ML20212D026
| ML20212D026 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/20/1987 |
| From: | Mcmurray C, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#187-2612 OL-3, NUDOCS 8703040046 | |
| Download: ML20212D026 (21) | |
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DOCKETED USflRC February 20, 1987
'87 FEB 25 TJ1 :58 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION n r.
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Before the Atomic Safety and Licensino Board In the Matt ~er of
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LONG ISLAND LIGHTING COMPANT
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Dockets No. 50-322-OL-3 (Shoreham Nuclear Power Station, Unit 1) x
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s s s RESPONSEOFSUFFOLKCOUNTYANDSTATEOFNEWYORKTb,LILCO'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION.OF DOCUMENTS REGARDING RECEPTION CENTERS
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Pursuant to 10.C.F.R. S 2.740b(b) and 10 C.F.R. S 2.741(df;.
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Suffolk County and the State of New York (the " Governments"), by' s
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their undersigned attorneys, hereby respond to LILCO's Seco,dd Set
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of Interrogatories and Request for Production of Documents '
Regarding Reception Centers (February 20, 1987) ("Second Set of Discovery-Requests"), subject to the general and specific objections set forth below.
GENERAL OBJECTIONS
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The Governments object to LILCO's Second Set of i
Discovery Requests on the ground that, in a number of instances, LILCO's Second Set of Discovery Requests seeks the Governments' views on how problems in LILCO'S Plan might be corrected (or 87C3040046 B70220
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Variations on that theme).
Such interrogatories are objectionable, for the Governments have no obligation to tell LILCO how its-Plan might be corrected.
Moreover, it is.the Governments' view that the shortcomings of LILCO's plan are not correctable.
SPECIFIC OBJECTIONS AND ANSWERS TO INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 1
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Discovery Recuest No. 13:
Please answer Nos. 1-8 of the First Set of Interrogatories dated January 16, 1987.
Besconse to Discoverv Recuest No. 13:
The Governments have responded to LILCO Discovery Request 4
Nos.
1-8, and have seasonably supplemented those responses.
- Sgg, e.g.,
Supplemental Response of Suffolk County and State of New York to LILCO's First Set of Interrogatories and Request for Production regarding Reception Centers (February 13, 1987).
Additional information regarding expert witness has been conveyed to LILCO by telephone and correspondence.
Moreover, as additional witnesses become available to the Governments, they will be identified.
Discovery Recuest No. 14:
In your January 30, 1987, Response to LILCO's First Set of Interrogatories you say (p. 5) that "[t]he number of persons who will arrive at LILCO's reception centers is much larger than those reception centers (and the facilities, resources, and personnel committed to them) can serve."
What number, in the Intervenors' view, is "the number of persons who will arrive at "LILCO's reception centers?"
_2_
Response to Discovery Recuest No. 14:
As disclosed at the deposition of Stephen Cole, data indicate that several hundreds of thousands of evacuees or more could arrive at the reception centers, depending on the circumstances of the accident.
With respect to EPZ residents and transients, LILCO must be prepared to monitor all such residents within the time constraints of NUREG 0654.
In order to do so, it must have the ability to monitor more than the population of the EPZ in order to assure that all EPZ evacuees and transients can be monitored.
Discovery Recuest No. 15:
What are the " facilities" and " resources" that you are referring to in the passage quoted above?
Response to Disc ->erv Recuest No. 15:
The facilities and resources referred to include, the areas (open or enclosed) where evacuees will be received, monitored, registered, decontaminated or provided with any other services, and the equipment committed to providing any services to arriving evacuees.
The limited roadway network around the reception centers further constrains their ability to serve arriving evacuees.
In addition, the results of discovery and further analyses may provide additional information concerning the inadequacies of the facilities and resources at the reception centers..
Discovery Recuest No 16:
Do tne Intervenors claim that the number of people referred to in Interrogatory 14 above must be monitored within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to comply with NRC regulations?
Resoonse to Discovery Recuest No. 16:
Seg Response to Discovery Request No. 14.
Discovery Recuest No. 17:
Do the Intervenors claim that LILCO must be prepared to decontaminate the number of people asked for in Interrogatory 14 above within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to comply with NRC regulations?
