ML20236E139

Lilco Motion for Summary Disposition of Contention 25.C (Role Conflict of School Bus Drivers).* Certificate of Svc Encl

ML20236E139
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/22/1987
From:	Leugers M HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20236E133	List: ML20236E129 ML20236E139
References
OL-3, NUDOCS 8710290084
Download: ML20236E139 (33)

Text

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LILCO, October 22,1987 00LKETED -

USNRC UNITED STATES OF. AMERICA l ,

NUCLEAR REGULATORY COMMISSION '87 N:T 26 A8 50 i

0FFICE Of $tChtju( ,

00CKElING A StifVICf' Before the Atomic Safety and Licensing Board . BRANCH In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL ) (Emergency Planning)  ;

(Shoreham Nuclear Power Station, )

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. Unit 1) )

I LILCO'S MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION 25.C l (" ROLE CONFLICT" OF SCHOOL BUS DRIVERS)

LILCO hereby' moves for summary disposition of emergency planning Contention 25.C, which alleges .that school bus drivers would not do their jobs in' a Shoreham ra- )

diological emergency because of " role conflict." The basis for this motion is the exist-ing record, the Board's reasoning in LBP-85-12 (the "PID") the additional evidence of an opinion survey of volunteer firemen that the Appeal Board, in ALAB-832, ordered the Board to consider, and LILCO's commitment to provide additional school bus drivers.

I. Background The first part of Contention 25, which addresses " role conflict," reads as follows:

Contention 25: Role Conflict of Emergency Workers  ;

Preamble to Contention 25. Emergency workers relied upon by LILCO will have conflicting duties in the event of an emergency. On the one hand, they will be obli-gated or expected to perform some emergency function  ;

under the LILCO Plan: on the other hand, they will be obil- i gated by preexisting f amily or occupational relationships, to attend to other matters such as the safety of their spouses, 1 children, or other f amily members. Role conflict for emer-gency workers was a documented problem at TMI, especially concerning medical personnel: behavior surveys conducted

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i L 1 l 1 by Suffolk County demonstrate that this will be a problem in a~ Shoreham emergency as well. Role conflict thus creates the possibility. that significant numbers of emergency per--

sonnel will look to the needs of their families or others for i

. which they have responsibility (including themselves) before . 1 they ; report (if at all) to their. designated emergency re- j sponse positions or otherwise respond to a request by LILCO j for assistance. This factor will be exacerbated by the fact i thatymany emergency . personnel will be asked to respond. ]

from a relatively safe area outside the EPZ to a more dan- j i gerous area within the EPZ. ]

i Contention 25.- Interveners contend.that the LILCO l i Plan ialls to comply. with 10 CFR Sections 50.47(a)(1), 'f

- 50.47(b)(1) and 50.47(b)(3), because the Plan falls.to address 1

! .the problem of emergency worker role. conflict. Interveners {

contend that a substantial number of the emergency workers - ]

. relied upon under the LILCO Plan will resolve such conflicts ,  !

= by attending to their other obligations prior to, or in lieu of performing;the emergency functions assigned to them by 1 LILCO. ~ In the absence of'such workers, the LILCO Plan cannot and will not. be implemented, and there can be no  ;

finding of compliance with 10 CFR : Sections 50.47(a)(1),

50.47(b), and s NUREG 0654 Section II. The emergency workers likely to experience role conflict, the type of con- i filet,J and the effect of such conflict upon the imple-  !

rentability of. the LILCO Plan are set forth in paragraphs A-F below.

Proposed Emergency Planning Contentions Modified to Reflect Revision 3 of the LILCO 1

Plan, January 12,1984, ~at 78-79. The rest of the contention. consists of subparts A through F, each of which addresses a different group of people who are alleged to be subject to " role conflict." In particular, Contention 25.C addresses role conflict of l

school bus drivers:

Contention 25.C. The LILCO Plan falls to take into account the role conflict that will be experienced by school bus drivers. In fact, a substantial number of school bus driv-ers are likely to attend to the safety of their own families before they report (if they report at all) to perform the bus driving duties which LILCO assumes will be performed. Role conflict of school bus drivers will mean that neither school buses nor school bus drivers will be available to implement the LILCO Plan. Without an adequate number of buses or bus drivers, LILCO will be incapable of implementing the following protective actions:

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1. early dismissal of schools (necessary under the I LILCO Plan to permit school children to be shel-tered or to evacuate with their parents);

2. evacuation of schools;

3. evacuation of persons without access to cars; and

4. evacuation of persons in special facilities.1/ 1 1

I_d. at 81-82.

When the parties submitted written evidence on this contention in late 1983, in-cluded in Suffolk County's testimony was information-about a survey of volunteer-firemen. Cole, ff. Tr.1216, at 12-16,18; Erikson and Johnson, ff. Tr.1455,'at 24-26, 28,30. Upon motion by the NRC Staff, the Board struck this testimony as irrelevant.

Tr. 792; Order Confirming Changes in Schedule with Regard to " Group II" Contentions -

and Rulings on Motions to Strike, Dec. 2,1983, at 4. Suffolk County asked for reconsid-1 eration of this ruling. Suffolk County Objections to Prehearing Conference of Counsel j I

Orders and Motion for Reconsideration, Dec. 8,1983, at 18-22. The' Board declined to j

- reverse itself, and eventually resolved the " role conflict" issue in LILCO's favor in its Partial Initial Decision (the "PID"). Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-85-12,21 NRC 644,671-79 (1985).

I The Interveners appealed the Board's decision to the Appeal Board. See Suffolk County, State of New York, and Town of Southampton Brief on Appeal of Licensing Board April 17, 1985 PartialInitial Decision on Emergency Planning, October 23,1985, at 58-59. The Appeal Board remanded, agreeing with the Interveners that the Board had erred in excluding the testimony related to the survey of volunteer firemen. Long 1/- Under the LILCO plan school bus drivers do not evacuate members of the general L ' public without access to cars or persons in special f acilities. Hence items 3 and 4 are a i~ misunderstanding and not at issue.

