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Category:AFFIDAVITS
MONTHYEARML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20073B7461991-04-17017 April 1991 Affidavit of EM Franz Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7211991-04-17017 April 1991 Affidavit of Jl Bateman Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7941991-04-17017 April 1991 Affidavit of Jr Stehn Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing Intervention as of Right.W/Certificate of Svc ML20073B7821991-04-17017 April 1991 Affidavit of J Scrandis Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7161991-04-17017 April 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc (Sese) Re Intervenors Status for Sese ML20073B7611991-04-17017 April 1991 Affidavit of SV Musolino Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073A6101991-04-0505 April 1991 Affidavit of Jl Bateman Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A4631991-04-0505 April 1991 Affidavit of Ag Prodell Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention.W/Certificate of Svc ML20073A6161991-04-0505 April 1991 Affidavit of AP Hull Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention.W/Certificate of Svc ML20073A5831991-04-0505 April 1991 Affidavit of E Franz Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5571991-04-0505 April 1991 Affidavit of Jr Stehn Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A6041991-04-0505 April 1991 Affidavit of SV Musolino Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5511991-04-0505 April 1991 Affidavit of J Scrandis Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5301991-04-0505 April 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc.* ML20067C5361991-02-0303 February 1991 Affidavit of Franz,E M.* Affidavit Re Mod to Facility License ML20067C6721991-02-0303 February 1991 Affidavit of Eena-Mai Franz.* Believes Confirmatory Order Constitutes Another Step in Decommissioning Process to Violate Rights Under NEPA & Represents Threat to Health & Safety ML20067D0671991-02-0202 February 1991 Affidavit of Jr Stehn.* Affidavit Re Mod of Plant License. W/Certificate of Svc ML20067C4911991-02-0101 February 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc.* Affidavit of Mm Todorovich Re Organizational Interest in Modifying License to Plant ML20067C5881991-02-0101 February 1991 Affidavit of J Scrandis.* Affidavit Re Mod of Plant License ML20067C6101991-02-0101 February 1991 Affidavit of Jr Stehn.* Affidavit Re Mod of Facility License.W/ Certificate of Svc ML20067C8651991-02-0101 February 1991 Affidavit of Ag Prodell.* Opposes Confirmatory Order Issued on 900329,prohibiting Licensee from Placing Fuel Into Reactor Vessel W/O Prior NRC Approval ML20067C4991991-02-0101 February 1991 Affidavit of Jl Bateman.* Affidavit Re Mod of Plant License ML20067C5741991-01-31031 January 1991 Affidavit of SV Musolino.* Affidavit Re Mod of Plant License ML20067C5631991-01-31031 January 1991 Affidavit of AP Hull.* Affidavit Re Mod of Plant License ML20091C6711990-03-30030 March 1990 Affidavit of WE Steiger.* Provides Info in Support of Util Request to Amend Facility Physical Security Plan. W/Certificate of Svc ML20247B8831989-09-0707 September 1989 Affidavit of WE Steiger in Support of Util Request for Exemption from Onsite Property Damage Insurance,Per 10CFR50.54(w) ML20206M9851988-11-22022 November 1988 Affidavit of LC Lanpher.* Affidavit Re Govts 881123 Motion to Stay 881121 Licensing Board Memorandum & Order Authorizing NRC to Make Necessary Findings on 25% Power Issues & to Issue 25% Power License to Util ML20206M9921988-11-22022 November 1988 Affidavit of Gc Minor in Support of Motion for Stay.* Supports Govts Motion to Stay ASLB 881121 Order Authorizing Issuance of 25% Power OL for Plant ML20206N0001988-11-0303 November 1988 Affidavit of Ej Gleason,Director of Planning,State of Ny Energy Ofc.* Provides Data on Whether Supply of Electric Power to Long Island Would Be Adversely Impacted If Plant Did Not Operate.W/Related Info & Certificate of Svc ML20205R5351988-11-0303 November 1988 Affidavit of CA Daverio in Support of Lilco Response to 1988 Exercise Contentions.* ML20205N5231988-10-31031 October 1988 Affidavit of Kj Letsche in Support of Motion to Disqualify Judges Gleason & Kline.* Certificate of Svc Encl ML20205D6451988-10-14014 October 1988 Affidavit of Am Madsen in Support of Lilco Request for Stay of ALAB-902.