ML20207A318
| ML20207A318 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/20/1987 |
| From: | Latham S, Mcmurray C, Zahnleuter R KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3214 OL-3, NUDOCS 8704270100 | |
| Download: ML20207A318 (23) | |
Text
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.f awl 00LKETED April 20, 1987USNRC UNITED STATES OF AMERICA 17 NH 23 P4 :26 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety andLicensinoBoarkOC d *>U U
BRANLH
)
In :he Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON MOTION TO STRIKE PORTIONS OF LILCO'S TESTIMONY ON THE SUITABILITY OF RECEPTION CENTERS Pursuant to 10 C.F.R. 5 2.743(c), Suffolk County, the State of New York and the Town of Southampton (the " Governments")
hereby move to strike the following portions of the Written Testimony of Charles A. Daverlo, Dale E. Donaldson, Edward B.
Lieberman, Roger E. Linnemann, Michael K. Lindell, Dennis S.
Mileti, and Richard J. Watts on the Suitability of Reception Centers ("LILCO Testimony"):
1.
the testimony of Dale E.
Donaldson concerning a " precursor" document to NUREG 0654 (LILCO Testimony at 8, Question and Answers 8-11); and 2.
the testimony of Charles A. Daverlo concerning the alleged monitoring capacities of relocation centers for selected nuclear plants other than Shoreham (LILCO Testimony at 12, Question and Answer 16 & Table).
?))D' 0704270100 070420 PDR ADOCK 05000 2
The Donaldson testimony should be stricken as irrelevant, immaterial, and prejudicial to the Governments.
Section J.12*of NUREG 0654 provides the relevant federal guidance concerning relocation (or reception) centers.
Donaldson's testimony purports to interpret S ?ction J.12 as it relates to monitoring capacity.
However, his testimony is based solely on his participation in developing a document which he claims was a draft " precursor" to NUREG 0654, but which (1) he cannot produce; (2) underwent wholesale revision before NUREG 0654 emerged; and (3) did not contain any language regarding reception center monitoring capacity.
Indeed, there is no evidence presented that the alleged " precursor" document was adopted in any manner when NUREG 0654 Section J.12 was issued.
The Daverlo testimony, particularly the Table which it introduces, is not only irrelevant, but also constitutes unreliable hearsay evidence.
The testimony is supported by nothing other than " contacts" with unidentified sources.
LILCO Testimony at 12.
As this Board is aware, LILCO has refused to identify the sources on which its hearsay evidence is based.
Thus, its admission into evidence would prejudice the Governments by denying them the oppor'tunity to conduct effective cross-examination.
For these reasons, as more fully set forth below, the referenced portions of the LILCO Testimony should be stricken from the record.
I.
The Donaldson Testimony Should Be Stricken As Irrelevant, Immaterial and Preiudicial1 A.
Irrelevance and Immateriality The Donaldson testimony concerning a so-called " precursor" to NUREG 0654 is wholly irrelevant to this proceeding.
Section J.12 of NUREG 0654 specifically addresses the adequacy of reception centers:
Each organization shall describe the means for registering and monitoring of evacuees at relocation centers in host areas.
The personnel and equipment available should be capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure EPZ arriving at relocation centers.
Mr. Donaldson purports to testify that in drafting a so-called " precursor" to NUREG 0654, he and other drafters of that
" precursor" had certain " beliefs" as to the number of people who would require monitoring at reception centers.
LILCO Testimony at 8 (Q&A 11).
However, there is absolutely no evidence presented in the LILCO Testimony that Mr. Donaldson's and his co-drafters' " beliefs" were in any way incorporated into NUREG 0654 Section J.12.
Mr. Donaldson acknowledges that his " precursor" document neither contained the language that was eventually adopted for Section J.12, see LILCO Testimony at 8 (Q&A 9), nor set focth the requirement that emergency planning should include monitoring for. _ _ _ _ _ _ _.
a t
members of the general public.