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1 Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), ALAB-832, 23'NRC 135, 153-54 (1986). The Appeal Board's reasoning was as follows:

While the applicant does not rely on volunteer firemen to implement protective actions in the event of a Shoreham emergency, that fact alone was insufficient to deny admis-sion of the testimony. In our view, the results of a survey as to the potential for role conflict among firemen, if they had been part of the emergency response, would provide insight j into the likely course of conduct of school bus drivers.  ;

Stated in its simplest terms, if a trained professional emergency worker such as a fireman would put family obli-gations ahead of the discharge of any Shoreham emergency duties that might be assigned to him or her, it is a f air infer-ence that an individual not in such a line of endeavor would -

encounter at least as ' great role conflict. It is thus .

unsurprising that, in the consideration of emergency plan- I '

ning .in Zimmer, we found that surveys of volunteer life squadsmen and firemen concerning the role conflict they would encounter raised "a serious question as to whether bus drivers could be depended upon to carry out their responsi-bilities" in the event of an accident at that plant. We fur-  ;

ther determined there that those surveys precluded, on the  !

evidence of record, a finding that the school bus drivers would respond promptly.

On the record now before us, we similarly cannot j make a finding that a sufficient number of school bus drivers can be relied upon to perform their duties if an accident '

occurred at Shoreham. Therefore, we are remanding this matter to the Licensing Board for further exploration. All parties will be free to adduce additional evidence on this issue; at minimum, the Licensing Board is to accept the tes-timony related to the survey of volunteer firemen. Upon re-view of the evidence presented at the reopened hearing, the Licensing Board should reconsider its prior findings and con-clusions regarding the potential for role conflict among school bus drivers. J l

Ld. (footnotes omitted),

t LILCO asked the Commission to review the Appeal Board's decision but the Com-mission declined to do so. Commission Order, September 19, 1986. Accordingly, the issue is now before this Board on remand, pursuant to the Appeal Board's decision in ALAB-832.

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n LILCO- submits that ' the issue of whether school bus drivers will respond as 'l i.

needed can be resolved summarily, without further evidentiary hearings. It is true that the Appe'al Board remanded this issue, saying that "[a]Il parties will be free to adduce  !

additional evidence." ALAB-832,23 NRC 135,154 (1986). But the Appeal Board did not 'l

, i specify that there must be an evidentiary hearing; rather, it said that "at minimum, the  !

1 Licensing Board is to accept the testimony related to.the survey of voluntur firemen" .j and "[u]pon review of the evidence presented at the reopened hearing . . . reconsider 1 its prior findings and conclusions regarding the potential for role conflict among school- ]

bus drivers." Id. (footnote omitted). . That is what LILCO now urges: that the Board 'I i

take into account the previously excluded evidence and reconsider its findings. But such reconsideration will still reach the same conclusion. Moreover, the Appeal Board

'did not in'its remand order nullify 10 CFR S 2.749'which permits the presiding officer y

'to dispose 'of all'or any part of the issues on the pleadings. A litigant does not get to the trial stage unless he can withstand a motion for summary disposition by presenting affidavits or other indication that there is a material issue of fact. Here there is no 'I such issue, for the reasons recited below.

1 A.- The firemen poll is similar to, though less rele-vant than, the bus driver survey that the Board j already considered

.l The first reason why the admission of the firemen poll does not change the out-come of the case is that the firemen pollis repetitive of the school bus driver poll that the Board did consider in reaching its decision.

The school bus drivers were surveyed on September 7.1982. Interviews were taken of 246 drivers employed by the Riverhead Central School District and two bus companies. Of those interviewed,69 percent said that they would first make sure that l l

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their families were safely out of the evacuation zone, four percent volunteered that they would first check on their families and then report to work,24 percent said that they would report directly for work, and three percent said that they would immediate-ly leave the evacuation zone. Cole, ff. Tr.1216, at 7.

This survey was duly considered by the Board. But the Board concluded that the bus driver survey did not show that there would be a significant abandonment of jobs during an emergency:

The Board finds that the actual' behavior of any particular bus driver during an emergency would be influenced by the specific conditions existing at that time. Thus, the school bus driver survey cannot predict what drivers will do at the time of an accident. I_d. at 8-9; Cordaro et al. ff. Tr. 831, at

35. People behave differently in an unfamiliar situation from the way they say they will when speculating about their future behavior. Tr.1085 (Mileti). The Board agrees with Dr. M11eti's conclusion that opinion polls are very poor predictors of behavior in an emergency. Tr.1166 (Mileti).

See also Board Finding I.A. Even if we assume the survey has some predictive value, it does not suggest a massive de-fection of drivers because only 3% said they would immedi-ately leave the evacuation zone. Cordaro et al., ff. Tr. 831, at 34-35. ,

PID at 676.

The firemen poll showed the same thing as the bus driver poll. See Cole, ff. Tr.

1216, at 10-11,13-14. For the firemen poll,291 volunteer firemen from volunteer fire departments were surveyed by phone on September 28 and 30 and October 2,1982. Of {

l those surveyed, 68 percent .said they would first make sure their families were safely j .

out of the evacuation zone, 21 percent said they would first report to the fire station for work, one percent said they would leave the evacuation zone seven percent said ) i they would do something else, and four percent said they did not know. Of the 68 per-cent that said they would first make sure their f amilies were safely out of the EPZ,51 l i

percent said they would call home and tell the f amily to leave the evacuation zone by I

themselves,32 percent said they would personally drive their family away,12 percent said they would protect their family in some other way, and five percent did not know.2/ From these data the Interveners' witnesses concluded that 55 percent of the firemen believed they would report "relatively quickly" to work,36 percent would look af ter the safety of themselves and their family first, and eight percent did not know. .

Id. at 14. .

In short, the firemen survey adds no useful information to the bus driver survey.

Set out in summary fashion, the results of the two polls are as follows:

1 Say They Say They Number Would Make Say They Would '

of Sure Their Would _ Immediately People Families were Report Leave the Evac- 3 Poll Surveyed Safe First To Work uation Zone Other Bus Drivers 246 69 % 24% 3% 4%

Firemen 291 68% 21% 1% 10 %

The results of the two polls are quite consistent. Leaving aside the issue whether the polls are methodologically flawed (and LILCO maintains that they are),3/ the two polls show a similarity in what groups thought they would do if a hypothetical emergency should happen. However, as the Board explicitly found, " opinion polls are very poor predictors of behavior in an emergency." PID at 676. The reasoning applied to the bus driver poll applies a fortiori to the firemen poll: "Even if we assume the survey has 2/ School bus drivers who responded that they would first make sure their families were safely out of the EPZ were not asked this follow-up question (how would they make sure their f amilies were safe) that was asked in the firemen poll.

