ML20207Q309
| ML20207Q309 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/15/1987 |
| From: | Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#187-2246 OL-5, NUDOCS 8701270147 | |
| Download: ML20207Q309 (45) | |
Text
r j2,fb 00LMETED USHRC January 15, 1987
'87 JAN 20 P3 :48 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFF:a ^:
. A.
00CKUUA -
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Before the Atomic Safety and Licensino Board EA "
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
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Unit 1)
)
)
RESPONSE OF SUFFOLK COUNTY, THE STATE OF NEW YORK, AND THE TOWN OF SOUTHAMPTON IN OPPOSITION TO "LILCO'S MOTION TO COMPEL SUFFOLK COUNTY, THE STATE OF NEW YORK, AND THE TOWN OF SOUTHAMPTON TO RESPOND TO LILCO'S FIRST REQUEST FOR ADMISSIONS AND THIRD SET OF INTERROGATORIES AND REOUEST FOR EXPEDITED RESPONSE AND DISPOSITION" On January 5, 1987 LILCO filed a motion entitled "LILCO's Motion to Compel Suffolk County, the State of New York, and the Town of Southampton to Respond to LILCO's First Request for Admissions and Third Set of Interrogatories and Request for Expedited Response and Disposition" (hereafter, " Motion" or
" Motion to Compel").
Suffolk County, the State of New York, and
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the Town of Southampton (hereafter, " Governments") hereby demonstrate that the Governments have already responded as fully and adequately as possible to LILCO's discovery requests and that the Motion to Compel must therefore be denied.
EA'"lEN E550!*
6 35
s I.
INTRODUCTION "LILCO's First Request for Admissions and Third Set of Interrogat6tles' Directed to Suffolk County, New York State, and the Town of Southampton" (hereafter, " Request for Admissions"),
filed by LILCO on December 1, 1986, consisted primarily of a request that "Intervenors admit or deny.
as to each and every entry on the attached timeline, that LILCO's Timeline of the Exercise Events accurately states the exercise events and communications recorded in LERO player logs and messages."
The referenced " attached timeline" consisted of 278 pages, each page containing an average of 10 entries, each of which purportedly was either the complete text of the log or message or, when such log or message was lengthy, an accurate summary of every writing contained on message forms and logs, generated by LILCO players during the February 13, 1986 Exercise.
LILCO counsel has represented orally to counsel for Suffolk County that the timeline was prepared by secretaries in the offices of Hunton &
Williams, not by counsel.
Following receipt of the Request for Admissions, counsel for Suffolk County on behalf of the Governments engaged in discussions with counsel for LILCO in an effort to reach an l
agreement, by way_of stipulation or otherwise, to avoid unnecessary disputes during trial concerning the authenticity of Exercise documents and the times at which Exercise events of relevance to admitted contentions occurred or were simulated to 4 t
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i have occurred.1 When no such agreement had been reached, the Governments filed on December 22, 1986, a " Response of Suffolk County, the State of New York, and the Town of Southampton to
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LILCO's First Request for Admissions and Third Set of Interrogatories" (hereafter, " Response").
The Governments' Response went as far as it could in terms I
of admitting or denying matters related to the timeline.
- Thus, the Governments stated:
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Counsel for LILCO has tepresented that the entries set forth in LILCO's 278 page ' time-line' are a ' compilation,' prepared by secre-taries in the office of Hunton & Williams, of message forms and logs prepared by LERO players during the February 13 Exercise.
The Governments received what purports to be a complete set of all such messages and logs generated during the Exercise from LILCO, and admit that such documents were in fact prepared by the LERO players indicated on such documents during the Exercise and that the notations contained in such documents were made at approximately the times indicated on the documents that they were made.
Based upon l
representations by LILCO's counsel that the set of documents provided to the Governments are a complete set of documents generated during the Exercise, the Governments also admit that to the best of their knowledge, there are no other documents generated by LERO players during the Exercise reflecting events that occurred during the Exercise.
The Governments are also willing to stipulate and reach agreement with the other parties upon a set of Exercise-generated documents upon which all parties could draw in connection with the Exercise litigation, to avoid the need for multiple copies of similar or the same messages or logs in prefiled testimony or for use during cross examination.
1 The Governments advised the Board of these ongoing efforts on December 15, 1986.
Egg Notice Concerning Governments' Response to LILCO's First Request for Admissions, December 15, 1986.. _._.._.
e Response at 2-3.
However, the Governments also explained why the Governments could not go further to admit or deny the approxi-mately 2,780 requests for admission contained on the LILCO time-line.
Beyond the above statements (i.e., those quoted immediately above], the Governments are unable to respond to LILCO's Request for Admissions.
The 278 pages of summaries of Exercise generated documents are not only-voluminous, but they purport to cover huge numbers of Exercise messages and references that have no relevance to admitted contentions or matters in controversy.
In addition, because the entries in the LILCO 'timeline' are very brief summaries of, in some cases, detailed or lengthy notations on Exercise documents, the Governments cannot agree to the characterizations contained in such summaries.
Furthermore, since many of the referenced
' events' in Exercise-generated documents in fact never happened at all, but instead were simulated, or reflect LILCO-generated assumptions, or ' events' that were ' pretended' by Exercise players during the Exercise, the Governments clearly cannot ' admit' that so-called ' events,' mentioned in Exercise players' documents, occurred at the times noted, as LILCO requests.
Response at 3.
Despite the explanation provided in the Governments' Response as to why the Governments could neither admit nor deny the almost 3000 entries in the timeline, LILCO filed the Motion to Compel.
Some basic _ factual background is necessary to assist the Board in ruling on the LILCO Motion.
The so-called " exercise-day" documents, some samples of which are attached hereto, amount to approximately one and one-half file drawers of paper, most of which consist of individual one-page documents.
The vast o
e majority of them are " message forms," such as those set forth in attachments A, C, E, G, and H.
In many instances during the
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Exercise, purportedly the same or similar " messages" were transmitted to and from multiple LERO senders and recipients within a relatively short timeframe (itgt, 30 minutes or so),
some because the information was substantively important to the sender or recipient, but many only for " informational" purposes, or because the transmittal up and down organizational chartlines was called for by procedure.
Thus, many of the messages and their timing are substantively unimportant.
