ML20214G832

Affidavit of CA Daverio in Support of Util Motion for Protective Order.Certificate of Svc Encl

ML20214G832
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/18/1986
From:	Daverio C LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20214G780	List: ML20214G777 ML20214G813 ML20214G832
References
OL-5, NUDOCS 8611260199
Download: ML20214G832 (19)

Text

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LILCO, Novembsr 18, 1986 DOCKETED USNRC UNITED STATES OF AMERICA ,85 NW 24 P4 35 NUCLEAR REGULATORY COMMISSION GFFL Before the Atomic Safety and Licensina BodfdMi' , ,

/i i-m In the Matter of )

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

) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

AFFIDAVIT OF CHARLES A. DAVERIO IN SUPPORT OF LILCO'S MOTION FOR PROTECTIVE ORDER Charles A. Daverio, being duly sworn, deposes and says as follows:

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

as Assistant Department Manager, Nuclear Operations Support Department. My professional qualifications are bound into the record of this proceeding following Tab 6 at Tr. 4068. I have personal knowledge of the facts recited in this affidavit because I have supervised or been involved in LILCO's emergency prepared-ness effort for Shoreham Nuclear Power Station since January 1980.

2. Those activities have included oversight of the Local .

Emergency Response Organization (LERO) and negotiations with out-side organizations who assist LILCO in implementing its Emergency Plan (the Plan).

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3. Since 1982, controversy surrounding the operating license proceedings for Shoreham has created an increasingly hos-

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tile and bitter environment in which LERO workers and other indi-I viduals associated with outside organizations who assist in the j implementation of the Plan must work and live.

4. In addition to the governmental intervenors in this proceeding numerous Long Island private groups, including the Shoreham Opponents' Coalition for Safe Living, People's Action l Coalition, and Parents Opposed to Shoreham have opposed and con-tinue to oppose the licensing of Shoreham. Part of their opposi-tion efforts have included distribution of inaccurate and inflam-matory propaganda, and telephone and other contacts with outside organizations to coerce or otherwise induce them into severing all ties with LILCO.

5. State, County and local officials have also voiced strong opposition to the Shoreham plant and its emergency plan.

The opposition of Governor Mario Cuomo and Suffolk County Execu-tive Peter Cohalan is well known. They are parties to this pro-ceeding. Other local officials such as Hempstead Presiding Supervisor Thomas Gulotta have recently been quoted as opposing Shoreham's operation. (See attached articles from Newsday, "Hempstead Fights Use of LILCO Site in Shoreham Plan," dated November 15, 1986, and from the New York Times, " Town Fights LILCO Evacuation Center," dated November 15, 1986.

6. As a result of this virulent opposition to the Shoreham plant on the part of these citizen groups, politicians and

others, many organizations which once assisted in the imple-mentation of the Plan have withdrawn. (See attached articles from Newsday, "Hempstead Fights Use of LILCO Site in Shoreham Plan," dated November 15, 1986, and from the New York Times,

" Town Fights LILCO Evacuation Center," dated November 15, 1986.

7. The withdrawal of organizations from participation in the Plan has accelerated since the February 13, 1986 FEMA graded Exercise as detailed below.

8. In May and June of this year a local group called Par-ents Opposed to Shoreham Evacuation solicited signatures from Suffolk County school bus drivers to signify their agreement with the following statements:

"l) I will not participate in implementing any LILCO emergency plan for Shoreham, and

2) I cannot and will not agree to drive a school bus in the event of an accident at Shoreham."

A copy of this petition is attached to this affidavit.

9. Since the Exercise the Nassau Coliseum, which had

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served as the reception center for evacuees in case of a site emergency, was prohibited from participating in the Plan by a Nassau County ordinance dated June 16, 1986. A copy of the ordinance is attached to this affidavit.

10. Supervisor Thomas Gulotta's remarks on the Nassau County ordinance attest to the continuing nature of this hostile i political climate: "The resolution on the calendar today does J

l not preclude this Board (of Supervisors] from taking further

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steps with regard to this issue (whether Shoreham should receive an operating license] in the future." Enactment of this ordi-nance was actively political and supported by the Coalition for Safe Living. A copy of these remarks is attached.