3/ LILCO argued that there were significant methodological errors in the formula-tion and administering of the various polls. Because the firemen poll was excluded, LILCO's evidence on the methodological shortcomings was excluded also.

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some predictive.value, it does not suggest a massive defection of drivers because only (one percent of the firemen, as compared to three percent of the bus drivers] said they would immediately leave the evacuation zone." %

B. The firemen poll is enveloped by the Board's rea-soning. particularly as to the FEMA Testimony The second reason why admission of the firemen poll does not affect the out-come is that the reasoning of the Board's decision on school teachers and ambulance ,

drivers applies just as fully to bus drivers. This is particularly so with respect to the Board's and the Appeal Board's reliance on the FEMA testimony.

1. Schoolteachers The Board's finding that schoolteachers would not be significantly impacted by

" role conflict" is as follows:

The five school officials called as witnesses by Suffolk County testified that, in their opinions, a significant number of schoolteachers and administrative personnel would abandon such roles upon the announcement of the emergency,in favor of caring for their own f amilies. Petrilak, ff. Tr. 3087, at 4-5; ,

Muto et al., ff. Tr. 3087, at 4; Jeffers e_t al., ff. Tr. 3087, At-tach 1. The Board finds that this testimony is outweighed by 1 the FEMA testimony that the " history of disaster response has (

consistently shown that non-emergency workers, and particu- q larly teachers, also more than meet responsibilities when  ;

faced with emergency situations." McIntire, ff. Tr. 2086, at

5. The Board also accords greater weight to the testimony of Dr. Mileti that in the event of an actual radiological emergen- ,

cy, most schoolteachers would remain with their students l long enough to see them safely dismissed or safely onto school l buses. Mileti, ff. Tr. 831, at 36. Moreover, even if some l schoolteachers deserted their classes, there is no reason to believe that there would not be a sufficient number remaining to supervise students on evacuation buses or in shelters if those procedures were ordered. Cordaro and Weismantle, ff.

Tr. 831, at 36; Mileti, f f. Tr. 831, at 36; McIntire, ff. Tr. 2086, at 5. Even Dr. Erikson testified that teachers did not abandon their posts in the early stages of the TMI accident prior to any evacuation advisory. Tr. 1347-48 (Erikson).

PID at 677-78. The Appeal Board, in ALAB-832, agreed with the Licensing Board's conclusion on schoolteachers:

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z We conclude that, in the circumstances, the Licensing Board erred in excluding. the proffered . testimony of the teachers.D True, in some respects the teachers' testimony was cumulative to' that of the school-officials. But it provided perhaps a more authoritative indication'of the potential for '

role conflict among teachers than did that of the school offi-cials. Nevertheless, the Board's error was not prejudicial for, even considering. the: additional views of the teachers, the ,

outcome on the issue is not altered.

Whether the potential for teacher role conflict fatally-flaws the applicant's emergency response plan hinges upon whether such significant job abandonment might occur as to result in an insufficient number of teachers being available to supervise early dismissal, evacuation or sheltering activities.

The teachers' proffered testimony did not provide firm evi-dence on this question. While opining that some of their col-

. leagues would likely abandon their posts, the teachers did not discuss the' minimum number needed to allow for proper su-pervision of the students. For example, they did not address the possible placement of students in larger groups, which would reduce-the complement of teachers necessary for su-pervision. '

. 'In this. connection, neither the included nor the ex-  !

cluded testimony on teacher role conflict stood in the way of the Licensing Board's reliance upon. the ~ testimony of the

. Chief of FEMA's Natural and Technological Hazards Division.

He stated that, based on his 15 years of experience in emer- i gency operations, "(t]he history of disaster response had con- J

- sistently shown that . . . teachers . . . more than meet [their] l responsibilities when faced with emergency situations." This. l observation was supported by a school official who testified i that, in his experience, while some individual teachers were 1 affected.by role ' conflict, teachers as a group met their l responsibilities during emergencies. 'In sum, even if some job l abandonment were to occur (as the proffered testimony of the l

panel of teachers hypothesized), the totality of the evidence put before the Board precluded a finding that the remaining i teachers would be unable to provide adequate supervision of )

students during an emergency at Shoreham, i l

23 NRC at 151-52 (footnotes omitted).

l Thus, in deciding about schoolteachers, the Appeal Board relied heavily on the t-testimony of FEMA witness McIntire. Mr. McIntire also testified about bus drivers. He j 1

testified that training about radiation plus being equipped with personal dosimetry  ;

i helped bus drivers in the Indian Point plan mitigate their fears that they would be i i

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contaminated. McIntire, ff. Tr. 2086, at 5; Tr. 2142-43,2157-58 (McIntire).' Extra com-- i

. pensation also helped. Tr.'2143-44 (McIntire). As in the past, LILCO will cgain offer- ,

basic radiological training and dosimeters to school bus drivers and reimburse them for the time spent in such training. See Section III below; see also Cordaro e_t al., ff. Tr. }

'831, 'at 35; Tr. 960-61,1172 (Weismantle). Also, the bus companies that have con- ,

tracted with LILCO, some of which also provide buses to schools, have agreed to "emer- ' I gency preparedness training." See Cordaro et al., Tr. 4/6/84 Vol. II, Att.1-12. Finally, 1

the evidence shows that bus companies have extra drivers, Tr. 9315 (Robinson), and ,

1 that in some school districts, teachers and other school employees are qualified to drive y buses, Tr. 9315-16 (Cordaro).. Hence, every factor that went into the Appeal Board's decision on schoolteachers applies just as well to school bus drivers.

2. . Ambulance Drivers The Licensing Board also concluded that role conflict would not be a significant problem for ambulance drivers:

LILCO has entered into agreements with ambulance compa-

. nies to provide ambulances with drivers in the event of a ra-diological emergency at Shoreham. The ambulance drivers will receive radiation training; be reimbursed for their time spent during training, drills, and an actual emergency; and be l provided with dosimeters. Cordaro and Weismantle, ff. Tr.  !

831, at 37. Dr. Harris' opinion that ambulance drivers will choose to avoid the risk to themselves and their families and not report to assist with protective actions (Harris, ff. Tr. l 1218, at 14-15) is outweighed by the historical response of such drivers as testified to by FEMA (McIntire, ff. Tr. 2086, at

5) and by the failure of Dr. Harris to document any such role abandonment by ambulance drivers in any prior emergency.

