ML20212F771
| ML20212F771 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/02/1987 |
| From: | Bachmann R NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| References | |
| CON-#187-2669, RTR-NUREG-0654, RTR-NUREG-654 OL-3, NUDOCS 8703050153 | |
| Download: ML20212F771 (16) | |
Text
c 26 03/02/87 WM gRESPOMPEtif4, COLKETED ONPC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION P '87 WR -4 All :32 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD ,
,] _
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
x NRC STAFF SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO FEMA AND THE NRC STAFF On January 28, 1987, Intervenors Suffolk County ej al. II - filed interrogatorics and document requests on the Staff and FEMA. 2_/ The Staff responded to the Discovery Request on February 17, 1987. 3_/ The Staff hereby supplements its Response to the Discovery Request in accordance with 10 C.F.R. I:2.740(e)(1)(fi).
The Staff has designated the following witnesses to provide testimony and be available for oral examination at the hearing:
- 1. Falk I:antor and Leonard Soffer. The subject matter of their expected testimony concerns the number of persons for whom radiological monitoring / decontamination might be performed, in accordance with the l
[ 1/ Suffolk County, State of New York and Town of Southampton
("Intervenors") .
-2/ "Suffolk County, State of New York and Town of Southampton's First Set of Interrogatories and Request for Production of Documents to FEMA and the NRC Staff" (" Discovery Request").
i
- -3/ "NRC Staff Response to Suffolk County, et al. First Set of Interrogatories and Request for Production of Documents to FEMA and the NRC Staff" (" Response").
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guidance provided in the Licensing Board's Orders of December 11, 1986 S and Februaiy 9,1987 b, and ALAB-855, 24 NRC (December 12, 1986).
A copy of the professional qualifications of Mr. Kantor was previously provided in the initial Staff Response dated February 13,1987; A copy of Mr. Soffer's professional qualifications is attached to this response.
With respect to the specific questions propounded .in Interrogatories 3,
- 4 and 5, further information will i)e provided as it becomes available.
- 2. Dr. Thomas Urbanik. It is expected that Dr. Urbanik will testify regarding traffic and transportation problems at the reception centers.
In support of his testimony, Dr. Urbanik will rely the September 26, 1986 analysis prepared by KL7 Associates, Inc., NUREG-0654, and the gereral body of literature in traffic and transportation, including papers listed in his Curriculum Vitae, a copy of which is attached to this response, s
Richard G. Bachmann Counsel for NRC Staff Dated at Dethesda, Maryland this 2nd day of Ptarch,1987
-4/ "hiemorandum and Order (Rulings on LILCO Motion to Reopen Record and Remand of Coliseum Issue)".
- 5) " Memorandum and Order (Ruling on LILCO's and Intervenors' Motion for Reconsideration of Schedule)".
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! l LEONARD SOFFER l
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PROFESSIONAL QUALIFICATIONS REGULATORY IMPROVEMENTS BRANCH DIVISION OF SAFETY REVIEW AND OVERSIGHT OFFICE OF NUCLEAR REACTOR REGULATION l
1 I am a Section Leader within the Regulatory Improvements Branch, Division of Safety Review and Oversight, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. My duties in this position include the review and evaluation of accident source terms and consequence analysis 1
techniques to assess the potential impacts of severe accidents, and to apply such techniques and research knowledge of accident source terms towards the review and evaluation of potential revisions to regulatory requirements in areas such as containment performance, equipment qualification, emergency planning and siting.
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' In the event of a reactor emergency, I also serve on the NRC Incident Response Team where my position is Deputy Director of the Protective Measures Team.
This group performs independent assessments of the consequences of possible f
releases by utilizing plant conditions as well as site meteorology and
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t population distribution, and makes recommendations to the NRC Executive Team 1 on protective actions to be taken, n
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1 I receive,d a B.S. Degree (with honors) in Physics from the City College of I
New York in 1952 and attended graduate school a't Case Western Reserve Universit.y in Cleveland, Ohio.
Before joining the Commission, I was employed for 21 years as a Physicist and Nuclear Engineer with the National Aeronautics and Space Administration (NASA) at the Lewis Research Center in Cleveland, Ohio. In this capacity, I performed analyses on radiation shielding and nuclear safety requirements for nuclear power systems intended for lunar and space applications. I assisted in the radiation shielding design of the NASA Plum Brook reactor, served on an i
agency-wide study team investigating the radiological safety aspects of using
- k. radioisotopes for space power generation, and w:s section leader of a group sv
?) responsible for research on radiation shielding and radiological safety a
[ concerns. I also monitored contracts and occasionally lectured on radio-p logical physics and shielding to others within NASA.