11. By letter dated August 13, 1986, Alan S. Beck, Presi-dent and General Manager, WALK Radio, informed Ira Freilicher, Vice-President, LILCO, that WALK Radio had withdrawn from partic-ipation in the Plan. A copy of this letter is already in the record of this proceeding.

12. By letter dated September 2, 1986, Oak Hollow Nursing Home withdrew from further participation in the Plan until such time as Shoreham receives an operating license. A copy of that letter is attached to this affidavit.

13. A recent Newsday article, dated November 13, 1986 and attached to this affidavit, documents the efforts of a local group, Coalition for Safe Living (CSL), to induce outside organi-zations either to refuse to participate in the emergency plan or withdraw from participation. The article quotes a spokesman for the group, Jeffrey Newman, as taking credit for withdrawal of the Nassau County Coliseum and radio station WALK, and announces the group's intentions with respect to other organizations.

14. LILCO has verified by telephone survey that within the last three weeks various LERO contractors have been contacted by individuals soliciting the contractors' withdrawal from partici-pation in the Emergency Plan. These individuals have identified themselves as members of an unspecified " Nurses' Association" and

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unspecified " Teachers' Associations." One caller, self- )

identified as a member of the " Nursing Association," inaccurately 1

stated that another contractor had withdrawn from participation ,

l in the Plan and urged the recipient of the call to do the same, i

15. Faced with Suf folk County's refusal to participate in i

the Plan, the assistance of other organizations beyond LILCO and I the existence of LERO are critical to implementation of LILCO's Plan which protects the health and safety of Long Island resi-dents.

16. In my opinion, identifying by name individuals associ-ated with outside organizations who assist in the Plan is an un-necessary invasion of privacy which will result in further intim-idation of these individuals and the organizations with which they are associated. In the past identification has seriously impaired LILCO's ability to secure and retain the cooperation of such organizations in implementing its emergency plan. It requires LILCO'to expend enormous financial and staff resources to secure substitute organizations. These are resources which should be direc,ted to protection of public health and safety instead of to repairing the damage done to good working relation-

! ships by outside political pressure.

17. Recent events show that such harassment and intimida-tions has increased since the February 13, 1986 Exercise and will continue for the foreseeable future.

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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 testify if I appeared as a witness in a public hearing on this matter. / -~

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AW' Subscribed and sworn to before me on YMwb/8,1916 D Dr

[Si/gnature and tikle] W gwe , g p ys/4486

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KEUSPAPER Mu DATE l1 6 % PAGE__h *k U IIempstead Fights Use of LILCO Site In Shoreham Plan ByJohn Mcdonald - LIISD opon ===an William Sherrare I4aa Island Lighting Co.'s designation mid company omdals had not asen Oule6-ofit s Bellmore servios complex as a relo. ta's letter and could not comment on it.

cathn conter for evacuees in the event of Oyster Bay Supervisor Joseph Colby an accident at the 8boreham nuclear pow. sent a letter Nov. 3 to NRC chairman Lando Eoch erpressing concern about Supervisor Thoma;s Gulotta has told her plant is illegalrinse ble radiometive Hempstead water used in Presiding Nuclear baulatory Commlaston. e decontamination process' and the im.

In a letter asking the NRC to remove ' pact that water "would have on the the center kom the Shoreham emergency aquifer from which we receive out water

, plan, Gulotta said the designation of the supply." Marlene Kastleman, a kes-Bellmore center without town approval ' man for Colby, said the letter the violates local soning. He added that the NRC to furnish a copy of LIILO's latest facility is " wholly inadequate to respond l evacuation plan for the town to review. -

to the needs and insure the safety and Newman said that Colby's letter asking well being of thousands ofdesignated eva- for a copy of 6 LI140 plan, whieb is cuees, and the use of this site as proposed available in several local libraries on by LI140 could imperil the health and I.ong Island, troubles me. His whole poe-6afety ofthe residente of the densely popu. ture is one o* deferral? Newman aa!J to-lated surrounding areas." .

