ML20076E157
| ML20076E157 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/22/1983 |
| From: | Dynner A KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8308240168 | |
| Download: ML20076E157 (17) | |
Text
{{#Wiki_filter:' pnugu wWi3Yp[2'[8'3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 90CKETED USNRC Before the Atomic Safety and Licensing;3oggd
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h ,. . - ; In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 O.L.
)
(Shoreham Nuclear Power Station, ) Unit 1) )
)
SUFFOLK COUNTY'S NOTICE OF POTENTIAL MOTION TO ADMIT NEW CONTENTION ON DIESEL GENERATORS A week ago Friday, on August 12, 1983, the crankshaft on Shoreham emergency diesel generator no. 102 broke in two
/
during testing of the diesel with the "new-style" cylinder heads installed. Counsel for LILCO notified Suffolk County's counsel of this matter on Saturday. Neither' LILCO nor the 1/ NRC Staff know what caused the crankshaft to fail, and the 2/ failure analysis effort may take a significant time.- On August 18, 1983, the County sent LILCO a Request [ for Discovery regarding the crankshaft failure (a copy of which is attached hereto as Exhibit 4) and sent the Staff a similar l 1/ See "LILCO Report and Request for Temporary Deferral," dated August 15, 1983; and "NRC Staff Response to 'LILCO Report and Request for Temporary Deferral' of Filing of Testimony and Evidentiary Hearings on Emergency Diesel Generators," dated August 16, 1983. 2/ Ibid. See LILCO News Release, dated August 18, 1983 (attached hereto as Exhibit 1). See also article from Newsday, August 17, 1983, p. 3 (attached hereto as Exhibit 2); article from The Wall Street Journal, August 19, 1983, p. 5 (attached hereto as Exhibit 3). 8308240168 830822 PDR ADOCK 05000322 G PDR h y (? ,)
request (a copy of which is attached hereto as Exhibit 5) . These requests are in connection with the County's pending contentions concerning the Shoreham diesel generators (cylinder heads and vibration), which may be related to the crankshaft failure. LILCO has not yet responded to the County's Request for Discovery, which is intended to permit the County to observe and monitor the attempt to ascertain the cause(s) of the broken crankshaft. Suffolk County believes that the crankshaft failure denenstrates that the rapid starting and the safe and reliable operation of the Shoreham emergency diesel generatcrs has not been ensured. While the County has little doubt that a new contention to this effect would meet all standards for reopening the record and the criteria for a late-filed 3/ contention,~ there seems no good reason to file a new contention prior to LILCO reaching its conclusions on the cause(s) of the failure. Indeed, if LILCO complies with the County's Request for Discovery, and the County agrees with LILCO's conclusions on i
- the cause (s) of the failure, with the significance thereof, and with LILCO's corrective and preventive action, the County might not file a new contention at all.
I ! The County is aware that " timeliness" is one of the tests which a late-filed contention must meet. In the County's interpretation of this standard, a new contention on the crank-3/ Both standards and criteria must be met, according to the Board's Memorandum and Order Ruling on Suffolk l County's Motion to Admit New Contention, LBP-83-30, 17 NRC (June 22, 1983). For a summary of these standards and criteria, see LBP-83-30 at 12.
shaft failure would be timely if filed within a reasonable time after the County learns of LILCO's conclusions regarding the cause (s) of the crankshaft failure. At that time the significance of the broken crankshaft issue and whether it presents genuine triable facts will be adequately sharpened to determine whether a new contention is appropriate. On the other hand, if the County were to file a contention on the crankshaft failure before learning of the conclusions of LILCO's failure analysis, litigation would probably have to be deferred until those conclusions were known. Before then, neither party would nave a clear idea of the triable facts at issue. Hence, it would be absurd in this situation if the timeliness standard were interpreted to require filing of a new contention within a reasonable time after the breaking of the crankshaft, rather than after LILCO makes known its conclusions as to the cause (s) of the failure. To the extent that one aspect of the timeliness criterion may bc to avoid surprise, this Notice serves to communicate the County's present intentions to the Board and to all parties. If any party believes that the County's interpretation of the timeliness standard as applied to this matter is erroneous, it should raise that disagreement now. We should add that, in the context of timeliness, as well as the standard con-f cerning possible delay of the proceeding occasioned by a
late-filed contention, LILCO now estimates that Shoreham will not be ready for fuel load until sometime in the first i quarter of 1984.-4/ Respectfully submitted, David J. Gilmartin J Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 1-Herbert H. Br en / Lawrence Coe, anpher Alan Roy Dynner K1KKPATRICK, LOCKflART, HILL, CHRISTOPHER A PHILLIPS 1900 M Street, N,W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County August 22, 1983 4/ See Exhibits 1 and 3.