Resoonse to Discovery Recuest No. 17:
The Governments are unaware of a regulatory requirement establishing a specific timeframe within which must be completed.
However, delays in decontamination due to inadequate resources and facilities is in violation of the NRC's regulation.
Discovery Recuest No. 18:
You say in your January 30 Response (p. 5) that "[t]raffic congestion on the way to and in the vicinity of the facilities will render reception centers ineffective."
What studies or analysis support this statement?
Please provide copies.
Response to Discovery Recuest No. 18:
At this time, experts for the State of New York are conducting analyses which address this issue.
As those analyses are completed, documents which are not protected by applicable privileges and which are responsive to this interrogatory will be identified and provided.. -.
Discovery Recuest No. 19:
You say in your January 30 Response (p. 6) that LILCO's traffic management system, including the use of LILCO's Traffic
-Guides, is inadequate.
Precisely how is it inadequate?
What would make it adequate?
Response to Discoverv Recuest No. 19:
Discovery request No. 19 contains two questionc.
As to the question concerning the Plan's current inadequacies, at the present time LILCO's Traffic Guides are inadequate in number and training to satisfactorily perform the roles assigned to them by the Plan.
Moreover, the system, as established and operating in the constrained and congested environment of LILCO's inadequate reception centers, will not be effective in moving vehicles through the reception centers quickly enough for LILCO to provide necessary monitoring services to arriving evacuees.
In addition, discovery, and additional analyses may result in the identifi-cation of further inadequacies.
As to the question concerning what would make the Plan adequate, the Governments object to that question as irrelevant.
The Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities.
See, General Objection No.
1, supra.
Discovery Recuest No. 20:
You say in your January 30 Response that "[t}ransportation and traffic problems will develop as a result of the reception centers' locations and their distance from the EPZ."
Precisely what " problems" do you refer to?
Resoonse to Discovery Recuest No. 20:
At this time, the Governments contend that, given the number of people who will attempt to go to the evacuation centers, traffic delays of many hours will result due to the fact the roads leading to the reception centers cannot handle the traffic.
Severe congestion will lead to adverse health effects for those requiring decontamination.
Moreover, the distance of the reception centers from the EPZ is also likely to increase the public's perception of the area at risk, thus increasing the number of evacuees.
This in turn will lead to further congestion.
Finally, all of the reception centers are located in the same direction from the plant.
Thus, a plume traveling to the west could eliminate the availability of the reception centers or inhibit effective monitoring.
Discovery and additional analyses may result in the identification of further transportation and traffic problems.
Discovery Recuest No 21:
You say in your January 30 Response (p. 6) that LILCO's proposed monitoring procedures are inadequate.
Precisely how are they inadequate and why do they not, in your words, " provide reasonable assurance that all evacuees arriving at the reception centers to be monitored will be monitored, and that contaminated persons will be identified, in a timely manner"?
Response to Discovery Recuest No. 21:
At this time, the Governments contend that LILCO has not devoted sufficient mources to monitoring, and therefore cannot hope to monitor in a
'mely fashion the number of people who will _
f arrive at the reception center.
Indeed, under LILCO's current procedures, LILCO intends only to monitor the driver of vehicles arriving at reception centers and only a small portion of each arriving vehicle.
Furthermore, LILCO's attempts to increase the speed of the monitoring process will result in inaccurate readings.
Also, LILCO's equipment may not be fast or sensitive enough to provide accurate readings in the time alotted by LILCO 2
for monitoring individuals or personal property.
Discovery, and additional analyses may result in the identification of further monitoring inadequacies.
Discovery Recuest No. 22:
Is there any way in which LILCO's proposed monitoring procedures could made adequate in the Intervenors' view?
If so, how?
Response to Recuest No. 22:
The Governments object on grounds that Discovery Request No.
22 is irrelevant.
The Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities.
See, General Objection No.
1, supra.
Without waiving this objection, the Governments state that procedures which call for only some arriving evacuees to be monitored are inadequate.
Discovery Recuest No. 23:
You say in your January 30 Response (p. 6) that " inadequate shelter" not only "affects the public health" but "under certain circumstances will render LILCO's monitoring procedures _____-_______ -
ineffective."
Precisely how does it affect the public health, and what " circumstances" do you refer to?
