ML20214J506
| ML20214J506 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/26/1986 |
| From: | Latham S, Letsche K, Palomino F NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#486-1679 OL-5, NUDOCS 8612010333 | |
| Download: ML20214J506 (41) | |
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000KEIED us9RC Novembeer 36l, Pibli6 uw UNITED STATES OF AMERICA 0FFILE ' '
NUCLEAR REGULATORY COMMISSION 00CKEig,
f and Licensina Board Before the Atomic Safety
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)
In the Matter of
)
50-322-OL-S
)
Docket No.
LONG ISLAND LIGHTING COMPANY (EP Exercise)
)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
_)
STATE OF NEW YORK AND TOWN OF SOUTHAMPTON FOR PRODUCTION OF DOCUMENTS TO SUFFOLK SUFFOLK COUNTY, STATE AND TOWN OF SOUTHAMPTON 1986, LILCO filed its "Second Set of On November 10, to Interrbgatories and Requests for P:oduction of Documents
("Second Suffolk County, New York State andl Town of Southampton" 1
10 CFR Pursuant to the NRC's Edkes of Practice, Request").
and the Town of the State of New York, S 2.740b, Suffolk County, herjebyrespondtoLILCO'sSecond Southa'mpton (the " Governments")
GENERAL AESPONSE Request.
I.
forth herein Unless otherwise indicated, the answers set A.
When necessary, have been jointly provided by the (fovernments.
ffolk however, the answers distinguish between the responses of Su in and the Town of Southampton, County, tDe State of New York, accordance with LILCO's " Instructions."
8612010333 861126 PDR ADOCK 05000322 1)303 O
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. a B.
In general, the documents generated by LILCO players during the Exercise, the FEMA Report, and documents generated by FEMA or other " federal" personnel and contractors prior to, during, and after the Exercise, provide the bases for many of the Governments' Ex Contentions as stated in the contentions them-selves.
Since all of these documents are already well known to LILCO, having been created or produced by LILCO, or provided to LILCO by FEMA, when such documents are responsive to an inter-rogatory herein that fact is noted but individual documents are not separately identified or produced.
C.
The Governments understand LILCO's interrogatories and document requests to request information within the possession,.
custody or control of the Governments.
Any broader interpreta-tion of the information requested by LILCO is objected to by the Governments.
D.
In some instances, the interrogatories ask whether one of the Governments' contentions " alleges" a particular fact or conclusion, or a variation on such a question.
The Governments' contentions speak for themselves, and when appropriate, that fact is noted therein, rather than merely repeating verbatim the allegations contained in the contentions.
E.
The legal bases for the Governments' contentions, and the allegations contained in them, are stated in the contentions themselves.
Accordingly, in the responses below, the Governments
o a have not restated the legal authority, NRC or FEMA rules, regula-tions, or guidelines and materials which form the bases for their answers or contentions.
F.
In many instances LILCO has requested the Governments to state how LILCO's response during the Exercise should have been different in the Governments' view (for example, "how many" bus companies, etc., would have had to have participated in the Exer-cise for the results of the Exercise to have been meaningful, or how quickly information should have been provided to the media, or some variation on that theme).
While the Governments provide answers to some of these interrogatories, the Governments also object to such interrogatories as not being relevant to the particular contentions or subparts.
The relevant matter is that what happened during the exercise was inadequate and thus the exercise results do not provide a basis for conclusion that LILCO has the ability to implement portions of its Plan.
What LILCO might have to do to correct the deficiency is irrelevant because the parties are dealing only with the February 13 exercise and its results.
G.
In a number of instances, LILCO interrogatories seek the Governments' views on how problems revealed during the exercise might be corrected (or variations on that theme).
Such inter-rogatories are objectionable.
The Governments have no obligation
o a 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.
II.
ANSWERS AND OBJECTIONS TO INTERROGATORIES LILCO INTERROGATORY NO. 1 1.
a.
How many of the bus companies or bus yards listed in Contention EX 16(K) do Intervenors contend would have had to have participated in the Exercise in order for the Exercise to have yielded " valid or meaningful results?"
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
The Governments are not at this time able to provide a numerical response to this question but can state that the number of bus companies or yards which participated in the exercise was too small to justify a conclusion concerning the response capabilities of all the companies or yards relied upon by LILCO in its Plan, or concerning LILCO's ability to implement the portions of the plan cited in subpart K of Contention Ex 16.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to subpart (a) are the data and Plan references set out in Contention Ex 16 and subpart K and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to
identify to testify regarding this contention.
The results of discovery, analyses and research by those individuals may provide additional bases for the referenced proposition.
(c)
At this time the Governments have identified no documents responsive to this request.
LILCO INTERROGATORY NO. 2 2.
a.
How many buses from each bus company or bus yard-that participated in the Exercise (see Contention EX 18(C)(i)) do Intervenors contend would have had to have been supplied in order to demonstrate that emergency response personnel were " familiar with their duties?"
b.
