ML20214J538
| ML20214J538 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/26/1986 |
| From: | Latham S, Palomino F, Sutko P KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | LONG ISLAND LIGHTING CO. |
| References | |
| CON-#486-1677 OL-5, NUDOCS 8612010342 | |
| Download: ML20214J538 (40) | |
Text
3+ l6'77 Mtt.A R D CU RRES M DM Novem$@d%i53 1986 a
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UNITED STATES OF AMERICA 16 NOV 28 P7 :24 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and License 6@rBoard UUUnti m..
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e
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON RESPONSE TO LILCO'S FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON I.
GENERAL STATEMENT On October 29, 1986, LILCO filed its "First Set of Interrogatories and Requests for Production of Documents to Suffolk County, New York State and Town of Southampton" ("First Request").
Pursuant to the NRC's Rules of Practice, 10 CFR S2.741(d), Suffolk County, the State of New York and the Town of Southampton (the " Governments") hereby respond to the document request portion of LILCO's First Request.
Unless otherwise noted, copies of those documents responsive to LILCO's First Request which are not withheld based upon objection or claim of privilege accompany this Response.
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l II.
GENERAL RESPONSE Unless otherwise indicated, the responses set forth A.
Whenever herein have been provided jointly by the Governments.
necessary, however, the responses distinguish between the responses of Suffolk County, the State of New York and the Town in accordance with paragraph I of LILCO's of Southampton,
" Instructions."
The Governments understand LILCO's document requests to B.
information within the possession, custody or control of request The Governments object to any broader interpre-the Governments.
tation of.the information requested by LILCO.
T Certain requests seek identification and production of C.
documents previously provided to the Governments by LILCO or In the latter instance, copies of the documents were also FEMA.
Unless otherwise noted herein, no effort has provided to LILCO.
been made to identify or produce these documents, as the Govern-A.
ments object to identification and production of docuemnts LILCO already possesses.
III. RESPONSES TO REQUESTS FOR DOCUMENTS f
l LILCO Interrocatorv No. 1:
1.
Ggneral Matter Please identify all Intervenor personnel who observed, either at a particular facility or in the field, the a.
l With respect to each, describe his February 13 Exercise.
location and activities during the assigned duty, function, If the assigned duty, function, location and/or activities of the observer changed or varied during the course of Exercise.
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e the Exercise, please describe such changes and specify the time frame, by hours and minutes, to which each assigned duty, function, location and/or activity pertains.
b.
Please provide copies of all documents concerning the Exercise prepared by the persons identified in response to the previous interrogatory prior to, during, or after the Exercise.
Resoonse:
The following groups of documents, concerning observations made during the February 13 Exercise, are responsive to this request.
First, notes taken by Suffolk County Police Department
("SCPD") Inspector Robert Snow, Inspector Phillip McGuire, Captain Thomas Compitello, Deputy Inspector Peter Cosgrove, Deputy Inspector Russell Brown, Assistant Chief of Investigation Division Joseph Monteith, and Deputy Inspector Kenneth Regensburg.
While these notes were prepared at the request of counsel for Suffolk County, in anticipation of litigation, and therefore are subject to being withheld on the basis of the work product doctrine, without waiving such objection to production, these documents are nonetheless being produced.
Second, certain attorneys who represent the Governments, or agents of those attorneys, also took notes during their monitor-ing activities, concerning their observations of the February 13 Exercise.
Those notes were prepared in anticipation of litiga-t tion, and they contain the mental impressions, conclusions, opinions, and legal theories of the Governments' attorneys concerning this litigation.
The Governments object to production,
of these documents on the basis of the attorney work product doctrine, and they will not be produced.
They are identified in Exhibit A, attached to this Response.
Finally, the Governments note that subsection "b" of this request could be construed to request production of practically every pleading, memorandum, item of correspondence, and other document prepared by the Governments' counsel and other representatives subsequent to the Exercise, and many for several months prior to the Exercise.
To the extent that LILCO seeks production of all such documents, the Governments object on the basis of the attorney-client privilege and the work product doctrine, on the basis that the request is overly broad and urduly burdensome, and on the basis that the request is not reasonably calculated to lead to the discovery of admissible evidence.
Such documents will not be produced and no effort has been made to identify this massive group of attorney-produced documents.
All documents recording factual observations made during the Exercise have been produced or identified.
LILCO Interrocatory No. 2:
2.
Contention EX 15:
Please identify each witness Intervenors expect to a.
