ML20214E336
| ML20214E336 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/10/1986 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20214D730 | List: |
| References | |
| OL-5, NUDOCS 8611240411 | |
| Download: ML20214E336 (19) | |
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4 November yitfEA/e4 UNITED STATES OF AMERICA e S NUCLEAR REGULATORY COMMISSION Wara ,<
Before the Atomic Safety and Licensino Boal k28g 9 sta In the Matter of '
)
) Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY ) (EP Exercise)
)
(Shoreham Nuclear Power Station, )
Unit 1) , )
)
SUFFOLK COUNTY'S MOTION FOR ORDER COMPELLING FEMA TO ANSWER INTERROGATORIES Pursuant to 10 CFR S 2.740(f), Suffolk County hereby moves the Board to compel the Federal Emergency Management Agency
(" FEMA") to respond more fully to Suffolk County's First Set of Interrogatories to the NRC Staff and FEMA, dated October 15, 1986. As described below, established case law and the NRC's rules governing discovery make clear that Suffolk County is entitled to the information requested in its October 15 Inter-rogatories.
Such information is necessary if the County is to discover and marshall the facts relevant to the upcoming hearings regarding the February 13 Exercise so as to permit meaningful, effective and efficient proceedings before the Board.
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6 I. Overview j In its October 3, 1986 Prehearing Conference Order (here-after, " Order"), this Board held that "[t]he FEMA review is di- j rectly at issue in the proceeding and that agency can be called upon to defend it." Order at 8-9. Accordingly, the Board admitted numerous contentions challenging the scope, sufficiency and adequacy of the February 13, 1986 Exercise of the LILCO Plan (hereafter, " Exercise").1 The Board further held that "[b]ecause the scope of the emergency preparedness exercise and the manner in which it was conducted are material considerations in the licensing process, they are matters [the Governments] may contest." Order at 6.
In order to discover information and evidence relevant to the Governments' contentions, Suffolk County, on October 15, requested FEMA and the NRC Staff to answer separately and fully 24 interrogatories. These interrogatories, filed in accordance with 10 CFR SS 2.740b and 2.741, have now been responded to by FEMA and the NRC Staff.2 This Motion is limited to the FEMA Response.
1 Sag, e.g., Contentions Ex 15, 16, 18.C, 19, 21, 22.A, and 47.
2 FEMA General Response to Suffolk County's First Request for Production of Documents and First Set of Interrogatories to FEMA, dated October 30, 1986 (hereafter, " FEMA Response"); NRC Staff Response to Suffolk County's First Request for Production of Documents and First Set of Interrogatories to NRC Staff, dated October 29, 1986 (hereafter, " Staff Response").
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s As will be demonstrated below, the inadequacy of FEMA's Response requires the County to seek the Board's assistance in obtaining the information requested by the County -- information which is clearly relevant to this proceeding and which the County 4
needs if it is to litigate meaningfully the central issues of the Governments' admitted contentions. FEMA's refusal to provide such information flies in the face of generally accepted rules governing the conduct of discovery, as well as in the face of NRC regulations and precedent.
t The scope of discovery in a licensing proceeding encompasses any matter, not privileged, which is relevant to the subject matter of the proceeding. The fact that the information sought will be inadmissible at hearing is not grounds for objection, if the information sought appears reasonably calculated to lead to, the discovery of admissible evidence. 10 CFR S 2.740(b)(1). Put another way, pretrial discovery is liberally granted to enable parties to ascertain the facts, to refine the issues,'and to i
prepare adequately for a more expeditious hearing or trial.
Texas Utilities Generatino Comoany (Comanche Peak Steam Electric Station, Units 1 and 2), LBP-81-25, 14 NRC 241, 243 (1981);
{
Pacific Gas and Electric Comoany (Stanislaus Nuclear Project, '
Unit 1), LBP-78-20, 7 NRC 1038, 1040 (1978).
Even a cursory examination of FEMA's Response reveals that the agency has followed neither the letter nor the spirit of NRC rules and regulations governing the conduct of discovery. We 4
turn now to such an examination.
