ML20214P300
| ML20214P300 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/27/1987 |
| From: | George Minor, Sholly S SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20214P269 | List: |
| References | |
| OL-3, NUDOCS 8706030302 | |
| Download: ML20214P300 (25) | |
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
(Unit 1)
)
)
l REBUTTAL TESTIMONY OF GREGORY C. MINOR AND STEVEN C. SHOLLY i
ON BEHALF OF SUFFOLK COUNTY REGARDING LILCO'S RECEPTION CENTERS (ADDRESSING TESTIMONY OF LEWIS G. HULMAN) l l
May 27, 1987 i
l 8706030302 B70527 PDR ADOCK 05000322 O
PDRn
t UNITED STATES OF AMERICA-NUCLEAR REGULATORY. COMMISSION Before the Atomic Safety and Licensino Board i
i
)
)
In the Matter of
)
Docket No. 50-322-OL-3 i
LONG ISLAND LIGHTING COMPANY
)
)
(Emergency Planning) i (Shoreham Nuclear Power Station,
)
)
(Unit 1)
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TESTIMONY OF GREGORY C. MINOR AND STEVEN C. SHOLLY t
ON BEHALF OF SUFFOLK COUNTY REGARDING 4
LILCO'S RECEPTION CENTERS (ADDRESSING TESTIMONY OF)
LEWIS G. HULMAN
_ IDENTIFICATION QF WITNESSES I.
Please state your names and positions.
t 0:
I am Vice A
(Minor)
My name is Gregory C. Minor.
President of MHB Technical Associates of San Jose, California, a consulting firm specializing in energy related issues.
I am a consul-A:
(Sholly)
My name is Steven C. Sholly.
tant with MHB Technical Associates of San Jose, California.
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Q:
Have you previously testified in this proceeding?
A:
(Minor)(Sholly)
Yes.
Our testimony was part of the testimony of Stephen Cole, Susan C.
Saegart, James H. Johnson, Jr., David Harris, Martin Mayer, Gregory C. Minor and Steven Sholly on behalf of Suffolk County Regarding LILCO's Reception Centers (Planning Basis) (April 13, 1987).
Descriptions of our qualifications and copies of our vita may be found in the Direct Testimony of Stephen Cole gi al. Regarding LILCO's Reception Centers (Planning Basis).
II.
OVERVIEW 0:
What is the purpose of this testimony?
A:
(Minor) (Sholly)
This testimony is provided in rebut-tal to the testimony submitted in this proceeding by Lewis G.
Hulman of the U.S. Nuclear Regulatory Commission on April 13, 1987 ("the Hulman testimony").
Mr. Hulman's testimony estimates the conditional probability of the number of people within the 10-mile Emergency Planning Zone (EPZ) who could be within the plume of an accidental release of radioactivity from Shoreham.
He refers to this evaluation as a " footprint assessment."
Hulman Testimony at 1.
To make this footprint assessment, Hulman uses three sets of calculations which he labels as " Cases" 1.
I through 3.
Hulman Testimony at 5-7.
Mr. Hulman asserts that these three Cases "show the range of the number of people who could be in the plume in the event of an accident" at Shoreham.
Hulman Testimony at 9.
Based on his calculations, Mr. Hulman concludes that "the planning basis 20% would be a conservative estimate of the number of people who might be within a plume."
Hulman Testimony at 9.
Mr. Hulman's calculations of the number of people that might be expected to be exposed to the plume are not accurate, because he uses unrealistic assumptions and the three Cases he postulates generate calculations which are misleading.
- Indeed, Cases 1 and 3 are so flawed that they should be totally ignored, and Case 2 needs substantial modifications to present a realistic estimate of the number of people who may be exposed to a plume in the event of a Shoreham accident.
III. THE HULMAN ANALYSIS IS FLAWED Q:
As a general matter, what are the unrealistic assump-tions in Mr. Hulman's approach?
A.
(Minor) (Sholly)
It is our view that several factors need to be taken into account which have not been addressed by Mr. Hulman's calculations.
First, Mr. Hulman uses a straight-line Gaussian model which fails to account for the fact that wind l
4 shift is very likely during any Shoreham accident.