* Certificate of Svc Encl ML20151N5851988-07-23023 July 1988 Affidavit of Dp Dreikorn on Lilco Compliance W/Fema Guidance Memorandum MS-1.* Certificate of Svc Encl ML20151G6051988-07-18018 July 1988 Affidavit of Ja Weistmantle.* Discusses Assertion That Lilco Obtained Complete Copy of Suffolk County Emergency Operations Plan Outside of Formal Discovery Processes ML20196B3571988-06-23023 June 1988 Affidavit of Jn Christman.* Schedule of Dispositions & Certificate of Svc Encl ML20151T4791988-04-21021 April 1988 Affidavit of Gc Minor & Sc Sholly Re Validity of Analyses & Conclusions Ref in Youngling Affidavit.W/Certificate of Svc ML20149H7411988-02-11011 February 1988 Affidavit of Rt Hogan Re Disposition of Hosp Evacuation Issue,Per Rev 9 to Util Offsite Emergency Plan.W/Certificate of Svc ML20196D7771988-02-10010 February 1988 Affidavits in Support of Govts Opposition to Lilco Summary Disposition Motions on Contentions 1-2 & 4-10.* Supporting Affidavits Include Mm Cuomo,Pg Halpin,Rc Roberts,Je Papile, Kj Letsche & Rj Zahnleuter ML20196H1111988-02-0909 February 1988 Affidavit of Pg Halpin Re Matters Alleged by Util in Lilco Motions for Summary Disposition of Contentions 1-2 & 4-10 Dtd 871218.Summaries & Quotations of Util Assertions, Resolution 111-1983 & Pf Cohalan Statement Encl ML20196H0841988-02-0808 February 1988 Affidavit of Mm Cuomo Re Util Radiological Emergency Response Plan.Reaffirms Statements Made in 870506 Affidavit & 860630 Statement.Statement Encl ML20149D8311988-02-0404 February 1988 Affidavit of DM Crocker Re Suffolk County First Set of Requests for Admissions Dtd 880125.* Certificate of Svc Encl.Related Correspondence ML20149F1281988-01-25025 January 1988 Affidavit of T Urbanik Re Lilco Motion for Summary Disposition of Contentions 1,2 & 9.* Certificate of Svc Encl ML20148D4041988-01-19019 January 1988 Affidavit of Fg Palomino.* Util Had Matl Role in Activities Before Federal Govt by Endeavoring to Persuade Govt to Intercede in Proceeding During 1984 & 1985.Certificate of Svc Encl ML20148D3541988-01-19019 January 1988 Affidavit of Fr Jones.* Lists Conduct Supporting Fact That Util Has Not Made Good Faith to Secure & Retain Participation of Suffolk County ML20148D2281988-01-19019 January 1988 Affidavit of Gj Blass.* Util Refusal to Pay Property Taxes During 1984 & First Half of 1985 Constituted Severe Injury to County.Related Info Encl ML20148D1541988-01-19019 January 1988 Affidavit of LC Lanpher.* Submits Related Info to Support Contention That Lilco Has Not Made Isolated Good Faith Effort to Secure & Retain Participation of Suffolk County ML20147D7301988-01-15015 January 1988 Affidavit of Ms Miller Re Proposed Offsite Emergency Plan. Certificate of Svc Encl ML20148D3101988-01-11011 January 1988 Affidavit of T Urbanik.* Assumptions,Speeds & Methodology Used in Hosp Evaluation Time Estimates in Rev 9 to Util Plan Correct.Estimates Suitable for Inclusion for Use in Making Protective Action Recommendations.W/Certificate of Svc 1993-09-14
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18
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LILCO, January 10, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
LONG ISLAND LIGHTING COMPANY Docket No. 50-322-0L-3 (Emergency Planning (Shoreham Nuclear Power 1 Proceeding)
Station, Unit 1) )
AFFIDAVIT OF ELAINE D. ROBINSON ON NASSAU COLISEUM
- 1. My name is Elaine D. Robinson. My professional qualifications are at Tab 15 after page 4068 of the hearing transcript in this proceeding.
- 2. I managed the Local Emergency Response Implementing Organization team that is responsible for incorporating outside organizations, including the Red Cross, into the emergency planning effort. I participated in the discussions with the Hyatt Management Corporation of New York, Inc., which leases and manages the Nassau Veterans Memorial Coliseum, that led to the letter of agreement between LILCO and the Hyatt Management Corporation dated September 25, 1984. That letter authorizes LILCO and the Red Cross to use the Coliseum as a reception center. It was It is approved by Hyatt Management Corporation on October 8,1984.
1 Attachment 1 to this Affidavit.
- 3. Prior to the agreement embodied in Attachment 1, the County Executive of Nassau County advised the General Manager of the Coliseum that he approved the use of the Coliseum as a reception center in the 8501140544 850111 gDRADOCK 0500032y p
t event of an accident at the Shoreham Nuclear Power Station. His letter to that effect, dated October 1,1984, is Attachment 2 to this Affidavit.