What is the basis for the answer to paragraph (a)?
c._ Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
At this time the Governments are not able to provide a nume'rical response to this question, but can state that the activities of the bus companies and yards that participated in the Exercise were too limited to provide a basis for concluding that emergency personnel are familiar with their duties.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to subpart (a) are the data set out in the contention, the documents generated during the Exercise by FEMA and LILCO, the LILCO Plan, and the observations, knowledge, training, background, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding this contention.
The results of discovery, analyses and research by those individuals may provide additional bases for the referenced proposition.
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i (c)
At this time the Government have identified no documents as responsive to this request other than those referenced in (b) above.
LILCO INTERROGATORY NO. 3 3.
.a.
How many of the ambulance companies listed in Contention EX 16(L) do Intervenors contend would have had to have participated in the Exercise in order for the Exercise to have yielded " valid or meaningful results?"
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
At this time the Governments cannot provide a numerical response to this question, but can state that the number of ambulances and companies that participated in the Exercise was too limited to provide a basis for concluding that emergency personnel are familiar with their duties.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the data and Plan references set out in Contention Ex 16 and subpart L, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, tralning, background,
~
experience, and expertise of those individuals the Governments have or intend to identify to testify regarding this contention.
The results of discovery and the analyses and research by those individuals may provide additional bases for the referenced proposition.
.*. d (c)
At this time, the Government have identified no documents as responsive to this request other than those referenced in (b) above.
LILCO INTERROGATORY NO. 4 4.
a.
How many ambulances from each ambulance company that participated in the Exercise (see Contention EX 18(c)(ii))
do Intervenors contend would have had to have been supplied in order to demonstrate that. emergency organization personnel were
" familiar with their duties?"
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
At this time the Governments cannot provide a numerical response to this question, but can state that the number of ambulances and companies that participated in the Exercise was too limited to provide a basis for concluding that emergency personnel are familiar with their duties.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the data set out in the Contention Ex 18 and subpart (i), the documents I
generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, background, e:cperience, and expertise of those individuals the Governments have or intend to identify to testify regarding this contention.
The results of discovery and the analyses and research by those individuals may l
provide additional bases for the referenced proposition.
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e
, r (c)
At this time the Governments have identified no documents as responsive to this request other than those referenced in (b) above.
LILCO INTERROGATORY NO. 5 Contention EX 21 5.
Please state, for Contention EX 21 and each of its subparts, the basis on which Intervenors contend that the sample size evaluated by FEMA in the Exercise was insufficient to support the conclusions in the FEMA Report of April 17, 1986.
Response
The Governments incorporate their response to Interrogatory No. 5 contained in LILCO's First Set of Interrogatories and Request for Documents ("First Request"), and the Governments' production of documents in response thereto as if fully rewritten here.
In addition, at this time, and to the knowledge of the Governments, the primary bases for the Contention, and each of its subparts, are the data and Plan references set out in the Contention, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, background, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding this Contention.
The results of discovery and the analyses and research by those individuals may provide additional bases for the referenced propositions.
In addition, the Governments note that in general, a judgment on the adequacy of sample size requires the identifi-cation of three factors: first, a target upper limit for failure
0.
probability;.second, a discrepancy from the target upper limit one would like to be able.to detect; and third, the probability of such detection.
LILCO INTERROGATORY NO. 6 6.
a.
Please identify for Contention EX 21 and each of its subparts the criteria used for determining the adequacy of
. sample size.
b.
What is the basis for the answer to paragraph (a)?
c.
Identify-and provide a copy of each document relating to the criteria identified in paragraph (a).
Resoonse:
(a) and (b)
Egg answer to Interrogatory No. 5.
(c)
At this time the Governments have identified no documents as responsive to this request other than those referenced in (b) of the answer to Interrogatory No. 5.
LILCO INTERROGATORY NO. 7 7.
a.
How many route alert drivers from how many staging areas do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of cufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Resoonse:
(a)
At this time the Governments are not able to provide a numerical response to this question, but can state that the number of Route Alert Drivers who were observed by FEMA, and their activities observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions referenced in Contention Ex 21 subpart A.
o.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contention Ex 21 subpart A, and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to identify to testify on that contention.
The results of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
(c)
At this time the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b).
LILCO INTERROGATORY NO. 8 8.
a.
How many bus drivers from how many stEging areas do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the besis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Resoonse:
(a)
At this time the Governments are not able to provide a numerical response to this question, but can state that the number of bus drivers and staging areas observed by FEMA, and their activities observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions referenced in Contention Ex 21 subpart B.
1 (b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contention Ex 21 subpart B, and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to identify to testify on that contention.
The results of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b).
LILCO INTERROGATORY NO. 1 9.
a.