Moreover, Dr. Sorensen's testimony that role abandonment has not occurred in disasters that have been studied was uncontroverted. Tr.1135 (Sorensent PID at 678. The Appeal Board found no f ault with this reasoning. As with school-teachers, the reasoning applies to bus drivers as well as to ambulance drivers. First, there is no documented evidence of actual role abandonment by actual school bus j i

' l l drivers. Apparently the school administrators who testified for Suffolk County had I never encountered bus drivers who had abandoned school children. See Tr. 3167 l (Smith), 3130, 3133, 3168 (Rossi), 3138, 3169, 3185-86 (Jeffers). The only fact they j could offer in support of their theory was an example of a single bus driver who had tended her own child first af ter an accident.M Tr. 3166 (Smith). They did not say whether the child who was tended first had more serious injuries than the others or in- 4 1

deed whether the other children needed tending at all. In any event, this was not an ]

example of role abandonment because the bus driver's role was to tend the children on j I

the bus, one of which was her own. I l

l C. Opinion polls do not predict actual emergency behavior j I

Finally, the Board explicitly found, as noted above, that "the school bus driver survey cannot predict what drivers will do at the time of an accident." PID at 676. j l

The Board agreed with Dr. Mileti's conclusion "that opinion polls are very poor predic-tors of behavior in an emergency." Id. This conclusion obviously applies at least as strongly to an opinion poll taken of people, like the volunteer firemen, who are not even a part of the emergency plan.  ;

The Board's conclusion about opinion polls is solidly based in the record. The overwhelming weight of the evidence in this proceeding was that people's behavior in l an emergency is determined by situational f actors and cannot be predicted years in ad-vance by an opinion poll posing a hypothetical situation devoid of details. Even the In-tervenors' witnesses were forced to concede the importance of situational factors. As LILCO has maintained since the beginning of this proceeding, opinion polls have little 4/ Other attempts to come up with a concrete example were also unsuccessful. See Tr. 3133 (Rossi) (bus drivers refused to pick up children because roads were too bad),

3168 (Rossi) (drivers report in sick on snowy days and sometimes miss work or have to leave because of family problems),3169 (Jef fers)(absenteeism in bad weather).

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i use in emergency planning and ought not to be relied on here. There is simply no basis in the evidentiary record for concluding that school bus drivers alone, unlike school i

teachers, utility company employees, ambulance drivers, and the other people covered by Contention 25, would abandon their jobs. 3 l

III. LILCO's Commitment to Train Additional Bus Drivers Provides Reasonable Assurance (

In addition to the above argument, based on the existing record, LILCO bases this motion on its commitment to remove any lingering doubts about the availability of school bus drivers by (1) offering to work with the school districts to train, equip, and reimburse the existing school bus drivers and (2) recruiting additional auxiliary bus driv-ers to meet the required number of drivers to accomplish a one-wave evacuatica and to serve as back.ups in the unlikely event that some of the ragular schoot.hus drivers do not show up in a real emergency. This interim measure is described below. l A. 562 school bus drivers are needed to evacuate all public school children in a sjngit! wave LILCO estimates that about 562 school bus drivers would be requireb to evacuate all public school children from ths EPZ in a single wave.N To arrive at this estimate LILCO conducted a telephone survey during July 1987 of all school districts located within the ten-mile EPZ concerning the current school enrollment of rach school. I

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Data for Mount Sinal School District were updated in October 1987. A .opy of the 5/ The transportation requirements for handicapped, parochial, and nursery schools, jointly referred to by LILCO as " private" schools, have not been figured into this number, but rather the students f rom these schools are treated separately in the LILCO Plan as special populations. See OPIP 3.6.555.10 and Att. 3. LERO has been working with most of the private schools to establish emergency evacuaticn plans for I those schools. For the remaining schools not participating in preplanning LERO would f dispatch buses as needed to pick up students at the time 01 an emergenav according to the procedures set forth in OPIP 3.6.5. See Cordaro et al., ff. Tr. 9154. Vol. II, at 52.

LERO transportation, using LERO bus drivers, has already been desiganed tor special l populations, a

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! results of 'at survey is Attachment 1 to this motion. The total number of students en-rolled at these schools is 27,179.

New York State law permits 60 students seated and 12 students standing in a I standard school bus and 66 students seated and 12 students standing in a larger school ,

bus. For planning purposes, however, LILCO used 50 students per school bus EI in the e interest of conservatism to determine the number of bus drivers needed. In addition, schools were assumed got to share buses, and an extra bus was added to that school's re-quirement if there were fewer than 50 students remaining to be transported. In addi-tion, ten extra persons were added into this calculation to account for the bus drivers needed to drive vans for the handicapped. Based upon these assumptions, LILCO com-puted that altogether an estimated 562 bus drivers would be needed to complete a single-wave evacuation.2I A listing of the number of bus drivers needed per school can

,< be found at Attachment 2.

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B. LILCO believes that the regular school bus drivers would do their job in an emergency Of this number, the school districts already have on payroll or under contract at j

, least 340 bus drivers.EI LILCO made this determination by talking with each bus com- ,

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panyi where possible, and +.o other people having access to this information to discover i

f/ Earlier in this proceeding, LILCO testified that their estimates were based upon  !

40 passengers per tes for high school students and 60 passsengers per bus for elementa-ry and middle schoci students. Cordaro et al., ff. Tr. 9154, Vol. II, at 55. By using 50 '

students per bus LILCO has simplified the calculation. Since New York State permits more students per bus than LILCO assumed in its calculation, there should be no prob-lem with its estimares being too low. i 7/ Unlike LILCO's earlier estimaios in this proceeding, this number is more conser-vative because it does not reflect a reduction f or daily absences, split sessions, for stu-dents who drive thethselves to school, or for students who would leave with other students in their cars. See Cordaro et al., ff. Tr. 9154, Vol. II, at 55.

8/ , This number includes the two LERO drivers already designated to drive school burns for the Little Flower School District during an emergency at Shoreham.

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l how mary bus drivers each company has on e tNet to each school within the EPZ.