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each j
such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
l b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
e c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning the necessary elements of a FEMA-graded exercise of an emergency plan for a nuclear power plant.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
e.
Please identify all articles, papers, or other documents authored or co-authored by each witness on the subject of emergency planning exercises for nuclear power plants, which have either been published in the open literature, or, if not published in the open literature, circulated within the professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
1) the necessary elements of a FEMA-graded exercise of an emergency plan for a nuclear power
- plant, 2) the significance of any plan element listed in Contention EX 15, as admitted and modified by the Board, to the Shoreham Emergency Plan as a whole, 3) the significance of any plan element listed in Contention EX 15 as admitted and modified by the Board, to the reasonable assurance finding required by 10 CFR S 50.47(a)(1),
4) how the Exercise of the Shoreham Plan compares l
with exercises conducted by FEMA at other nuclear l
power plants.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 15 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 15.
1.
Please identify any communication between Intervenors and:
1)
WALK Radio, 2) any of the Radio Stations identified in subpart D of Contention EX 16,.
o 3) the United States Coast Guard, 4) officials of Central Suffolk Hospital, St.
Charles Hospital, John T. Mather Hospital or the Suffolk Infirmary, 5) representatives of any public, parochial or private school located in the Shoreham EPZ, 6) any school bus driver, or any representative of groups of school bus drivers, who serve schools
~ located within the Shoreham EPZ, 7) representatives of the State of Connecticut, 8) officials or personnel of any nursing or adult home located in the EPZ, 9) any congregate care center listed in Appendix B 4
to the Shoreham Plan, or 10) representatives of Nassau County prior to, during, or after the Exercise of the Shoreham Emergency Plan concerning that entity's participation in the Exercise.
Resoonse:
The curriculum vitae of Gregory Minor and Charles B.
Perrow accompany this Response.
They list relevant NRC testimony and publications, which are publicly available, and therefore are not separately provided.
LILCO Interrocatorv No. 3:
3.
Contention EX 16:
Please identify each witness Intervenors expect to-a.
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.. - -
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters j
concerning (1) the necessary elements of a FEMA-graded exercise of an emergency plan for a nuclear power plant and (2) comparisons of l
FEMA-graded exercises of emergency plans for nuclear power plants.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subject of emergency planning exercises for nuclear power plants, which have either been published in the open literature or, if not published in the open literature,-circulated within the professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
1) the necessary elements of a FEMA graded exercise of an emergency plan for a nuclear power
- plant, 2) the significance of any plan element listed in i
Contention EX 16, as admitted and modified by the i
Board, to the Shoreham Emergency Plan as a whole, 3) the significance of any plan element listed in i
Contention EX 16, as admitted and modified by the l
Board, to the reasonable assurance finding required by 10 CFR S 50.47(a)(1),
4) how the Exercise of the Shoreham Plan compares i
with exercises conducted by FEMA at other nuclear power plants.
Unless the answer to item f. is a simple negative, g.
please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 16 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 16.
i.
Please identify any communications between Intervenors and:
1)
Marketing Evaluations, Inc, 2) officials or personnel of any bus company listed in Contention EX 16K, or 3) officials or personnel of any ambulance company listed in Contention EX 16L prior to, during, or after the Exercise of the Shoreham Emergency Plan concerning that entity's participation in the Exercise.
Response
See response to LILCO Interrogatory No. 2 above.
f LILCO Interroaatorv No. 4:
4.
Contention EX 19:
NOTE:
Paragraphs (a) through (g) need be answered only in the event that Intervenors have sought reconsideration cr other interlocutory reversal or modification of the Board's October 3 disposition of Contention 19, admitting it solely for purposes of argument and not for testimony.
Paragraphs (h) through (j) should be answered in any event.
Please identify each witness Intervenors expect to a.
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each i
such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance l
of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of l
professional qualifications.
c.
Please list any NRC, legislative, or other legal i
proceeding in which each witness has testified on matters concerning the necessary elements for making a reasonable assurance finding under 10 CFR S 50.47(a)(2).
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subject of emergency planning exercises for nuclear power plants, which have either been published in the open literature or, if not published in the open literature, circulated within the professional community.
l l
f.
Please state whether each witness has prepared, or l
han had prepared, any written studies, reports, analyses or other documents with respect to any of the following: l-l
1) the necessary elements for making a reasonable assurance finding under 10 CFR S 50.47(a)(2).
g.
Unless the answer to item f.
is a simple negative, please identify and provide a copy of each document.
- h..