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,SD EXHIBIT 1 i
FOR IMMEDIATE RELT3.5E August 18, 1983 Long Island Lighting Company today announced that it has increased frc=
$50 to $75 million the a=ount of a sale of preferred stock scheduled for August 22.
At present, there is no new infor=ation available as to the status of the diesel generator which experienced a crankshaf: failure during a pre-operational test. The Cocpany is today filing a Current Report on Forn E-K with the Securities and Exchange Cc=:ission te report en the 2ecent developecnts at Shorehan raprding the diesel generator. The text. of the Form 8-K fellows:
Cm August 12, 1983, during testing, the crankshaf t of one of the three coergency diesel generators at Sborcha=
failed. The crankshaft was initially thought to have been cracked, but was in fact broken. Successful co=pletion of testing of all three generators is a prerequisite for permission to load fuel and to begin low-power testing. Although an analysis of the cause of the crankshaft failure has begun, until such analysis has been cocpleted, the Cocpany is unable to predict when fuel loading and cocnercial operation will occur. Under the most favorable circu= stances, correction of the dacage caused by the failed crankshaft as well as a deter =ination of the adequacy of all three diesel generators, in light of such failure, could be accc=plished by la.:e Novecher 1983.
-MORE-l
"Morsavar, the Comptny dess not know at present to what extent there will be delays in the co==ence=ent of the diesel generator hearings by the Ato=ic Safety and licensing Board thathasbeenconsider$ngtheCo=pany'sapplicationforan operating license. These hearings were to have begun on August 29, 1983, but have been suspended until additional information concerning the crankshaf t failure is available.
The Company believes that the diesel generator hearings will be lengthier than originally conte = plated. Thus the Company believes that, under the most favorable assu=ptions, fuel loading will not take place until some time during the first quarter of 1984. Under more adverse assu=ptions, fuel loading would begin significantly later. The Company's previous estimates that the successful co=pletion of power ascensien tests at Shoreham during the period between fuel load and commercial operation would require approximately six to nine months assumed timely authorization from the Nuclear Regulatory Cem:ission to increase levels of power beyond 5%. While the Co=pany believes that the emergency response planning hearings can still be conducted concurrently with those ! relating to the diesel generators, it cannot provide any assurance that the commencement of the e=ergency response planning hearings will not also be delayed. Any delays in the receipt of such timely authorization or in the emergency response planning hearings may delay the date of commercial operation. The Company believes that the , likelihood of such delays has increased as a result of the developments regarding the emergency diesel generators.
-MORE-i
* "Engad upon cn assu=ed co=mircial opsration date of May 1,1984, th2 Compcny had astimatsd the total cost cf the Shoreham unit at approximately $3.4 billion. Under all assumptions, the Cocpany now believes that co=:ercial operation by May 1, 198'4 is no longer achievable. Although the Company cannot provide an estimate of when coc=ercial operation vill take place, it does esti= ate that delay in the co=mencement of co==ercial eperation increases the cost of the unit approxi=ately $35 million to $45 cillion a conth.
Any delay in the commercial operation date of Shoreham and any change in its costs will nffect the assu=ptions and therefore the relief whi h the New York Public Service Cot =f asion may grant in the Company's pending electric rata case, i
NEWSDAY August 17, 1983, p. 3 EXHIBIT 2
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Shoreham Damage Worse Than Believed Continued from l'ero 5. munt arcrate pmperly if the utility is to report says it is not pouible to deelde if would have to rewire. repipc ond notami- r-t on al+ rating 14cnae. *he new heads orn adequato until the cally rndenien nucports Inc tim rencr- Eiiled Nut is annlyzed The ether 1:'3 tests havo lwen succena.