And, while the review of the entire set of Exercise documents is helpful as
+
background to gain an understanding of how the totality of LERO functioned during the Exercise, many aspects or events during the Exercise -- which may have generated many messages or documents
-- are of little if any direct relevance to the issues raised in the admitted contentions.
Thus, while the parties may have occasion in testimony to show a chain of communication by describing or referring to a group of related Exercise messages, that certainly will not be done with respect to all, or even the majority, of the messages generated during the Exercise and entered on the LILCO timeline.
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o II.
SUMMARY
OF ARGUMENT A.
The Governments Cannot Respond Further to the Recuest for Admissions There-are rultiple reasons why the Motion to Compel must be denied, and we summarize them here.
First, the Governments can neither admit nor deny the accuracy of the timeline as to whether the events did in fact occur or as to whether the timeline accurately reflects the exercise events as recorded in LILCO player logs and messages.
The number and location of Government observers during the Exercise were severely limited, and thus the Governments did not witness the large majority of communications or. events contained in the timeline.
In addition, such observers as were permitted were not privy to the numerous discussions that make up much of the message forms and logs upon which the timeline supposedly relies.
And, since many of the events were simulated and in many cases the Governments do not know which events in the timeline were simulated and which actually took place, the Governments are not in a position to admit or deny J
their accuracy.
Egg Section III.A below.
Second, even a cursory review of the timeline against the actual Exercise documents reveals that it is grossly inaccurate and thus provides_no basis upon which to expect other parties to have to file responses.
The Governments have attempted to respond to LILCO's admissions request by comparing certain entries in the timeline with the LILCO player logs and message forms from which they were purportedly taken.
For example, 4 1
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during one five hour period, an attorney for Suffolk County was able to compare sixty-eight entries from the timeline with the documents from.which they were purportedly taken.2 Despite LILCO's assertion that the timeline is a " complete chronology" of the Exercise events (agg LILCO Motion to Compel at 4), it was discovered that many items noted on message forms were not on the timeline at all.
Even more important, the comparison of timeline entries and LILCO documents which purportedly formed the basis of the timeline entries revealed that not one of the sixtv-eicht entries checked contained the "comolete text of the loa or messaae form from which they are drawn" as LILCO claimed most of them did (agg LILCO's Motion to Compel at 4).
The entries checked proved to be, at best, summaries of the actual messages in the LILCO player documents; however, many " summaries" clearly misrepresented the meaning of messages, left out critical events, or had blatant inaccuracies.
The Governments' attempt to respond to the timeline thus revealed that the timeline is not a complete and accurate chronology of the Exercise even as set forth in the LILCO player logs and message forms.
Rather, it is full of inaccuracies and omissions.
The Governments should not be forced to spend attorney time responding to a Request for Admissions concerning such a document! ~ Sag Section III.B below.
2 The Suffolk County attorney reviewed randomly chosen LERO message forms and then checked for the corresponding entry on the timeline..
Third, in addition to the numerous omissions and inaccura-cies contained in the timeline, the Request for Admissions is extremely voluminous.
The timeline contains roughly 2,780 individual requests for admission.
This is a far cry from the 223 requests for admission which the Governments served on LILCO and which LILCO compares with its Request (agg LILCO Motion to compel at 5).
Initial review demonstrates that merely to verify that entries in the timeline match player documents would take over 200 attorney hours.
This does not include the time necessary to attempt to document what the actual entries in player logs and message forms say, as opposed to the characterizations or " summaries" in th'e LILCO timeline.
The a
sheer volume of such a task, a task that LILCO counsel apparently never bothered to perform themselves, is overly burdensome.
Egg Section III.C below.
B.
The Governments' Actions and Suggestions Are Not Wasteful, and Make Much More Sense Than Restating Exercise Documents The purported bases for LILCO's request that the Governments admit or deny the accuracy of all the entries on its timeline is "to foster () judicial economy by obviating the need to introduce numerous documents in testimony and hearings to establish what
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happened during Ehe FEMA Exercise."
Motion at 3.
LILCO asserts f
that forcing the Governments to admit or deny the entries on the timeline would "streamlin(e) the hearing process."
Id.
- And, during the discussions among counsel prior to the filing of the
. 1
O Governments' Response, LILCO understood the goal to be a stipulation as to the authenticity of Exercise documents as well as to the ac_c,uracy of the times listed in such documents.
Id.
In fact, the Governments have gone as far as reasonably could be expected in attempting to " streamline the hearing process" by eliminating disputes concerning the authenticity of documents or the ability of the parties to rely upon Exercise documents during the trial.
These Government efforts are ignored in the LILCO Motion, but they are quite extensive and signifi-cant.
They support the Governments' position that they have already fully and adequately responded to LILCO's Request for Admissions and thus support the need to deny LILCO's Motion.
Specifically, in their Response, the Governments admitted that:
1.
The Exercise documents "were in fact prepared by the LERO players indicated on such documents during the Exercise."
2.
"The notations contained in (the Exercise documents]
I were made at approximately the times indicated on the documents that they were made."
3.
The Exercise documents "are a complete set of documents generated during the Exercise."
i 4.
Other than the Exercise documents, "there are no other documents generated by LERO players during the Exercise reflecting events that occurred during the Exercise."
Response at 2.
Further, the Governments also indicated that they are:
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willing to stipulate and reach agreement with the other parties upon a set of Exercise generated documents upon which all parties could draw in connection with the litigation, to avoid the need for multiple copies of similar or the same messages or logs in pre-filed testimony or for use in cross-examination.
Id. at 3.
This proposal -- in essence, to treat an agreed upon set of Exercise documents as an exhibit, similar to the treatment given in past litigation to the LILCO Plan and procedures --
would " foster judicial economy" in a way that does not force the wasteful squandering of resources on irrelevant, unnecessary or useless tasks, yet permits all parties to present their affirmative cases in an efficient manner.
Moreover, in their requests for admissions to LILCO and FEMA, the Governments proposed -- and in a substantial majority of instances obtained -- agreement as to the times, events, and other salient facts that are actually at issue in the admitted contentions.3 The Governments also remain prepared to discuss with the other parties possible additional stipulations as to times or sequences of relevant Exercise events, beyond those already agreed upon (if any).