Please provide a copy of the document in which is contained the basis for the representation in the contention that "In fact, however, FEMA's former Region II Director, Frank Petrone, stated on February 15, 1986, that a 'no reasonable assurance' finding was necessary:
'Since this Plan cannot be implemented without state and local gov!!rnmental. participation, we [ FEMA]
cannot give reasonable assurance under NUREG 0654 that the public health and safety can be. protected.'"
i.
Please state the exact basis, if there is one, in any FEMA or other. document, for the statement in that contention that "The exercise results were so limited that FEMA was unable to make the required reasonable assurance finding."
j.
Please identify and provide a copy of any document not already referred to in Contention EX 19 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 19, Resoonse:
f To date the following documents have been identified as J
being responsive to this Request.
They are:
the draft FEMA Post Exercise Assessment, dated April 7, 1986; a memo to the files from Roger Kowieski, dated April 15, 1986, re: Shoreham Post Exercise Assessment and an internal FEMA correspondence con-cerning the Exercise and FEMA post Exercise assassment.
Copies of these documents are already in LILCO's possession, having been produced to LILCO and the Governments by FEMA.
In addition, enclosed herewith are a handwritten document written by Frank l
Petrone which contains a statement made by Frank Petrone on February 15, 1986, and a transcript of a press conference i
conducted by FEMA on February 15, 1986.
l l _
LILCO Interroaatorv No. 5:
5.
Contention EX 21:
a.
Please identify each witness Intervenors expect to call on this contention.
For each prrrson, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion, b.
.With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
c.
Please list any NRC, legislative or other legal proceeding in which each witness has testified on matters concerning-(l) the choice of sample groups for evaluative purposes in FEMA-graded exercises of emergency plans for nuclear power plants, (2) the choice of sample groups for evaluative purposes and (3) the use of samples to draw conclusions about a larger population group.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
e.
Please identify all articles, papers, or other documents authored or co-authored by each witness on the subjects of (1) the choice of sample groups for evaluative purposes in FEMA-graded exercises of emergency plans for nuclear power plants,
-(2) the choice of sample groups for evaluative purposes and (3) the use of samples to draw conclusions about larger population groups, which have either been published in the open literature or, if not published in the open literature, circulated within the prcfessional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents for Intervenors with respect to any of the following:
1) the choice of sample groups for evaluative purposes, especially FEMA-graded exercises of emergency plans for nuclear power plants, 2) the use of samples to draw conclusions about a larger population group, 3) the statement in Contention EX 21 that "the samples which FEMA reviewed were much too small to permit valid generalizations or to support FEMA's conclusions concerning these objectives,". -.
i 4) how FEMA's sampling process during the February 13 Exercise compares with those used by FEMA during exercises at other nuclear power plants.
g.
Unless the answer to item f.
is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 21 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 21.
Response
Copies of the resumes of SCPD officers Roberts, McGuire, Dormer and Michel and Dr. Gary Simon accompany this Response.
NRC testimony of the SCPD personnel is already known to LILCO.
Dr. Simon's publications are listed on his resume and are publicly available.
Also responsive to this Request is an Internal Correspond-ence from Edward Webber, Lt., Commanding Officer Central Records Section, Command 5220, to Richard Roberts, Assistant Chief of Headquarters, Headquarters Division, Command 5000, dated May 20, 1986, enclosing a Motor Vehicle Accident Survey for Suffolk County covering the time period February 6, 1986 through February 20, 1986.
A copy of that correspondence and the Survey accompanies this Response.
The underlying data for this Survey are found in traffic accident reports filed with the Suffolk County Police Department; they may be inspected at the Depart-cent's headquarters in Yaphank, New York.
Also accompanying this Response is a copy of a February 13, 1986 memorandum.from Detective.Schaffer to Captain Michel of the SCPD listing and describing aerial photographs taken during the day of the February 13, 1986 Exercise.
The photographs may be 1 ~.
inspected by LILCO at the offices of Kirkpatrick & Lockhart, 1900 M Street, N.W., Washington, D.C. 20036.
If copies are desired, they will be provided at LILCO's expense.
Also responsive to this Request is a large map of Suffolk County which shows the location of motor vehicle accidents that occurred in Suffolk County on February 13, 1986 between 5:00 a.m.
and 4:30 p.m.
This map may be viewed at the offices of Kirkpatrick & Lockhart.
The Gcvernments will reproduce a copy of this map, at LILCO's expense, if LILCO so requests.
Other documents which are responsive to this Request are identified in Exhibit B attached hereto.