Egg id. (Q&A 10).
Thus, the i
LILCO Testimony establishes no link between the " precursor" document and the language or intent of Section J.12.1/
In the l
absence of any such link, the Donaldson testimony is both i
I irrelevant and immaterial.2/
Likewise, his role as a co-drafter of the precursor document does not qualify him to address whether i
LILCO's Emergency Plan and procedures comply with Section J.12 of k
NUREG 0654, as there is no evidence that he had any input 3
whatsoever on the issue.
1 Even the broad definition of " relevance" in the Federal Rules of Evidence does not encompass the Donaldson testimony:
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" Relevant evidence" means evidence having any tendency to make the existence of any fact that l
1s of consequence to the determination of the action more probable or less probable than it j
would be without the evidence.
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1/
Mr. Dcnaldson concedes that his precursor document was revised on the basis of input from public agencies.
He had no role in the formulation of NUREG 0654 once the precursor document left his hands, and only the " intent" of Section J.12 was presented in his original draft.
See Deposition of Dale Edward j
Donaldson (March 11, 1987), at 9-12 (Relevant portions attached i
hereto as " Exhibit 1").
l 2/
In Catawba, the Appeal Board excluded f rom evidence a staf f working paper which had been neither adopted nor sanctioned by the Commission itself and which neither represented nor purported to represent Commission policy.
See Duke Power Co. (Catawba j
Nuclear Station, Units 1&2), ALAB-335, 4 NRC 397, 416 (1976).
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Fed. R. Evid. 401. Donaldson's testimony as to his recollection of a subsequently revised " precursor" document has no relevance under even the most liberal reading of this Rule where, as here, there is no evidence that the " precursor" had any bearing at all on the language or intent of Section J.12.
Mr. Donaldson's recollection does not tend to make LILCO's Testimony on the meaning of NUREG 0654 Section J.12 any more probable than in the absence of that testimony.
Accordingly, the Donaldson testimony should be stricken.
B.
Best Evidence The best evidence of the " precursor" document is the document itself.
However, while Mr. Donaldson seeks to testify as to his recollection of the " precursor" document and the
" beliefs" embodied in it, the actual document either no longer exists or cannot be obtained.
LILCO Testimony at 8 (Answer 10).
Mr. Donaldson's recollection is not the best evidence of the precursor document.
In fact, it is hearsay testimony as to the contents of that precursor document.
In light of the apparent irrelevance and immateriality of his testimony, his hearsay
" recollections" are unreliable and will only serve to mislead this Board.
Thus, the testimony should be stricken. /
C.
Preiudice Admission of the Donaldson testimony would greatly prejudice the Governments.
As discussed above, the proffered testimony is so irrelevant as to be misleading and confusing.
Rather than presenting the best evidence of the precursor document, LILCO seeks to substitute Donaldson's hearsay recollection of " beliefs" and intentions existing at the time of the drafting of the
" precursor" document.
This hearsay testimony is particularly prejudicial because neither Mr. Donaldson nor LILCO have produced the " precursor" despite requests to do so.
Therefore, admission of the testimony will deny the Governments the opportunity to conduct effective cross-examination of Mr. Donaldson.
Moreover, the Board will have little evidence on which to assess the credibility of the testimony.
For this reason, again, the Donaldson testimony should be stricken.
II.
The Daverlo Testimony Should Be Stricken As Irrelevant and Unreliable Hearsay.
A.
Unreliable Hearsay In his testimony, Mr. Daverio offers data, in the form of a table, which purport to represent the monitoring capacities of relocation centers for certain New York State nuclear plants
( _-_______ _
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other than Shoreham.
The table was developed solely on the basis of " contacts" made by unidentified members of Mr. Daverio's staf f I
with unspecified county and utility personnel.
Egg LILCO l
l Testimony at 12 (Answer 16).
As such, the Daverio testimony is
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hearsay.
Indeed, the Daverio testimony consists of multiple levels of hearsay.