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$ I joined the Commission staff in 1973, first as a member, and, beginning D
% in 1976, as Section Leader within the Accident Analysis Branch of the r~ 1
- Office of Nuclear Reactor Regulation. I have participated in the detailed 4
safety and environmental review of over 20 nuclear power plants. My respon-A Fj sibilities included evaluation of the demographic characteristics of nuclear s'
{ power reactor sites and the hazards posed by nearby man-related activities U as well as the independent assessment of the likelihood and consequences of p
9 various postulated accidents utilizing data on plant safety features, site f
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3 meteorology nd population characteristics. In my capacity as Section Leader, I was responsible for reviewing the results of similar efforts by others.
I have prepared and presented testimony at hearings on the population density and use characteristics of nuclear power reactor sites as well as the radiological consequences of accidents.
In 1980 I became Section Leader within the Siting Analysis Branch in the Office of Nuclear Reactor Regulation. My section had responsibility for review'and evaluation of the population characteristics of nuclear power reactor sites as well as the hazards posed by nearby man-related activities.
I was detailed to the Accident Source Term Program Office from January 1983
- to January 1984 and became Acting Assistant Director for Policy Development and Implementation in August 1983. This involved responsibility for developing and coordinating agency-wide policy reconsnendations for emergency response, siting criteria and plant accident mitigation features based upon severe accident and source term research.
From January to December 1984 I was Leader of the Accident Risk Section ,
within the Office of Nuclear Regulatory Research where I supervised research f on severe reactor accident sequences and offsite consequences and also
- examined the possible impact of such risk on the development of NRC regulations i and criteria.
4 From Januarj to October 1985 I was a section leader within the Accident EvaluationIIranchoftheOfficeofNuclearReactor'Regulationwheremy section performed independent evaluations of the likelihood and consequences of reactor acci. < nts.
I assumed my present position in November 1985.
Pertinent experience has also included participation in development of a draft standard entitled " Guidelines for Estimating Present and Forecastin'g Future Population Distributions Surrounding Power Reactor Sites," membership in the NRC Working Group that wrote the " Report of the Siting Policy Task Force" (NUREG-0625), extensive technical participation in the reactor accident consecuence analyses contained in the so-called Sandia Siting Report " Technical Guidance for Siting Criteria Development" (NUREG/CR-2239), and part-authorship of the Chernobyl accident implications report " Assessment of the Implications of the Accident at Chernobyl for Nuclear Safety Regulation in the United States" (NUREG-1251).
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I have also lectured widely at numerous courses sponsored by the IAEA and others'on radiological consequences of severe accidents, dose calculation methodology, accident risk considerations relating to siting, emergency planning and probabilistic risk assessment. I was a member of an IAEA l Siting Mission to Greece to assist that Government in the development of demographic criteria for nuclear power plants, and have been invited to l lecture, as well, on severe accident risk considerations at IAEA courses l held in Korea, Egypt, Mexico and Yugoslavia.
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I have written about 12 technical papers and reports on various topics s i related to radiological safety aspects of nuclear reactors. I am a member of the American Nuclear Society and the Population Association _
' I of ' America, which is the professional society of U.S. demographers.
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. CURRICULUM VITAE URBANIK II, Thomas P.E., Ph.D. OFFICE PHONE: 409/845-1535
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HOME ADDRESS: 12 Post Oak Bend Rd. HOME PHONE: 409/690-6795 College Station. Texas 77840 Birthdate: February 15, 1946 Citizenship:
~
U.S.
S.S. No.: 079-36-0185 Marital Status: Married, 2 Sons PROFESSIONAL INTERESTS: Traffic Engineering Transportation Planning Evacuation Planning Highway Design / Safety Public Transportation EDUCATION:
Ph.D., Civil Engineering, Texas A&M University,1982 M.S., Transportation Engineering, Purdue University,1971 B.S., Civil Engineering, Syracuse University, 1969 B.S., Forest Engineering, New York State College of Environmental Science and Forestry, 1968 PROFESSIONAL LICENSES:
Registered Professional Engineer, Michigan No. 22008 Registered Professional Engineer, Texas No. 42384 EXPERIENCE:
1982-1986
- Lecturer -
Department of Civil Engineering Civil Systems Group Texas A&M University College Station, Texas 77843-3136 Undergraduate instruction in transportation engineering and planning, traffic engineering, and highway design.