As we testi-fled in our direct testimony, LILCO's. environmental report indi-cates that winds are persistent in one direction for periods of six hours or longer only about 14% of the time.
This means that changes in the wind direction are likely to occur over the period of release following an accident at Shoreham.
Given that a pos-tulated release of radioactivity is a stochastic phenomenon, it is clear that there is a substantial chance of one or more wind direction changes over any given four-hour period.
This could greatly increase the number of people exposed to the plume.
Mr. Hulman's second unrealistic assumption is his failure to account for precipitation.
Precipitation must be considered because it has an impact on dose Ic.'els at dif ferent distances from the plant, as compared with the no precipitation cases.
Third, Mr. Hulman also fails to include consideration of scenarios involving evacuation during a release.
Such scenarios are significant because an ill-timed evacuation could significantly increase the number of people potentially contaminated by the plume.
As we testified in our direct testimony, the location of the reception centers west of the EPZ increases the likelihood that evacuation might increase exposure to the plume for releases in certain directions (e.g. Southwest).
A Finally, Mr. Hulman states that his data shows that 46,000 people, or 20% of the EPZ population, is a conservative estimate for the number of people who would be exposed to plume.
This statement is totally arbitrary and is not explained.
It appears, however, to represent roughly a 90 percentile criterion.
Even using Hulman's flawed assumptions and the resulting unrealistically low estimates of population exposure, it is equally possible to conclude that a 95 percentile or a 98 percentile criterion represents a conservative estimate of the number of people who would be exposed to a plume.
Based on Mr.
Hulman's curves this would correspond to 60,000 to 100,000 people who would potentially require monitoring.
Q:
Please identify what you consider to be the deficien-cies in each of the cases Mr. Hulman presents.
A.
Case No. 1 A
(Minor) (Sholly)
For Case No.
1, Mr. Hulman assumed a narrowed plume which moves in a straight line and never achieves more than 3,000 meters in width even as it moves out to a 10 mile distance.
The failure to account for plume expansion makes this i
scenario highly unrealistic.
Coupled with the high probability of wind shifts during a Shoreham accident, Case No. 1 grossly.
A underestimates the potential number of individuals who could be Nevertheless, Mr. Hulman deems this calcula-within the plume.
tion conservative on'two grounds.
Mr. Hulman contends Case No. 1 is conservative
- First, because a narrow plume concentrates the potential exposure and therefore increases the dose which people would receive.
However, an analysis of dosage is irrelevant to the purpose of his testimony, which purports to be assessing the likely number of people who would be exposed to the plume -- not the maximum Indeed, to the extent Mr. Hulman's testimony is relevant dosage.
It must to analyzing the adequacy of LILCO's reception centers.
focus on how many people may have been'in or near the plume's path -- not how high their doses would be.l./
is that conservatism is obtained in Hulman's second argument Case No. 1 by adding to his weighted population assumptions the
" number of people out to 2 miles in all directions not under the plume."
Hulman Testimony at 6.
The addition of the people with-in the 2 mile EPZ is a relatively insignificant addition because they represent only 6% of the population in the 10 mile EPZ.
Even Mr. Hulman acknowledges that the narrow plume assumption 1/represents NRC staff practice for calculations for design basis Hulman Testimony at 5.
The purpose of design basis accidents.
accident calculations is to conservatively estimate dose, not to estimate the number of people exposed.
4 a-Accordingly, the calculation's presented in Case No. 1 do not' represent a conservative estimate of the number of people who might be exposed to a Shoreham plume.
In fact, it represents a non-conservative estimate of the numbers involved and should therefore not be used in assessing a planning basis number.
B.
Case No. 2 Q:
Please describe the deficiencies in Hulman Case No. 2.
As Case No. 2 in Mr. Hulman's analysis is similar to Case No. 1, but it allowed the plume to expand as it moves away from the plant.
The plume thus becomes wider than it did in the Case No. 1 scenario, where plume width was artificially restrained.
Although this part of the case is more realistic, Mr. Hulman fails to account for other factors which are necessary for a realistic estimate.
In particular, the key factor not accounted for is that the wind direction on Long Island is likely to change.