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II. FEMA's " General Response" FEMA divides its Response into two parts. The first part, i
l entitled " FEMA General Response to Suffolk County's First Request l
for Production of Documents and First Set of Interrogatories to i FEMA," raises general and generic objections to the County's October 15 Interrogatories. The second part, entitled " FEMA Specific Response to Suffolk County's First Request for Production of Documents and First Set of Interrogatories to
- FEMA," sets forth FEMA's answers to each of the interrogatories filed by the County. We will first addreca FEMA's so-called
" General Response."
Although general objections to interrogatories are frowned upon in NRC proceedings,3 FEMA has nonetheless chosen to raise a number of " generic" objections in the first part of its Response, and to hint at others.4 The vagueness with which these objections are stated makes any cogent answer to them difficult to frame. Some of the assertions made by FEMA, however, demand that the County try.5 3
Sgg, Duke Power Comoany (Catawba Nuclear Station, Units 1 and 2), LBP-82-ll6, 16 NRC 1937, 1944 (1982).
4 FEMA's failure to number the pages of its Response requires the County to key its discussion of FEMA's assertions to the paragraph format utilized by FEMA. In the future, it would be helpful if FEMA simply numbered its pages, so that citations and references by responding parties are not so cumbersome. !
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In this Motion to Compel, Suffolk County addresses only l those FEMA objections to the October 15 Interrogatories which are i followed by a refusal to respond to a request for information.
That is, we do not address herein objections which were apparently made for the record, but which were nonetheless followed by substantive responses. FEMA's assertion, in point II (footnote continued) l
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A. Information Disclosed to LILCO Must Also Be Disclosed to the Governments s
In point X of its " General Response," FEMA makes the following statement:
I FEMA Counsel has also instructed the Counsel for Applican** that no documents prepared at the direction or request of FEMA officials, employees, or its contractors may be released without FEMA Counsel [ sic] being given the right of review and inspection to enter appro-priate objections.
i (footnote continued from previous page) of its " General Response," that the agency is not subject to discovery under NRC rules and regulations and the FEMA-NRC Memorandum of Understanding ("MOU") dated April 8, 1986, is an example. Such an assertion is plainly wrong.' Clearly, FEMA is a party to this proceeding, and it is subject to the same discovery rules which govern the other parties.
Nothing could be more clear than is the fact of FEMA's stat-us as a party to this proceeding. Throughout this proceeding, FEMA has been individually represented by its own counsel. FEMA has filed its own pleadings. Most.recently, FEMA of its own -
acccrd and on its own behalf, separately filed a motion seeking a reconsideration of the Board's October 3 Prehearing Conference Order. Egg FEMA's " Motion to Reconsider Atomic Safety and Licensing Board Prehearing Conference Order Dated October 3, 1986, and Memorandum and Supporting Affidavit in Support of that
( Motion," dated October 27, 1986. FEMA cannot be permitted to act '
as a party in protecting its own interests and in taking its own positions on the issues in this proceeding, while at~the same time claiming that it is not a party, and hence is entitled to special treatment, whenever it is asked to disclose relevant information.
Indeed, notwithstanding FEMA's assertion that it is not '
subject to formal discovery, counsel for FEMA states in point X of the " General Response" that " FEMA intends to provide the lead role in responding to discovery requests for NRC staff and FEMA contractors for this proceeding." Such a role cannot be recon-ciled with FEMA's claim that it is not subject to formal dis-covery. In addition, the NRC Staff has indicated that it has turned its documents over to FEMA, and that the Staff's answers to the County's interrogatories will be " encompassed within FEMA's answers." Clearly, the Staff's reliance on FEMA to comply with discovery requests is wholly incompatible with FEMA's claim that it is not subject to formal discovery.
I This statement is troubling, to say the least. It implies that FEMA intends to pre-screen and perhaps object to the release to the Governments of FEMA generated documents, even though such documents have already been provided to and reviewed by the applicant, LILCO. This kind of double standard has no place in this proceeding and the County hereby requests the Board to instruct FEMA to turn over to the Governments, forthwith, any and all documents or information which FEMA has previously shared only with LILCO.6 6
For somewhat different reasons, the County also takes exception with FEMA's assertion (Agg " General Response," point II) that " Counsel to Intervenors has evidenced in writing to Counsel for FEMA that the purposes of its discovery is to obtain information for use other than in this proceeding." This assertion requires response since it seriously mischaracterizes statements by counsel for the County. In an October 24, 1986 letter to counsel for FEMA, Ms. Karla J. Letsche stated the following in reference to certain documents previously forwarded to the County by FEMA:
Regarding the Inspector General documents, I have now had an opportunity to look at them.