- 4. I also participated in discussions with the Nassau County Chapter of the American Red Cross leading to a letter of agreement, dated October 23, 1984, that sets out the Red Cross's and LER0's responsibilities in using the Coliseum as a reception center. That letter of agreement is Attachment 3 to this Affidavit.
- 5. The Nassau Veterans Memorial Coliseum is a sports and entertainment / exhibition complex designed to accommodate crowds of 15,000 to 17,000 people, depending on the event. The Coliseum is located in south-central Nassau County at the intersection of Hempstead Turnpike and Meadowbrook Parkway. Its location is marked on the map that is Attachment 4 to this Affidavit. The Coliseum is 43 miles from the Shoreham Nuclear Power Station and 33 miles from the 10-mile EPZ boundary.
- 6. It has a Receiving Area with 15,500 square feet of space, an Arena (17,000 square feet), and Exhibition Hall (59,000 square feet), and an Arena lobby (5750 square feet). A diagram of the Coliseum is Attachment 5 to this Affidavit. The Coliseum has locker rooms and dressing rooms with at least 30 showers. In addition, there are numerous sinks that could be used to clean evacuees with localized contamination.
- 7. The Nassau County Executive has assured LILCO that the Nassau County Government would cooperate to the fullest in making the Coliseum available in the event of an accident at Shoreham. His letter to that effect is Attachment 6 to this Affidavit. If a sporting or entertainment D
i i
3-event were in progress at the Coliseum when an accident at Shoreham occurred, Hyatt Management has advised LERO that it would take no more than 1-1/2 hours to completely clear the Coliseum and its parking lot.
For example, on January 8,1985, the New York Islanders (a professional hockey team) played to a capacity crowd of over 15,0b0 fans. A LILC0 consultant clocked the clearing of the parking lot and found that the parking lot had emptied and surrounding streets were cleared with approximately 45 minutes after people began to leave the game.
^ -
-c-4~1 ElaTrie F.~Yo inson 4.y h Subscribed and sworn to before me this ia day of ,
1985.
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My corrmission expires: 0 _' ^ - - , ,
ylYary P b &&LA ic /) d ho PHYLLIS A. GRoEZI ER NOTARY PUBLIC, Stcte of New York Quotfted n uffolk County #
Comm.ssion Eores March 30,19A!"
a
9 Attachment 1 mnv:
3
/gg LONG ISLAND LIGHTING COMPANY l ,
EXECUTIVE OFFICES: 250 OLO COUNTRY ROAD MINEOLA. NEW YORK 11501 September 25, 1984 Mr. E. B. Sumerlin, Jr.
General Manager Nassau Veterans Memorial Coliseum Hyatt Management Corporation of N.Y., Inc, c/o Nassau Coliseum Uniondale, NY 11553
Dear Sir:
LETTER OF AGREEMENT FOR USE OF NASSAU VETERANS MEMORIAL COLISEUM BY LONG ISLAND LIGHTING COMPANY This letter confirms our recent discussions regarding the use of Nassau Veterans Memorial Coliseum by Long Island Lighting Company (LILCO) as a reception center during a radiological emergency at the Shoreham Nuclear Power Station.
Use of Facility. Hyatt Management Corporation of New York, Inc.,
the lessee of the Nassau Veterans Memorial Coliseum, agrees to allow LILCO to use the Coliseum, consisting of the Nassau Veterans Memorial Coliseum building and all parking lots and immediately surrounding property, as a reception center for the general public in planning for and responding to a radiological emergency at Shoreham, pursuant to the Local Offsite Radiological Emergency Response Plan (LILC0 Plan) developed by LILCO.
LILC0's use of the Coliseum pursuant to the LILC0 Plan shall include the following activities:
- 1. Identifying the Coliseum, in the LILC0 Plan and brochures and other information distributed to the public, as a reception center for joint use by LILC0 and the American Red Cross in the event of a radiological emergency at Shoreham, where (1) LILC0 will register, monitor decontaminate (if necessary), and issue " clean tags" to evacuees, and (2) the Red Cross will provide information and assistance to evacuees as required.
- 2. Performing radiological monitoring and decontamination, if necessary, in the Coliseum and/or surrounding property in the event of a radiological emergency at Shoreham, including using showers in the building and waterworks on the property for decontamination, n
i' ,
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s
~
Mr. E. B. Sumerlin, Jr.
t September 25, 1984 Page 2
- 3. Developing layouts and implementing procedures for use of the
! Coliseum, in cooperation with Nassau County employees to allow LILCO to develop these items expeditiously.