Thus, Mr. Hulman's calculations assume that the plume travels in a straight line (it does not account for meandering or wind shift), and his calculations also assume a lack of rain.
Accordingly, Case No. 2 does not account for the exposure of more than one sector of the EPZ.
As we stated in our direct testimony, wind direction changes are more likely to occur than not.
Thus, during the course of the development of an accident j
and the release and movement of the plume away from the plant, I.
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there is likely to be a wind shift.
This would cause the plume to meander across more than one sector which would involve a much greater portion of the population.
Hulman stated that he believed he compensated for this fail-ure to include likely wind shifts by (1) including within the exposed population all those within 2 miles of the plant and (2) ignoring emergency response.
(Hulman Testimony at 8.)
Mr.
Hulman provides no basis for this assertion, and we believe these two factors do not compensate for failure to include wind shifts.
As was indicated before, the population within 2 miles of the plant is only 6% of the total EPZ population, so this adds little or no conservatism to the calculations.
Moreover, wind shifts are likely to occur outside this two mile zone, which is the area in which the vast majority (94%) of the population resides.
As to the failure to account for emergency response providing a source of conservatism, we indicated in our direct testimony that emergency response could conceivably increase the number of people exposed to the plume.
Failure to account for emergency response therefore provides no conservation to Hulman's calculations.
C.
Case No. 3 Q:
Please state your understanding of Case No. 3 as pre-sented by Mr. Hulman. - -
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A:
In all three cases, Mr. Hulman divided the population into sixteen sectors.
Case No. 3 presents the same scenario as Case No. 1, except that Mr. Hulman weighted each of his 16 population sectors by the percentage of time the wind would be expected to blow in that direction.
In essence, Case No. 3 is little more than another way of looking at the site population distribution by simply weighting the population distributed by wind rose probabilities.
This effort is fundamentally flawed because underlying this calculation is an assumption that the plume will never occupy more than one of the sixteen compass sectors.
This is an unproven assumption and one which fails to account for wind direction changes during the duration of the release.
Therefore, it is our belief that Case 3's calculation should be totally ignored as misleading and not useful for the purposes of determining the number of people exposed to the plume.
IV.
CONCLUSION Q:
What does your testimony conclude?
At We conclude that none of Mr. Hulman's cases is repre-sentative of the consequences of an accident at Shoreham and therefore should not be relied on to the number of people poten-tially exposed to a Shoreham plume.
b Q:
Does this conclude your rebuttal testimony?
As Yes it does.
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April 17, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION Before the Atomic Safety and Licensina Board i
)
In the Matter of
)
i
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Docket No. 50-322-OL-3 l
LONC ISLAND LIGHTING COMPANY
)
(Emergency Planning)
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(Shoreham Nuclear Power Station,
)
Unit 1)
)
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SUFIOLK COUNTY MOTION FOR LEAVE TO FILE REBUTTAL TESTIMONY Suffolk County (the " County") hereby moves for leave to file i
i limited rebuttal testimony which will address the testimony of NRC witness Lewis G. Hulman concerning the number of people who may be affected by a Shoreham accident.
The testimony that the j
County seeks to file will be prepared by Gregory C. Minor and l
l Steven C. Sholly, both of whom have already been identified as witnesses in this proceeding.
I.
BACKGROUND On March 6, 1987, the County received the NRC Staff's Second Supplemental Response to Defendant's First Set of Interrogatories
("Second Supplemental Response"), which contained the NRC Staff's l
final designation of is witnesses.
This Second Supplemental Renponse designated Mr. Lewis Hulman as a witness and, for the first time, the Staff informed the County that the Staff intended k
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to rely on probabilistic risk assessments, consequence analyses and similar technical analyses for the purpose of addressing the issue of how many people will arrive at the reception centers.
Indeed, even at that late date, the technical nature of Mr.
Hulman's testimony was not made explicit by the NRC's witness designation, but was only indicated b/ the technical documents on which the Staff stated Mr. Hulman intended to rely.
Mr. Nulman was deposed by the County on March 10, 1987.
At that deposition, Mr. Hulman confirmed that he intended to conduct a technical analysis of the number of people who would likely be affected by a plume released during a Shoreham accident.