How many bus drivers from how many public, private, and parochial schools do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to vield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Resoonse:
(a)
At this time the Governments are not able to provide a numerical response to this question, but can state that the number of bus drivers observed by FEMA (apparently a total of two at most), and their activities observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions referenced in Contention Ex 21 subpart C.
O.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contention Ex 21 subpart C, and the observations, knowledge, training, background, experience and expertise of those individu-als the Governments have or intend to identify to testify on that
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contention.
The restalts of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
In addition, at a meeting of a bus drivers association on June 23, 1986, which was attended by LILCO personnel, bus drivers made statements to the effect that the purported demonstration of bus driver capabilities and preparedness on February 13 was inadequate.
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b).
~
LILCO INTERROGATORY NO. 10 10.
a.
How many of the ambulette and ambulance drivers serving how many special facilities do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
At this time the Governments are not able to provide a numerical response to this question, but can state that the number of ambulette and ambulance drivers observed by FEMA, and
o.
their activities observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions referenced in Contention Ex 21 subpart D.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contention Ex 21 subpart D, and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to identify to testify on that contention.
The results of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b).
LILCO INTERROGATORY NO. 11 How many traffic guides do Intervenors contend 11.
a.
would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
At this time the Governments are not able to provide a numerical response to this question, but can state that the number of traffic guides observed by FEMA, and their activities
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observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions referenced in Contention Ex 21 subpart E.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contention Ex 21 subpart E, and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to identify to testify on that contention.
The results of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b).
LILCO INTERROGATORY NO. 12 12.
a.
How many traffic impediments do Intervenors contend would have had to have been observed, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Response
(a)
At this time the Governments are not able to provide a numerical response to this question, but can state that the number of traffic impediments observed by FEMA, and their
activities observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions referenced in Contention Ex 21 subpart F.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contention Ex 21 subpart F, and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to identify to testify on that contention.
The results of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b), and those identified'in response to Interrogatory No. 4 of LILCO's First Request.
LILCO INTERROGATORY NO. 13 4
13.
a.
How many evacuee congregate care centers (see Contentions EX 15(I), 22(F), and 31) do Intervenors contend would c
have had to have been cbserved, evaluated or sampled in order to create a sample of sufficient size to yield valid or meaningful results?
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document relating to the answer to paragraph (a) or (b).
Resoonse:
(a)
At this time the Governments are not able to provide a f
numerical response to this question, but can state that the num-ber of congregate care centers observed by FEMA, and their activ-
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ities observed by FEMA during the Exercise, were insufficient to justify FEMA's generalizations and conclusions as referenced in Contention Ex 15 subpart L.
(b)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the facts, Plan references, and FEMA conclusions and observations referenced in Contentions Ex 15 subpart L, Ex 16 subpart N, Ex 22 subpart K, and Ex 32, and the observations, knowledge, training, background, experience and expertise of those individuals the Governments have or intend to identify to testify on that contention.
The results of discovery, analyses and research by those individuals may also provide additional bases for the referenced proposition.
(c)
At this time, the Governments have identified no docu-ments as responsive to this request other than those referenced in the answer to (b).
LILCO INTERROGATORY NO. 14 14.
a.
Please state whether Intervenors contend based on the statement "Nassau County has expressly refused to agree to, or permit, the use of Nassau County facilities as part of, or to implement, the LILCO Plan" that in the event of an actual emergency at Shoreham, Nassau County would refuse to permit the use of the Nassau Coliseum (and/or any and all other Nassau County facilities or resources) by LERO for registration, monitoring, and decontamination of evacuees, or for any other emergency purpose during an actual emergency at Shoreham.
b.
Please state whether Intervenors contend based on the statement "Nassau County has expressly refused to agree to, or permit, the use of Nassau County facilities as part of, or to implement, the LILCO Plan" that Nassau County would refuse to permit use of the Nassau Coliseum (and/or any and all other Nassau County facilities or resources) by the American Red Cross for registration, monitoring, and decontamination of evacuees, or for any other emergency purpose during an actual emergency at Shoreham.
c.
What is the basis for the answers to paragraphs (a) and (b)?
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d.
Identify and provide a copy of each document upon which Intervenors intend to rely or which relates to the answer to paragraphs (a), (b) and (c).
Resoonse:
(a)
The Governments contend that in light of the Nassau i
County Board of Supervisors Resolution No. 782B-1986, there is no basis for a finding of reasonable assurance that adequate protec-tive actions can and will be taken in the event of a Shoreham emergency, as long as the LILCO Plan relies upon the Nassau Coliseum, or any Nassau County facilities, for reception center purposes, or for any other purpose.
(b)
Sgg answer to paragraph (a).
(c)
Nassau County Resolution 782B-1986; letter of Edward T.
O'Brien to NRC, dated May 2, 1986; letter of Thomas S. Gulotta to Morton Margulies, dated November 7, 1986; 10 CFR S 50.47, and NUREG 0654.