Not only are Mr. Daveri Ps statements hearsay, but they in turn are based on hearsay information given to him by his staff, which in turn is based on hearsay i
information from unspecified " sources."
Thus, the Daverio testimony consists of at least three levels of hearsay.
Such multi-leveled hearsay is inherently unreliable.
Furthermore, LILCO's refusal to identify the sources contacted makes the hearsay testimony even more unreliable.
Hearsay testimony is only properly admissible in administrative proceedings where it is accompanied by sufficient indicia of reliability.
Richardson v. Perales, 402 U.S. 389, 407-08 (1971);
Carter ))allace, Inc. v. Gardner, 417 P. 2d 1086,1095-96 ( 4 th Ci r.
n 1969),
I cert. denigd sub aqm. Carter-Wallace v. Finch, 398 U.S.
.i 938 (l"70).
Here, LILCO has made no showing that the proffered i
j testimony is reliable.
Thus, the Daverio testimony should be stricken as unreliable hearsay testimony.
LILCO's attempt to introduce unreliable hearsay while at the same time refusing to identify the sources contacted for purposes l
of developing the table in the LILCO Testimony is also prejudicial to the Governments.
LILCO's asserted grounds are i
that disclosure of the sources would lead to their harassment and i
1 4
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intimidation.
Egg Letter of Mary Jo Leugers, Esq. to Christopher M. McMurray, Esq. (April 3, 1987) (Attached hereto as
" Exhibit 2"); ggg also Suffolk County and State of New York Motion To Compel LILCO To Provide Sources of Data Relied Upon in Testimony (April 13, 1987).
This refusal denies the Governments any opportunity to conduct an appropriate investigation of the basis of the table for purposes of effective cross-examination.
LILCO cannot deny the Governments this right.
Admission of this testimony would thus unfairly prejudice the Governments.
For this independent reason, the table should be stricken.
B.
Irrelevance The Daverio testimony regarding the monitoring capacities of relocation centers for selected New York State nuclear facilities other than Shoreham is also irrelevant to this proceeding.
The Board has defined the scope of the hearing to be the adequacy of LILCO's provisions for monitoring at its reception centers.
Egg Memorandum and Order at 15-16.
The monitoring capacity of other relocation centers--in New York or elsewhere--simply has no bearing on whether LILCO can adequately provide for monitoring at its own designated reception centers in the event of a radiological emergency at Shoreham.
i L
t
CONCLUSION For the foregoing reasons, the following portions of the LILCO Testimony should be stricken:
1) the Donaldson testimony concerning a precursar draf t of NUREG 0654; and 2) the Daverio testimony concerning the monitoring capacities of relocation centers for selected nuclear plants i
other than Shoreham, l
Respectfully submitted, 1
Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex i
Veterans Memorial Highway Hauppauge, New York 11788
.c stopher M. McMurray
/
David T. Case
/
I KIRMPATRICK & LOCMHART 1800 "M" Street, N. W.
i South Lobby - Ninth Floor
[
Washington, D. C.
20036-5891 Attorneys for Suffolk County i
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j Ric'hard J. Zahq)'eugt
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Deputy Special Codsel to the Governor of the State of New York j'
Capitol Building Executive Chamber, Room 229 Albany, New York 12224 Attorney for Governor Mario M. Cuomo and the State of New York i
~ snY h bW
-~~
S tephen 41. Latham
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Twomey, Latham and Shea Post Office Box 398 i
33 West Second Street l
Riverhead, New York 11901 i
Attorney for the Town of Southampton 4
April 20, 1987
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EXHIBIT 1
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TIMNSCRIFF OF PROCEFDINGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
x In the Matter oft Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)
(Shoreham Nuclear Power. Station, a
Unit 1)
- - - - - - - - - - - - - - - - - - -x DEPOSITION OF DALE EDWARD DONALDSON Washingtcn, D. C.