The resuNs of this survey can be found at Attachment 2.

l LILdd expects that these drivers would do their jobs in a radiological emergency because it is their ordinary job to (Hve children in school buses,N because they have i c f amiliarity with this job, and because LILCO wfD,0ffe/ these drivers, through the school districts, training and dosimetry as is commonly done in other emergency evacuation plans. As the record in this proceeding shopJ, " role conflict" db not prove a prc'clem if the people have a clear idea of their emergency roles. Cordaro et al., ff. Tr. 831, at 63,65, 67, 71; Tr. 924 (Mileti). One means of instilling this understanding of their roles

(" role dbfinition") is through training. Cordaro et al., ff. Tr. 831, at 30-33, 67, 97-98; Tr. 9N,1110,1146 (Mileti); Tr. 939 (Sorensen); see also Affriavit of Diane P. Dreikorn, I >

Att. 3. 'In this case, LILCO has provided and cohtinues to offer training to school bus drivers:through the school districts. Cordsro et al., ff. Tr. 831. at 35; Tr. 935-39 (Sorensen, Weismantle), 961 (Weismantle); Cordv o nt al., ff. Tr. 9154, Vol. II, at 60; see  ;

Affidavit of Douglas M. Crocker, Att. 4. In its present proposal, LILCO commits to provide the regular school bus c1ivers, through the school districts, with the same training that the auxiliary bus drivers would ieceive, and with bonuses and relm-bursement for time spent participating in the training program. See Section C below.

b LILCO will offer direct, reading dosimeters (DRD's) and training in how to use them to all school bus drivers;l 9 well. i  !

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9/ It will be argued that driving children in a radiological emergency is not an ordi-nary pb, but the requirements of the jo') - that is, driving a bus - are the same wheth-er in an emergency or in ordinary times. Furthermore, part of a school bus driver's job requirement is driving a school bus in otner emergency situations such as hurricanes, snow storms, e_tc. that require early dismissal from school.

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Since the number of bus drivers already employed or contracted to the schools is not'suffic}ent to fill the ranks of the 562 bus drivers needed to evacuate the entire pub-

~1 ic school population in a single wave, LILCO will provide the additional school bus

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' drivers from the pool of auxiliary bus drivers discussed below.

C. LILCO will recruit and train additional school bus drivers LIL'CO commits to recruit,. train, and have licensed 562 additional' school bus driveis - the total number of drivers needed to evacuate all public school children in a single wave.N Thus, there will be an additional auxiliary school bus driver for every regula[ bus" driver l'n addition' to the extra drivers needed to complete a single-wave c l evacuation.jTo fill the ranks, LILCO will recruit its own employees.

Euch person agreeing to become an auxiliary school bus driver will be required to sat.afy the following requirements:

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• 1. Live on Long Island.

2. Sign a participation form.

3. Have a vehicle that could be used in training sessions, drills, and an actual

. - ' " emergency.

4. Maintain a telephone so that he or she can be contacted for training ses-sions, drills, or an actual emergency.

?

5. Attend school bus driver training classes for a Class 2 license, if he or she does not already have a license, and successfully complete the driving test which would be a prerequisite to continuation in the program.

y .

Attend four hours of classroom training concerning emergency planning

-y .6.

and the Shoreham Nuclear Power Plant, The four' hours of classroom training would provide information on the Shoreham

_10/ Recently, LILCO conducted a general recruitment drive that resulted in approxi-

, mately 550 LILCO employees signing up to be LERO workers. It is projected that about 400 of these recruits will be designated as auxiliary school bus drivers. However, the roster of new LERO recruits first must be reviewed to see if the new people meet the (j' e requirements for a school bus driver. See Affidavit of Douglas M. Crocker. Att. 4.

I h <

Nuclear Power Station, the effects of radiation, emergency planning, the LERO Family.

Tracking System, and the requirements of a school bus driver during an emergency. -

The training would also focus on how each participant's position is interrelated with L

I and dependent on other emergency functions. The importance of teamwork and how it  !

works during other emergencies at LILCO and among _different types of emergency l workers such as firemen, police, hospital attendants, ele. would be explained. .This training class would also be offered to the regular school bus drivers through the school districts. According to LERO training instructors, training has a positive effect on workers' attitudes about their emergency roles. See Affidavit of Diane P. Dreikorn, A t t. 3.

All individuals, including regular school bus drivers, who agree to drive a school bus during an emergency at Shoreham can participate in the LERO Family Tracking ]

j l' System. Thus, family members would be able to leave messages with the LERO )

l tracking system for family members driving buses. j Each non-LILCO participant would receive $10.00 per hour for attending four hours of general trainingN nda Class 2 license training would be provided. Bonus checks would be distributed to all participants at the end of the one-year period upon satisfaction of all the requirements for that period. According to FEMA witness McIntire, compensating bus drivers for performing emergency services was a factor in resolving role conflict at Indian Point. Tr. 2144 (McIntire).

There is ample precedent for relying on utility personnel as bus drivers in an emergency. Utility bus drivers were made available as backups at Indian Point. Tr.

2158 (McIntire). Moreover, they were the solution to a similar issue at the Limerick plant. Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2),

i LBP-86-32,24 NRC 459 (1986).

l

,11/ LILCO employees would receive their regular hourly wages plus overtime pay where appropriate.

1 I-I Accordingly, LILCO hereby commits to undertake the recruitment, training, and l 1

l bonus program for both the regular school bus drivers who wish to participate and the additional auxiliary school bus drivers that LILCO will recruit so as to be able to ensure

- a pool of at least 562 school bus drivers willing to drive in a radiological emergency.

D. LERO will preassign school bus drivers In a radiological emergency all 562 auxiliary school bus drivers would be mobi-lized to assure that a sufficient number of drivers were on hand at each bus company to l fillin for any regular driver who did not report for work and to supply the extra driv- )

ers needed to accomplish a one-wave evacuation. Auxiliary bus drivers who serve as l backups to regular school bus drivers would be preassigned a bus yard to report to in the event of an emergency at Shoreham and would be provided maps to their destinations as part of their training. The additional auxiliary school bus drivers needed to effectu- i ate a single-wave evacuation would be assigned to drive one of the additional buses needed for the evacuation. LILCO will make arrangements for these additional buses.MI Direct reading dosimeters and written instructions on how to use them would be provided to the bus drivers at each bus yard.

t

)

l M/ LILCO does not address here whether there is a sufficient number of buses to l l complete a single-wave evacuation of the schools within the EPZ because that issue l was not part of the Appeal Board's remand. In accordance with this Board's decision in f its partial initial decision, PID at 874. LILCO is making arrar.gements to secure an ade- I quate number of buses to accomplish a single-wave evacuation.