(d)
Aside from the Nassau County Resolution and letters referenced in (c), which LILCO already has, no other documents are responsive to this request.
LILCO INTERROGATORY NO. 15 15.
a.
What is the basis for Intervenors' statement that "the exercise scenario, and FEMA's conclusions on objectives EOC 16 and Field 9, 17, 19, and 21, are all based upon an assumption that the Nassau Veterans Memorial Coliseum is available for use by LILCO and the American Red Cross as a Reception Center.
.?"
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer in paragraph (a).
Resoonse:
(a)
At this time, and to the knowledge of the Governments, the primary bases for the referenced statement are the documents generated during the Exercise by FEMA and LILCO, the Exercise objectives, the events of February 13, 1986, the LILCO Plan and OPIPs referenced in Contention Ex 22 subpart A, the FEMA Report of April 17, 1986, and documents generated by LILCO and FEMA prior to, and after the Exercise.
(b)
Other than the documents identified in response to paragraph (a), which LILCO already has, at this time the Governments have identified no documents as responsive to this request.
LILCO INTERROGATORY NO. 16 16.
a.
Does Contention EX 36 allege that protective action recommendations other than those made by LERO during the exercise would have resulted in greater dose savings to the general public?
b.
State the basis for Intervenors' answer to paragraph (a).
c.
Unless the answer to paragraph (a) is a simple negative, please state (1) the protective action recommendation or recommendations that Intervenors assert would have resulted in greater dose savings and (2) the amount of dose savings asserted realized by Intervenors' alternative protective action recommendation or recommendations.
d.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a) through (c).
Resoonse:
(a)
Objection.
Contention Ex 36 speaks for itself.
See also response to Interrogatory 17.
. I (b)
Objection.
Contention Ex 36 speaks for itself.
Egg also response to Interrogatory 17.
(c)
Not applicable.
(d)
Not applicable.
LILCO INTERROGATORY NO. 17 17.
a.
Is it Intervenors' contention that, in light of the projected wind shift, LERO personnel should have rescinded their recommendation to evacuate zones A-M, O and R and instead recommended that people in those zones shelter?
b.
Is it Intervenors' contention that the change in protective action recommendation described in paragraph (a) would have produced greater dose savings?
c.
Unless the answer to paragraph (b) is a simple negative, state the amount of dose savings.
d.
State the basis for the answers to paragraphs (a) through (c).
e.
Identify and provide a copy of each document upon which Intervenors rely or which provides support for the answers to paragraphs (a) through (c).
Response
(a)
As stated in Contention Ex 36, the Governments contend that in light of their knowledge of the timing of the projected wind shift and the number of people who had not yet evacuated, LERO personnel should have:
considered whether to recommend protective measures other than a continued recommendation of evacuation for Zones A-M, Q and R; analyzed whether evacuation remained the appropriate protective action for Zones A-M, O and R; and made calculations and dose projections to determine whether alternative protective actions would have resulted in more dose savings.
(b)
Egg response to (a).
e-.
(c)
Egg response to (a).
(d)
At this time, and to the knowledge of the Governments, the primary bases for the answer to paragraph (a) are the data set out in the Contention, the documents generated during the Exercise by FEMA and LILCO, the events of February 13, 1986, the LILCO Plan and OPIP 3.6.1, and the observations, knowledge, training, experience and expertise of those individuals the Governments have or intend to identify to testify regarding this Contention.
The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.
(e)
Other than the privileged documents identified in response to LILCO's request for production number 7 contained in LILCO's First Requests, and the documents referenced in (d) above, which are documents already in LILCO's possession, the Governments have not yet identified other documents as responsive to this request.
LILCO INTERROGATORY NO. 18 18.
a.
Please state the time Intervenors believe the ENC should have been declared operational.
b.
State the basis for the answer to paragraph (a).
Identify and provide a copy of each document upon c.
i which Intervenors rely or which relates to the answers to i
paragraphs (a) and (b).
I Resoonset The Governments have not yet made a final determination (a) information should have regarding this matter, but can state that been provided to the media earlier than it was during the Exer-e Egg also General Response F and G.
cise.
this time, and to the knowledge of the Governments, (b)
At are the data the primary bases for the answer to paragraph (a) in Contention Ex 38, the documents and Plan references set out the even,ts of generated during the Exercise by FEMA and LILCO, and the observations, knowledge, February 13, the FEMA Report, h
training, experience and expertise of those individuals t e, i
Governments have or intend to identify to testify regarding th s The results of discovery and ongoing analyses and Contention.
for research by those individuals may provide additional bases the referenced proposition.
/
at this Other than the documents referenced in (b),
(c) the Governments can identify no documents as responsive to
- time, this request.
19_
LILCO INTERROGATORY NO.