Wodnesday, March 11, 1987 ACE-FEDERAL REPORTERS, INC.
$ltitCtyptityOttfr3 444 North Ca sitolStreet Washington, 3.C. 20001 (202) 347 3700 Nationwide Cmmge 800 336 6646
~
1
9 document to NUREG-0654 in our capacity as employees of the NRC.
Q What is that precursor document?
A It really was a draft document that was submitted to the steering committee that was used as a basis for the first revision.
That is the January 1980 revision of NUREG-0654.
Q So that precursor document, as you have identified, is a draft document that you or the two other gentlemen penned and then was submitted to a committee?
A That's correct.
Q What was this committee it was submitted to?
A It was called the Federal Steering Committee for Emergency Preparedness.
The name of the committee is in front of NUREG-0654.
Bryan Grimes was the committee chairman.
i Q
once your draft document was submitted to the l
committee, what procedures were followed, as you recall?
i A
To be honest about it, I have no knowledge of l
that.
The draft was published, and it went on the street to l
general comment.
Subsequent to that, revisions were incorporated based on input from agencies that had reviewed l.
ACE FEDERAL REPORTERS. INC.
10 the document, and revision 1 was then issued in November of 1980, I believe was the date.
October or November of
'80.
Q So there was a draf t published, comments, revisions incorporated, then the revised version was published?
A that's correct.
We refer to the first draft as interim guidance.
Q The revision 1 is what?
A That's revision 1 that you currently have.
If you flip to the page to the front, the first part of the manuscript, is that October 80?
Q Yes.
l A
that's the current revision.
i' Q
What role did you have in incorporating the comments that came in as a result of the interim guidance?
Did you have a function there?
?
A No.
Q So essentially, you created the original document but then --
A That's correct.
Q Your role after that was nonexistent?
A Essentially to use the document in inspections and Ace. FEDERAL REPORTERS, INC.
202.H7 3700 Nationwide coverase soo.336-6646
11 evaluations.
Q Should it be called planning standard J.12?
What's the proper terminology for J.12?
A Planning standard J.12.
It is usually ref erred to by the generic number.
That's the best way.
Q I assume you are familiar with that provision?
A Yes.
Q Was it incorporated to your recollection in the original draft that you submitted?
A Not 1,n the form that you see it there.
Q What form was it submitted in?
A The original provisions for off-site relocation were handled in I guess what would best be, described as a holistic fashion, where elements of it were incorporated into different portions of the planning process.
It was not a stand-alone criterion.
Since rarely are there things in emergency preparedness which are stand-alone and should be looked at or implemented in a stand-alone fe.shion, I might also mention that the original draf t had two sections.
The first section was written specifically for licensees of the NRC, and the language and tone was written in a manner that they would be able to unders tand and be directed toward their Acs FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 3M4646
12 l
needs, and section 2 was directed toward state and local
)
I planning.
Q What was the catalyst for the J.12 becoming a separate Provision?
A I don't know.
Q Do you have any knowledge of how the decision was1 1
made to make J.12 a separate provision?
A No.
In fact I have not even been able to find it in any of the public comments, so I could only give you conjecture as to why it was.
Q-What is your co,nfecture?
A, That some individual in the rev'iew process in the commission wanted it in there.
That's not an unusual way fo:
things to happen.
Q Was the substance of J 12 incorporated within your draft?
A Yes.
I might add intent more than substance.
Q What was the intent?
A The intent of our original draft publication was to, in this particular area of interest, was to recognize that there's a need to grade the types of preparedness that you have and to recognize that there is some highly ACE FEDERAL RsponTEas, INC.
202 347 3700 Nationwide Coverage 800-336 4 46
pmmumiiim 16 the effect where we had said, there should be provisions for monitoring instrumentation at off-site assembly areas.
We're not specifying the types or the numbers, but provisions for it.
Whether that instrumentation would come from someplace else and be transported, whether it would be stockpiled in some small number there or provided by a supporting agency was less important than the fact that the provisions were clearly worked out.