!?:lwn 4 Creenman, on MitC official II,fio r id I tank ou t a fully completed.Salit anid.The fmal die- who menm Shanham t,wtlons, he luind for Aug. 22.imt it months. Ll!LO vmuld ch.o have in tent . rol test wn ' I "
down a wall in the buildine..rt.ecal it b1R bren mdefinitely pastroned.as hnvo l.{I. rssolve t ble a alter installing the new crtuipment and I"'leral liennngs on the tituta. . g g then retent the building. The !?horchnm dic cIn. Inntailed in +n, chine, a= long ns they can ensure the The units wern made hy Transamerica la7.9 nmi 197'). h.tve harl numernus entf. the NIIC und the public that the Delaval, which has hten cited fier dic el "linpment problems, inriuding crnektd synerntors are reliable." ho paid."If they prcblems at other recetorn. V.'arrantics " unsier bcnds, cicessive vibration, rnn't l. monstrate that, they can't itm on two ni the three I.llf 0 units appear nusing bolta, defects in parti nnd misn- she gibint." tn have espired. Vnrious NI'C reonrts li,:ned parts. I.:lf0 wns lined ilo.tXM ,g,, p.,tenlay, Gav. '.fario Cunmo's have idamed I.!ILO fir inamtennnce I.y thn HitC this part Apni for irrorrect rnmnuulon investic=tmg lhorehnm tidlures anel Delsvnt for mrinuinetunn; le tme. Neitber I.!!EO nnr NltC n'h- !n ord temmnny !.mm Ilrnnkhaven Na-defects. Delaval has declined to com. cials wnuld lir.t pomble rnumes for the tinnai labnratory scientists sup;nrting rnent. l'ut 1.llf0 vice prenident Irn renerntor probicmn. thitinur authon,ts- the plant and frem vamus nonkchnical l'rtilicher rnid.ycrteninv. if there t ttvo textbooks on dicaol renerntorn incli- residents nyposing it. r.cmething h rn taat'a I; lsval'n fault.- r: te that crarits ran ncrur f om gmr warranty or no wntranty, we nre ping t imitarture. cnolmq, nr p hgnment <!iir- -- - - in vek reemerv from Deinval."' M maintennnce. , no dicsci renerntnr tents enmnnacd %e Shoreham dicscis have been test-the Im.t nil'2 malelv trats scheduled for
- 4 manir times dunng the past two tFo !!horrham phmt 1+1hrn etw rr' inn. vor=, nnel rame of the problems h1ro Te of the three rencrn orn e nre r.rrdest b~en found during the tre.ta, tblit rsud.
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*nr m orne Irtn<'t.nf .9etuir nta. but all ler brndg this year.1:nt on f l!C st,tf
EXHIBIT 3 1 4 9W P TIIE WALL STREET JOURNAL y Friday. August 19, 1983 U i l ing won't occur until the first quarter of J* c0 Generator Woes J.A i.. unde, me,e ad e,se assumptions. fuel loading would begin significantly later," Mean Nuclear Facility S' e " " " 7 *dd'd-The situation will push the date of com-mercial oleration beycod Ulco's target of
; To Face FurtherI;3elay wey 1, im the company said. it didn t esa o
mate a new target date, but plans six to nine j months for testing between fuel loading and av a wau. stater Joumman. Staff Repeww, CommeTClal operation. MINEOLA, N.Y.-Img Island ughting "We won't know for several weeks ex- , Co. said new problems with diesel genera. actly what we're dealing with" In the gener-tors will force another delay in its schedule ator problem,'a spokesman said. The delay for bringing the Shoreham nuclear plant into may mean an adjustment in the 56.57e rate-operation. increase request pending before the state The ersnkshaft of one of the plant's three
- P " '"'
, t emergency generators broke during a test The company made the disclosure in a Friday. The incident will delay further tests filing with the Securities and Exchange of the equipment r.nd probably prolong Nu clear Regulatory Commission hearings into Commission in conmuon wim an an-various problems the company has had with nounced increase to $75 million from $50 million in a sale of preferred stock sched-the generators. Ulco said. uled for Monday. A spokesman said the
.Ulco was planning to load fuel at the move reflected good market conditions and plant in October, but now says that "under wasn't related to the diesel generator prob-the most favorable assumptions," fuel load- lems.