Program Manager -
Transport Operations Texas Transportation Institute Texas A&M University College Station, Texas 77843-3135 Duties and responsibilities are to provide specific direction to program in its conduct of transportation research projects for fed-eral, state, and local transportation agencies.
The range of transportation projects include: traffic engineering, transportation planning, highway safety, public_ transportation, and transportation systems management.
pManagement responsibilities are to. identify and pursue research opportunities, locate and recommend staff, monitor research activities to meet budget and project objectives, develop overall
, program funding, provide an annual staff review (15 personnel),
supervise preparation of proposals, develop writing and communica- -
tion -skills of the program staff, review and allocate work, coor-dinate equipment and staffing needs, recommend and approve perti-nent expenditures for annual budget of approximately $600,000.
1976-1982
- Assistant Research Engineer Conducted research, prepared proposals, and provided project super-vision on research activities. Responsible for final report preparation and presentation. Research areas included traffic engineering, transportation planning, public transportation and evaluation planning.
1972-1976
- Traffic Engineer City of Ann Arbor Department of Streets, Traffic and Parking Ann Arbor, Michigan Responsible to Director of Streets. Traffic and Parking, Ann Arbor, Michigan. Responsible supervisory and professional traffic engi-neering work in directing the traffic engineering function of the department. Work' involved responsibility for the application of professional engineering skill and knowledge to difficult traffic engineering problems in traffic regulation and control, street use, street lighting, geometrics, parking, school safety, curb cuts, and related traffic engineering activities. Was directly responsible for the supervision of the traffic signal and traffic sign mainte-nance personnel.
1971-1972
- Transportation Planning Engineer City of Ann Arbor Traffic Engineering and Transportation Department Ann Arbor, Michigan Responsible to Director of Traffic Engineering and Transportation, Ann Arbor, Michigan. Reviewed transportation aspects of all plans
.. for development in the city. Staff member to the Ann Arbor Trans-portation Authority responsible for budget and union negotiations.
Staff Coordinator for the planning, design, implementation, and op-eration of the Dial-A-Ride demand-responsive demonstration project.
1970-1971
- Research Assistant Joint Highway Research Project Purdue University West Lafayette, Indiana Conducted research concerning high-way related grade crossings.
Designed attitudinal questionnaire concerning public transportetion for a home interview survey in Lafayette, Indiana. Also analyzed survey results for inclusion in a report on public transportation in Lafayette, Indiana SDCIETY MEMBERSHIP:
Transportation Research Board Institute of Transportation Engineers American Society of Civil Engineers American Society for Engineering Education HONOR SOCIETIES Chi Epsilon CURRENT COMMITTEE MEMBERSHIP Chairman, Institute of Traffic Engineers Texas Section, Committee on Continuing Education Member, Transportation Research Board, Committee on Intercity Bus Transportation PUBLIC SERVICE Member, Wellborn Community Center, Board of Directors CONTINUING EDUCATION / PROFESSIONAL DEVELOPMENT Association of oil Pipelines, Educators Tour, July 1984 The University of Michigan, Bureau of Industrial Relations, Graduate School of Business Administration, Principles of Effective Supervisory Management U.S. Department of Transportation Federal Highway Administration, Digit-al Computer-Urban Traffic Control / Bus Priority System (UTCS/8PS)
Course.
a Michigan Department of Civil Service, Principles of Public Sector Labor Relations.
CURRENTIESEARCH
" Cost-Effectiveness Analysis for Ranking New Interchanges and Highway Railroad Grade Separations", Texas State Department of Highways and Public Transportation -
" Automated Transit Ridership Data Collection", Texas State Department of Highways and Public Transportation.
" Computerized Dispatch Aids for Small Public Transportation Providers",
Texas State Department of Highways and Public Transportation.
" Safety and Operational Evaluation of Shoulders on Urban Freeways,"
Texas State Department of Highways and Public Transportation.
" Traffic Engineering / Transportation Planning Relative to Evacuation-Time Estimates", Battelle Pacific Northwest Laboratories.
" Evaluation of Transportation Analysis Techniques Used for Estimating Evacuation Timer at Nuclear Power Plant Sites", Battelle Pacific Northwest Laboratories.
PUBLICATIONS AND PAPERS Traffic Engineering Understanding Forced Flow, ITE Journal, Institute of Transportation Engineers, Washington, D.C., October 1986.