So throughout the entire document, almost every organization -- we might have another provision, in fact did have provisions where the organization should clearly specify the duties, function's and responsibilities of the various elements of the response organization, and in this case, also being an inspector, we would look for where the functlern for monitorings of individuals might be.
That function may be within the licensee's organization, it might be within the state, or it might be combined with state and federal.
It would depend.
Throughout the entire planning i
scheme, therefore, we sort of considered that to be a consideration t. hat's interwoven in every aspect of the response.
Q In your original draft, did you provide that each organization should describe the means for registering and ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336.6646
17 monitoring of evacuees at relocation centers?
A In those words?
Q Well, let's start in those words.
A No, not in those words.
Q Did you have something you believed in effect made that same statement?
A I would say similar.
I wouldn't say the same.
Some provision for monitoring, yes.
I would say.
Q Did you have in your original draf t a statement that required that personnel and equipment available should be capable of monitoring, within about a 12-hour period, all residents and transients in the plume EPZ arriving at relocation centers?
A No.
Q Did your original draf t have any time period for monitoring focused within it?
A Not in a direct fashion, no, no period at all.
Q In an indirect fashion?
A Not really.
Q Do you know how that 12-hour time period came to be incorporated within J.12?
A No idea.
ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 8CO 33 4 646
18 Q
And it also indicates that within about a 12-hour period all residents and transients in the plume exposure EPZ arriving at relocation centers should be monitored.
Did your original draft encompass all residents and transients arriving at relocation centers?
A No, it did not.
Q Do you know how that language got in the provisions of J.12?
A Not that language particularly.
In relation to the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the discussion I had with -- Ray Priebe apparently had some knowledge of that, indicates that the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as he was aware of it -- indicates people who had.
arrived within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, whoever they night be, that was sort of like the limit of time.
Not that it had to be within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, but anybody who arrived within the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Q Did Mr. Priebe to your knowledge have a different role once the draft was submitted?
A Not to my knowledge, no, not in relation to this dociinent.
MR. CASE:
If we could have marked as Donaldson 1 this document.
(Donaldson Exhibit 1 identified.)
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VIA TELECOPY Christopher M. McMurray, Esq.
Kirkpatrick & Lockhart South Lobby - 9th Floor 1800 M Street, N.W.
Washington, D.C.
20036-5891
Dear Chris:
This letter responds to your latest request for informations we received it at 5:00 p.m. yesterday and so could not make much progress on responding to it until today.
First, the basis for the statement on page 12 of LILCO's testimony about " contacts made by (Mr. Daverio's) staff with county and utility personnel
- are the documents identified as Nos. 5 and 6 in Section III of LILCO's Responses and Objections (dated February 4, 1987) to your first As we said then, both documents are workset of interrogatories.
enclosing them for you in order products however, we are have redacted the names of individualsto avoid a needless dispute.
We from the first of the documents.
Your latest request seems aimed at the identity of the people contacted, and we object to producing those names on the grounds stated in our February 4, response to your Interrogatory No.12, particularly the ground that disclosure might subject indisiduals to harrassment and intimidation.
We might add that, sirce LILCO's testimony names the counties, and since your client and the State surely have better access to information about the capabilities of those counties than LILCO has, we do not believe you can show any substantial need to 9'et this information from LILCO.
Second, Dr. Lindell has informed us that he does not have access to the raw data files for the first study mentioned in his testimony; the data are stored on a computer at Battelle Memorial Institute.
If the data and figures in the Nuclear Safety article are not sufficient for your purposes, Dr. Lindell says th'at it
H UNTON & WILLI AM S Christopher M. McMur ray, Esq.
Apr il 3,1987 Page 2 l
would be possible to hire someone at Battelle to run all the data on the computer.
Please let us know if you wish to bear this expense.
hs you know, Dr. Linde11's secCnd study has not been completed.