Continued on PageIl '

The letter sent earlier this week,is b . . . .

16 test netbac,k for LIISO in ite drive to  ; -Continued from Page 4 wia a commercial operating 11oense for the alltion representatives would attend the Oystar Bay auclear plant. LILCO designated the Bell. Town Board meeting on Tuesday to call ibr a stron.

more along wita its Roelyn ib. - 'ger stand against b use of LIILO's Hicksville cility and 11e headquarters, after headquarters as an evacuation center. "We will enll Naassu County withdrew permissian for , en b town board to esercise responsiblity and car.

LIILO to use the Nanaan Veterone Masso. ry out the mandate of h citianas ofOyster Bay?

rlalColiseumla Usloodale. On Wednesday Newman's group is to meet with LIISO also has lost its primary emer. Noath !.'ag.m Yown SupervisorJohn Kiernan to breedenst station, and the Nessau diaeues the use af LII40'e la semple in the of the Red Crees has plan. Kieraan le on town " information tha it is unable to provide Ancili re- said, quired -

Mean the plan. Ouwta who is also actively a stock was among the most leader of the Nassau County onWallStmetyesterday withnear.

Board E ' Iy 1.4 million shares, or more than one pe,rcent of the the withdra;wal ofcounty support for thei.e.s.wasiastrumentalin y's comunon stock, changiar hands. Heavy Alhomham emnergency plan. he state and of on'1%uraday and yesterday Soested h prio.

Suffolk County have refused to partid. O atock bom 811.26 to 812.25 a share. Ex.

pate la emergency plannlag ihr Shoreham pata in h anancial community were at a loss to since 1983. explain the heavy trad nr. LI140 ofEcials said they Nassau County's withdrawal frem b ~ knew~-of no reason for it.--

emergency plan came after a lobbying ef.

fort by b Coalf tion for Safe Living, a bl.

cuanty gr tarday, appeared to contain no surprise.

Newman,oup opposed to the plant. Jeffrey for b year ended Sept. 80 were down from S3.71 in

! a spokaaman for the group, said ht in recent weeks the group has been 1995was crease to pr83.21 thf a ear. LI140 omeials said the de.

talking to officials of Nassau's towna, ly due to increamad interest costa

• a. king hm to more closely amamine this and the uclusion of reimbursement on 81.4 biliton plan to bring 130 000 to 150,000 radioac. of Shoreham's cost as a result of a state Pubhc Ser-tive people and their vehiclee and dump vloe Cerranission finding that thert sw mismanap,-

,' snent in the construction orthe p! ant.

them in Nassau County. Thry are bring.

' ing Shoreham to Museu County. It Ja a master plan fordinnerr

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.G*SFAPER TownFightsilcoEvacuation Cen4:er

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By CLIFFORD D MAY Gulous.

' " " " * * " ' Jeff M. Newman, e's chairman of alRM'PsTRAD, L.I., Nov. H In te Idand Coombaaor Safe uv-the og 4, hh anti M 2l7.6. w.e'u,3'

- wa m 'a" her -

eat M.g_imilerty d.

r?= a,,v, ,,"d,e;;

d aa _e _e, u. _ u.,. .r. restrict the util

- to s as an scuouen Telegallaethe use etitsInndless as

" a use is not " said Gene evacuattert centers, Mr. Newmar. said, Turner, a spokesman Thomas J. Liles would have to obtain "sening Prookling Supervlect for the variane** and special permita" from Town Mempstead."We also ese auch the town governmenta.

a use as contrary to the health and "Ihe utility said it had not yet applied safety of the residents." r such variances and permits, anti Linco can obtain a commercial r.

sting Heense for its St6 blillon n er r. Newman contendal that was el-ther because they doubt their applica-

• I power nt only if an emergency tions would be approved or "because '

evacuat en is approved by the '

they still think they can get away with

' Federal Nu leer Regulatory Commis- it if the just keep rest quiet." The util-

elon.. itywo d not comment onhis charges.