l

IV. Conclusion and Reauest for Relief l I

In conclusion, for the reasons cited above, LILCO hereby asks for summary dis-position of the school bus driver availability issue remanded in ALAB-332 and asks the Board to authorize the issuance of a full power operating. license, conditioned on the )

i successful demonstration to the NRC Staff that 562 bus drivers are available to drive in a radiological emergency. 1 Respectfully submitted, I

W GAAA JaRes N tmff MarfJo gets

..Hunton & Williams P.O. Box 1535 Richmond, VA 23212 DATED: October 22,1987 l

i STATEMENTS OF THE MATERIAL FACTS AS TO WHICH LILCO CONTENDS THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION 25.C (" ROLE CONFLICT" OF SCHOOL BUS DRIVERS)

The following are the material facts ~as to which LILCO contends there is no genuine issue to be heard under Contention 25.C:

1. A telephone survey of all school districts located within the ten-mile EPZ conducted in July 1987 and updated for Mount Sinal School District in October 1987 shows that the school enrollment for the present year for these schools is 27,179.

2. Handicapped, parochial, and nursery schoolchildren would receive LERO transportation during an emergency according to the procedures set forth in OPIP 3.6.5.

Transportation has already been designated for these populations.

3. According to the breakdown of students per school, a total of 562 school bus drivers would be needed to evacuate all of the schools within the EPZ in a single wave. This figure is based upon 50 students per bus with no schools sharing buses and includes ten additional bus drivers to drive buses for the handicapped.

4 .' The school districts within the ten-mile EPZ already have at least 340 bus drivers on payroll or under contract.

I

5. This number includes the two LERO bus drivers already designated to pro- )

l vide transportation during an emergency at Shoreham for the Little Flower School Dis- i trict. ,

l

6. One of the job requirements of a regular school bus driver is to drive a j school bus in other emergency situations such as hurricanes, snow storms, e_tc. that re- I quire early dismissal f rom school.

7. LILCO has committed to recruit 562 additional auxiliary school bus drivers l

to fill the ranks of the 562 bus drivers needed to provide backups for any regular school j bus drivers who may not report for work during an emergency and to evacuate the en-tire public school population in a single wave.

l i

n  ;

l

8. LILCO will' recruit their own employees to be school bus drivers.

9. LILCO recently conducted a general recruitment drive that resulted in..

approximately 550 LILCO employees signing up to be LERO workers. LILCO projects that about 400 of these recruits will be designated as auxiliary school bus drivers. f 10.- LILCO employees who agtbe to become auxiliary school bus drivers will be required to satisfy the following requirements:  ;

.i

a. ' Live on Long Island.

b. Sign a participation form.

c. Have a vehicle that .could be used in training sessions, drills, and  !

during an actual emergency.

d. Maintain a telephone so that they could be contacted for training sessions, drills, or an actual emergency. ,

e. Attend school bus driver training classes for a Class 2 license, if they do not already have a license, and successfully complete the driving test which would be a prerequisite to continuation in the program.

1

f. Attend four hours of classroom training concerning emergency j planning and the Shoreham Nuclear Power Plant.

11. LILCO has committed to provide training and bonuses to each of the 562 ]

auxiliary school bus drivers. l

12. The training for school bus drivers would include a four-hour class about .

I the Shoreham Nuclear Power Station, the effects of radiation, emergency planning, the LERO Family Tracking System, and the requirements of a school bus driver during an 1 emergency.

13. LILCO employees who agree to become auxiliary school bus drivers would receive their regular hourly wages for training and drills plus overtime pay where ap- l l

propriate. l l

14. LILCO has committed to offer the regular school bus drivers, through the school districts, the same training as the auxiliary school bus drivers would receive.

l

___o

4; c4-

)

l

15. Each regular bus driver who participates in the school bus driver program -

will be reimbursed for time spent in training and will receive a bonus at the end of the 1

one-year period upon satisfaction of all the requirements for that period. .j i

16. .Each regular school. bus driver who agrees to participate in LERO's J training program and each auxiliary school bus driver would be provided with direct reading dosimeters (DRD's) and would be trained in how to use them.

17. All auxiliary school bus drivers and any regular school bus driver who par-ticipates in LILCO's training program can participate in the LERO Family Tracking

. System.

18. All of the auxiliary school bus drivers would be fully mobilized.

'19. Auxiliary school bus drivers who serve as backups to the regular bus driv-ers would be preassigned a bus yard to report to 'in the event of an emergency at Shoreham and would be provided maps to their destinations as part of their training.

20. The additional auxiliary school bus drivers needed to effectuate a single .

wave evacuation would be' assigned to drive one of the additional buses needed for the- 'i evacuation. LILCO will make arrangements for these additional buses.

21. Direct reading dosimeters (DRD's) and written instructions on how to use them will be distributed at the bus yards to all school bus drivets participating in the school bus driver program.

I-(

g7 ci Attichment 1  !

I 1

Student Enrollment for Schools within the 10-Mile EPZ South Manor Union Free School District ,

South Street School- 500 Dayton Avenue School 425 total 925 Riverhead Central School District Riley Avenue Elementary School 331 Pulaski Street Elementary School 544 Riverhead Junior High School 755 Riverhead'High School 1,019 ,i total 2,649' Shoreham-Wading River Central School District Briarcliff Road School 170 ,

Miller Avenue School 274 Shoreham-Wading River Middle School 498 l Shoreham-Wading River High School -788 ,

Wading River School 386 l total 2,116 i

Little Flower Union. Free School District  :

1 Little Flower Elementary School 80. )

total 80 q l

1 Patchogue-Medford Union Free School District Eagle Elementary School 814 total 814 l

1 Rocky Point Union Free School District i l

Joseph A. Edgar School 550 Rocky Point Junior-Senior High School 1,200 l

Rocky Point Elementary School 900 l total 2,650 l

l

l Miller Place Union Free School District North Country Road School- 425  !