Please state the time Intervenors believe the in order for it to first press briefing should have been held, 19.
a.
have been deemed " timely" under the circumstances of the Exercise.
State the bases for the answer to paragraph (a).
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers-to c.
paragraphs (a) and (b).
A
P.
Response
(a)
Egg answer to Interrogatory 18(a).
(b)
Egg answer to Interrogatory 18(b).
(c)
Egg answer to Interrogatory 18(c).
LILCO INTERROGATORY NO. 20 20.
a.
Do Intervenors consider the asserted delay in activation of the ENC and holding of the first press briefing to reveal, by themselves, a fundamental flaw in the Shoreham Emergency Plan?
b.
Identify and provide a copy of each document upon which Intervenors relay or which relates to the answers to paragraph (a).
Resconse:
(a)
The Governments have not yet made a final determination on this matter, but do contend that together with the other exer-cise results set forth in all the subparts of Contention Ex 38, the referenced delays preclude a finding of reasonable assurance that adequate measures can and will be taken in the event of a Shoreham accident.
(b)
At this time the Governments have identified no docu-ments as responsive to this request other than the materials referenced in Contention Ex 38 and materials generated during the Exercise by LILCO and FEMA.
LILCO INTERROGATORY NO. 21 21.
a.
State the basis for the statement that "such a delay would result in substantial confusion, speculation, rumor generation, lack of confidence in LILCO's ability to deal with the emergency, and refusal to believe information, advice or instructions subsequently disseminated by LILCO personnel."
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
i
Response
s (a)
At his. time, and to t'he knowledge of the Governments,
~
the primary bases for the contention are the data and Plan
$bferences set out in Contention Ex 38, the conclusions of the ASLB concerning Contentions 15 and 23 set forth in 21 NRC 644 and lthe stated bases for such, conclusions, and the observations,
),
.. ~
knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding Contention Ex,38.
i'h'e results of discovery and analysed and research by those individuals may provide additional bases for the referenced proposition.
f-(b)
At this time, the Governments have identified no docu-ments as responsive to this request'other than those referenced in the answer-to (a).
LILCO INTERROGATORY NO. 22
\\
22..
a.
Do Intervenors contend that the absence of any reference._in-the 08:21 News Release No. 1 to the fact that a Site Area Emergency had been declared at 08:19 constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan?
4
,'b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon Ohich Intervenors rely or which relates to the answers to para-graphs (a)'and (b).
Resoonse:
(a)
The Governments have ndt yet made a final determination on this issue, but do contend that together with the other exer-cise results set forth in all the subparts to Contention Ex 38, 4
the referenced deficiency in the news release precludes a finding of reasonable assurance that adequate measures can and will be taken in the event of a Shoreham accident.
(b)
Egg answer to Interrogatory No. 21(a).
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (b).
LILCO INTERROGATORY NO. 23 23.
a.
Do Intervenors contend that, if the Site Area Emergency had been declared at 08:21, some 30 seconds ahead of News Release No.
1, the absence of any reference in the 08:21 News Release No. 1 to the fact that a Site Area Emergency had been declared constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which provides support for the ansvers to paragraphs (a) and (b).
Response
(a)
Objection.
This question calls for speculation, fails to include crucial data upon which a response could be premised, and is not reasonably calculated to lead to the discovery of admissible evidence.
(b)
Eeg answer to Interrogatory 23(a).
(c)
See answer to Interrogatory 23(a).
LILCO INTERROGATORY NO. 24 24.
a.
Do Intervenors contend that the alleged delay between approval of the EBS message at 08:37 and issuance to the press of a news release containing the same information constituted or revealed, by itself, a fundamental flaw in the Shoreham Plan?
b.
State the basis for the answer to paragraph (a).
Identify and provide a copy of each document upon c.
which Intervenors rely or which relates to the answer to paragraph (a).
Response
(a)
The Governments have not yet made a final determination on this issue, but do contend that together with the other exer-cise results set forth in all the subpart3 of Contention Ex 38, the referenced delay precludes a finding of reasonable assurance that adequate measures can and will be taken in the event of.a Shoreham accident.
(b)
Egg answer to Interrogatory No. 21(a).
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (a).
LILCO INTERROGATORY NO. 25 25.
a.
Do Intervenors contend that the time interval between the LERO Director's determination to issue the information in News Release No. 2 and his approval of that
- release (08:37 to 09:00) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Resoonse:
(a)
The Governments have not yet made a final determination on this issue, but do contend that together with the other exer-cise results set forth in all the subparts to Contention Ex 38, s
c a-.
the referenced delay precludes a finding of reasonable assurance that adequate measures can and will be taken in the event of a Shoreham accident.
(b)
Egg answer to Interrogatory No. 21(a).
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (a).
LILCO INTERROGATORY NO. 26 26.
a.