That plan must include adequate fa- Mr. Newman said Linco plans to be-cilities for the evacuation and decon. gin bringing trailers to Bellmore in tamination of the more than 100.000 January for use in in a radiation emer- -

le living within 10 miles of Shore- gency. Mr. Sherrard the Lilco a plan es-which is on the north shore of man,said "traners are part of m, Island about 55 miles from New but no t' ming has been set."

.lY City.

Earlier. Lilco'had des'tsnated the Nassau Coliseum as its evacuation cen-ser. This summer, however, Nassau '

County's Board of supervisors voted to

. block Lilco from using the cotmty- .

owned conseum.

Lilce then designated three of its eum s asevacuation centers,includ-he maintenance conter h Sep-snore, an unincorperstad aves et IIemposeed, in a letter sent sa me Nuclear Rege.

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C as 1,l r ".". -gruie .7" FnoJ'a ed "l.a a .l m 5.

A man for the commissaan, Ciel Miles, said this afternoon that agency officials were studying the let-ter and had no comment yet.

A Lilco spokesman ~dilltem Sher-( rard, said the utility wouM "stylew the letter carefully." He adled. "We are Prepered tu discuss all ti,e details with the town " He decimed to answer ques-tions on the legal issues raised by Mr.

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' l' h.dpffl;O f. f E '; EDUCATION SAFETY q2 u p  ;

h *?_U ? _p; DRIVERS ASSOCIATION OF SUFFOLK, INC.

P.O. Box 103 Centereach, N.Y.11720 June 10, 1986 LERO---LILCO 1660 Walt Whitman Rd.

Melville, N.Y. 11747 Dear Joan Wiggins or  !

Charles DaVerio:

First, let me apologize for sending this letter at this lata date, but it was unavoidable. -

Enclosed you will find a copy of the questionnaire being circulated to bus yards around the Shoreham Nuclear Power Plant. This is being done by a group called Parents Opposed to Shoreham Evacuation (POSE).

POSE gave an emotional presentation at our May 1986 General Meetinc.

The Board of Directors believe Lilco ought to be given the opportunity to refute or confirm cote of the statements beir.g made by thic group, ca our me::.bers can make an intelligent choice if we are indeed acked to driva during an emergency evacuation. Let ce add, about 95f' of the 3chool Buc Drivers are signing this questionnaire and are "up-in-arms" against Lilco.

We suspend General' Meetings during the months of July and August. Our next scheduled meeting will be on Sept.3, 1986. However, the Board' meets every Monday night at the New Village necreation Center, located at the corner of Wireless and Hawkins Rds in Centereach at 7:30 p.m. If you would like to' attend or have.sany questions, call me at $16-732-9349 Yours truly, of& $dn Dianne Rechinda Vice President Enc

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e I am a bus driver amployed by bus company and I drivs a school bus for the l t'1 n / :o - 't -

1 School OlatrLat I have-been told 'that according to en amergency plan proposed ,

by LILCD, I may bs expected to drive a school bus its-the event of a radiological accident at the Shoreham plant, as part of either an early dismissal or an evacuation of schools.

This in to state that:

1. I will not participate in implementing any LILCO emorgancy plan far Shorchem, and

2. I cannot and vill not agraa to crive a -

school bus in the evont of an accident et Shoreham.

Date $ ",' T ".~E'#- Signature e

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l RESOLUTIONNO.N)/1936 1

l A RESOLUTION R3LATIVE TO THE USE Ok' TNE NASSAU

. MEMORIAL COLISEUM IN A LONG ISLAND <

LIGHTING cQ$ANY

' PLAN. "

(Passed by Board of supervisers on JUNE 2ig votos forfe 7 : votes osatant.p+ . Beense a gt resetution on Jug 161335'Ith th' *PProval j of the Acttag County Executive.) f ,

NHEREAS, the Long Island Lighting Company has entered into an agreement with the N yatt !!anagement Corpora, tion of New l York, Inc. , which purports to, designata the Nass44 Veterans

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' Memorial Coliseum as a Nuclear Disaster Evacuation Center, and WHfREAS, the Couaty Attorney of the County of Nassau

,!has advised the Board of Supervizors as follows:

". . . .The terms of the lease do not allo ('such a N I

use by the tenant. The provisions of the New .