Suffolk County objects to production of these documents on the basis of the attorney-client privilege and the attorney work product doctrine.
Accord-ingly, the documents will not be produced.
LILCO Interrocatory No. 6:
6.
Contention EX 22:
Please identify each witness Intervenors expect to a.
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualificaticms.
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning to (1) the necessary elements of a FEMA-graded exercise of an emergency plan for a nuclear power plant, (2) reception centers for disaster sheltering and (3) the use of the Nassau Veterans Memorial Coliseum as a reception center for the Shoreham Emergency Plan. -
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
e.
Please identify all articles, papers, or other documents authored or co-authored by each witness on the subjects of the necessary elements of a FEMA graded exercise of an emergency plan for a nuclear power plant and the use of reception centers for disaster sheltering, which have either been published in the open literature or, if not published in the open literature, circulated within the professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents for Intervenors with respect to any of the following:
1) the necessary elements of a FEMA-graded exercise of an emergency plan for a nuclear power
- plant, 2) the use of reception centers for disaster sheltering, 3) the use of the Nassau Veterans Memorial Coliseum as a reception center for the Shoreham Emergency Plan.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 22 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 22.
Resoonse:
Documents responsive to this Request include the prefiled testimony of Assistant Chief Roberts submitted in February 1985 in the reopened relocation center proceeding, which LILCO already possesses, and the resumes and/or curriculum vitae of SCPD offi-cers Roberts, Michel, Dormer, McGuire, and that of Dr. Perrow, copies of which accompany this Response.
The curriculum vitae of SCPD officers Streeter and Cosgrove will be provided in the near future.
In addition, the Newsday article from September 21, 1986, a copy of which is provided, and other survey-related 13 -
documents already in LILCO's possession, also support the Govern-ments' position concerning the matters raised in subpart F of Contention Ex 22, which are subsumed in Contentions Ex 38 and 39.
LILCO Interrocatory No. 7:
7.
Contention EX 36:
a.
Please identify each witness Intervenors expect to l
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on natters concerning the making of protective action recommendations as a i
result of a radiological accident.
y d.
Please provide copies of-any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subject of protective action recommendations for radiological emergencies if not which have either been published in the open literature or, published in the open literature, circulated within the professional community.
~
f.
Please state whether each witness has prepared, or i
has had prepared, any written studies, reports, analyses or other documents for Intervenors with respect to any of the following:
4 1) the making of protective action recommendations during a radiological accident, especially one involving conditions like those in the accident scenario used in the Exercise.
2) the " appropriateness" of protective action recommendations actually made by LERO during the Exercise.
. 4
~. - -
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document..
h.
Please identify and provide a copy of any document not already referred to in Contention EX 36 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 36.
Resoonse:
Except as discussed below, there are no documents responsive to this Request.
A copy of the curriculum vitae of Gregory Minor accompanies this Response.
Egg response to LILCO Interrogatory No. 2 above.
In addition, Mr. Minor and Suffolk County's counsel, Kirkpatrick & Lockhart, singularly or jointly have compiled, prepared, reviewed, or commented upon certain documents which are responsive to this Request, but which were prepared in anticipation of litigation or for trial and/or which contain the mental impressions, conclusions, opinions, or legal theories of Kirkpatrick & Lockhart.
Suffolk County objects to the production of such documents on the basis of the work product doctrine.
Accompanying this Response as Exhibit C is a list of the privileged documents which will not be produced.
LILCO Interrocatory No. 8:
8.
Contention EX 38:
Please identify each witness Intervenors expect to a.
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications. -
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning the. operation of an emergency news center during an emergency or news dissemination during a natural or man-made emergency.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subjects of the operation of an emergency news center during an emergency or news dissemination during a natural or man-made emergency, which have either been published in the open literature or, if not published in the open literature, circulated within the professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents for Intervenors with respect to any of the following:
1) the operation of LERO's emergency news center during the Exercise, especially in regard to the appropriateness and timeliness of actions taken by LERO at the ENC, 2) news dissemination during a natural or man-made emergency, and in particular, the timeliness and content of news releases issued to the media during the Exercise, 3) the conducting of press briefings during a natural or man-made emergency, especially in regard to the timeliness and content of LERO press briefings during the Exercise, 4) the required number and form of maps, displays,
)
and other visual aids in a media briefing room during a radiological accident, especially as compared to the LERO maps, displays, etc., present in the briefing room during the Exercise.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 38 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 38.