No decision has been made whether any will be
( "made public" other than by their use in the normal course of the litigation. However, particularly in view of the fact that the Governments, by nature, have obligations not to keep material information secret, I cannot provide any assurance that such documents, received in discovery, will not be provided to other persons.
This statement was made in response to FEMA counsel's inquiry whether County counsel would represent that documents produced would not be "made public." Parties to a proceeding, particu-larly one which is of interest to the public (as this one is),
are under no obligation to keep secret any materials which are l obtained through the discovery process. If FEMA has any objec- i tions to third parties obtaining information which FEMA has released through discovery, FEMA must properly seek a protective order.
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B. The Pendency of FEMA's " Motion for Reconsideration" Does Not Excuse FEMA from Complying with the County's Discoverv Recuests FEMA states in point XI of its General Response that " . . .
many of its objections are premised on the need to protect in the discovery process its concerns as expressed in its MOTION FOR RECONSIDERATION filed on October 27, 1986." FEMA's disagreement with the Board's October 3 Prehearing Conference Order, however, provides no basis for withholding otherwise discoverable
( information from the County. The Board's Order expressly provided that the discovery period on the issues raised by the admitted contentions was to commence as of the service date of the Order. Moreover, it cautioned that "[t]he [ discovery]
schedule will be strictly adhered to." Order at 31.
Furthermore, in granting FEMA's request for an extension of the time to file objections to the October 3 Order, the Board specifically stated that "[t]his Order in no way stays the effec-tiveness of the ruling and schedule set forth in the October 3 Prehearing Conference Order." Egg Order, dated October 16, 1986, at 2.
FEMA cannot be allowed to amend unilaterally the discovery i
schedule set by the Board, and the pendency of FEMA's Motion for 4
Reconsideration does not excuse FEMA from complying with the Board's October 3 Order. FEMA has not sought a stay of the l Board's Order and therefore cannot choose to ignore the Order as if it did not exist. Simply put, FEMA must be disabused of its belief that mere disagreement with an order excuses compliance with it.
C. Obiections to Interrocatories Must Be Soecific In point VIII of its " General Response", FEMA notes its objection "in general" to the County's interrogatories "as being overly broad, unduly burdensome, and designed to gain information not relevant and not material to this proceeding." FEMI. then goes on to " enter [] this objection for each and every interroga-tory and will for economy not restate the objection in each answer."
FEMA's " economy" in this regard was a false economy. Objec-tions to interrogatories must be specific; general objections are insufficient. The burden of persuasion is on the objecting party to show that the interrogatory should not be answered. Egg Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), 16 NRC 1937.
In any event, "[f]ailure to answer or respond shall not be ex-cused on the ground that the discovery sought is objectionable unless the person or party failing to answer or respond has applied for a protective order. "
10 CFR S 2.740(f). If FEMA
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seriously asserts that it has grounds for objecting to each and every interrogatory, it must at the very least come forward with l
an explanation of the bases for these objections. Put another way, FEMA's objections must be made in reference to particular interrogatories, and its grounds for objecting, if any, must be !
specifically stated.
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D. FEMA Has Failed to Raise Procerly Any Claims of Privilece FEMA's attempt to raise the attorney-client privilege or the attorney work-product doctrine in point IV of its " General Re-sponse" is similarly unavailing. FEMA nowhere identifies information or documents in its possession that are privileged; indeed, FEMA does not even identify which interrogatories it has interpreted as seeking privileged information. To make out a prima facie claim of privilege, specification is required. Egg l
( Lono Island Lichtino Co. (Shoreham Nuclear Power, Unit 1), LBP-82-82, 16 NRC 1144, 1153 (1982); Public Service Co. of New Hamoshire (Seabrook Station, Units 1 and 2), LBP-83-17, 17 NRC 490, 495 (1983).
FEMA therefore fails to raise properly any claims of privilege.
III. FEMA's "Soecific Response" In the second part of its Response, FEMA provides individual answers to the County's interrogatories. In many instances, as I
part of its answer to an interrogatory, FEMA simultaneously l raises objections to, and places limitations upon, the scope of the interrogatory being answered. For the reasons discussed below, the County submits that many of FEMA's objections must be overruled, and that FEMA should be directed to provide the information requested by the County's interrogatories. To aid i
the Board's analysis, each of the interrogatories objected to by
FEMA for which the County seeks to compel further answer is set forth below, along with a description of FEMA's objection (s), and a discussion of why the objection cannot be upheld.