Safety and Operational Evaluation of Shoulders on Urban Freeways, With Carlos R. Bonilla Texas State Department of Highways and Public Transportation, Research Report Number 395-1, Austin, Texas , August 1986.
The Effectiveness of Using Freeway Shoulders for Traffic With Wes Lum, District 6-District 7 Joint Annual Meeting, Institute of Transportation Engineers, Vancouver, B.C., Canada, July 1986.
Effects of Shoulder Reductions on Highway Safety, With Wes Lum, American Society of Civil Engineers, Specialty Conference on Effectiveness of Highway Safety Improvements, Nashville, Tennessee, March 1986.
Speed / Volume Relationships on Texas Highways, State Department of Highways and Public Transportation, Research Report 327-2F, Austin, Texas, October 1983.
Priority Treatment of Buses at Tra f fi c Signals, Transportation
( Engineering, November 1977.
! Priority Treatment of High-Occupancy Vehicles on Arterial Streets.
l State Department of Highways and Public Transportation, Report 205-5, 1977.
Evaluation of Alternative Concepts for Priority Use of Urban Freeways in Texas, State Department of Highways and Public Transportation, Report 205-1, 1977.
l Driver Information Systems for Highway-Railway Grade Crossings, with
> K.W. Heathington, Highway Research Record Number 414, 1972.
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Evacuation Planning Transportation Analysis for Evacuation: State-of-the-Art, ITE Journal, Institute of Transportation Engineers, Washington, D.C., March 1986.
An Isndependent Assessment of Evacuation Times For a Peak Population S'cenario in the Emergency Planning Zone of the Seabrook Nuclear Power Station, with others U.S. Nuclear Regulatory Commission, NUREG/CR-2903, 1982.
CLEAR (Calculates Logical Evacuation And Response), A Generic Transpor- -
tation Network Model for the Calculation of Evacuation Times Esti-mates, with others, U.S. Nuclear Regulatory Commis-sion, NUREG/CR-2504 October 1981.
Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, with others, U.S. Nuclear Regulatory Commission NUREG/CR-1745, 1980.
Analysis of Evaucation Times Around 52 Nuclear Power Plant Sites, with others, U.S. Nuclear Regulatory Commission, NUREG/CR-1856 Volume 1, 1980.
Texas Hurricane Evacuation Study, The Coastal and Marine Council,1978.
Public Transportation Analysis of Rural Public Transportation in Texas, with others, State Department of Highways and Public Transportation Technical Report 1069-1F, August 1982.
Intercity Bus Riders in Texas. Transportation Research Record 887, 1982.
The Intercity Bus Industry in the U.S. and Texas, witn others, State Department of Highways and Public Transportation, Technical Report 0 965 -1 F, 1981. Bryan-College Station Energy Contingency Study, Metropolitan Planning Organization of Bryan-College Station,1980.
Bryan-College Station Transit Improvement Plan, with others, Metro-politan Planning Organization,1979.
Ann Arbor Dial-A-Ride Project Final Report, Ann Arbor Transportation Authority, 1973.
Ann Arbor Dial-A-Ride Uperations, Highway Research Board Special Report 136, 1973.
The Greater Lafayette Area Bus Transit Study, with others, Joint Highway Research Project, Purdue University,1971.
Elderly and Handicapped Transportation Guidelines for Evaluation of Human Services Transportation Programs, with others, State Department of Highways and Public Transportation, Report 1065-2F, 1981.
Evaluation of Selected Human Services Transportation Providers, with Diane Bullard, State Department of Highways and Public Transportation, 1980.
Cost-Effectiveness of Accessible Fixed-Route Buses in Texas, with Jose Soegard, Technical Report 1061-1F,1979.
n l Transportation of the Elderly and Handicapped in Texas: A Case Study, with Jose A. Soegard, State Department of Highways and Publ ic Transportation Technical Report 1056-2F,1979.
Tota.1 Accessibility Versus Equivalent Mobility of the Handicapped.
Ipstitute of Transportation Engineers, Compendium of Technical Papers, 49th Annual Meeting,1979.
Survey of Vehicles and Equipment for Elderly and Handicapped Trans-portation. State Department of Highways and Public Transpor-tation, Technical Report 1056-1, 1978. -
Corpus Christi Elderly and Handicapped Transportation Study, with R.W.
Holder, City of Corpus Christi, Texas,1978.
PRESENTATIONS Presentation entitled Shoulder Reductions on Urban Freeway, ASCE Specialty Conference, " Shaping the Future of American Highways", San Diego, CA. April 15-17, 1985. .