Response
No documents are responsive to this Request.
LILCO Interroaatory No. 9:
9.
Contention EX 39:
Please identify each witness Intervenors expect to a.
call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning rumor control during a natural or man-made emergency.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subject of rumor control during a natural or man-made emergency, which have either been published in the open literature or, if not published I
in the open literature, circulated within the professional l
community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents for Intervenors with respect to any of the following:
1) rumor control during a natural or man-made emergency, especially in regard to the time within which rumors should be confirmed, denied, or corrected, l
2) rumor control during the February 13 Exercise, and in particular, (a) the timeliness of LERO rumor responses, and i
(b) the accuracy or " correctness" of LERO rumor responses at the time and under the conditions existing at each called-in rumor.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document, h.
Please identify and provide a copy of any document not already referred to in Contention EX 39 or identified in response to item g. of.this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 39.
Response
No documents are responsive to this Request.
LILCO Interroaatory-No. 10:
10.
Contention EX 40:
Please identify each witness Intervenors expect to a.
i call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
l 9
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning to (1) the mobilization of emergency workers and (2) the content of EBS messages.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subjects of mobilization of emergency workers or the content of EBS messages, which have either been published in the open literature, if not published in the open literature, circulated within the or, professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
l 1 _
~
./
l'
\\
e l
1) the mobilization of emergency workers, especially traffic guides (from time to time of their initial call-out through their reporting to their posts) during the February 13 Exercise, f
2) the effect of the mobilization time of'. traffic guides during the Exercise on evacuation time.
estimates for the Shoreham EPZ, thecontentofEBSmessages,especiallykhose 3) formulated during the February 13 Exercise, f 4) the effect of changes in dispatching m,
instructions for traffic guides contained in Revision 7 to the Shoreham Plan.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 40 or identified in.
response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EK/40.
Resoonse:
Other than documents responsive to LILCO Interrogatory No.
5, no documents are responsive to this Request.
f LILCO Interrooatory 11:
11.
Contention EX 41:
a.
Please identify each witness Intervenors expect to call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on ~hich each w
such witness is expected to testify and the substance of the facts l
to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the~ substance of the facts and opinions to which he is expected to testify and a-summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
l c.
Please list any NRC, legislative, or other legal 1
proceeding in which each witness has testified on matters concerning (1) the mobilization of emergency workers, (2) traffic accident rates, either nationally or specifically on Long Island and (3) the removal of impediments from roadways.
F' Y' I
_ 19 _
l l
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
e.
Please identify all articles, papers, or other documents authored or co-authored by each witness on the subjects of mobilization of emergency workers, traffic accident rates or removal of impediments from roadways, which have either been published in the open literature, or, if not published in the open literature, circulated within the professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
1) mobilization of emergency workers, especially the mobilization of LERO road crews during the February 13 Exercise, 2) traffic accident rates, 3) removal of impediments from roadways, especially LERO's response to the two hypothetical traffic impediments during the February 13 Exercise, 4) the conclusion in Contention EX 41 that "LILCO's proposal for the removal of impediments to evacuation is inherently unworkable,"
5) the conclusions about the addition of a Traffic Engineer to the EOC contained in subpart E of Contention EX 41.
g.
Unless the answer to item f.
is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 41 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 41.
Resoonse:
Other than documents responsive to LILCO Interrogatory No. 5 and the curriculum vitae of Dr. Perrow, no documents are respon-sive to this Request.
i _ _ -.
C
- It 1
LILCO Interroaatorv No. 12:
12.
Contention EX 47:
a.
Please identify each witness Intervenors expect to callion.this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each s
such witness !sc expected to testify and the substance of the facts o
to which he is; expected to testify.~
For each person whom Intervenors expect to call as an expert witness,. state the subject ie matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please. provide a copy of his most current curriculum vitae, resume or statement of
,g J
professional qualifications.
c.
Please list any NRC, legislative, or other legal
[S proceeding in which each witness has testified on matters i
concerning the monitoring and decontamination of individuals potentially exposed to radiation.
d.
Please provide copies of any prefiled testimony by each' witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subject of the monitoring and decontamination of individuals potentially exposed to radiation, which have either been published in the open literature, or, if not published in the open literature, circulated within the professional community.
.f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
1) procedures concerning the registration, monitoring-and decontamination of individuals I
potentially exposed to radiation, especially I
relating to the monitoring and decontamination of evacuees from special facilities (nursing-homes, j
adult homes and hospitals), including those in T.
wheelchairs or on stretchers, 3
2) procedures concerning the registration, monitoring, and decontamination of evacuees from schools.