-Andrew Muller Primary School 786 Sound Beach School 600 Miller Place High School 807 total 2,618 i

.Longwood Central School District Charles E. Walters Elementary School 1,042 Longwood High School 1,879  ;

Ridge Elementary School 1,275 l West Middle Island Elementary School 806 Coram Elementary School 991 Longwood Junior High School / Middle School 2,680 total 8,673 Mt. Sinal Vnion Free School District Mt. Sinai Elementary-Junior High School 960 Mt. Sinal Elementary School 783 total 1,814 Port Jefferson Union Free

• School District Port Jefferson Junior High School 289 Port Jefferson Elementary School ,

563 Earl L. Vandermeulen High School 1j 150 total 2,002 Comsewogue Union Free School District Clinton Avenue Elementary School 492 Comsewogue Senior High School 1,355 Terryville Elementary School 402 J.F. Kennedy Jr. High School 589 total 2,838 Total Enrollment 27,179 l

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Attachment 3 LILCO, October 21, 1987 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-3

)(Emergency Planning)

(Shoreham Nuclear Power )

Station, Unit 1) )

AFFIDAVIT OF DIANE P. DREIKORN Diane P. Dreikorn, being duly sworn, deposes er'd says as follows:

1. I am employed by Long Island Lighting Company ("LILC0")

as-Senior Emergency Planner. My professional resume was introduced into the record in this proceeding at Tr. 17,421 as part of LILCO Exhibit 1. I have personal knowledge of the facts recited in this affidavit because I have helped supervise or been involved in LILCO's emergency preparedness effort for Shoreham Nuclear Power Station since September 1985.

2. These activities have included assisting in the development and maintenance of the offsite emergency preparedness program for Shoreham, consulting about and conducting emergency plan training on health physics-related topics with members of the Local Emergency Response Organization (LERO), and performing as an observer / controller for drills and an exercise of the emergency plan and procedures.

i

_ _ _ _ _ _ _ _ _ - _ _ - _ . J

i q

3. As one of LER0's main training instructors, it has been my experience that training itself has a positive effect on the i

attitudes of LERO workers about their roles as emergency workers, i i

Specifically, concerns about the risks associated with potential f

radiological exposure are alleviated when Shoreham, nuclear power, I

the effects of radiation, the LILCO Plan, and the question these topics generate are discussed. Also, their concerns about their own children (if they live within the ten-mile EPZ) typically become more manageable once they learn about how the emergency plan would I work to protect their children. In addition, the availability of the LERO Family Tracking System works to reduce their uncertainty about the status of family members during any postulated emergency.

4. Furthermore, during discussions about this matter with other training instructors, including those who train bus drivers, I have discovered a general agreement about the beneficial effect of training on emergency workers' concerns for the health of )

themselves and their families and on parental role strain, j The foregoing facts are known by me to be true, of my own knowledge. I am competent to testify to such facts, and would so j I

testify if I were to appear as a witness in a public hearing on this matter.

P. h Diane P. Dreikorn

)

]1 Subscribed and sworn before me on b/ 67/ ,19b.

{ -

=7 0dinnen]

l c g/

l M C mmission expires f/ 8_' l l

JOAN M. WlG INS NOT AftY P U GUC St3

• ef New York l

Qual e n" CbMY commis sion bpires Sep te mber L S.19(./(/

b . '

Attachm@nt 4 - .J l

LILCO, October 20,1987 l 1 l I

UNITED STATES OF AMERICA .)

NUCLEAR REGULATORY COMMISSION j

'Before the Atomic Safety and Licensinst Board l In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 .,

) (Emergency Planning) l

- (Shoreham Nuclear Power Station, ) I i

Unit 1) )

AFFIDAVIT OF DOUGLAS M. CROCKER .

Douglas M. Crocker, being duly sworn, deposes and says as follows:

1

1. I am employed by Long Island- Lighting Company ("LILCO") as Nuclear Emergency Preparedness Manager with the Nuclear Operations Support Department.

My professional resume was introduced into the record in this proceeding at Tr.17,421 l as part of LILCO Exhibit 1. I have personal knowledge of the facts recited in this affi-

- davit because I have supervised or been involved in LILCO's emergency preparedness <

effort for Shoreham Nuclear Power Station since June 1984.

2. These activities have included developing and maintaining facilities, plans, )

1 procedures, training, and drill programs to meet federal requirements for a Shoreham 1 1

offsite emergency response. I have also participated as an observer / controller for drills I

and an exercise of the emergency plan and procedures. 1 1

3.- A telephone survey of all school districts located within the ten-mile EPZ 1

conducted in July 1987 and updated for Mount Sinal School District in October 1987

( shows that the projected school enrollment for the present year is 27,179.

I

> l l 1

_.i_._____._..____ _ _ _ . _ _ _ _ . ._..

4. According to the breakdown of students per school, a total of 562 school

' bus drivers would be needed to evacuate all of the schools within the EPZ in a single wave. This figure is based upon 50 students per bus with no schools sharing buses and

' includes ten additional bus drivers to drive buses for the handicapped.

5. . Children attending handicapped, parochial, and nursery schools, referred to i jointly as " private" schools, would receive separate LERO transportation during an emergency according to the procedures set forth in OPIP 3.6.5. Transportation has al-1 ready been designated for these populations.

6. There are at least 340 bus drivers on payroll or under contract to the school districts for the schools within the ten-miles EPZ. This number includes the two LERO bus drivers already designated to provide transportation for the students at the Little Flower School District.

7. One of the job requirements of a regular school bus driver is to drive his or i

her school bus in other emergency situations such as hurricanes, snow storms, ey. that require early dismissal from school.

8. LILCO commits to recruit 562 additional school bus drivers to fill the ranks of the 562 bus drivers needed to provide backups for any regular school bus drivers who may not report for work during an emergency at Shoreham and to evacuate the entire public school population in a single wave.

LILCO will recruit their own employees to be auxiliary school bus drivers. f 9.

10. LILCO recently conducted a general recruitment drive among its employ-ees that resulted in approximately 550 individuals signing up to be LERO workers.  ;

i LILCO projects that about 400 of these recruits will be designated as auxiliary school j l

j bus drivers. . j

. 1 I 11. LILCO employees who agree to be auxiliary school bus drivers will be re- )

{

L quired to satisfy the following requirements:

l

)

)

w- --

4 a .w 4 P i

(_, E l 1

/

[ l l

l a. Live on Long Island.

l

b. Sign a participation form.

c.- Have a vehicle that could be used in training sessions, drills, and dur-

'ing an actual emergency.

d. Maintain a telephone so that they could be contacted for training sessions, drills, or an actual emergency.

e. Attend school bus driver training classes for a Class 2 license, if they do not already have a license, and successfully complete the

, driving test which would be a prerequisite to continuation in the.

program.

f. Attend four hours of classroom training concerning emergency plan-ning and the Shoreham Nuclear Power Plant.