Thus f ar, we have provided you his summary sheet containing the results of the f requency analysis.
This sheet
)
his manuscript.contains all the data Dr. Lindell will be looking at in preparing dif ficult, because it wouldTo copy the f requency data themselves would be that may have data written on the perforated edges. require separating print-out p If you feel that the summary sheet is not adequate and that you need the raw data as well, Dr. Lindell can have the six diskettes containing
[
the key-punched data copied, at your expense, and sent to you for
[
your own analysis.
(
Third, apparently you have misconstrued Jim Christman's letter of March 17, 1987.
Dr. Milett has not conducted additional analyses in support of his testimony.
Rather, the data you request are from studies he conducted several years ago, which came to eur attention the week-end of March 21, we anticipate having these data, or a citation to where they are publicly available, for you on Monday.
Fourth, as we discussed earlier today, the underlying data for KLD TR-201 will be produced for you on Monday, since you indicate you cannot use them stored on a disk, which could be provided to you tomorrow.
Consistent with our past arrangements, we will expect Suf folk County to cover the cost of reproducing the documents.
Fif th, LILCO has not yet written the information sheet to be disseminated to evacuees at the reception centers.
I hope this answers the questions raised in your letter of yesterday.
If you have know.
any fur ther inquiries, please let us Sincerely, Mary Leugers 443/735 cc:
James N. Christman, Esq.
Stephen W. Miller, Esq.
00LKETED April 20#S1V87 UNITED STATES OF AMERICA in MR 23 P4 :26 NUCLEAR REGULATORY COMMISSION k
OFFICE ET L-t its Before the Atomic Safety and LicensinaDEDard'i t SERV!U BHANCH
\\
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON MOTION TO STRIKE PORTIONS OF LILCO'S TESTIMONY ON THE SUITABILITY OF RECEPTION CENTERS have been served on the following this 20th day of April, 1987 by United States mail, first class, except as otherwise noted.
Morton B. Margulies, Esq., Chairman
- Joel Blau, Esq.
Atomic Safety and Licensing Board Director, Utility Intervention U.S. Nuclear Regulatory Commission N.Y. Consumer Protection Board Washington, D.C.
20555 Suite 1020 Albany, New York 12210 Dr. Jerry R. Kline*
William R. Cumming, Esq.*
Atomic Safety and Licensing Board Spence W. Perry, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C.
20472
Mr. Frederick J. Shon*
Anthony F.
Earley, Jr.,
Esq.
Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 Ms. Elisabeth Taibbi W. Taylor Reveley, III, Esq.*
Clerk Hunton and Williams Suffolk County Legislature Post Office Box 1535 Suffolk County Legislature 707 East Main Street Office Building Richmond, Virginia
'!3212 Veterans Memorial Highway Hauppauge, New York 11788 Mr.
L.
F.
Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 "H"
- Street, N. W.
Smithtown, New York 11787 Washington, D.C.
20555 Mary M. Gundrum, Esq.
Hon. Michael A.
LoGrande New York State Department of Law F"ffolk County Executive 120 Broadway, Third Floor H. Lee Dennison Building Room Number 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite "K"
Post Office Box 231 San Jose, California 95125 Wading River, New York 11792 i
Martin Bradley Ashare, Esq.
Fabian G.
Palomino, Esq.
Suffolk County Attorney Richard J.
Zahnleuter, Esq.*
Bldg. 158, North County Complex Special Counsel to the Veterans Memorial Highway Governor of the State Hauppauge, New York 11788 of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Mr. Jay Dunkleburger Richard G. Bachmann, Esq.*
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency Building 2 Washington, D. C.
20555 Empire State Plaza Albany, New York 12223 _ _
r David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick and Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 West 43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 Chfistophe'r M.
McMurray '
KIRKPATRICK & LOCKHART 1800 "M"
Street, N. W.
South Lobby - Ninth Floor Washington, D.
C.
20036-5891
- Via Telecopier April 20, 1987 I
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