Unless the answer to item f.
is a simple negative, g.
please identify and provide a copy of each document.
i l l
O o
h.
Please identify and provide a copy of any document not already referred to in Contention EX 47 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 47.
ggsoonse:
At this time, there are no documents responsive to this Request.
LILCO Interrocatorv No. 13:
13.
Contention EX 49:
a.
Please identify each witness Intervenors expect to call on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of professional qualifications.
c.
Please list any NRC, legislative, or other legal proceeding in which each witness has testified on matters concerning the registration, monitoring and decontamination of individuals potentially exposed to radiation.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subject of registration, monitoring and decontamination of individuals potentially exposed to radiation, which have either been published i
in the open literature, or, if not published in the open literature, circulated within the professional community.
f.
Please state whether each witness has prepared, or l
has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
l 1) registration, monitoring and decontamination of individuals potentially exposed to radiation as a result of an accident at Shoreham, including but not limited to:
4 (a) the staffing required to perform these functions, (b) the equipment required to perform these functions, and (c) the time required to perform these functions.
2) the number of persons who would seek monitoring under the conditions imposed during the Exercise.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document.
h.
Please identify and provide a copy of any document not already referred to in Contention EX 49 or identified in i
response to item g. of this interrogatory on which Intervenors
~
intend to rely in support of their position on Contention EX 49.
Response
l No documents are responsive to this Request.
1 1
LILCO Interroaatory No. 14:
i 14.
Contention EX 50:
a.
Please identify each witness Intervenors expect to call'on this contention.
For each person, other than experts, whom Intervenors expect to call, state the subject matter on which each such witness is expected to testify and the substance of the facts to which he is expected to testify.
For each person whom Intervenors expect to call as an expert witness, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which he is expected to testify and a summary of the grounds for each such opinion.
l-l b.
With regard to each witness, please provide a copy of his most current curriculum vitae, resume or statement of L
professional qualifications.
c.
Please list any NRC, legislative, or other. legal proceeding in which each witness has testified on matters l
concerning (1) the training of workers, (2) the selection of sample I
groups for evaluative purposes, (3) the number of mistakes, errors or deficiencies needed to demonstrate that workers are inadequately trained to perform their jobs, (4) the severity or gravity of mistakes, errors or deficiencies needed to demonstrate that workers are inadequately trained, (5) the use of narrative evaluation procedures, (6) the use of numerical evaluation procedures, (7) the 1 l l.
O performance of trainees or employees under test conditions and (8) the performance of emergency workers during a FEMA graded exercise.
d.
Please provide copies of any prefiled testimony by each witness in the proceedings listed in response to item c.
Please identify all articles, papers, or other e.
documents authored or co-authored by each witness on the subjects of the training of workers, the selection of sample groups for evaluative purposes, the number of mistakes, errors or deficiencies needed to demonstrate that workers are inadequately trained, the severity or gravity of mistakes, errors or deficiencies needed to demonstrate that workers are inadequately trained in the use of narrative evaluative procedures, the use of numerical evaluative procedures, the performance of trainees or employees under test conditions, the performance of workers during a FEMA-graded exercise which have either been published in the open literature if not published in the open literature, circulated within the or, professional community.
f.
Please state whether each witness has prepared, or has had prepared, any written studies, reports, analyses or other documents with respect to any of the following:
1) the training of workers, 2) the selection of sample groups for evaluative
- purposes, 3) the number of mistakes, errors or deficiencies needed to demonstrate that workers are inadequately
- trained, 4) the severity or gravity or mistakes, errors or deficiencies needed to demonstrate that workers are inadequately trained, 5) the use of narrative evaluative procedures, 6) the use of numerical evaluative procedures, 1
7) the performance of trainees or employees under test conditions, 8) the performance of emergency workers during a FEMA-graded exercise.
g.
Unless the answer to item f. is a simple negative, please identify and provide a copy of each document. ---
h.
Please identify and provide a copy of any document not already referred to in Contention EX 50 or identified in response to item g. of this interrogatory on which Intervenors intend to rely in support of their position on Contention EX 50.
Resoonse:
Documents responsive to this Request include the resumes of SCPD officers Michel, McGuire, Cosgrove and Streeter, and the curriculum vitae of Dr. Perrow and Dr. Simon.
Also responsive is the prefiled testimony of SCPD personnel previously filed in this proceeding.
Obiections Stated Bv Counsel All objections and references to objections were stated by counsel.
Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial' Highway Hauppauge, New York 1788
/
h(
((f{-
=
Karla J. Letsche Michael S. Mill r P. Matthew Sut o Kirkpatrick & Lockhart 1900 M Street, N.W.
Washington, D.C.
20036 l
Attorneys for Suffolk County nL
' c. P _
/r--/
Fabian G. Palomino #
/
Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 l r
O Capitol Building Albany, New York 12224 Attorney for Mario M. Cuomo, Governor of the State of New York r+-,L. a. LA /
/
Stephen B. Lathafn' /
Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton November 26, 1986
i Exhibit A DOCUMENTS WHICH OTHERWISE ARE RESPONSIVE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON BUT WHICH WILL NOT BE PRODUCED BECAUSE THEY ARE PROTECTED BY ATTORNEY-CLIENT PRIVILEGE AND/OR WORK PRODUCT DOCTRINE 1.
ATTORNEY NOTES
~
By:
Karla J.
Letsche Date:
February 21, 1986 Re:
Typed version of notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
Kirkpatrick & Lockhart ("K&L")
-Recipients:
None Privilege:
Work Product 2.
ATTORNEY NOTES By:
Lawrence Coe Lanpher Date:
February 18, 1986 Re:
Typed version of notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
K&L Recipients:
None Privilege:
Work Product
3.
ATTORNEY NOTES By:
Michael S. Miller Date:
February 26, 1986 Re:
Typed version of notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
K&L Recipients:
None Privilege:
Work Product 4.
ATTORNEY NOTES By:
Agnes M.
Brown Date:
February 19, 1986 Re:
Typed version of notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
K&L Recipients:
None Privilege:
Work Product. _..
5.
ATTORNEY NOTES By:
Claib L. Cook (K&L law clerk)
Date:
undated Re:
Typed version of notes taken by agent of attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
K&L Recipients:
None Privilege:
Work Product 6.
ATTORNEY NOTES By:
Fabian G. Palomino (" Palomino")
Date:
February 13, 1986 Re:
Notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
Palomino Recipients:
None Privilege:
Work Product 7.
ATTORNEY NOTES By:
Richard J. Zahnleuter ("Zahnleuter")
Date:
February 13, 1986 Re:
Notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
Zahnleuter Recipients:
None Privilege:
Work Product - _.
8.
ATTORNEY NOTES By:
Stephen B.
Latham Date:
February 13, 1986 Re:
Notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
Twomey, Latham & Shea ("TL&S")
Recipients:
None Privilege:
Work Product 9.
ATTORNEY NOTES By:
John Shea Date:
February 13, 1986 Re:
Notes taken by attorney on February 13, 1986 during FEMA exercise for use in preparing for litigation Custodian:
TL&S Recipients:
None Privilege:
Work Product Exhibit B DOCUMENTS WHICH OTHERWISE ARE RESPONSIVE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON BUT WHICH WILL NOT BE PRODUCED BECAUSE THEY ARE PROTECTED BY ATTORNEY-CLIENT PRIVILEGE AND/OR WORK PRODUCT DOCTRINE 1.
MEMORANDUM By:
Assistant Chief Richard C.
Roberts Date:
May 14, 1986 Re:
Comments on FEMA Report of April 17, 1986
(" FEMA Report")
Custodian:
Kirkpatrick & Lockhart ("K&L")
Recipients:
Suffolk County ("Suffolk") and K&L Privilege:
Attorney-Client and Work Product 2.
MEMORANDUM By:-
Assistant Chief Joseph L. Monteith Date:
May 14, 1986 Re:
FEMA Report Custodian:
K&L Recipients:
Suffolk and K&L Privilege:
Attorney-Client and Work Product
3.
MEMORANDUM By:
Inspector Robert A.
Snow Date:
May 12, 1986 Re:
FEMA Report Custodian:
K&L Recipients:
Suffolk and K&L Privilege:
Attorney-Client and Work Product 4.
MEMORANDUM By:
Deputy Inspector Russell E. Brown Date:
May 13, 1986 Re:
FEMA Report Custodian:
K&L Recipients:
Suffolk and K&L Privilege:
Attorney-Client and Work Product 5.
MEMORANDUM By:
Captain Thomas P. Compitello Date:
May 9, 1986 Re:
FEMA Report Custodian:
K&L Recipients:
Suffolk and K&L Privilege:
Attorney-Client and Work Product 6
i i
u.
6.