Mr.
Hulman also stated at his deposition that he had not yet reached even tentative conclusions and had not completed any calculations.
Hulman Deposition at 8.
Faced with this unexpected and incomplete technical analysis, counsel for the County requested the results of Mr. Hulman's calculations on the record.
In addition, three hours after the deposition, the County designated Messrs. Minor and Sholly as anticipated wit-nesses and proffered them for deposition.
Letter of Christopher M. McMurray to James N. Christman, William R. Cumming and Richard G. Bachmann, March 10, 1987.
LILCO subsequently moved to strike Messrs. Minor and Sholly as witnesses.
On March 16, 1987, the Board convened 1 telephone conference to. discuss the LILCO motion.
During that conference,.
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the County stated that because Mr. Hulman had yet to prepare any 4
e analysis, Messrs. Minor and Sholly would likely testify in rebuttal.
When counsel for the NRC asserted that Mr. Hulman's testimony would be limited to a meteorological analysis, the Board encouraged counsel to work together to reach an understanding as to the limits of Mr. Hulman's testimony.1/
1 Pursuant to the Board's suggestion that counsel work together to ascertain the scope of Mr. Hulman's testimony, on March 18, 1987, counsel for the County sent a letter to the NRC l
Staff seeking both a clarification of Mr. Hulman's proposed l
l testimony and the results of Mr. Hulman's calculations.
This letter is attached to this Motion as Exhibit 1.
Counsel for the l
Staff never responded to the March 18 letter from Suffolk County.
t
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In fact, it was not until April 10, 1987 that counsel for the County received the calculations which are the basis for Mr.
l Hulman's testimony.
Thus, the County received no information as I
to the nature of Mr. Hulman's testimony until three days before i
j the County's testimony was due in the hands of the Board and the t
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parties.
Moreover, Mr. Hulman's calculations were indecipherable i
without his testimony as to the purpose of the calculations, the source of the data, and the methodology used.
Thus, it was not j
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The LILCO motion to strike was denied by this Board during the March 16, 1987 telephone conference.
The Board's ruling is set forth in the Memorandum Memorializing Ruling on Motion to Strike Two Designated Individuals as Witness (March 17, 1987).
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until after April 13 -- the day the County's direct testimony was due and filed -- that the County could begin to understand Mr.
Hulman's calculations.
The County's review of Mr. Hulman's testimony reveals that it contains a technical analysis of the " conditional probability of the number of people within the 10 mile Emergency Planning zone (EPZ) which could be within the plume of an accidental release of radioactivity from Shoreham."
Hulman Testimony at 1.
His testimony provides the basis for another NRC witness to conclude that an adequate planning basis for the number of people who might arrive at the reception centers for monitoring is 20%
of the EPZ population.
Kantor Testimony at 7.
Even a quick reading of Mr. Hulman's testimony shows that the procedures used in deriving the probabilities of the number of people who would be affected by a plume released from Shoreham is quite technical and based on computer generated calculations.
In particular, Mr. Hulman uses a Gaussian dispersion model to assess plume dispersion, and has made several assumptions as to the meteorological and demographic conditions.
l Analyses of Mr. Hulman's tantimony and data conducted by the County's experts show that his calculations are misleading.
For I
instance, the cases he has evaluated are unjustifiability restricted and he has artificially limited his base case.
Moreover, some of his assumptions, such as those concerning l
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Rebuttal testimony is i
therefore necessary to show that the conclusions drawn by Mr. Nulman (and Mr. Nantor) are unreliable.
l tr. orscussrgg Rebuttal testimony may be filed where " good cause" is shown.
In this case, good cause is shown for three reasons.
First, the rebuttal testimony offered by Messrs. Minor and sho11y could not have been included in the County's April 13, 1987 direct testimony.
Despite the efforts of the County, the Staff did not provide Mr. Hulman's calculations until three days before the county's testimony was filed.
Moreover, even this limited piece of information could not be analysed in the absence of Mr.
Hulman's testimony, which was filed around April 13, 1987.