York State Executive Law preempts to the Governor f

and the County Executive the implementatiori of i

all facilities within the territorial limits l of the disaster . area in the event of.a nuclear r l (radiological) - dis aster.

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....Th3 pr FOsid amendstent to th'315050 agr5cae.

. prchibiting tho uso Cf th3 Naessu Vatartns Memorici ,

Colicoum ao cn evacustica csnter in the cv:nt of n nuclear (radiological) catastrophe would be a nullity.",

now, therefore be it mas 0LVED, that the purported designation of the Nassau veterans Memorial Coliseum by the Long Island Lighting Company as a Nuclear Disaster Evacuation Center be and the same is hereby declared a nullity, contrary to law and voids and be it further

• mzsoLVED, that a copy of this resolution shall be forth-

. with served upon the Long Island Lighting Company and Facility '

b f Management of New York, Inc. , formerly known as Hyatt Managernent g c Corporation of New York, Inc., and filed with notice of such

! service with the office of the Nuclear Reg 151atory Commission at

't Washington, D.C.tand be it further

. . RISOLVED, that a copy of thLs resolution shall be forth-

. .with published in the official newspaper of the County of Nassau. l l1 i i

{U lI - e j Jul( 18506 i iy .OKOVED: '

'P temyw.ewrrn

Aeone twu. w  !

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l l STATE OF NEW YORK (

g gg) l COUNTY OF NASSAU h I I. JOHN A. DeGRACE Clerk of the Board. Nessau Cou Board of Supervisors. d$ koreby certify that the j

foregoing in a true and correct copy cf the origmal &5 E** 0"IW l penned by the Board supervisors of Nansea County, New York. on _ JUhE I

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and approved by tRC unty Esecutive qn__JhO 6,,,]b .. and onIslein my l of.hcr and recorded in the record of the proceedings of the Board of Superv sors of the County of Neeseu in the whole of neid original l

IN WITNiss WNEREOF, I keer hereunto ser my hand l end offund the offactul seat of acid Enerd n' ' _=

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nassaucounty boardof supervisors

+ SXECUTIVE ButLDING, WEST STREET. IANISOLA. N.Y.11801 s

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= = :. - !nc. "m Contacts Anthony J. Santino For Immediate Releases (c) 535-4215 June 16, 1986 (h) 599-3740 X"A*_WS OF TNE HONORABLE THOMAS S. GUP,OT'A ON BEHALF 0F THE NASSAU COUNTY BOARD OF SUPERVISOR i P' 2TAINING TO TNE UIi!_OF THE NASSAU VETERA15 MEMORIAL Ci,'LI lEUM IN THE L.I.

1 LIGHTING COMPANY'S SHORE (AM EVACUATIOT P.AN

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The Board of Supervisors is, this day, considering

( the adoption of a resolution that would reinforce the legal opinion of the County Attorney shat the Nassau County Veterans Memorial Coliseum cannot-legally be a part of Long Island Lighting Company's evacuation plan, and that it's inclusion in such plan would be illegal and improper. The resolution on the calendar today does not preclude this Board from.

taking further steps with regard to this issue in the future.

This resolution, inevitably, raises the broader question of Shoreham and all of its ramifications. It should not be the role of this Board to seek to usurp the jurisdiction  ;

of the various State and Federal regulatory agencies that have been vested with the power to r.ake crucial determinations with regard to shorehem. It is, however, the proper role  ;

1 of this' Board to 'take.those steps which are necessary to i i

protect the health and welfara'of the residents of this i

County. Being fully cognisant of Long Island's future s energy needs, I applaud the seabers of this Board for proceeding cautiously ar.d in a responsihIe fashion evaluating each j facet of the Shoreham issue. 1

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From tho very ine:ptien, many armb:ro of this Bacrd have voiced the opinion that Shoreham should not open, unless it can do what it was intended to dos safely provide an abundant supply of affordable electricity. The position of these Board members has not changed, but the extrinsic information, data and facts with regard to Shoreham have.