A. FEMA's Resoonse to Interroaatory No. 1 Suffolk County Interrogatory No. 1 reads as follows:
- 1. Identify each person whom FEMA and/or the NRC Staff expects to call as an expert or non-expert witness during the emergency plan-c
' ning exercise hearings and state the subject matter on which each is expected to testify.
In its October 30 Response, FEMA provided the County with a list of proposed witnesses in response to this interrogatory.
FEMA refused, however, to state the subject matter on which each witness is expected to testify. As a rationale for refusing to i supply this information, FEMA stated that:
Concerning the subject matter of the testimony of the FEMA witnesses, on advice of Counsel, until the Board rules on FEMA's October 27, 1986 Motion for Reconsideration of the Board's October 3, 1986 Order, this information will not be provided.
As discussed in Section II.B. above, the fact that FEMA has sought reconsideration of the Board's October 3 Order fails to provide a proper basis for withholding the information requested by the County. We will not repeat here arguments already made; 1
l rather, the Board is directed to the discussion set forth above.
! In the County's. view, however, it is sufficient to note that l
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FEMA's findings and conclusions form a rebuttable presumption in licensing proceedings. Indeed, in this case, FEMA's evaluation of the February 13 Exercise provides the centerpiece for the Governments' admitted contentions and the litigation which will be conducted. If it is to prepare adequately for that litiga-tion, the County must be informed of the subject matter upon which FEMA's witnesses propose to testify. Accordingly, the Board is requested to direct FEMA to disclose for each of its witnesses the subject matter on which each is to testify.
B. FEMA's Response to Interrocatory Nos. 9, 10. and 11 Interrogatory Nos. 9, 10 and 11 read as follows:
- 9. Identify every agency, organization, group, entity, institution, and individual, other than those identified in response to Interrogatory No. 5, who participated in, or reviewed, discussed, or received correspon-dence or documents concerning, the FEMA Report, drafts thereof, or the bases therefor.
- 10. Identify all communications concerning in any way the statement or any comments made by Frank Petrone during the Exercise Critique held on February 15, 1986, and documents known to, or in the possession of, FEMA or the NRC Staff, which concern such communications.
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- 11. Identify all communications and docu-ments known to, or in the possession of, FEMA l or the NRC Staff, concerning in any way the resignation of Frank Petrone, or events con-l cerning such resignation.
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In its response to Interrogatory No. 9, FEMA included the following statement: "
. . . on advice of Counsel, aspects of the
[ FEMA] (R}eport related to Interrogatories #10 or #11 are not discussed." Thereafter, FEMA refused to disclose any information in response to Interrogatory No. 10 or 11; rather, in response to both questions, FEMA merely stated:
On advice of Counsel, because the ASLB in its October 3, 1986, PREHEARING CONFERENCE ORDER (Ruling on Contentions and Establishing Discovery Schedule) refused to admit evidence on Contention Ex 19, FEMA objects to this Interrogatory and no answer will be provided.
FEMA's objections to these interrogatories must bE over-i ruled. As all parties to this proceeding are well aware, the scope of discovery extends to any matter, not privileged, which is relevant to the subiect matter of the oroceedina. 10 CFR S 2.740(b)(1). As all parties to this proceeding are also well aware, Frank Petrone was compelled to resign from his position with FEMA when he insisted that the FEMA Report contain a statement to the effect that:
Since the LERO plan cannot be implemented without state and local participation, FEMA cannot given (sic] reasonable assurance under NUREG-0654 that the public health and safety can be protected.
Draft FEMA Report, dated April 7, 1986. The final FEMA Report obviously contained no statement or finding similar to the one insisted upon by Mr. Petrone.