Second, good cause is demonstrated because the proposed rebuttal testimony is relevant to issues before the Board and necessary for the Board to evaluate the evidence presented by the Staff.
It is undisputed that LILCO's planning basis for the reception centers is one of the key issues in this case.
LILCO has submitted testimony on this issue and related issues (LILCO testimony at p. 3-23), as has the county (Direct Testimony of Stephen Cole, et al. on behalf of Suffolk County regarding Reception Centers (Planning Basis)), the State of New York (Direct Testimony of James D. Papile, et al. on behalf of the 5-L.
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l FEMA (Direct Testimony of Thomas E. Baldwin, Ihor W. Husar and Joseph Meller at 7), and now the NRC' Staff.
The Staff has attempted to address the planning basis by assessing the
" footprint" of a likely plume from a Shoreham accident.
The 1
County's review of the NRC Staff's testimony, however, shows that it is misleading and therefore not valid.
The County's rebuttal testimony will identify the flaws in Mr. Hulman's analysis.
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Third, good cause exists because the County's rebuttal l
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testimony will not be cumulative and will be narrowly focused.
Messrs. Minor and Sholly have not submitted any testimony on Mr.
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Hulman's " footprint" analysis because the County could obtain i
l neither the underlying calculations nor an explanation of Mr.
Hulman's calculations or methodology.
Now that the County has this information, it will be able to focus its rebuttal on Mr.
j Hulman's testimony.M Conclusion l
For the foregoing reasons, the County's Motion for Leave to j
rile Rebuttal Testimony should be granted.
F The County continues to support to the proposed schedule for filing rebuttal testimony set forth in the suffolk County and State of New York Motion for Rescheduling of Relocation Center l
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Hearing to Commence Upon Completion of Exercise Litigation (April i
13, 1987).
Specifically, that proposed schedule calls for the filing of rebuttal testimony on May 4, 1987, filing of motions to strike on May 11, 1987, and filing of responses to cuch motions on May 18, 1987.
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Respectfully submitted, i
Martin Stadley Asnare Suffolk County Attoeney H. Lee Dennison Building Veterans Memorial Highway Hauppauge, New York 11780 l
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i Lawrence Coe Lanpher l
Christopher M. McMurray l
David T. Case NIRMPATRICK 4 LOCNNART 1000 M Street, N.W.
South Lobby - Suite 900 Washington, D.C.
20036-5491 Attorneys for Suffolk County April 17, 1947 l
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- 4 1202) 778-9084 March 18, 1987 BY TEI,ECOPY Richard G. Dachmann, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, DC 20555 RE:
Docket No. 50-322-OL-3 Testimony of Lowis G.
Hillma n Dear Mr. Bachmann I am writing in an attempt to clarity some confusion resulting from statements concerning Mr. Hulman's testimony which were made to the Board during the conference call of March 16, 1987 In particular, you suggested that Mr. Ilulman's testimony would be limited to the meterological aspects of consequence analysis.
If Mr. Ilu1 man's testimony is so limited, please l
oxplain how Mr. Ilulmaa's testimony will address meterology without any discussion of other aspects of consequence analysis.
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In addition, as I stated at the deposition of Mr. Ilulman, Suffolk l
County requests a copy of Mr. Ilulman's calculations and analysos l
as soon as they are completod.
please rail if you have any questions.
i Sincerely yours, J C-David T. Case cct All counsol DTC/tre EX111 BIT 1 l
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Anril 17, 1937 UNITED STATES OF AMERICA NUCLEAR RCCULATORY COMMISSION Before the Atomic Safet:v and Licensina Board
~~
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
_)
CERTIFICATE JF SERVICE I hereby certify that copies of the SUFFOLK COUNTY MOTION FOR
[
LEAVE TO FILE RESUTTAL TESTIMONY have been served on the l
following this 17th day of April. 1987 by United States mail, i
first class, except as otherwise noted.
Morton 5. Margulies, Esq., Chairman
- Joel Blau, Esq.
Atomic Safety and Licensing Board Director, Utility Intervention U.S. Nuclear Regulatory Commission N.Y. Consumer Protection Board Washington, D.C.