The Chernobyl incident has helped to crystallise the fact that safety.must be a first priority and it must be established beyond any rossonable doubt and not lef t to conjecture.

This Board must uphold 1,ts primary responsibility to the

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residents of this County. Based upon all available data, it is the opinion of this Board that the shorehan plant has not mot the necessary criteria to assure this Board of it's safe operation, nor has a reasonable evacuation plan been developed. Frankly, based upon all of the information available, it is doubtful that an effective evacuation plan can every be developed. While the ultimate determination, in this regard, will be made by the appropritte Federal agencies, and not this Board, it is important that the voice of local government be heard. In the absence of a dramatic change of circumstances, that will provide convincing

, evidence that shoreham can provide an abundant supply of safe, affordable power, Shoreham should not open.

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6.Jif. +#.W./ OAK HOLLOW NURSING CENTER r

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S'eptember 2, 1986 Charles A. Gentile

Radiation Protection Section LILCO 175 E. Old Country Road Hicksville, NY 11801

Dear Mr. Gentile:

In reference to the evacuajien transportation agreement signed between Oak Hollow Nursing Center and Crest Hall NRF 11/27/84, we feel that we were premature in consummatini this agreement.

We hereby rescind said agreement until such time as the Shoreham plant receives its operating license.

Very truly yours, A k F Joan Portnoy Administrator l

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Next Year Crucial tO

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ByJohnMcDonald. _.- LILCO's Fate M.TIIe NBCMelonlavelveumys Aetions emeial to 14ag Island IJghting Co. and g, the abereham nuclear power plant are es ** % a Umaan ha t8** to operage e,,3, neek a senslusion during the next sear. pected t' ~ 8 "* **" 888dk-I*

. Over the nest is sesoths, the Naalear Esgule- ' and how y,,, egg,as ap-even andSibikCounty gpbf esense hl:'Mr eC e

.tePasser*mswm c e-- ':e z=ll're de;show*:'m = 4 - b h a"" 'p M "d D.

munk LIICO enn shargela rates ww.de ra ,iew of an. te and sount tt ,,;;; -

tharitymaybe Armed to take our;theand a months he the NEC to arrang,e a

.. or AH of those actions will represent the suhaina, Shorehans planlast tienof a plant without .!asonsing and

. etdebate involving LIII.O. $boreham and eeustF in emergency planalaghas neverbeen alearpowerplant peciest. sentiment about the utility and the an. and

• i For at leastibur the unabarted must be held within asourse oftheis a diSoult sea. 'the situ called hr reshaping the ihr example, Caomo has operatinglieease, obtainiasan in response to com. to regulations that year wiu be NRC hennage the on,%n plaints that it has not been responsive to . . . . . ,

drillhave been concluded.

needs. By February, he will be in a position to ap.

point Sw of the seven PSC members amid criticism U.S. Rep. Edwa,rd Erkey's (D.Wae.) subcom thatand ties thei commission has too oAen sided withonener utiu. power nr.d eenaervation owr the reconsti.

has alrea orod the deslas of consumers. Cuomo tution~ Shorehamlioe

( Bradfont announced that he will soneint Peter the board heard three days of le board shortly testimony. In aner r NEC commissioner ah3 chairman of the h,ine Public Service Commission, as chair, the Senate, Sen. Daniel Patri mynihan (D N.Y.)

had sought hearings into the forced resignation last man of the PSC. Bradfbrd has a rs),utation for being spring of Federal Emo

%=W. anted. regionaldirectorFrank haarment Agency IECO has aald it wul & a request this month '

The 1A00 plan'atin faces with the P9C to raias rates by about Sve perosat, onlangIsland.The tems, tionibr8eh Lt , a citi.