How will those
" circumstances" render LILCO's monitoring procedures ineffective?
Response to Recuest No. 23:
At this time, the Governments contend that failure to provide adequate shelter may expose evacuees to adverse environmental conditions which may affect their health.
t Furthermore, under certain circumstances, monitoring conducted outdoors may result in inaccurate readings.
If monitoring is thus rendered inaccurate, adverse health effects may result.
Finally, the lack of shelter, as well as LILCO's inability to respond adequately to evacuees' needs could result in conflicts which could have adverse health consequences.
Discovery and additional analyses may result in the identification of additional inadequacies.
Discovery Recuest No. 24:
In your January 30 Response (p. 6) you say that the reception centers and their " facilities" and the " resources" provided by LILCO are physically inadequate.
What " facilities" and " resources" are you referring to?
Response to Recuest No. 24:
At this time, the Governments contend the following resources and facilities are inadequate:
(a) the number and type of personnel assigned to the reception centers are inadequate; (b) the physical dimensions of the reception centers, including buildings and grounds, are inadequate; (c) the decontamination trailers are inadequate; (d) the parking lots are inadequate; l
(e) the equipment to be used in providing services for evacuees is inadequate; (f) health-related facilities (such as toilets, washrooms, etc.) are inadequate; and (g) waste (liquid and solid) storage facilities are inadequate.
Discovery and additional research may result.in the further identification of inadequate facilities and resources.
Discovery Recuest No. 25:
In your January 30 Response (p. 6) you say that the reception centers and their facilities and the resources provided by LILCO are physically inadequate to provide "otner necessary services" to evacuees.
List all such "necessary services" to which you refer.
Resconse to Discovery Recuest No. 25:
At this time, the Governments contend the following resources and facilities are inadequate to provide the following services: (a) medical services; (b) sanitary services; (c) food preparation and distribution; (d) registration; (e) reunification of families; (f) the accurate dissemination of information concerning the disaster at Shoreham and the location of congregate care centers; and (g) security.
Discovery and additional analyses may result in the identification of additional services which are inadequate.
Discovery Recuest No. 26 In your January 30 Response (p. 6) you say that LILCO has provided inadequate staff.
What would make LILCO's staff adequate?
How many people do the Intervenors believe should be provided for monitoring, decontamination, and other purposes?. -
9 Response to Discoverv Recuest No. 26:
The Governments object that Discovery Request No. 26 is irrelevant.
The Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities.
Egg General Objection No.
1, suora.
Discovery Recuest No. 27:
In your January 30 Response, in your Response 9 (h) on page 6, what are the "other purposes" to which your refer?
Response to Discovery Recuest No. 27:
At this time, the Governments contend that the purposes for which reception centers are designated require adequate provisions for security, medical treatment, dissemination of certain information, registration, reunification and traffic control.
Discovery and additional analyses may result in the identification of further requirements for the reception centers to fulfill their purposes.
Discovery Recuest No. 28:
In your January 30 Response you say that LILCO's proposal to transport all evacuees traveling on buses to the parking lot next to its Hicksville facility renders that facility inadequate.
Precisely how is it inadequate?
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Resoonse to Discovery Recuest No. 28:
At this time, the Governments contend that the use of the Hicksville facility for all evacuees who are travelling on buses will add even further to the congestion and confusion at the Hicksville facility.
Discovery, and additional analyses may result in the identification of further inadequacies.
Discovery Recuest No. 29:
In your January 30 Response (p. 7) you say that the
" proposal to send the evacuees to the LILCO parking lots can never be implemented in a way to protect the public health and safety."
Why not?
Response to Discovery Recuest No. 29:
LILCO's parking lots, where most of the activity at LILCO's reception centers will be conducted are too constrained to handle the influx of cars and other vehicles which will converge on LILCO's reception centers.
Furthermore, LILCO's limited facilities will inhibit providing necessary services to evacuees.
Finally, they lack adequate shelter which will result in adverse health consequences.
Discovery and additional analyses may result in the identification of further inadequacies in the LILCO Plan.
Discovery Recuest No. 30:
In your January 30 Response (p. 7) you say that the
" reception centers locations will give rise to a larger evacuation shadow phenomenon, as well as inhibiting evacuation and the timely processing of the evacuees at the reception centers."