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Investigation into the circumstances of the Petrone resignation could lead to evidence regarding the nature, scope, and extent of the Exercise. It could also lead to information relevant to FEMA's and/or LILCO's rationales for testing some parts of the LILCO Plan, while sparing or subjecting to only limited testing other parts. Such information would obviously be relevant to a number of the Governments' admitted contentions, including Contentions Ex 15, 16, and 21. Thus, the fact that the Board has admitted Contention 19 "for argument only" in no way supports FEMA's refusal to answer interrogatories regarding the
- Petrone resignation. The simple fact is that information concerning the Petrone resignation may shed light on the February 13 Exercise and FEMA's role in developing, observing and evaluating that Exercise. Such information would be highly relevant, and cannot be concealed by FEMA from the Governments or this Board. Accordingly, the County requests the Board to direct FEMA to respond to Interrogatory Nos. 10 and 11, and to answer more fully Interrogatory No. 9.
C. FEMA's Resoonse to Interrocatorv Nos. 17 and 18 Interrogatory Nos. 17 and 18 read as follows:
- 17. Identify all communications, con-cerning the response to a Shoreham emergency, the LILCO Plan, or the Exercise between FEMA
} personnel and:
j (a) representatives of school districts having children inside the 10-mile EPZ;
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l (b) representatives of hospitals inside l i
or in the vicinity of the 10-mile EPZ; (c) representatives of nursing homes, adult homes, or other special facilities inside the 10-mile EPZ; (d) representatives of school districts, hospitals, or special facilities on Long Island but outside the 10-mile EPZ; (e) representatives of the State of Connecticut; (f) representatives of radio stations identified by LILCO as participants in the LILCO emergency broadcast system ("EBS");
(g) school bus drivers for schools located in the 10-mile EPZ; 2
i (h) representatives of bus companies identified in the LILCO Plan as having agreed to make buses avail-q able to LILCO; (i) representatives of ambulance com-panies identified in the LILCO Plan as having agreed to make vehicles available during a Shoreham acci-dent;
, (j) representatives of Nassau County; (k) members of the public of Long Island.
- 18. Identify all-documents concerning the communications identified in response to In-terrogatory No. 17.
In its Response, FEMA unilaterally chose to limit the scope ,
A of its answer to these interrogatories to the day of the Exer- !
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cise:
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t FEMA finds that the inclusion of " response to a Shoreham emergency" and."the LILCO plan" to the scope of the interrogatory is overly broad and burdensome, since the routine conversations and communications relating to these areas covered by the sections of the interrogatory extend over a period of about two years. For that reason, on advice of Counsel, FEMA declines to provide information covering these areas.
The following responses relate to communica-tions of FEMA personnel during the exercise Despite FEMA's complaint about the "burdensomeness" of these interrogatories, it has been able to locate and forward to the County copies of correspondence it nas received from members of the public concerning the Exercise in response to subpart (k) of
- Interrogatory No. 17, whenever written. In addition, documents relating to some parts of the areas inquired into by Interroga-tory No. 17 (i.e., contacts with school districts, representa-tives of radio stations, representatives of Nassau County), have been forwarded to the County. Thus, FEMA, in its discretion, has
(, chosen to selectively locate and produce certain information, while claiming that the broadness and burdensomeness of the County's request nevertheless justify its refusal to locate and l produce other of the requested information.
l The County submits that FEMA's ability to locate the infor- l mation it chose to produce in answering these interrogatories l demonstrates that FEMA is also capable of locating the other j
information requested. In any event, it must. The adequacy of the Exercise is at issue in this proceeding. If FEMA has l
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information related to the entities listed in Interrogatory No. 17(a)-(k), the information is relevant to the Governments'- , j admitted contentions and must be made available. For FEMA arbitrarily to select to disclose only communications made on the g
l dar of the exercise, when it admits that it possesses information concerning " conversations and communications" between FEMA and i
such entities " extend [ing) over a period of abaut two years," is insupportable. If FEMA is concerned about the resources it would
, have to expend to locate and duplicate the requested information,
(
an accommodation of any such problems can likely be worked out between counsel for the parties. Butunderdocircumstances should FEMA be permitted to withhold'such patently relevant information.7 9
7 In its response to Interrogatory No. 17, FEMA refused to disclose the identities of evaluators who had contact with the entities listed in Interrogatory No. 17(a)-(j). Similarly, FEMA's Response refused to identify the evaluators who had observed the organizations,Lactivities and events inquired into by Interrogatory Nos. 13'(Red Cross), 14-(the Shoreham-Wading River School District) and 15 (the U.S. Coast Guard).