Do Intervenors contend that the interval between the LERO Director's approval of News Release No. 2 and its distribution to the press (09:00 to some unspecified time after 09:15) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Resoonse:
(a)
The Governments have not yet made a final determination on this issue, but do contend that together with the other exer-cise results set forth in all the subparts to Contention Ex 38, the referenced delay precludes a finding of reasonable assurance that adequate measures can and will be taken in the event of a Shoreham accident.
(b)
Egg answer to Interrogatory No. 21(a).
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in the answer to (a).
LILCO INTERROGATORY NO. 27 27.
a.
What is the maximum length of time that Intervenors believe is acceptable between the LERO Director's determination to issue a press release and approval of that release?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Epsoonggi (a)
The Governments have not yet made a final determination regarding this issue.
Egg also General Response F and G.
(b)
Egg answer to (a).
(c)
Egg answer to (a).
LILCO INTERROGATORY NO. 28 28.
a.
What is the maximum length of time that Intervenors believe is acceptable between the LERO Director's approval of a press release and its distribution to the press?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Response
(a)
The Governments have not yet made a final determination regarding this issue.
Egg also General Response F and G.
(b)
Egg answer to (a).
(c)
Egg answer to (a).
LILCO INTERROGATORY NO. 29 29.
a.
Identify each basis for the statement
" insufficient copying capabilities at the ENC contributed to delays in the distribution of information (sic] to the media."
3 b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
Response
(a)
At this time, and to the knowledge of the Governments, the primary bases for.the statement are the FEMA Report reference set out.in Contention Ex 38 subpart D, and the documents gen-erated during the Exercise by FEMA and LILCO.
The results of discovery and analyses and research by individuals the Governments have or intend to identify to testify regarding that contention may provide additional bases for the-referenced proposition.
(b)
At this time the Governments have identified no docu-ments as responsive to this request other than those referenced in (a) above.
LILCO INTERROGATORY NO. 30 30.
a.
Identify each instance in which the copying facilities at the ENC are alleged to have been insufficient and state the manner in which Intervenors believe LILCO could have avoided or corrected such insufficiencies.
b.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answer to paragraph (a).
Rgsoonse:
(a)
With respect to the first half of question (a), see i
j response to Interrogatory No. 29, and the FEMA Report reference stated in Contention Ex 38 subpart D.
The Governments object to the second request in paragraph (a) as irrelevant.
The Govern-i i
ments have no obligation to instruct LILCO on how to avoid or correct deficiencies in its Plan or abilities to implement it.
Egg General Response F and G.
(b)
Egg answer to Interrogatory No. 29(b).
LILCO INTERROGATORY NO. 31 Identify each map or display at the ENC which 31.
a.
Intervenors allege was inadequate.
b.
For each map or display identified in paragraph (a), state the inadequacy.
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Resoonse:
(a)
At this time, since discovery is still in progress, the Governments are not in a position-to respond further than to refer to the FEMA Report references in subpart E of Contention Ex 38.
The results of discovery may provide additional data.
(b)
Egg response to (a).
(c)
Egg response to (a).
-LILCO INTERROGATORY NO. 32 32.
a.
Identify each EBS message provided to the press which Intervenors assert contained extraneous information.
b.
For each EBS message identified in paragraph (a),
identify the information which Intervenors believe to be extraneous.
c.
State the basis for the ainswers to paragraphs (a) and (b).
d.
State the basis for Intervenors' assertion that the presence of extraneous information in fact made each EBS message " unclear" and " confusing."
e.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) through (d).
Response
(a)
Since discovery is still in progress at this time, the Governments are not in a position to respond further other than to refer to the FEMA Report references in subpart F of Contention Ex 38, and the EBS messages themselves.
In addition, the Governments note that LILCO itself is in the best position to know what information in EBS messages was extraneous, or marked for deletion.
(b)
Egg response to (a).
(c)
Sag response to (a).
(d)
Egg response to (a).
(e)
Egg response to (a).
LILCO INTERROGATORY NO. 33 33.
a.
For each LERO Press Release listed in Contention EX 38(G)
(i.e., Nos.
3, 4,
5, 6, and 7), state whether Intervenors contend that the time interval between the ENC's receipt of each press release and the time each was posted was excessive.
b.
For each press release described in paragraph (a),
state separately the basis for the answer to paragraph (a).
Resoonse:
(a)
As stated in subpart G of Contention Ex 38, the Governments contend that "LERO press releases were distributed much too late."
(b)
The bases for the allegations in subpart G of i
Contention Ex 38 are stated in that subpart.
LILCO INTERROGATORY NO. 34 34.
a.
State the maximum length of time between the ENC's receipt of a press release and the posting of that release which Intervenors believe is acceptable.
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Response
(a)' The information sought is not relevant, since the allegation in subpart G of Contention Ex 38 is that during the Exercise, LERO press releases were distributed much too late.
In addition, the Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or its implementation capabilities.
Egg General Response F and G.