Precisely how do the locations affect the so-called
" shadow phenomenon?"
Response to Disuovery Recuest No. 30:
See the Governments' Response to Discovery Request No. 20.
Discovery Recuest No. 31:
How will the alleged larger " shadow phenomenon" inhibit the timely processing of the evacuees?
Response to Discovery Recuest No. 31:
The result of the shadow phenomenon will be more automobiles on the roads around the reception centers and more people seeking monitoring.
This will cause traffic congestion, delaying the arrival of evacuees at the reception centers and, once there, will overload LILCO's inadequate facilities and resources.
Discovery and additional analyses may result in the further reasons why the evacuation shadow phenomenon will inhibit the timely processing of evacuees.
Discovery Recuest No. 32:
In your January 30 Response (p. 7) you say that the use of the reception centers threatens to contaminate water supplies.
What studies or analysis support this statement?
Please provide copies.
Response to Discovery Recuest No. 32:
At this time the Governments are aware of no documents responsive to this request.
However, the testimony of Sarah Meyland Offered in the Nassau Coliseum proceeding may apply by analogy to the current issues before the Board.
Discovery and additional research may result in the identification of additional analyses or studies.
Discovery Recuest No 33:
In your January 30 Response (p. 7) you say that " waste products from the decontamination procedures could pose additional environmental hazards."
What " waste products" do you refer to, and what additional " environmental hazards" do you refer to?
Response to Discovery Recuest No. 33:
Waste products include materials contaminated during an accident or during the monitoring / decontamination process (including water, wipes, monitoring equipment, sponges, etc.).
Environmental hazards are threats to the environment, and thus to the public health, from contamination.
Discovery and additional analyses may result in the identification of further waste products and environmental hazards resulting from the LILCO Plan.
Discovery Recuest No. 34:
In your January 30 Response (p. 7) you say that the
" distance of the three facilities from the EPZ will increase the adverse health effects of those exposed to radiation during an accident."
Is the Intervenors' position that the distance of the LILCO facilities from the EPZ is categorically too great as c matter of law?
Or is your position that they are too far because of particular conditions on Long Island?
If the latter, what are those particular conditions?.
Response to Discovery Recuest No. 34:
Both reasons cited by LILCO are correct.
The distance which must be traveled by evacuees, coupled with the inadequate roadways leading to the reception centers and the congestion resulting from the number of people attempting to use those reception centers makes the facilities inadequate.
Discovery Recuest No. 35:
You say in your January 30 Response (p. 7) that "LILCO cannot lawfully use its facilities as relocation centers."
Please state what laws Intervenors claim would prevent LILCO from using its facilities as relocation centers.
Response to Discovery Recuest No. 35:
The zoning ordinances of the Towns of Hempstead, North Hempstead, and Oyster Bay, which have been adopted pursuant to authority delegated by the laws of the State of New York, prevent LILCO from using its facilities as reception centers.
These zoning laws have been interpreted and applied by the appropriate government tribunals -- the town boards of the respective towns -- which have determined that the use of the LILCO reception centers constitute zoning violations.
Discovery Recuest No. 36:
j At transcript page 16010 of the Shoreham emergency planning l
hearings FEMA witness Keller referred to a letter written by the Environmental Protection Agency to the State of New York addressing the release of contaminated washwater to sewer systems.
Mr. Keller believed this was in connection with the Nine-Mile Point Station.
Please provide a copy of the letter.
e Response to Discoverv No. 36:
The Governments object that Discovery Request No. 36 seeks information which is irrelevant.
The issue in this proceeding is "whether LILCO's emeroency resoonse olan contains adequate provision for reception centers for use by the public in the event of a radiological emergency at Shoreham."
Memorandum and Order (Ruling on LILCO Motion to Reopen Record and Remand of Coliseum Issue) (December 11, 1986) at p. 16 (emphasis added).
Since this proceeding is specific to the Shoreham plant, matters regarding other nuclear power plants are irrelevant, and are not proper subjects for discovery under 10 C.F.R. S 2.740(b)(1).
Without waiving this objection, the State of New York states that the requested letter is not in the State's possession, custody or control.