MEMORANDUM By:
Deputy Inspector Kenneth J. Regensburg Date:
May 13, 1986 Re:
FEMA Report Custodian:
K&L Recipients:
Suffolk and K&L Privilege:
Attorney-Client and Work Product 1
7.
MEMORANDUM By:
Deputy Inspector Peter F. Cosgrove Date:
May 12, 1986 Re:
FEMA Report Custodian:
K&L Recipients:
Suffolk and K&L Privilege:
Attorney-Client and Work Product
s s
Exhibit C DOCUMENTS WHICH OTHERWISE ARE RESPONSIVE TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON BUT WHICH WILL NOT BE PRODUCED BECAUSE THEY ARE PROTECTED BY WORK PRODUCT DOCTRINE 1.
Draft of Contention Ex 36 4
By:
Kirkpatrick & Lockhart ("K&L") attorneys and Gregory C. Minor (" Minor")
Date:
Custodian:
K&L Recipient:
None Privilege:
Work Product 2.
Draft of Contention Ex 36 By:
K&L and Minor Date:
Custodian:
K&L Recipient:
None Privilege:
Work Product 3.
Handwritten Notes Re: OPIP 3.6.1 and Radiation Emergency Data Form l
By:
Minor Date:
Custodian:
K&L Recipient:
K&L l
Privilege:
Work Product l
l l
_. _ _ _ _ _ _ -. _. _.. _ _ -. _ ~ -.. _, _. _ - _
O 4
4.
Radiation Dose Calculations i
By:
Minor i
Date:
Custodian:
K&L Recipient:
K&L Privilege:
Work Product f -
t h
-t 03RRgsPOM DOLMETED g TE0 November L2'6BC 1986 16 NOV 28 P7 :24 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION Before the' Atomic Safety and Licensina bIr k [ N [ r eMAN&
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 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO SUFFOLK COUNTY, NEW YORK STATE AND TOWN OF SOUTHAMPTON have been served this 26th day of November 1986 by U.S. mail, first class, except as otherwise noted.
John H.
Frye, III, Chairman 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 Dr. Oscar H.
Paris Mr. Frederick J.
Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissicr.
Washington, D.C.
20555 Washington, D.C.
20555
7.g 1p Bernard M.
Bordenick, Esq.
Anthony F.
Earley, Jr.,
Esq.
U.S. Nuclear Regulatory Comm.
General Counsel Washington, D.C.
20555 Long Island Lighting Company 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 Mr. Phillip McIntire Kirkpatrick & Lockhart lederal Emergency Management 1500 Oliver Building Agency Pittsburgh, Pennsylvania 15222 26 Federal Plaza New York, New York 10278 By Federal Express
/rb h
/ps Michael 6. Miller
/'
KIRKPATRICK & LOCKHART 1900 M Street, N.W.
Suite 800 Washington, D.C.
20036 Date:
November 26, 1986
p.
l November 26, 1986 UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
NOTICE OF ENTRY OF APPEARANCE Please take notice that pursuant to 10 CFR 52.713(b) P.
Matthew Sutko, an attorney at law admitted to practice before the United States District Court for the Northern District of Ohio, and the Supreme Court of the State of Ohio hereby enters an appearance on behalf of Suffolk County in the captioned matter.
bi o+k?
sarla J. Letsche
/
Michael S. Miller /
P. Matthew Sutko Kirkpatrick & Lockhart 1900 M Street, N.W.
Washington, D.C.
20036
b k
{j
' \\
l jfI November 26. 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
)
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 NOTICE OF ENTRY OF APPEARANCE have been served this 26th day of November 1986 by U.S. mail, first class, except as otherwise noted.
John H.
Frye, III, Chairman 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 Dr. Oscar H.
Paris Mr. Frederick J.
Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board i
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 1
}
8 4
l i
I,_-,-
I
\\
?.)
Bernard M. Bordenick, Esq.
Anthony P. Earley, Jr., Esq.
U.S. Nuclear Regulatory Comm.
General Counsel Washington, D.C.
20555 Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801 l
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 Gove:nor Bldg, 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 i
David A. Brownlee Mr. Phillip McIntire Kirkpatrick & Lockhart Federal Emergency Management 1500 Oliver Building Agency Pittsburgh, Pennsylvania 15222 26 Federal Plaza New York, New York 10278 By Federal Express W re]
ber Michael'S. Miller
/~
KIRKPATRICK & LOCKHART 1900 M Street, N.W.
Suite 800 Washington, D.C.
20036 Date:
November 26, 1986
.