All such efforts by the 3
Egg Suffolk County, State of New York and Town of Southampton's First Request for Admissions and Second Set of Interrogatories Directed to LILCO (November 5, 1986) and LILCO's Response thereto (November 17, 1986); and Suffolk County, State of New York, and Town of Southampton's First Request for Admissions and Second Set of Interrogatories Directed to FEMA (November 4, 1986) and FEMA's Response thereto (November 19, 1986).
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Governments are a productive use of counsel's time and energy; correcting a 300-page conglomeration of relevant and irrelevant entries fraugbt with errors and omissions is not.
II.
DISCUSSION LILCO claims that the Governments' inability to respond to its requests for admission is " disingenuous and unsubstantial" (see LILCO Motion to Compel at 4).
These strong words fail to take into account the clear explanation provided in the Governments' December 22 Response.
For the reasons stated therein and in this response, if the Governments were forced to.
respond any further to the LILCO Requests, it would consist merely of a restatement of the fact that the Governments cannot admit or deny the entries on the LILCO timeline.
A.
The Governments Cannot Respond as to Whether the Events Actually Occurred LILCO's admission requests and the related interrogatories essentially ask the Governments to perform an impossible task.
LILCO asks the Governments to admit or deny whether the timeline
" accurately states the events and communications recorded in LERO player logs and messages."
Request for Admissions at 1.
(As discussed in Subpart III.B below, contrary to the implication in this LILCO request, the timeline is clearly not even accurate itself.)
LILCO then goes on to request that the Governments
"(s] tate the exact portion of each timeline entry which is not d. _-- _ _ _ - -
4 admitted, and for each (a) the reason it is not admitted or (b) the reason Intervenors cannot truthfully admit or deny it."
- 14. at 2.
The Governments clearly are n21 in a position to respond to these requests beyond the response already provided in the Governments' December 22 Response.
The Governments were extremely limited as to the number and location of observers who could be present at the February 13 Exercise.
And, the i
Governments' observers were not permitted during the Exercise to speak to any of the LILCO players or to get close enough to review at that time log entries or messages which were prepared.,
Thus, the Governments' observers did not witness most of the events listed in the timeline.
Lacking personal knowledge of whether these events did or did not occur, the Governments can neither admit nor deny their accuracy.
Further, since most of the entries on the timeline were based on conversations between LILCO players to which the Governments' observers were not privy, the Governments can neither admit nor deny whether those conversations actually took place.
Clearly, the only individuals who can know whether these events and conversations actually occurred are the LILCO players who participated in the events and/or conversations in question.
Thus, for this reason in
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addition to those stated in the Governments' December 22 Response, the Governments cannot admit or deny the accuracy of the entries in the LILCO timeline.
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Further, the Governments cannot admit nor deny individual entries because many of the so-called events described in the entries were simulated and, in fact, never occurred.
This is not, as LILCO claims, "a calculated refusal to deal with the basic premise of the exercise -- a hypothetical accident at the plant" (agg LILCO Motion to Compel at 10).
The fact is that in many instances the Governments do not know if the entries on the timeline relate to real or simulated eventa.
Without such knowledge, the Governments are not in a position to be able to admit or deny whether the entries " accurately state [] the exercise events," as opposed to matters simulated, assumed, or pretended by players, or set forth as ground rules or scenario assumptions.4 4
Even LILCO does not appear to know in some instances what happened during the Exercise.
For example, the County separately asked LILCO and FEMA whether the U.S. Coast Guard actually participated in the Exercise.
LILCO answered on November 17, 1986, stating that the Coast Guard had not participated except for accspting one or two phone calls.
Egg LILCO's Response to Suffolk County, State of New York and the Town of Southampton's First Request for Admissions, at 1, 5, and 6.
FEMA, on the other hand, asserted on November 19, 1986, that the Coast Guard had participated and even had dispatched a boat into the EPZ (although FEMA had observed no such activities).
Egg FEMA's Response to Suffolk County, State of New York, and the Town of Southampton's First Request for Admissions and Second Set of Interrogatories Directed to FEMA, at 4 and 5.
LILCO did not amend its discovery response after FEMA had answered.
On January 8, 1987, the Governments deposed Mr. Wilm, a LILCO employee.
He stated that the Coast Guard had participated in the exercise and that LILCO personnel had been in contact with Coast Guard personnel many times during the Exercise.
LILCO's counsel, when questioned by the Governments' counsel about the new LILCO position, stated that LILCO had only learned of the new data the previous evening and would be amending its discovery response. -. _ -
Furthermore, the Governments have already admitted as much as they are able, or that could reasonably be expected.
Thus, as described in Section II.B, the Governments have admitted that the notations contained on message forms and logs were made by the indicated LERO players at approximately the times indicated on the documents; that, to the best of their knowledge, the set of documents provided to the Governments are a complete set of documents generated during the Exercise; and that, to the best of their knowledge, there are no other documents generated by LERO players during the Exercise reflecting events that occurred during the Exercise.
The documents -- and their notations --
speak for themselves.
B.
Inaccuracies and Omissions Uncovered in Initial Review of the LILCO Admissions Requests Preclude the Governments from Having to Respond Any Further by Checkina the Accuracy of Everv Entry 1.
The Timeline Contains Numerous Omissions LILCO claims that "the timeline provides a complete chronology of the events on the day of the Exercise that were noted on message forms or in players' log books" (LILCO Motion to Compel at 4).
Initial review by counsel for Suffolk County demonstrates that this is far from the case.
Numerous messages
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noted in player m'essage forms are absent from the LILCO timeline.
For example, an entry at 15:30 on a LERO message form to Road Crew 2008 from the Road Logistics Coordinator reads in part:
i "BA() RADIO NOT WORKING - RADIO REPAIR TO REPAIR UNIT" (sgg __ _
Attachment A).
The LILCO timeline at 15:30, however, does not mention this message (ggg Attachment B).
Another example is a LERO message at 10:24 to Staging Areas, from the Lead Communicator.
This message reads in part: " Sirens Sounded /EBS Message Instructing Public to Evacuate Zones A-M, Q R" (agg Attachment C).
Despite the existence of this message, no such entry exists at 10:24 in the LILCO timeline (agg Attachment D).
A further example can be found on a message form at 8:40 to the Ambulance Coordinator from the Public Service Liaison which reads:
" Send dosimetry record keeper to Peconic Ambulance Jamesport Yard - Call (Me) when arived [ sic]" (see Attachment E).