(b)
Egg response to (a).
(c)
See response to (a).
LILCO INTERROGATORY NO. 35 35.
a.
Do Intervenors contend that the interval between the LERO Director's decision to recommend evacuation of the entire EPZ (11:46) and the alleged time at which the media were informed of the recommendation (12:47) was excessive?
b.
State the basis for the answer to paragraph (a)-
c.
Identify and p: ovide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Response
(a)
Yes.
(b)
The bases are as stated in Contention Ex 38, including subpart H, the documents generated during the Exercise by FEMA and LILCO, and the cbservations, knowledge, training, background,
experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention.
The results of discovery, analyses and research by those individuals may provide additional bases for the referenced proposition.
(c)
At this time, the Governments have identified no documents as responsive to this request other than those referenced in (b).
LILCO INTERROGATORY NO. 36 36.
a.
Do the Intervenors contend that the interval between the 12:00 Noon EBS message containing the recommendation to evacuate the entire EPZ and the alleged time at which the media were informed of that recommendation (12:47) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
Response
(a)
Yes.
(b)
The bases are as stated in Contention Ex 38, including subpart H, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, background, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding ' hat Contention.
c The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.
(c)
At this time the Governments have identified no documents as responsive to this request other than those referenced in (b).
LILCO INTERROGATORY NO.
37 37.
a.
State the maximum length of time between the LERO Director's decision to recommend a protective action and the time the media are informed of the recommendation which Intervenors believe is acceptable.
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to para-graphs (a) and (b).
Response
(a)
The information sought is not relevant, since the allegations in Contention Ex 38 go to what LILCO did during the February 13 exercise, and the fact that such actions demonstrate LILCO's inability to provide timely, accurately, consistently and I
non-confusing information to the news media.
In addition, the Governments have no obligation to instruct LILCO on how to cor-rect deficiencies in its Plan or in its implementation capabili-ties.
Egg General Response F and G.
(b)
Egg response to (a).
(c)
See response to (a).
LILCO INTERROGATORY NO. 38 38.
a.
Do Intervenors contend that the interval between the alleged time that LERO workers were instructed to ingest KI (09:45) and the alleged time the media were informed of that instruction (13:05) was excessive?
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to paragraphs (a) and (b).
l c Resoonse:
(a)
Yes.
(b)
The bases are as stated in Conatention Ex 38, including subpart I, the documents generated during the Exercise by FEMA and LILCO, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to identify to testify regarding that Contention.
The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.
(c)
At this time the Governments have identified no docu-ments as responsive to this request other than those referenced in (b).
LILCO INTERROGATORY NO. 39 39.
a.
State the maximum length of time between the instruction of LERO workers to ingest KI and the time the media are informed of that instruction that Intervenors believe is acceptable.
b.
State the basis for the answer to paragraph (a).
c.
Identify and provide a copy of each document upon which Intervenors rely or which relates to the answers to para-graphs (a) and (b).
Resoonse:
(a)
The information sought is not relevant, since the allegations in Contention Ex 38 go to what LILCO did during the February 13 exercise, and the fact that such actions demonstrate LILCO's inability to provide timely, accurate, consistent and non-confusing information to the news media.
In addition, the 1
m.
Governments have no obligation to instruct LILCO on how to correct deficiencies in its Plan or in its implemed ation capabilities.
Egg General Response F and G.
(b)
Egg response to (a).
(c)
Egg response to (a).
LILCO INTERROGATORY NO. 40 40.
a.
Do Intervenors contend that the general public should have been informed that LERO workers had been instructed to ingest KI?
b.
State the basis for the answer to paragraph (a),
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
Resoonse:
(a)
The Governments' contentions on this matter are as set forth in Contention Ex 38, including subpart I.
(b)
Not applicable.
(c)
Not applicable.
LILCO INTERROGATORY NO. 41 41.
a.
What is the basis for Intervenor's statement in Contention EX 38(I) that "such a delay and the attempt to conceal pertinent information about the life-threatening effects of the accident would result in further reductions in LILCO's credibility and refusals of the media and the public to obey LILCO's advice during a real emergency."
b.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answer to paragraph (a).
Resoonset (a)
At this time, the primary bases for the contention are the data and plan references set out in Contention Ex 38, the conclusions of the ASLB concerning Contentions 15 and 23 set 0
forth in 21 NRC 644 and the stated bases for such conclusions, and the observations, knowledge, training, experience, and expertise of those individuals the Governments have or intend to testify regarding Contention Ex 38.
The results of discovery and analyses and research by those individuals may provide additional bases for the referenced proposition.
(b)
At this time the Governments have identified no documents as responsive to this request other than those referenced in (a).
LILCO INTERROGATORY NO. 42 42.
a.
Identify each specific instance in which LERO personnel were allegedly " unable to respond satisfactorily or accurately to questions about evacuation" (see Contention EX 38(J)).
b.