- 4. Identifying, in cooperation with Coliseum employees, an area in j
which to store any necessary amounts of equipment and supplies on the
- property at the facility, and storing such equipment and supplies upon reasonable terms to be agreed to by the parties.
i Access. LILCO will be given reasonable access to the Coliseum upon notification by LILCO to Hyatt or the County that a radiological emergency exists at Shoreham. LILCO will also be granted access to the
' Coliseum to plan for and conduct drills and exercises of the Local Emergency Response Organization. These activities will be scheduled on a time-to-time basis by the parties so as not to interfere with the nonnal 3
operation of the Coliseum.
Expenses. LILCO will be responsible for any expenses (1) l incurred in the development of plans for use of the Coliseum, and (2) in
> using the Coliseum for planning, drills, exercises, or an emergency
-response. LILCO will reimburse Nassau County and/or Hyatt, as appropriate, for any expenses incurred by them in connection with such activities.
i Insurance and Indemnity. LILCO will be liable for all damage to the Coliseum, normal wear and tear excepted, as a result of LILCO's use of
- the Coliseum pursuant to this Letter of Agreement, and LILCO will
' indemnify and hold the County and Hyatt harmless from any claims or suits
- arising out of injury or death to any person or damage to property resulting from LILCO's use of the Coliseum pursuant to this Letter of Agreement. For all contractual and noncontractual non-nuclear liability f
j arising out of either (1) the training of emergency response members or (2) response to a simulated or actual radiological emergency at Shoreham,
- LILCO will furnish a statement of self-insurance and/or an appropriate
- certificate of insurance showing that there is in effect, and will remain in effect throughout the term of this agreement, comprehensive general liability insurance, including property damage, in the following amounts
i Comprehensive General Liability (Including Personal Injury and Contractual Liability) - $1,000,000.
o BodilyInjury(eachoccurrence)-$1,000,000.
PropertyDamage(eachoccurrence)-$300,000.
LILCO will name, as additional insured, Hyatt Management Corporation of New York, Inc., its officers, directors, agents, and employees, and the County of Nassau and its cognizant officials, as their interests may appear. Within 10 days after the signing of this Letter of Agreement by the County and Hyatt, LILCO will deliver to Hyatt and the County certificates of insurance or evidence of self-insurance with the limits specified above, evidencing that the po.licies or self-insurance required from LILCO are in full force and effect.
b
y
Mr. E. B. Sumerlin, Jr. -:
'. - September 25, 1984 Page 3
'l, . j4ls
-o %. .. g If you find that this L ..
Agreement accuratelpW#esents"M our understanding regarding LILCO's ttfe of the Coliseum during an emergency at Shoreham, please sign the Letter below and return it to me.
Thank you very much for allowing us to use the Coliseum in our efforts to aid the public in the unlikely event that an emergency were to occur at Shoreham.
Very truly yours, A LM 1.
Dr. Wi 1 am J. Catacosinos Chairman of the Board and Chief Executive Officer Long Island Lighting Company
)
- e. .
HYATT MANAGEMENT CORPOR ION OF NEW YORK, INC.
DATE: to / 9 /g A -
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Attachment 2 3 .
i.[4CO w JGwmo :OMPANY AAseC38 T. PURCELL
NASSAU COUSEUA OFFICE OF THE EXECUTIVE g
NASSAU COUNTY EXEdUTIV? SusLDING ONE W EST STR EET MINEOLA. N. Y.11501 October 1, 1984 Mr. E.B. Sumerlin, Jr.
Vice President / General Manager Nassau Veterans Memorial Coliseum Hyatt Management Corporation of New York, Inc.
Uniondale, New York 11553
Dear Mr. Sumerlin:
This letter will confirm' discussions between members of my staff with you and officials of the Long Island Lighting Company regarding the use of the Nassau Veterans Memorial Coliseum as a reception center for the public in the event of a radiological emergency at the Shoreham Nuclear Power Station.
I am aware of and approve the use of the Coliseum as a reception center for members of the public requiring assistance from the Local Emergency Response Organization and/or the American Red Cross as a result of any accident at Shoreham which results in the recommendation that the public evacuate from part or all of the Emergency Planning Zone around Shoreham. Included will be:
- a. The identification in public information of the Coliseum as the reception center,
- b. ,The use of the Coliseum for performing radiological monitoring and decontamination as necessary, and
- c. Cooperation with LILCO in planning, training and exercises as well as in the event of an accident.
9
1*
l 1
EiT l Mr. E. B. Sumerlin, Jr.