No entry was made on the timeline for this message (ggg attachment F).
These omissions clearly indicate that the timeline is not the " complete chronology" LILCO claims.
Rather it is a document which contains some of the events that were noted in player log books and message forms.
By compiling a partial timeline and requestine the Governments to either admit or deny the accuracy of each entry beyond what they have already stated, LILCO is, in effect, requesting the Governments to fill in its omissions.
To put it differently, LILCO is requesting the Governments to do its work for it by asking the Governments' attorneys to complete an incomplete timeline compiled by secretaries in LILCO's counsel's office.
Such a request clearly is not appropriate.
Accordingly, the Governments should not have to respond any further than they already have to LILCO's Request for Admissions..-.
2.
Many Message Forms Lack Times, Making It Impossible for Governments to Check Their Accuracy LILCO" claims that responding to its Request-for Admissions is "a relatively uncomplicated process" in which one " compare (s) the timeline descriptions of events with the actual message forms and logs.
(Hgg LILCO Motion to Compel at 5).
What LILCO envisions, and what counsel for Suffolk County in fact attempted to do, was to look at message forms and log books and then find the entry on the timeline.
In addition to the length of time involved in this process (see below), the poor documentation by 7
LILCO players during the Exercise often makes it impossible to compare a message form with the timeline.
For instance, on one message form examined during the Governments' initial attempt to respond to the Request for Admissions, the LILCO player message form lacked both the date and the time (agg Attachment G).
This made it impossible to find this item on the timeline and also impossible for LILCO to have included it at any given time on that document.
Thus, the Governments cannot determine the accuracy of the entries on the timeline when they cannot find items due to poor recordkeeping by LILCO players during the Exercise.
3.
Th'e Timeline Contains Numerous Inaccuracies Initial review of the timeline reveals that the entries that comprise that document do not, as LILCO claims, " reflect either the complete text of the log or message form from which they are __
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drawn or in some cases lengthy notations on Exercise documents have been summarized."
Egg LILCO Motion to Compel at 4.
- Rather, of the 68 entries checked by the Governments' counsel, not one was the " complete text" of the LILCO player document from which it was drawn.
Further, numerous documents either had inaccuracies or were summarized in a manner that mischaracterized the notation on LILCO player message forms and logs.
The examples of such problems are numerous.
The following are just a few, discovered during the Governments' initial attempt to respond to the Request for Admissions:
a.
A LERO message form at 14:30 from the Traffic Control Coordinator at the EOC to the Evacuation Coordinator at the EOC reads:
"The staging area lead traffic guides have reported traffic flow to be normal with the exception of the detour at Rt.
25A and Miller Pl. Yaphank Rd.
Detoured traffic on North Country Rd., while heavy, is moving at a reduced pace.
All evacuation rt. spotters have made contact and report traffic to be light" (agg Attachment H). This message is " summarized" in the timeline as follows:
" Report on flow of traffic" (sag Attachment I).
It is difficult to ascertain how LILCO could ask the Governments to admit that this entry accurately reflects the actual message - _
or "what happened during the Exercise."
This so-4 called " summary" says nothing about the events d.es,qr.ibed in the message.
b.
A message form at 15:10 from the Road Logistics Coordinator to Road Crew 2008 reads:
"2008 proceed to Victory ave west of William Floyd Pkwy to gas tanker location 3008.
Lost contact with 3008 after calling in with site problem.
Contact the EOC when at site" (agg Attachment J).
The entry in the timeline reads:
" Proceed to gas tanker location 3008" (agg Attachment K).
This " summary" leaves out critical information such as the fact that contact was lost with 3008 and that road crew 2008 was instructed to call the EOC when they reached the site.
This information, which LILCO chose to leave out of the timeline, describes what actually occurred.
Thus, under no stretch of the imagination could LILCO's summary be considered accurate or complete.
c.
A message form at 11:25 to the Health Facilities Coordinator from the Logistics Support Coordinator reads:
" Truck dispatched from Brentwood to Oak Hollow Nursing Home to transport medicine and health equipment to LaSalle Military Academy" (see Attachment L).
The timeline entry, however, reads: " Truck to transport nursing and health equipment to military academy" (agg Attachment M).
Not only does this entry contain an
inaccuracy in substituting " nursing" for " medicine,"
4 but critical information such as where the truck was dispatched from, where it was dispatched to, whether it was dispatched,~and the name of the military academy were left out.
Thus, the timeline entry is far.from the " complete text" or accurate summary of the message form as LILCO claims.
d.
A message form at 11:44 from the Private School Coordinator to the Homebound Coordinator reads:
"all homebound residents listed on the Homebound Evac. List, pages 1 thru 9 have been contacted and their transportation confirmed.
There were no exceptional problems" (agg Attachment N).
The corresponding timeline entry reads:
"All homebound residents have been contacted and their transportation confirmed" (see Attachment O).
To interpret pages "I thru 9" as "all" without explanation potentially misrepresents the meaning of the message.5 e.
A message at 13:30 from Road Crew 2006 in Yaphank to the Road Logistics at 13:30 (sgg Attachment P) appears on the timeline as being from Patchogue, not Yaphank (agg Attachment Q).
5 As the Governments do not have access to the referenced Homebound Evacuation List, they have no way of knowing how many pages it has, or how many pages were in the simulated list used during the Exercise.,
_. ~. _. - _ _ _ ---.-.~. ~ ___ _ -
LILCO counsel has represented that the timeline was prepared by secretaries at the offices of Hunton & Williams.
Apparently, it was not, prepared by LILCO's attorneys.
Considering the many inaccuracies and' omissions detected in review of 68 entries, it further appears that the document was not carefully (if at all) checked by LILCO's counsel prior to being served on the Governments.
In demanding that the Governments respond further than they already have to the Request for Admissions, LILCO, in essence, asks that the Governments be required-to go through every timeline entry and explain why they are inaccurate, which would result in the Governments' producing a correct timeline.
Fairness and reason dictates that the Governments not be required to perform such a task.
First, LILCO should do its own work.
Second, and even more significant, an accurate and complete compilation of the Exercise documents would be nothing but a restatement of them.
Such an exercise serves no purpose.
The documents say what they say.
The Governments, and presumably all other parties, agree on that.
It makes no sense to restate their substance when, instead, the actual doc ~uments can be identified, agreed upon as authentic, and drawn upon equally, and without dispute, by all parties.