Discoverv Reauest No. 37:
For each of the other operating nuclear power plants in New York State, please state (a) the capacity of the relocation centers provided for an emergency at the plant to monitor people and vehicles for radioactive contamination within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and (b) their capacity to decontaminate people and vehicles, either within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or within such other times as you have information for.
Response to Discovery Recuest No. 37:
The Governments object that Discovery Request No. 37 seeks information which is irrelevant.
The issue in this proceeding is "whether LILCO's emeroency resoonse plan contains adequate provision for reception centers for use by the public in the 1
event of a radiological emergency at Shoreham."
Memorandum and Order (Ruling on LILCO Motion to Reopen Record and Remand of Coliseum Issue) (December 11, 1986) at p.
16 (emphasis added).
Since this proceeding is specific to the Shoreham plant, matters concerning reception centers at other nuclear power plants are irrelevant, and are not proper subjects for discovery under 10 C.F.R. S 2.740(b)(1).
Discoverv Recuest No. 38:
For each operating nuclear power plant in New York State other than Shoreham, are any of the relocation centers required to (a) have an SPDES permit or (b) have an environmental impact statement prepared under SEQRA or other state law?
Response to Discovery Recuest No. 38:
The Governments object that Discovery Request No. 38 seeks information which is irrelevant.
The issue in this proceeding is "whether LILCO's emeroency resoonse olan contains adequate provision for reception centers for use by the public in the event of a radiological emergency at Shoreham."
Memorandum and Order (Ruling on LILCO Motion to Reopen Record and Remand of Coliseum Issue) (December 11, 1986) at p.
16 (emphasis added).
Since this proceeding is specific to the Shoreham plant, matters concerning reception centers at other nuclear power plants are irrelevant, and are not proper subject for discovery under 10 C.F.R. S 2.740(b)(1). l
D Discovery Recuest No. 39:
For each of the other operating nuclear power plants in New York State, has anyone addressed the question whether the use of the relocation centers for monitoring and possible decontamination would violate local zoning laws or other state or local laws?
If anyone has addressed this question for any relocation center in New York State, please provide any documents addressing the question.
Please identify any people who have addressed or analyzed this question for relocation centers in New York State.
Response to Discovery Recuest No. 39:
The Governments object that Discovery Request No. 39 seeks information which is irrelevant.
The issue in this proceeding is "whether LILCO's emeroency response olan contains adequate provision for reception centers for use by the public in the event of a radiological emergency at Shoreham."
Memorandum and Order (Ruling on LILCO Motion to Reopen Record and Remand of Coliseum Issue) (December 11, 1986) at p.
16 (emphasis added).
Since this proceeding is specific to the Shoreham plant, matters concerning reception centers at other nuclear power plants are irrelevant, and are not proper subjects for discovery under 10 C.F.R. S 2.740(b)(1).
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppage, New York 11788 Ottf'i s t o p h e f M. McMurray David T. Case KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C. 20036-5891 Attorneys for Suffolk County bm Fabian G.
Palomino
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Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for Mario M. Cuomo, Governor of the State of New York,...,,.......
SCLMEIG U%FL 8
'Hbfah25 :f6U51987 NUCLEAR REGULATORY COMMISSIdh"E k;,0&
UNITED STATES OF AMERICAffh e
Before the Atomic Safety and Licensino Board
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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-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of the RESPONSE OF SUFFOLK COUNTY AND STATE OF NEW YORK TO LILCO'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING RECEPTION CENTERS have been served on the following this 20th day of February, 1987 by U.S. 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 Elisabeth Taibbi, Clerk W. Taylor Reveley, III, Esq.*
Suffolk County Legislature Hunton & Williams Suffolk County Legislature 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 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 Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 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 P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Fabian G.
Palomino, Esq.
Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 Mr. Jay Dunkleburger Richard B.
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
Mr. Frederick J.
Shon Anthony F. Earley, Jr.,
Esq.
1 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 Elisabeth Taibbi, Clerk W. Taylor Reveley, III, Esq.*
Suffolk County Legislature Hunton & Williams Suffolk County Legislature 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 Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792
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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 Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 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 P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Fabian G. Palomino, Esq.
Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 Mr. Jay Dunkleburger Richard B. 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
)
David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500. Oliver. Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 Via Federal Express Ctfristoph'er M. McMurray KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891
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