest, have there been I l t t _ _
l
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. .-- . . . :. ... -:. : ::. . . c n ., f EXHisty
. 1 Al Y7 l STATE OF NEW YORK DEPARTMENT OF HEALTH vowe= sun.mwo e twe oevc==on = stso= 4. accuracusan twaiar av Art e64: A e 46 sue v. =.v. i 2n 9
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3* August 29, 1993 l l O
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m 1 $33 " SEP Smitlf tattELItf ft!PifiltlSE t Mr. George Brower ' Director - g ., Disaster / Emergency Preparedness 200 North Second street Fulton, NY 13069 f . Dear Mr. Brower
%P Raferring to your question today on 'the decontaminatierf i
of vehicles leaving the 10 mile EPE as to what problems may arise from water us*ad to wash off a. vehicle that may become contaminated, any major concern. we believe that this is not a problem that creates N'tisbelievedthatth small amount of contamination that may settle on a car will be diluted to a great extent by , washing and that this water can either seep into the ground or enter the sewer system. Care should be taken to see that the wash water does not enter the area where people gather. ! Esings fixatiand equip) ment second.TheI hope major this coroern information with contamination gives is still w 1 you*enough g'aidanoeito answer your questione. * ** Sincerely you , a f ,
& l* -
l nald D. Davidoff
' Director Radiological Emergency Preparedness Group 1
.h ee: Mr. Kowieski, FEMA
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STATQOF NEW YORK
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DEPARTMEm vr WALTd.
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- November 16, 1983 f.'
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i]! ! si ; L jf5!Mp!?r/; . NOV1 Igg 6 a Mr.GeErgeBrower nu u rm:an y.:., ::a Direc r . Disas Tr/ Emergency Preparedness '; - t.. q-g . 200 N th Second'5treet '- - Fulto NY 13069 ' ' g. Dear . Browers . s .
- The questica of what to do with waste shower water t 8a t ,, a become conta=1nated due tc the cleansing of a s conta=inated i. individual has been asked.-
( In cenaulistion with Dr. Karim Rimawi, Director, Bursal i'of Environmental Radiation Protectisn, it has been deter:.ined that such waste water should be allowed to flow ,I dirac lay into the normal. sewer system since it would be ,. great p diluted by the volume of t'ater in the system and , ther- ere poes no health problems. {<@c di T . .
; i .
-r h
i
, sincerely yours, J, n #
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- e- t nald . Day d
, . 4 .t. irector 6
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dialogical Emergency
, Preparedness Group
.6
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Q IL_ . -_
O e .] LILCO, April 17,1987 000 METED USNPC
'87 - APR 20 P2 51 CERTIFICATE OF SERVICE OFFICE OF Siet.TM Y 00ChETxi 4 MPVICF 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 Motion for Summary Dismissal or, in the Alterna-tive, Summary Disposition of the State Environmental Law Issue and Groundwater Issue were served this date upon the following by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid. Morton B. Margulies, Chairman ** Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers, Rm. 407 4350 East-West Hwy. Atomic Safety and Licensing Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline ** Washington, D.C. 20555 Atomic Safety and Licensing Board Richard G. Bachmann, Esq. ** U.S. Nuclear Regulatory Commission George E. Johnson, Esq. East-West Towers, Rm. 427 U.S. Nuclear Regulatory Commission 4350 East-West Hwy. 7735.Old Georgetown Road Bethesda, MD 20814 (to mailroom) Bethesda, MD 20814 Mr. Frederick J. Shon ** Atomic Safety and Licensing Herbert H. Brown, Esq. ** Board Lawrence Coe Lanpher, Esq. U.S. Nuclear Regulatory Commission Karla J. Letsche, Esq. East-West Towers, Rm. 430 Kirkpatrick & Lockhart 4350 East-West Hwy. South Lobby - 9th Floor Bethesda, MD 20814 1800 M Street, N.W. Washington, D.C. 20036-5891 Secretary of the Commission, Attention Docketing and Service Fabian G. Palomino, Esq. ** Section Richard J. Zahnleuter Esq. U.S. Nuclear Regulatory Commission Special Counsel to the Governor 1717 H Street, N.W. Executive Chamber Washington, D.C. 20555 Room 229 State Capitol Albany, New York 12224
0 O Mary Gundrum, Esq. Jonathan D. Feinberg, Esq. Assistant Attorney General New York State Department of 120 Broadway Public Service, Staff Counsel Third Floor. Room 3-116 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 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 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 New York, New York 10278 b.
James N. Cliristman Hunton & Williams 707 East Main Street P.O. Box 1535 l Richmond, Virginia 23212 DATED: April 17,1987 i l 1
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