C.
LILCO's.Recuest for Admissions Is Undulv Burdensome As previously noted, the LILCO timeline has an estimated 2,780 individual entries or requests for admission.
In five hours of initial review, an attorney for Suffolk County was able. -.
to check only 11 of the entries against notations in the documents from which the entries were taken.
At this rate, just locating and checking each entry on the timeline would alone take approximately 200 attorney hours.
This does not include the time needed to respond to each request by noting and/or correcting the inaccuracies and omissions present in the timeline.
Even without considering the fact that the timeline is full of mistakes, this is a vast amount of time to spend responding to such a request.
And when the manner in which the timeline was prepared is considered, such a request is clearly unduly burdensome.
LILCO's claim that responding to its 2,780 item timeline "is not out of proportion to the Request for Admissions that Intervenors propounded to LILCO" (sgg LILCO Motion to Compel at
- 5) must be rejected.
As LILCO acknowledges, the Governments' request consisted of 223 requests, which is a far cry from the approximately 2,780 individual requests in the LILCO Request for Admissions.
This LILCO argument fails to address in any meaningful fashion the voluminous and obviously burdensome nature of the LILCO Request.
III. CONCLUSION The Governments have already responded fully, honestly, and adequately to LILCO's Request for Admissions.
As demonstrated above, there is no basis for compelling the Governments to respond any further since they have already stated why they are unable to admit or deny the " accuracy" of the events or summaries,
4 or characterizations contained in the timeline.
The Exercise documents speak for themselves.
The Governments have admitted that the notations contained in those documents were made during the Exercise at the approximate times indicated in the documents, and have indicated they will not challenge the authenticity of the docunents.
No more can be gained by attempting to summarize, characterize or restate the exercise documents.
To " streamline the hearing process," a set of such documents should be agreed upon by the parties, and drawn upon, or referred to, by all.
For the reasons set forth above, the LILCO Motion should be denied.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 t
baftfence Coe Lfat5her Karla J. Letsche Michael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County e
f
)
Fabian G. Palomino Richard J.
Zahnleuter Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorneys for Mario M. Cuomo, Governor of the State-of New York St @ en B.
Lat?nfm Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton
ATTACHMENT A OFIF 4.1.2, y
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ATTACHMENT B To Rad. Health coord., EOC From: Nuclear enginaar, EOC Times 15:27 Hessages-Plant update as of 3:23 LOGS Admin. Support, INC TIMEi= 15:30 MESSAGE: Talk to controller ret second shitt, will I call out at 4:00 LOG Admin. Support, EOC TIME: 15:30 MESSAGE: Received from ENC news release (19 LOG Dos. Coord., EOC Tn'E 15:30 MESSAGE: Continuing to process worker record forms LOG: Health Services Coord., EOC ~" TIME: 15:30 MESSAGE: Report on buses at Port Jeff., Patchogue j and Riverhead TO: Leed Traffic Guide, Patchogue FROM: Traffic Control Point Coord., EOC TIME: 15:30 MESSAGE: (LC Log] - FEMA completed evaluation in - U# Patchogue I',,., '. l - To: Lead Traffic Guide, Patchogue O From: Traffic Control Point Coord., EOC Times 15:30 Message FEMA completes evaluation of all traffic guides from Patchogue staging area, they are to return to Decon. facility at Brentwood To: Lead Traffic Guide, Patchogue From: Traffic Control Point Coord., EOC l Times 15:30 l Message: FEMA completes evaluation of all traffic guides from Patchogue staging area, they are to return to Decon. facility at Brentwood -258-
DESCRI'/TICII w LOG: Manager of Local Response, 20C TIMRr 15:30 MESSAGE: Hesith Services Coord.- reports; reviewed previous projections total dose LOGL Staging Area Coord., Port Jeff. TIME: 15:30 l MESSAGE: Received word from EOC to' call-out 4 2nd . shift to report at 19:45; briefed key personnel (Bus Dispatchers, Lead Traffic Guides, Administrative Support) LOG Traffic Control Point Coord., BOC TIME: 15:30 MESSAGE: Traffic Guide at Patchogue rel, eased, To: Trans. Support Coord., EOC From Bus Dispatcher, Riverhead Times 15:30 Message Attachment Attach Staging Area Status Request Form LOG: Rad. Health Coord., EOC TIME: 15:34 MESSAGE: Confirmed for Lead Communicator that the new RECS message consists of increased thyroid dose numbers (real iodine isotopics) LOG Admin. Support, ENC TIME: 15:35 MESSAGE: Staff briefing #10; plant and elect. equip. status To: Dos. Record Keeper, Riverhead From: Dos. Record Keeper, Riverhead Times 15:35 Message All 4 members of shift 2 to report prior to 20:00 for a briefAng by Dos. record keeper To: Dos. Record Keeper, Riverhead From: Dos. Record Keeper, Riverhead Time: 15:35 Message: Shift two report prior to 20:00 for briefing m Yo -259-P
i "XX # ATTACHMENT C ~ OFIF 4.1.2 t 1 r L ' d Page 1 of 1 tc at 1 L tino usssaan rann ..s. No. .--..uu. -e s w-Lead OwsrnUnirah'v' Ett 11 Sr.ai1:!(Pak DJ b-ch.RM Et/O PErd. n' v.: o.t./rCW#Eh % '/O 3 6 ?prewhhn :(fnrer ($ Lns3a0 n.s. ChIisevin &Hvalet np 1015 / jWh 't:0oiDmenb irailer3~h0Vd amVfd miUhhslMP-lA N h2C0(&?milh?f1dfi Guinrnenhll 14d C(Dss & ras 500 (Mb Mitte hate a156 om%d f in24 - 8/ ens Sounda:// Eb5 YY1Mame RMrir!ina 'PahliG +b EnaaicWh 26nis M-KM O fc' %r Routing for: l[lAction aformation i Response Required: l[l In Response to'Hessage No.