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October 1y 1984 Page 2 I want to asisure you that in the event of an emergency at Shoreham, as at all times, the Nassau County Police Dep~drtment will be prepared to protect the public welfare of all those in Nassau County. The Department will, therefore, be available to provide assistance with security at the Coliseum, and to facilitate traffic flow and parking at the Coliseum and its aoproaches.
I hope that an agreement can be reached promptly witn the Ndosau County Chapter of the American Red Cross to formalize their relationship with the Coliseum for its use by the Red Cross during any emergency, including a radiological accident at Shor m.
Ver truly your ,
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Francis T. Purcell FTP:ser County Executive cc: Dr. William J. Catacosinos i Long Island Lighting Company Mr. Frank Rasbury I
American Red Cross ,
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October 23, 1984 Mr. Frank M. Rasbury Executive Director American Red Cross Nassau County Chapter 764 Old Country Road Mineola, New York 11501 Letter of Agreement for Use of Nassau Veterans Lecid Cc!!num by American Red Cross
Dear Mr. Rasbury:
As you know, Long Island Lighting Cocapany has entered into an agreement with Hyatt Management Corporation for the use of the Nassau Veterans Memorial Coliseum (Coliseum) as a reception center pursuant to the Local Offsite Radiological Emergency Response Plan (LILCO Plan) developed by LILCO. A copy of that agreement, dated September 25, 1984, is attached to this letter. The purpose of this letter is to set out our understanding regarding LILCO's and the American Red Cross' use of the Coliseum as a reception center pursuant to the LILCO Plan.
LILCO will identify the Nassau Veterans Memorial Coliseum in the LILCO Plan, brochures, and other information distributed to the Red Cross '
in the event of a radiological emergency at Shoreham, where 1) the Local Emergency Response Organization (LERO) will register, monitor, decontaminate (if necessary), and issue " clean tags" to evacuees, and 2) the American Red Cross will provide information and assistance to evacuees as required. The American Red Cross will provide Red Cross staff to assist evacuees and to direct ovacuees to congregate care centers operated by the Red Cross, chosen from among those on the list provided with the Letter of Agreement between Long Island Lighting Company and the American Red Cross dated July 25, 1984.
Red Cross Staff at the Nassau Coliseum will coordinate with LERO moni-toring and decontamination personnel to define a " clean" area from which the Red Cross will operate at the Coliseum; evacuees will be monitored and, if necessary, decontaminated by LERO personnel prior to being directed to Red Cross staff members at the Coliseum. American Red Cross staff at congregate care centers will be trained to send any evacuee who has not been monitored (should any find his way to a congregate care center without first going to the Coliseum) back to the Coliseum for monitoring prior to accepting him into
,f lorw2 ses Ano uowfine compey Mr. Frank M. Rasbury October 23, 1984
,gg _.~ , . ,t aN O . . r .; w r a iw u , :t )m PAN V the congfida6 care centers. The location of specific congregate care centers will not be included in public information materials; all evacuees will be direc-te.1 to go to the Coliseum.
If you find that this letter accurately represents our understanding regarding the American Red Cross' use with LILCO of the Nassau Veterans Memorial Coliseum during an emergency at Shoreham, please sign the letter below and return it to me. Thank you very much for your continued efforts to provide aid to the public in the unlikely event that an emergency were to occur at Shoreham.
Very truly yours, Matthew C. Cordaro, Ph.D.
Vice President b b' l
rank M. Rasbury ~ /
Executive Director /
American Red Cross Nassau County Chapter l
DATED: October 4,1984 l
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OFFICE OF THE E X EC U TIV E NAssAU CcVNW EXECUTIVE sulLDING O N E W EST STRegT MIN EOLA. N. Y.11501 December 31, 1984 Re.t r A Dr. William J. Catacosinos Chairman and Chief Executive Officer Long Island Lighting Company '
250 Old Country Road Mineola, New York 11501 .,
Dear Dr. Cartacosinost The article appearing in the Thursday, December 27th issue of Newsday appears to have raised some confusion with respect to the use of the Nassau Coliseum in the event
- of a radiological accident at the Shoreham Nuclear Power Plant. .
In an attempt to clarify any misunderstanding, let me assure you that should such an accident occur, Nassau County Government will cooperate to the fullest in making all public facilities, including the Coliseum, available at Jan time. The health and public safety of the residents of Wng Island take precedent over any other activities that might be occurring within buildings of public assembly.
I trust that the foregoing will leave no doubt in anyone's mind as to our position in this matter. -
Very truly yours, -
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. . . . . FRANCIS T. PURCELL County Executive FTP:jgb n ._