ML20207Q273
| ML20207Q273 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/16/1987 |
| From: | Cumming W Federal Emergency Management Agency |
| To: | SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2240 OL-5, NUDOCS 8701270112 | |
| Download: ML20207Q273 (5) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 JAN 20 P4 :16 Before the Atomic Safety and Licensing Board GFFna 00Cr.r T. -
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station, Unit 1)
)
)
FEMA SUPPLEMENT TO SUFFOLK COUNTY FIRST INTERROGATORIES FEMA hereby supplements its answers to Suffolk County's First Set of Interrogatories as follows:
Interrogatory # 10:
In addition to those. individuals named in the previous supplemental filing, the following individuals were informed, on the evening prior to the press conference, of the Frank Petrone statement: (1)
Marianne Jackson; (2) Joseph Keller; (3) Thomas Baldwin; (3) William McAda.
-Additionally, FEMA Counsel has had information brought to his attention that in the FEMA Response to the Motion to Compel, dated December 1,1986, the legal argument was premised, in part, on factual misunderstandings do to the unavailability of Mr. Rogsr Kowleski. Although the Board has since ruled on December 17, 1986, and January 9, 1987, on the motion FEMA Counsel believes this correction is warranted.
Accordingly, the Motion is revised as follows:
Page 4, at lines 8 and 9:
The statement that the RAC members developed the PEA is misleading.
Personnel from the Argonne National Laboratory staff drafted the Report.
These drafts were prepared from the individual Exercise Evaluation Critique Forms (EECFs) and comments on the drafts made by the evaluators, including the RAC members.
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6 Page 14, at lines 1 and 3:
The RAC was not convened to write the PEA.
See comment for page 4 above.
Page 14, at line 10:
There was never any attempt to obtain absolute consensus on the content of the PEA. As stated in line 6, the RAC Chairman made decisions on the final versionof the Report.
Page 17, at ilne 19:
See comment for page 14 at line 10 above.
Respectfully submitted, 4 e.4-William R. Cumming Counsel for FEMA Dated the 16th day of January, 1987 at Washington, D.C.
5hifD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of
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)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " FEMA'S SUPPLEMENT TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES DATED JANUARY 16, 1987" in the above-captioned proceeding have been served on the following by deposit in the United States mall, first class this 16th day of January, 1987:
John H. Frye, III, Chairman Fabian G. Palomino, Esq.
Administrative Judge Richard J. Zahnleuter, Esq.
Atomic Safety & Licensing Board Special Counsel to the Governor U.S. Nuclear Regulatory Commission Executive Chamber Washington, D.C.
20555 State Capitol Albany, NY 12224 Oscar H. Paris W. Taylor Reveley III, Esq.
Administrative Judge Hunton & Williams Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission P.O. Box 1535 Washington, D.C.
20555 Richmond, VA 23212 Frederick J. Shon Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, D.C.
20555 Albany, NY 12223
-d Stephen B. Latnam, Esq.
John F. Shea, III, Esq.
Herbert H.. Brown, Esq.**
I Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
o Attorneys at Law Karla J. Letsche, Esq.
P.O. Box 398 Kirkpatrick & Lockhart 33 West Second Street 1800 M Street, N.W.
Riverhead, NY 11901 9th Floor Washington, D.C.
20036-5891 Atomic Safety and Licensing Board Panel Joel Blun, Esq.
U.S. Nuclear Regulatory Commission Director, Utility Intervention Washington, D.C.
20555 NY State Consumer Protection Board Suite 1020 Atomic Safety and Licensing 99 Washington Avenue Appeal Board Panel Albany, NY 12210 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Docketing and Service Section Wading River, NY 11792 Office of the Secretary U.S. Nuclear Regulatory Commission Philip II. McIntire Washington, D.C.
20555 Federal Emergency Management Agency 26 Federal Plaza Spence Perry, Esq.**
New York, New York 10278 General Counsel, Rm. 840 Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 Robert Abrams, Esq.
Attorney General of the State Gerald C. Crotty, Esq.
of New York Ben Wiles, Esq.
Attn:
Peter Bienstock, Esq.
Counsel to the Governor Department of Law Executive Chamber State of New York State Capitol Two World Trade Center Albany, NY 12224 Room 46-14 New York, NY 10047 Anthony F. Earley, Jr., Esq.
MHB Technical Associates General Counsel 1723 Hamilton Avenue Long Island Lighting Company Suite K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501 Hon. Peter Cohalan Martin Bradley Ashare, Esq.
Suffolk County Executive Suffolk County Attorney County Executive / Legislative Bldg.
H. Lee Dennison Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, NY 11788 Hauppauge, NY 11788
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Mr. Jay Dunkleberger Ms. Nora Bredes New York State Energy Office Shoreham Opponents Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, NY 11787 Albany, New York 12223 Ellen Blackler Mr. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Energy Committee Ms. Sharlene Sherwin 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Bernard M. Bordenick, Esq.
475 E. Main Street U.S. Nuclear Regulatory Agencyg Patchogue, NY 11772 7735 Old Georgetown Road Bethesda, MD 20814 H1111am R. Cumming Federal Emergency Management Agency
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