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ATTACHMENT D To Staging Area Coord., Port Jeff. From: Lead Communicator, E3C Times 10:22 Message: Protective clothing LOG - Admin. Support, ENC TIM s. 10:24 3 MESSAGE: Press release #10 LOG: Director of Local Response, BOC TIME: 10:24 MESSAGE: E25 message broadcasted, sirens activated LOG: Evac. Coord., BOC TIME: 10:24 MESSAGE: Sirens sounded /EBS message to public to evacuate zones A-N, Q & R LOG: Hospital Coord., EOC i TIME: 10:24 MESSAGE: Sirens. sounded /EBS message, public to evacuate Zones A-N, Q and R i LOG: Manager of Local Response, E0C TIME: 10:24 MESSAGE: Sirens sounded /EBS message i LOG l Operation Supervisor, ENC TIME: 10:24 MESSAGE: Press release #10, 11 i 3 LOG Public Info. Support Staff, EOC TIME: 10:24 HESSAGE: EBS message #5 read over radio; sirens sounded; Market Eval. contacted LOG: Red Cross Coord., EOC TIME: 10:24 MESSAGE: Sirens sounded /EBS message, public to i evacuate Zones A-M, Q & R LOG Road Logistics Coord., EOC l TIME: 10'24 MESSAGE: -Sirens sounded message to clear zones A-M, Q & R i 4 -114-4 l
DESCRIPTICII ..). r, Tb Staging Area Coord., Riverhead Frems Lead Communicator, BOC Times 10:24 Messages' OPIP 4.1.2 attachat t LOGS Decom. Leader, ENDF TIME 10:25 MESSAGE ENDF activated LOG Dos. Coord., EOC TETE 10:25 MESSAGE: Return call for message to Port Jeff., Rivehead, Patchogue To: Dos. Record Keeper, Port Jeff
- From Dos. Coord., EOC Times 10t25 Message:
When record keepers released to EOC l To: ( Dos. Record Keeper, Riverhead From: Dos. Coord., EOC Time 10:25 Message: Time record keepers will be released to the EOC l To: Evac. Coord., EOC, From Staging Area Coord., Riverhead Times 10:25 Message Attachment Attach Evac. Coord. Emerg. Resp. Action Checklist, manning status LOG Evac. Support Connunicator, EOC TIME: 10:25 MESSAGE: Weismantle announced that Coliseum has i been manned for some time now 1 LOG Health Services Coord., EOC TIME: 10:25 MESSAGE: Sirens sounded /EBS message informing public to evacuate Zones A-M, Q f. R, Coliseum has been activated l TO: I~ Lead Traffic Guide ~ FROM: Traffic Control Point Coord., EOC i TIME: 10:25 MESSAGE: (LC Log) - Zones A-M, Q&R to be evacuated i 1 -115-
ATTACIIMENT E OPIP 4.1.2 y436Cf7 ,/ Paga 1 cf 1 ?>n s xm o massaas Paan ht- / no. - uu. -.uon ..m. From: Od/M4SWEMEbAs5*8 6OD Tot AMAut.4rt CoatO. 5 0 C-Date/ Times Neeenget b]GisfacO fa%+96 of Ters A&stt Gasdtcuet t ~ 0%: 37 Y ' ' g heco,.l.c. M,nsMA40 & _y ar1\\0RL4act d e>, % Au ut M s. 2.We(19en0 5 mut96 M/la3 O t?'fo P~ swo Dos,n Ls flucon.O WuM E hsec9ee bat (tMLAwc E e O G'c.L*7 '!A % - Os% &a QML78 A r<. JEb. l l l l. h'. oMj., Routi* gfor: l~l Action l l Information n Response Required: l~l / In Response to Massage No. 3. White copy - Addressee Yellow copy - Originator Rev. 5 Pink copy - Lead Communicator l l 725998 . _. -.. _... -.. = 1 4.ese
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4 ATTACHMENT F DESCRIPTICIf l 4' \\ i To Support Services Coord., EOC Frcut Decon. Leader, ENDF Times 08:39 Me'isage Plow storage yard entrance gate LOlb Director of Local Response, EOC TIME: 08:40 MESSAGE: ESS message 82 (conferred w/Wingert and Sucich, they agreed w/LERO reccamendations To: Dos. Record Keeper, Riverhead From: Dos. Coord., 30C Times 08:40 Message Plant equipment malfunction (cca SAC). LOG Emer. Medical /Public Services Coord., EOC TIME: 08:40 MESSAGE: Public Service Coord. called Riverhead, send dosimetry to Jamesport Yard LOG: Health Services Coord., EOC TIME: 08:40 MESSAGE: Jim Thomas (Deputy County Exec.) has just arrived LOG: Lead Communicator, EOC TIME: 08:40 MESSAGE: Review status of group zones to alert AVS 100% To Lead Communicator, EOC From Staging Area Coord., Port Jeff. Times 08:40 Message Identify key personnel LOG: Manager of Local Response, E0C (Ass't. to Mgr.) TIME: 08:40 MESSAGE: Not assuming control, briefing on how we are going to operate, EBS message out LOG Manager of Local Response, EOC TIME: 08:40 MESSAGES... Announcement to EOC - Mr. Thomas, Deputy ~ ~ of Suffolk County to be informed before all important decisions. f_________________-_-__-__-------_------J
l DESCRIFFI W \\ t LOGS Public Service Liaison, EOC TI M s-08:40 ISSSASs Peconic Ambulance notified ,q. TOs m. Rad. Realth Group, 30C FRIEtt Rad. Realth Consunicator, 30C TDE: 08:40 MESSAGE: (LC Log] - Minor release three RBSYS To: Rad. Realth Group, BOC From Riverhead Communicator, EOC Times 04:40 Message: Minor release TO: Staging Area Coord., Port Jeff. From Lead Traffic Guide, Port Jeff.' Times 08:40 Message Security dispatched to posts 1, 2, 3 To Staging Area Coord., Riverhead From Public Service Liaison, ROC Times 08:40 i Message: Dos. Record Keeper to Peconic Ambulance Service 1 I To Staging Area Coord., Riverhead From Evac. Coord., ROC Times 08:40 Messages Time of site area emergency changed LOG Manager of Local Response, EOC TIME: 08:41 MESSAGE: Representative of Hyatt Management, called, status update TO: Lead Communica':or, EOC FROM Decon. Leader, EWDF TIME: 08:42 MESSAGE: (LC Log] - Personnel unavailable because they are on shift To: Lead Communicator, E0C From: Decon. Leader, EWDF Times 08:42 Message Attachment Attach.: List of EWDF workers unavailable for additional shift, F ..-.,-,--,l.