t There is no legitimate basis for FEMA's refusal to identify the evaluators it reliediupon at the Exercise.in its Response to the County's October 15 Interrogatories. Since the County's Interrogatories were filed, however, FEMA has produced documents to the County which reveal the names, functions and duties of almost all of the Federal personnel involved in the Exercise. l Therefore, at this time, the Countyils willing to proceed with l discovery on the assumption that sufficient information has been l provided by FEMA to permit th6 County to learn the information it I originally sought by way of its Interrogatories. If it later l becomes apparent that the County's understanding of the information already in its possession is wrong, the County will then consider whether to seek relief from the Board'. ;
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IV. Conclusion For all the foregoing reasons, Suffolk County submits that !
the Board should direct FEMA to complete its Response to the County's October 15 Interrogatories by answering fully each of the interrogatories discussed above, within 5 days. As the Board has made clear by its discovery schedule, time is of the essence in this proceeding. Depositions are scheduled to begin on November 17 and, in light of the December 19 discovery cut-off c set by the Board, it is essential that the information sought by the County in this Motion be provided as soon as possible.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Highway Veterans Memorial Highway Hauppauge, New York 11788 4
Michael S. Mi1Ier -
tl
' Susan M. Casey Kirkpatrick & Lockhart 1900 M Street, N.W.
Washington, D.C. 20036 -
Attorneys for Suffolk County 1
November 10, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION /,J ..\
Before the Atomic Safety and Licensina Boa) .
- NOV181986>;
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<Et2nio *N.w.:::e Eo
,p In the Matter of ) '4 ,
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5 (Shoreham Nuclear Power Station,
) (EP Exercise)
)
Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON RESPONSE TO " FEDERAL EMERGENCY MANAGEMENT AGENCY'S MOTION TO RECONSIDER ATOMIC SAFETY AND LICENSING BOARD PREHEARING CONFERENCE ORDER DATED OCTOBER 3, 1986, AND MEMORANDUM AND SUPPORTING AFFIDAVIT IN SUPPORT OF THAT MOTION"; SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON MOTION FOR LICENSING BOARD TO FOLLOW THE RULES OF PRACTICE IN RULING ON MOTIONS; SUFFOLK COUNTY MOTION FOR FOUR-DAY EXTENSION OF TIME WITHIN WHICH TO FILE MOTION FOR ORDER COMPELLING RESPONSES TO
{ INTERROGATORIES; SUFFOLK COUNTY'S MOTION FOR ORDER COMPELLING LILCO TO RESPOND TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS; and SUFFOLK COUNTY'S MOTION FOR ORDER COMPELLING FEMA TO ANSWER INTERROGATORIES have been served on the following this 10th day of November, 1986 by U.S. mail, first class, except as otherwise noted.
John H. Frye, III, Chairman
- Atomic Safety and Licensing Board Dr. Oscar H. Paris
- U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. U.S. Nuclear Regulatory Commission 20555 Washington, D.C. 20555 Mr. Frederick J. Shon* Spence W. Perry, Esq.
Atomic Safety and Licensing Board William R. Cumming, Esq.*
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 Federal Emergency Management Agenc3 500 C Street, S.W., Room 840 Washington, D.C. 20472
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Anthony F. Earley, Jr., Esq. Bernard M. Bordenick, Esq.*
General Counsel Long Island Lighting Company U.S. Nuclear Regulatory Commissio$
Washington, D.C. 20555 175 East Old Country Road l Hicksville, New York 11801 l l
Mr. William Rogers W. Taylor Reveley, III, Esq.**
Clerk Suffolk County Legislature Hunton & Williams P.O. Box 1535 Suffolk County Legislature 707 East Main Street Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street
< North Country Road Riverhead, New York Wading River, New York 11901 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 MHB Technical Associates Hon. Peter Cohalan 1723 Hamilton Avenue Suffolk County Executive Suite K San Jose, California 95125 H. Lee Dennison Building Veterans Memorial Highway Hauppauge, New 'sork 11788 i
Martin Bradley Ashare, Esq. Fabian G. Palomino, Esq.
Suffolk County Attorney Special Counsel to'the Governor r Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway 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
- By Hand w
Karlq J. Letsche/L/
h a
- By Federal Express KIRKPATRICK & LEKHART 1900 M Street, N.W.
Suite 800 Washington, D.C. 20036 Date: November 10, 1986 l
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