LD40 maintains that its rate uke win be in line senag opposed to Shoreham, la a*

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erstles. Cuomois suing t so to reduas Lg ..re"loostion" foraeN ""7."sa's"El2 la the IACO plan. WALE' radio a ICE 2 MI5L'a"siQFem'co"* "ra* ""g": !*,.'.2 i!'t2ll'a"Ae",i2R*e L"."iMll%

• et *el 2 1 W e E d @. E "'

' Ins new 790 will have the opportunity asst &H

• to sumat LIICO the rate hike it erit ses vote te rednes L1Z40's rates. What PSCdoesla

. likely to esad signals to the Saaacial commualty that could sway latestors toward er awny fireta

$boreham,

" state emaials said.

1 think that Well Street is jittery," said Richard Kessel, eascutive director of the state Consumer .

Protection Board. "I think they reallas that the new -

PSC will be more oriented toward the a morepubh'c.lyoriented.Idon't we'n willy.awy si 1100 money it needs to stay alive and boense "

l Utility Saancial analyst Danie! Scotto of L.F.

RomaWid, Unterberg i said, aThis .-=='='an,Towbin, an innstment firm.

is producing an alamant et

,mejoruncertainty. . .lftheawnmtmaionwantinand started a major rate inveettgation. it certaialy woul N hampne the capital raising ability of the company.d I( C)s l - i

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trW5 PAPER Q( DATE'll IA 9(.e PAGE_b$

working to convince other participante in the plan, such as bus and ambu. lance companine, to drop out, said coalition spokesman Jeffrey Newman.

Another local laeue that could have sa knpast on Shoreham is the selection of a replacemens ihr Suffolk Count will become a Executive Peter F. Cohalan, who se Jan.1. "The count executive will be cruci to the Asht," said . Wayne Prospect (D. Din Hille)

Aght against Shor*%n, a leader of e sounty's

% one area that ofbre the quickest solutten to

! w Shoseham situationinvolves the tk.nounder between LD40 and the state said.h is to agree en a workable celution bohre Jan.

'1 em, when the state's Imag Zeland Powcr Authority la ered LU40 to ma==anaa a sublie takeover of 1 the has WAliana Sherrard sold

'the with thea"Besible" state, attitude toward who will asseint Sve of the 'nine sesen-bars of the authertty, has said that Ebereham esuet beabandonedand be ode-te n.d assrau.that .imookee electric maedum state has solled to no,e ho neen ofbran alternative to shosehem.

,v er of aimu in = t tag ineeds.h %ith-h,th sides ma,am, in Efm""i are nos lhe, ai- .

Iwoue De' l Peeter 'cisions Ahead Status for LILCO and Shoreham' 1%soPower ' l.ong island Power

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Authortry A board for the authert y v.Non een pu* sue a friendly or hostile takeover of ULCO as long as retoe would De

. lower,le to be oested Jan.15 UnutyItates '. l.M.CO requeste .

Bytheend of the momb ULCOle expectedtoaskforan

' increece of about 5 perc,ent, o"380 mison

"" N ?.> ' . '" PublicServloe 7; Commission .- Gov. Mario Cuomo wtB have appointed to theof the *

. u-gg , .i ,

.a -

.,. g. . , .

seven memtwo of the PSC, wtwoh ratehike

.-(* .*

rogueen byPetwuary, ses7

' "Used and UsefVr'818 - ,, ..

. .. g; .:,. ;., . ,~. .".- ,- U that if Shor@em is not Ieensed by January,1908, will. not bei. .b.;le. to, charge lie cost to rasepayers i '

' Shorehem's ?

.;unenes SiWom Emeoudve' Peter

L .., . , . . , ? f. Cohelen' selection tojudpe The dearse of he toplaisements oppoeluen to Shore-

.g.>.c .....(. . . ... . hem wifaNoct r..the.r scorg appeelson movement in county k ft . ~ Y. . .,

t.! U //. .' 0

y. O %.; I 4 Ocmmiselon

' 't'

?

&MNWN onespedleof &W

r. ,. %.a< r ,A. '.'. :. . . -

sortest w, w ..:::. '

.t.r.