20555 Suite 1020 1
Albany, New York 12210 1
Dr. Jerry R. Kline*
William R. Cumming, Esq.*
t Atomic Safety and Licensing Board Spence W. Perry, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel l
l Washington, D.C.
2055$
Federal Emergency Management Agency' 500 C Street, S.W.,
Room 840 t
Washington, D.C.
20472 l
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Mr. Frederick J. Shona Anthony F. Earley, Jr., Esq.
Atomic Safety and Licensing Board General Counsel i
U.S. Nuclear Regulatory Commission Long Island Lighting Company i
Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 l
Ms. Elisabeth Taibbi W. Taylor Reveley, III, Esq.*
Clerk Hunton and Williams Suffolk County Legislature Post Office 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 Stat.,on 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 Oppnents Coa 11tiin U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 "H" Street, N. W.
Smithtown, New York 11787 Washington, D.C.
20555 Mary M. Gundrum, Esq.
Hon. Michael A. Lo0rande New York State Department of Law Suffolk County Executive 120 Broadway, Third Floor H. Lee Dennison Building Room Number 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite "M" Post Office Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Pabian G. Palomino, Esq.*
Suffolk County Attorney Richard J. Zahnleuter, Esq.
Bldg. 158, North County Complex Special Counsel to the Veterans Memorial Highway Governor of the State Hauppauge, New York 11788 of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Mr. Jay Dunkleburger Richard G. Bachmann, Esq.*
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency Building 2 Washington, D. C.
20555 Empire State Plaza Albany, New York 12223 l
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David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick and Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 West 43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 MM tb David T. Case KIRKPATRICK & LOCKHART 1800 "M" Street, N. W.
South Lobby - Ninth Ploor Washington, D. C.
20036-5891
- Via Telecopy April 17, 1987 l
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USNRC f
May 27. 1987 i
'87 JLN -1 P1 ;55 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.yFFlu_... >
. s Before the Atomic Safety and Licensino Bob h $5[h4 l
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)
l In the Matter of
)
l
)
l LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
l Unit 1)
)
i
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l CERTIFICATE OF SERVICFi l
I hereby certify that copies of the RENEHED SUFFOLK COUNTY MOTION FOR LEAVE TO FILE REBUTTAL TESTIMONY WITH ATTACHMENTS have been served on the following this 27th day of May, 1987 by United States mail, first class, except as otherwise noted.
Morton B. Margulies, Esq., Chairman **
Joel Blau, Esq.
Atomic Safety and Licensing Board Director, Utility Intervention U.S. Nuclear Regulatory Commission N.Y. Consumer Protection Board Washington, D.C.
20555 Suite 1020 Albany, New York 12210 Dr. Jerry R. Kline**
William R. Cumming, Esq.**
Atomic Safety and Licensing Board Spence W. Perry, Esq.
U.S. Nuclear Regulatory Commission.
Office cf General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W.,
Room 840 l
Washington, D.C.
20472 I
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Mr. Frederick J.
Shon**
Anthony F.
Earley, Jr., Esq.
Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 Ms. Elisabeth Taibbi W.
Taylor Reveley, III, Esq.*
Clerk Hunton and Williams Suffolk County Legislature Post Office 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 Mary M. Gundrum, Esq.
Hon. Michael A. LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, Third Floor H.
Lee Dennison Building Room Number 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite "K"
Post Office Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Fabian G.
Palomino, Esq.*
Suffolk County Attorney Richard J.
Zahnleuter, Esq.
Bldg. 158, North County Complex Special Counsel to the Veterans Memorial Highway Governor of the State Hauppauge, New York 11788 of New York Executive Chamber, Room 229 l
Capitol Building Albany, New York 12224 Mr. Jay Dunkleburger Richard G. Bachmann, Esq.**
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency Building Two Washington, D.'C.
20555 Empire State Plaza Albany, New York 12223 i i u
6.
6 David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick and Lockhart Business / Financial 1500 Oliver Building-NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 West 43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 M
David T. Case KIRKPATRICK & LOCKHART 1800-"M" Street, N. W.
South Lobby - Ninth Floor Washington, D. C.
20036-5891
- Via Telecopy
- Via Hand Delivery May 27, 1987 'l c