Presented seminar on transportation analysis at Emergency Praparedness P1ans and Programs Workshup Battel 1e Pacific Northwest Laboratories, Williamsburg, VA.
Presentation on Evacuation, Transportation, and Traffic Control, National Emergency Training Center, Emergency Management Institute Evacuation Planning and Response Actions Simulation Course.
Emmitsburg, Maryland, July 8-12, 1985.
EXTENSION:
Texas Engineering Extension Service, Instructor on various courses including basic traffic engineering, geometric design of highways and highway capacity.
University of California at Berkely, Institute of Transportation Studies, Extension Programs, Guest Lecturer, highway capacity courses presented to California Department of Transportation.
EXPERT W... 4SS Presented expert testimony before the Atomic Safety and Licensing Board, U.S. Nuclear Regulatory Commission, concerning evacuation times at several nuclear power plant sites including Three-Mile Island, Diablo Canyon, Indian Point Seabrook and Shoreham.
o ANSWERS TO INTERR0GATORIES Thomas Urbanik II Intervenors' Interrogatory No. 1 i
Thomas Urbanik II Dr. Urbanik will testify regarding traffic and transportation problems at reception centers.
Intervenors' Interrogatory No. 2 See attached resume Intervenors' Interrogatory No. 3
- 1. NUREG 0654
- 2. KLD Associates, Inc., Capacity Analysis of Highways in the Vicinity of Reception Centers for Evacuees from within the Shoreham Station Emergency Planning Zone (September 26,1986).
- 3. The general body of literature in traffic and transportation including papers listed on resume.
Intervenor's Interrogatory No. 4 Dr. Urbanik has testified, based on his recollection, of the NRC staff at Three Mile Island, Zimmer, Three Mile Island. Diablo Canyon, Allen's Creek, Commanche Peak, Shoreham, Seabrook, Pil grim, Perry, Limmerick, Byron, and Catawba. Dr. Urbanik has been deposed atleast once, based on his recol-lection, at the Shoreham hearings.
Intervenor's Interrogatory No. 5 See response to interrogatory No. 1 l
Intervenor's Interrogatory No. 6-12 l
Not relevent Intervenor's Interrogatory See response to Interrogatory 3.
EIGl
. UNITED STATES OF AMERICA
> NUCLEAR IiEGULATORY COMMISSION 87 mR -4 A11:32
~BEFORE THE ATOMIC SAFETY AND LICENSING BOARD tM y
. . ~ WICf. ..
p:n In the Matter of )
)
LONG ISLAND LIGHTINO COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
CEPTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO FEMA AND THE NRC STAFF" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system or, as indicated by a double asterisk, by telecopy and first class mail, this 2nd day of March 1987.
Morton B. Margulies, Chairman
- Joel Blau, Esq.
Administrative Judge Director, Utility Intervention Atomic Safety and Licensing Doard Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 Jerry R. Kline* Fabian G. Palomino, Esq.**
Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 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, DC 20555 Albany, NY 12223 Philip McIntire W. Taylor Reveley III, Esq.
Federal Emergency Management Donald P. Irwin, Esq.**
Agency Hunton a Williams 26 Federal Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212
4.
Stephen B.-Latham, Esq. Herbert H. Brown, Esq.
Twomey, Litham a Shea Lawrence Coe Lanpher, Esq.**
Attorneys at Law Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick & Lockhart Riverhead, .NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel
- U.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, DC 20555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel
- Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.
Martin Bradicy Ashare, Esq. General Counsel Suffolk County Attorney Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq.
North Shore Committee Attorney General of the State P.O. Box 231 of New York Wading River, NY 11792 Attn: Peter Bienstock, Esq.
Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center 195 East Main Street Room 46-14 Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr. William R. Cumming, Esq.
General Counsel Office of General Counsel i Long Island Lighting Company Federal Emergency Management l 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW Dr. Robert Hoffman Long Island Coalition for Safe Docketing and Service Section*
i Living . Office of the Secretary P.O. Box 1355 U.S. Nuclear Pegulatory Commission Massapequa, NY 11758 Washington, DC 20555 i
Mary M. Gundrum, Esq. Barbara Newman New York State Department of Law Director, Envfronmental Health 120 Broadway Coalition for Safe Living 3rd Floor, Room 3-116 Box 944
! New York, NY 10271 Huntington, New York 11743 j /0 l e f" _
J dra G. Bachmann Counsel for NRC Staff 1