12. Each of the 562 auxiliary school bus drivers would be provided training and bonuses for participation in the school bus driver program.

13. Training for school bus drivers will include a four-hour class about the

'Shoreham Nuclear Power Station, the effects of radiation, emergency planning, the )

LERO Family Tracking System, and the requirements of a school bus driver during an emergency.

14. LILCO has committed to offer the regular school bus drivers, through the school districts, the same training as the auxiliary bus drivers would receive.

15. . Each regular school bus driver who participates in the school bus driver program will be reimbursed for time spent in training and will receive a bonus at the end of the one-year period upon satisfaction of all of the requirements for that period.

16. LILCO employees who agree to become auxiliary school bus drivers would receive their regular hourly wages for training and drills plus overtime pay where ap-propriate.

17. Each regular school bus driver who participates in LERO's training program and each auxiliary school bus driver would be provided with direct reading dosimeters (DRD's) and will be trained in how to use them.

1

, .pd l 1

i

18. All auxiliary school bus drivers and any regular school bus. driver who par- {

l ticipates in LILCO's training program can participate in the LERO Family Tracking System. - I 19.- All of the auxiliary school bus drivers would be fully mobilized.

20. Auxiliary school bus drivers who serve as backups to regular school bus 1

drivers would be preassigned a bus yard to report to in the event of an emergency at j

. Shoreham and would be provided maps to their destinations as part of their training.

I

21. The additional auxiliary school bus drivers needed to effectuate a single- l l

wave evacuation will be assigned to drive one of the additional buses needed for the evacuation. LILCO will make arrangements for these additional buses.

22. Direct reading dosimeters (DRD's) and written instructions on how to use them will be distributed at each bus yard to all school bus drivers participating in the  ;

school bus driver program.

The foregoing facts are known by me to be true, of my own knowledge. I am competent to testify to such f acts, and would so testify if I appeared as a witness in a public hearing on this matter.

~

Douglas M. Crocker

-Subscribed and sworn to before me on do ,19@.

I h 4 Notar

[0AN f INS worayegi.sgorn.,v...

e.-.?"'lt;ll";;;; :,""a. Af My commission expires _,

I I

J

I . i 4 f-.. i

' LILCO, October 22,1987 I L 00LXE T,ED USNH(.

l:

r i

CERTIFICATE OF SERVICE I EI 26 AS $1 OFFICE OF Shh %

00CMETING A SERVICT~

In the Matter of BRANCH LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) i l; Docket No. 50-322-OL-3 I hereby certify that' copies of LILCO'S MOTION FOR

SUMMARY

DISPOSITION

' OF CONTENTION 25.C (" ROLE CONFLICT" OF SCHOOL BUS DRIVERS) were served this date upon the following by telecopier as indicated by one asterisk, by Federal Ex- i press as indicated by two asterisks, or by first-class mail, postage prepaid. l l

1

'Morton B. Margulies, Chairman ** Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel i Board .

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 t East-West Towers, Rm. 407 i 4350 East-West Hwy. Atomic Safety and Licensing j '

Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline ** Washington, D.C. 20555 ,

Atomic Safety and Licensing i Board. Richard G. Bachmann, Esq. ** i U.S. Nuclear Regulatory Commission George E. Johnson, Esq. 1 East-West Towers, Rm. 427 U.S. Nuclear Regulatory Commission  !

4350 East-West Hwy. 7735 Old Georgetown Road Bethesda, MD 20814 (to mailroom)

Bethesda, MD 20814 Mr. Frederick J. Shon **

Atomic Safety and Licensin'g Herbert H. Brown, Esq. ** i Board Lawrence Coe Lanpher, Esq.

U.S. Nuclear Regulatory Commission Karla J. Letsche, Esq.

East-West Towers, Rm. 430 Kirkpatrick & Lockhart 4350 East-West Hwy. South Lobby - 9th Floor Bethesda, MD 20814 1800 M Street, N.W.  !

Washington, D.C. 20036-5891  ;

=. Secretary of the Commission l

Attention Docketing and Service Fabian G. Palomino, Esq. ** (

Section Richard J. Zahnleuter, Esq. J U.S. Nuclear Regulatory Commission Special Counsel to the Governor 1717 H Street, N.W. Executive Chamber j Washington, D.C. 20555 Room 229 i State Capitol {

Albany, New York 12224  !

o ,

.. - 'g -

p Mary Gundrum, Esq. . Jonathan D. Feinberg, Esq. )

i Assistant Attorney General New York State Department of 120 Broadway .

Public Service, Staff Counsel Third Floor, Room 3-116. Three Rockefeller Plaza- .l New York, New York 10271.

Albany, New York 12223 l Spence W. Perry,'Esq. ** - Ms. Nora Bredes William R. Cumming, Esq. Executive Coordinator

' Federal Emergency Management

~

Shoreham Opponents' Coalition .

Agency 195 East Main Street 500 C Street, S.W.', Room 840 Smithtown, New York 11787

, Washington, D.C. 20472 - ,, 1 Gerald C. Crotty, Esq.

Mr. Jay Dunkleberger .

Counsel to the Governor j New York State Energy Office Executive Chamber i Agency Building 2 State Capitol 1 Empire State Plaza . Albany, New York 12224 Albany, New York 12223 l l )

Martin Bradley Ashare, Esq. **

Stephen B. Latham, Esq. ** . . Eugene R. Kelly,' Esq.  ;

Twomey, Latham & Shea . Suffolk County. Attorney ,

, ~ 33 West Second Street H. Lee Dennison Building .

L P.O. Box 298 Veterans Memorial Highway -

i Riverhead, New York 11901 Hauppauge, New York 11787

Mr. Philip McIntire Dr. Monroe Schneider _l '

l Federal Emergency Management North Shore Committee f Agency P.O. Box 231 -

l 26 Federal Plaza Wading River, NY 11792 l New York, New York 10278 l l

l 1

2 lf/}n/gers 0/fth% /g Mar {Jo i 'Hunton & Williams l- 707 East Main Street l P.O. Box 1535 -

Richmond, Virginia 23212 DATED: October 22,1987 I

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