. . .;. .... E . ete wr '. 3. y5 .-

deep le summer 1987. . deelslon,

{;.'.QM'g ~.C 'Altecke en Shoreiam whosswer R.is,is Acltlaene

., - tobeaheBengedinseurt. ..

. .. ...~-

a CoeNon for8sh pereued-

<. . m ' *g c'; . -owesuason plan. .c . . edNassau mytownhdrewfrom

@ @.7. s{j .1'c Ns**D.

t  :-i .:.u; A .

. . {g.. . FE .'. gng 3 and- le now workin0 on eqhet perdolpents, gmgylghgg L. gf.. . **.pI- ., (;,+ f . g "; * * , ,# es.Ithe lggygggeg.

- .s . . .

. ful,RmWIbe tougherIbr tosteelna .

, E of ;[r * -

F.6...'

.pF,Or~? - A r~- < c.

Seth the House'ard Genet are NM hendung

/* '

of the Shoreham case. W!!h the tald con-9- , " . ' ~ ' *.

• ., trol of the Ser.ete and involvement by Sen. Pat-fick Moynthan (D N.Y.), the NMC can sapect inore Irk tense scrutiny of its Shorensin deoielone 1

l 3D' 1

, - - _ _ _ , . _ _ _ _ ___,m, _ _

'

• LILCO, Nov mber 21,1986 Cat 4Eit:

CERTIFICATE OF SERVICE

'86 NOV 24 P4 :55 In the Matter of LONG ISLAND LIGHTING COMPANY '

(Shoreham Nuclear Power Station, Unit 1) [0hk I '4 Docket No. 50-322-OL-5 aR.hc" I hereby certify that copies of LILCO'S OPPOSITION TO SUFFOLK COUNTY'S MOTION FOR ORDER COMPELLING LILCO TO RESPOND TO SUFFOLK COUNTY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCU-MENTS and LILCO'S MOTION FOR PROTECTIVE ORDER IN RESPONSE TO SUFFOLK COUNTY'S MOTION TO COMPEL were served this date upon the following by hand as indicated by an asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.

John H. Frye, III, Chairman

• Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers 4350 East-West Hwy. Atomic Safety and Licensing Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Oscar H. Paris

• Washington, D.C. 20555 Atomic Safety and Licensing Board Bernard M. Bordenick, Esq.

• U.S. Nuclear Regulatory Commission Oreste Russ Pirfo, Esq.

East-West Towers Edwin J. Reis, Esq.

! 4350 East-West Hwy. U.S. Nuclear Regulatory Commission Bethesda, MD 20814 7735 Old Georgetown Road (to mailroom) l l Mr. Frederick J. Shon

• Bethesda, MD 20814 l Atomic Safety and Licensing Board Herbert H. Brown, Esq.

• U.S. Nuclear Regulatory Commission Lawrence Coe Lanpher, Esq.

East-West Towers, Rm. 430 Karla J. Letsche, Esq.

l l 4350 East-West Hwy. Kirkpatrick & Lockhart

Bethesda, MD 20814 Eighth Floor 1900 M Street, N.W.

Secretary of the Commission Washington, D.C. 20036

! Attention Docketing and Service Section Fabian G. Palomino, Esq. **

U.S. Nuclear Regulatory Commission Richard J. Zahnleuter, Esq.

1717 H Street, N.W. Special Counsel to the Governor Washington, D.C. 20555 Executive Chamber Room 229 State Capitol Albany, New York 12224

~ ,

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

Assistant Attorney G'sneral New York State Department of 120 Broadway Public Service, Staff Counsel Third Floor, Room 3-116 Three Rockefeller Plaza New York, New York 10271 Albany, New York 12223 i

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 Gerald C. Crotty, Esq.

Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 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 Buildir.g P.O. Box 298 Veterans Memorial Highway Riverhead, New' York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 l

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

i 1

Ad4f'l(/ Y.

ine A. Monaghan W

j Hunton & Williams

707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 21,1986 l

l

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