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ATTACHMENT H OPIP 4.1.2 Page 6 of 7 Page 1 of I
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,_,, m.y ATTACHMENT I To: Evac. Coord., EOC Frce: Traffic Control Coord., EOC Timer 14:30 Messages Report on flow of traffic l LOG: Health Facilities Coord., ECC TIMEt. 14:30 i MESSAGE: All facilities evacuated and sheltered LOG: Health Services Coord., EOC TIME: 14:30 MESSAGE: Announcement to EOC, status from each Lead Coord. LOG: Hospital Coord., EOC TIME: 14:30 MESSAGE: INFO sending 110 monitoring and decontamination personnel in addition to the 100 originally sent i 'l TO: Lead Traffic Guide, Patchogue FROM: Traffic Control Point Coord., EOC TIME: 14:30 MESSAGE: (LC Log] - I need info. on flow of traffic j To: Lead Traffic Guide, Patchogue l From: Traffic Control Point Coord., EOC L Times 14:30 Messages Request for information on traffic flow i To: Lead Traffic Guide, Patchogue From: Traffic Control Point Coordinator, EOC Times 14:30 Message Need information on traffic flow; reply ASAP; answer at 14:30 To: Lead Traffic Guide, Patchoque From: Traffic Control Point Coord., EOC Times 14:30 Message Request for information on flow of traffic LOG: Manager of Local Response, EOC TIME: 14:30 MESSAGIR I General briefing of EOC -239-
~ l ATTACllMENT J '3 .o [ OFIF 4.1.2 ,,. Q -)$ P N 0 A ac at L .( y .... ::.c. Pag.1 of 1 e.. +:. g g ne.'/?L C &\\ = ::.-. nn.- . a.,. ~. from: 011 _*,.a r,. J $6 C ) 1 94 % h) CN f$es.N/Afs.&,!*' 'Y!:lb= 1 Tos u ?x9 Dete/ Tines 0k/s3/E4 ' /.t'/o ')p. \\ n.e..g., 'cd. x kl9 n 200 ? / A.-el
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ATTACHMENT K DESCRIPTION 1 LOGS Decon. Leader, ENDF TIMs 15:10 MEssacs: Instructed by FEMA controller to shut down facility except for dosimetry collection 2 4.: LOG Health Services Coord., EOC TIME: 15:10 MESSAGE: Hesith Services Coord. sent message to Decon. Coord. to arrange for monitoring of special evacuations from Zones A,5,F,G,K TO: Home Coord., EOC FRON: Bus Coord., EOC TIME: 15:10 MESSAGE: (LC Log] - Zone O pickup, zone.,0 no pickup Tor Home Coord., EOC From: Bus Coord., EOC Time: 15:10 Message Curbside pick ups, Zone 0 To Public School Coord., EOC From: Decon. Coord., ERC i Times 15:10 Message School bus with 40 children from Ridge Elementary School, Longwood School District has not arrived LOG: Red Cross Coord., EOC TIME: 15:10 MESSAGE: Call from R.C. Disaster Worker to notify of injury to Don Connors TO: Road Crew FROM: Road Logistics Coord., EOC TIME: 15:10 MESSAGE: (LC Log] - Contact EOC when at site To Road Crew 2008 From: Road Logistics Coord., EOC Times 15:10 Messagef ~ Proceed to gas tanker location 3008 -252-
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I f f).o /J Q jg/Q ATTACHMENT L OFIP 4.1.2 F43 4 Cf 7 + ' 'A. Page 1 of 1 LEO MSSAS Magg V no. ' t..rs y. --_r rasa. _- n - ,e tuems Lesum S -e/9 I & or / Tes / E,_. (n.... -. 4 - Afa e h.s - Date/ Times Yav/Js : // W an. O Neenages -G-m e - . u.. u-Asn aa,, 7-s f)n,r tI- ...'n A) na..n. 1.Lm m.. u._l n an.... . n.. -.. -a i r.. A, _., .* A nu* t/ _ / + l Routing fors l[lAction l2fInformation ~ 6 Responsa Required: l[l 7 In Response to Message No. '~6 U j White copy - Addressee (3,ignature) Yellow copy scriginator t Rev. 5 Fink copy - Lead Conusunicator { 725851 1 l l i 3M%C4WD 8eM~-n. iip;5% ftj h '$Y M P M TJ" 4 } L-S
ATTACHMENT M D850tIrff0F \\ LOGS Director of Local Response, EOC TIMr 11:25 Ms called Wingert to see if he can assist us in any way LOGk , Dos. Coord., E0C TIME: 11:25 MESSAGE: Logistic Supt.Coord. requested dosimetry for one worker to go into IFE To: Dos. Record Keeper, ROC ,From: Dos. Record Keeper, Riverhead Times 11:25 Message Instructions for dosimetry record keepers ? TO: Health Facilities Coord., E0C l FROM: Logistics Support Coord., BOC TIME: 11:25 MESSAGE: (LC Log) - Trucks dispatched from Brentwood LOG Health Facilities Coord., EOC TIME: 11:25 MESSAGE: Truck dispatched To Health Facilities Coord., EOC From: Logistics Support Coord., IOC l Times 11:25 Message Truck to transport nursing and health equipment to military academy LOG Hospital Coord., EOC TIME: 11:25 MESSAGE: Water level decreasing in reactor vessel; fuel started to be uncovered at 11:15 To: Lead Cosaunicator, EOC Prom: Staging Area Coord., Patchogue Times 11:25 Message Manning status LOG: Manager of Local Response, EOC TIME: 11:25 MESSAGE: -- State Resources - ~ " EPA #1 11:18 recommended expansion of evac. A-S entire 10 mile zone because of wind shift -151- - - ~ - ------^'
ATTAC!! MENT N A s j ')f/f 4, 4, OPIP 4.1.2 gf ~ I Pgo 6 cf 7 ff 'e %';,( N'3 Page 1 of 1 IL t LIE 0 MESSAGE FORN 'N f No.' / [r s.zmu atras weaston name From: PRi Stk.ot eao A fOC /_ 4+ To: MMadeuA/D coe 4 2 f Data / Time: 2-/3-7[ // <f f Nessage: iY w.) Y L. ~f4//J ~ 1E-n.cv._ n l 2L 9 LL Jf21 JL t~a:4 s J.- / / M gas / Au~ & 3 r1 r? w At I / P l 1 \\ t Routing for: l[lAction l l Information Rest.onse Required: l[l In Response to Massage No. }) (Signature) White copy - Addressee Rev. 5 Yellow copy - Originator Pink copy - Lead Communicator 725789
DESCRIFFION ATTACHMENT O LOGt Operation Supervisor, ENC TDER: 11:41 MESSAGE *- Received plant status LOG 8 Admin. Support, 30C TIME;. 11:42 MESSAGE: Received from Dept. of Energy LOG: Evac. Coord., ECC TDEE: 11:42 MESSAGE: Coast Guard called (Chief), on the scene at 11:27
- LOGS, Public Info. Support Staff TDEI:
11:43 MESSAGE: Rumor #17 - is it safe to eat' lobster caught this morning at Shoreham LOG: . Rad. Health Coord., EOC TIMES 11:43 MESSAGE " Consideration given to evacuating Zones N, 0, P, S To Evac. Route Coord., EOC From: Lead Traffic Guide, Patchogue Times 11:44 Message: Helicopter duty To: Home Coord., EOC FROM Private School Coord., EOC TIME: 11:44 MESSAGE: [, LC Log] - Ilomebound resi* dents listed evac. To Home Coord., EOC From Private School Coord., EOC Times 11:44 Message: All homebound residents have been contacted l and their transportation confirmed LOG: Manager of Local Response, EOC TIME: 11:44 t MESSAGE: Meeting Tot .- Jr ulance Coord., EOC From: Assistant Home Coord., EOC Times 11:45 Message: Name of Homebound Address, town, phone -162-h_.