State the criteria that Intervenors would use for judging whether the response was " satisfactory."
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
Resoonse:
(a)
At this time the Governments are not in a position to respond further than to refer to the facts set forth in subpart J of Contention Ex 38.
(b)
Egg answer to (a).
(c)
At this time the Governments have identified no documents as responsive to this request other than the documents produced by LILCO and FEMA during the Exercise, particularly logs and messages relating to ENC and Public Information personnel activities, and the ENC videotapes produced by LILCO.
LILCO INTERROGATORY NO. 43 43.
a.
Identify each specific instance in which ENC personnel were " unable to provide any information to the media concerning traffic conditions, conditions or evacuation activity on the water portion of the EPZ, or protective actions for the correctional facility in the EPZ" (see Contention EX 38(J)).
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to y
paragraphs (a) and (b).
Resoonset (a)
At this time the Governments are not in a position to respond further than to refer to the facts set forth in subpart J of Contention Ex 38.
(b)
Not applicable.
(c)
At this time the Governments have identified no documents as responsive to this request other than the documents produced by LILCO and FEMA during the Exercise, particularly logs and messages relating to ENC and Public Information personnel activities, and the ENC videotapes produced by LILCO.
LILCO INTERROGATORY NO. 44 44.
a.
Identify each specific instance in which LERO personnel were allegedly " unable to respond to questions about manpower at bridges and tunnels on evacuation routes, or the activities of the Nassau County Police" (see Contention EX 38(J)).
b.
What is the basis for the answer to paragraph (a)?
c.
Identify and provide a copy of each document upon which Intervenors rely or that relates to the answers to paragraphs (a) and (b).
[
L~
(.
Response
(a)
At this time the Governments are not in a position to respond further than to refer to the facts set forth in subpart J of Contention Ex 38.
(b)
Not applicable.
(c)
At this time the Governments have identified no documents as responsive to this request other than the documents produced by LILCO and FEMA during the Exercise, particularly logs
-and messages relating to ENC and Public Information personnel activities, and the ENC videotapes produced by LILCO.
LILCO INTERROGATORY NO. 45 l
45.
a.
What is the basis for Intervenors' statement that l
"LERO Public Information personnel were unable to contact Marketing Evaluations, Inc., in a timely manner?"
b.
What is the maximum acceptable period within which Intervenors contend that Marketing Evaluations, Inc. must be l
l contacted in order for the contact to be " timely?"
I c.
What is the basis for the answer to paragraph (b)?
d.
Identify and provide a copy of each document upon l
which Intervenors rely or that relates to the answers to paragraphs (a) through (c).
Resoonse:
(a)
LILCO Logs reveal repeated unsuccessful efforts by LILCO to contact Marketing Evaluations, Inc.
At this time the l
Governments are not in a position to respond further than to refer to the facts set forth in subpart J cf Contention Ex 38.
(b)
The information sought is not relevant, since the allegations in Contention Ex 38, including subpart J, go to LILCO's inability during the Exercise to provide information to the media concerning siren activation failures.
I l
I
s
. s (c)
Not applicable.
(d)
At this time the Governments have identified no documents as responsive to this request other than the documents produced by LILCO and FEMA during the Exercise, particularly logs and messages relating to ENC and Public Information personnel activities, and the ENC videotapes produced by LILCO.
Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 LaGrdnce Coe La p er Karla J. Letsche P. Matthew Sutko Kirkpatrick & Lockhart 1900 M Street, N.W.
Washington, D.C.
20036 Attorneys for Suffolk County A
/
M
/
- N Fabian G.
Palomino
/
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
/Srephth B.
Latham Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton November 26, 1986
WELATED CORRE9PMON D0C.KE T E P November 2699fE85 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFILE 0i lo.. A Before the Atomic Safety and Licensino Ball 0fdU g: "V mi A
)
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 I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON RESPONSE TO LILCO'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON, responding to Interrogatories 1-45, have been served on the following this 26th day of November 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 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 Agency 500 C Street, S.W.,
Room 840 Washington, D.C.
20472 4
A l
Anthony P.
Earley, Jr., Esq.
Bernard M.
Bordenick, Esq.
General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 Mr. William Rogers W.
Taylor Reveley, III, Esq.*
Clerk Hunton & Williams Suffolk County Legislature 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 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 MHB Technical Associates Hon. Peter Cohalan 1723 Hamilton Avenue Suffolk County Executive Suite K 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 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 David A.
Brownlee, Esq.
Mr. Philip McIntire Kirkpatrick & Lockhart Federal Emergency Management 1500 Oliver Building Agency Pittsburgh, Pennsylvania 15222 26 Federal Plaza New York, New York 10278 By Federal Express Lawrence Coe La'npWEr KIRKPATRICK & LOCKHART 1900 M Street, N.W.
Suite 800 Washington, D.C.
20036