ATTACIIMENT P ~ 0FIF 4.1.2 Pge 6 of 7 Page 1 of 1 n. c-:: - LERO MEssacs rotu l no. - x usa. we.c w. i Trom: 0 9_- lSh N B00 d
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ATTACHMENT Q DESCRIPriOIf Ter Bus Dispatcher, Port Jeff. From4 Transfer Point Coord., Miller Place Timer 13:29 Messager Curbside pick-up zone F LOG Admin. Support, ROC TIME: 13:30 MISSAGE: Sent to ENC E55 rolesse 87 LOG Health Services Coord., EOC TIME: 13:30 MESSAGE: Verified Zones of concern for deposition (A,8,F,G,Q,K) ? TO: Logistics Support Coord., EOC \\ 1 FROM: Dos. Coord., EOC 1 TIME: 13:30 MESSAGE: (LC Log] - Pickup 40 sets of dosiaan;7 To Logistics Support Coord., EOC ~~ From: Dos. Coord., E0C Times 13:30 Message Pick up 40 sets of dosimetry from EWDF for delivery to Reception Center at Nassau Coliseum LOG: Manager of Local Response, EOC TIME: 13:30 MESSAGE: Ed Lieberman, KLD, 10-mile evac. total addition of absolute maximum time, I hour LOG: Public Info. Support Staff, EOC TIME: 13:30 MESSAGE: preparing EBS message #8 TO: Road Logistics Coord., EOC FROM: Road Crew, Patchogue TIME: 13:30 (LC Log] - Gravel truck cleared off roadway MESSAGE: To: Road Logistics Coord., EOC From: rT Road Crew, Patchogue (2006) Time: 13:30 Message: Gravel truck cleared off roadway -214- ~ ~ ~ ~ ~ ~~' ~~ ~
l 00f.ME in TiNkC January 15, 1987 '87 JM120 P3 :48 UNITED STATFS OF AMERICA 'N' NUCLEAR REGULATORY COMMISSION OFF:cE >..... + i 80CXETiT6 4 2 PWCf. Before tha Atomic Safety and Licensina Board BFAMCH 4 ) In the Matter of ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5 ) (EP Exercise) (Shoreham Nuclear Power Station, ) Unit 1) ) ) CERTIFICATE OF SERVICE 4 I hereby certify that copies of RESPONSE OF SUFFOLK COUNTY, THE STATE OF NEW YORK, AND THE TOWN OF SOUTHAMPTON IN OPPOSITION TO "LILCO'S MOTION TO COMPEL SUFFOLK COUNTY, THE STATE OF-NEW YORK, AND THE TOWN OF SOUTHAMPTON TO RESPOND TO LILCO'S FIRST REQUEST FOR ADMISSIONS AND THIRD SET OF INTERROGATORIES AND REQUEST FOR EXPEDITED RESPONSE AND DISPOSITION" have been served on the following this 15th day of January, 1987 by U.S. mail, first class, except as otherwise noted. John H. Frye, III, Chairman Dr. Oscar H. Paris Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon 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
Anthony F. Earley, Jr., Esq. General Counsel Bernard M. Bordenick, Esq. U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C. 20555 175 East Old Country Road Hicksville, New York 11801 n-. Clerk Suffolk County Legislature W. Taylor Reveley, III, Esq.* Suffolk County Legislature Hunton & Williams P.O. Box 1535 Office Building 707 East Main Street Veterans Memorial Highway Richmond, Virginia 23212 Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq. Long Island Lighting Company Shoreham Nuclear Power Station Twomey, Latham & Shea North Country Road 33 West Second Street Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Executive Director Docketing and Service Section Shoreham Opponents Coalition Office of the Secretary U.S. Nuclear Regulatory Comm. 195 East Main Street 1717 H Street, N.W. Smithtown, New York 11787 Washington, D.C. 20555 MHB Technical Associates 1723 Hamilton Avenue Hon. Michael LoGrande Suite K Suffolk County Executive H. Lee Dennison Building San Jose, California 95125 Veterans Memorial Highway Hauppauge, New York 11788 Martin Bradley Ashare, Esq. Fabian G. Palomino, Esq. Suffolk County Attorney Bldg. 158 North County Complex Special Counsel to the Governor Veterans Memorial Highway Executive Chamber, Rm. 229 State Capitol Hauppauge, New York 11788 Albany, New York 12224 David A. Brownlee, Esq. Mr. Philip McIntire Kirkpatrick & Lockhart 1500 Oliver Building Federal Emergency Management Agency Pittsburgh, Pennsylvania 15222 26 Federal Plaza New York, New York 10278 .l Gbf }
- By Federal Express Karl'a'J. Letsch9y' KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C. 20036-5891 l l l 1 - _ - - _ - _ _ _ _ _.}}