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b _ lif$7 EXHIBIT 4 ENNATRICK, IA>CKHART, HrLL. CHRISTOPHER & PHILLrrs A Pmmeste lacLesswo A PoorsassoNAL COE70EuTSON i 19o0 M Srnurr, N. W. WASHINGTON, D. C. 20o36 tr2CPstows (sos) ase.tooo gy prrresemor CARLE NEPM2 ggag7AT.JG,wra ang,goceot 6 MMIJSON TutOh *eosos ansi c isoo oxiven sezzarvo
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202/452-7044 =e: = ==c
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(BY TELECOPIER) T. S. Ellis, Esq. , Hunton & Williams 707 East Main Street . P.O. Box 1535 Richmond, Virginia 23212 - i pe: Recuest for Discovery
Dear Tim:
Last Saturday you informed me by telephone that the crankshaft on diesel generator No. 102 had broken in twc during testing with the "new-style" Transamerica Delaval cylinder heads installed. In the LILCO Report and Request for Temporary i Deferral, dated August 15, 1983, LILCO stated that the-cause ; of the failure is unknown, and the time necessary to determine the cause and the ramifications of the failure is uncertain. In LILCO's Supplemental Report on the Diesel Generators, dated August 16, LILCO stated that in its " preliminary view" the breaking of the crankshaft is act related to issues raised in Suffolk County's contention regarding the cracking of cylinder heads, but that "no firm conclusions" can yet be reached. The NRC Staff, in its Response to the LILCO Report, dated August 16, 1983, indicated that the relationship between the crankshaft failure and the cylinder head issue "cannot be ascertained prior to dismantling the disabled diesel to determine the cause of failure." It also noted that the crankshaft failure may impact upon the County's contention regarding vibration of the Shoreham emergency diesels. The County, in its filing dated August 15, 1983, agreed that the 1 crankshaft failure may be related to both the cylinder head and the vibration issues, but no conclusions can be reached until the cause of the crankshaft breaking is ascertained. Accordingly, matters relating to the crankshaft failure are clearly relevant to the County's diesel generator
6=- 6=-
- e .
KIREPATRICK. LOCKMART, HIn, Ca.nISTOPHER & Pruures T. S. Ellis, Esq. August 18, 1983 Page 2 contentions. Therefore, Suffolk County is requesting cngoing discovery (as set forth below) as to the crankshaft failure until it is determined to the County's.or the Board's satis-f action that there is no relationship between the breaking of the crankshaft and either the cylinder head cracking issue er the vibration issue. The County hereby requests: -
- 1. That LILCO promptiv notifv the County of its plans (and any changes thereto) to determine the cause (s) of the crankshaft failure, including the kinds of examinations, tests and analyses it will carry out, the schedules for them, and the identification of persons who will be involved,in the failure analyses and their responsibilities..'
- 2. That LILCO give the County reasonable advance -
notice of all examinations, tests end analyses to be carried - out in connection with the attempt to ' determine the cause (s ) of the crankshaft failure, including without limitation any diesel engine tear-down, and permit representatives and. consultants of the County to witness such examinations,. tests and analyses.
- 3. That LILCO promptly provide the County with copies of all documents (as defined below), whether preliminary er final, as and when they come into LILCO's possession or under its control, pertaining to the crankshaft failure cr the attempt to determine the cause (s) of the failure. 1/
- 4. That LILCO give the County reasonable advance notice of all meetings concerning the crankshaft failure which are to be attended by NRC Staff personnel, er to which such Staff personnel are invited, and that representatives and consultants of the County be invited to attend such me~etings.
- 5. That LILCO promptly notify the County by telephone of any and all significant developments in the attempt to determine the cause (s) of the crankshaft failure.
For purposes of this request, the word " documents" is to be given its broadest meaning, to include, without-limitation,
-1/ An example would be the report on the analysis of the oil in diesel generator No. 102,. referred to by Mr. Novarro in his comments to the Cuomo Commission on August 17, 1983.
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~ EinxrArmacx, LocxxAmr, B12.L. Cantatoruza & Puzt.t.rP3 T. S. Elli.s,, Esq.
' August 18, 1983
' Page 3 .
[ ' : A correspondence, memoranda, written data, photographs, reports,
, notes, drawings, computer printouts, written analyses, cnd I other forms'of written data and material.
- ~-
- - As you know, the Board's Memorandur and Order Deferring
- 7 -Filing of Testimony and Commencement of Hearing on riesel Generators, dated August 16, 1983, requires the parties to
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. file by August 25 a status report r.egarding any progress in .
determining the cause (s) of the crankshaft failure, and expects the parties to coordinate their " efforts and views." Other than your August 13 telephone call informing me of'the failure, the~ county has not received any.other information directly~from LILCO regarding the crankshaft failure. This discovery request _is consistent with the Board's August 16 Memorandum and Order, and obviously a rapid response by LILCO will be required if the County is to be capable of filing a l s meaningful status report with the Board. i. Enclosed is a request to the Staff which we are delivering today concerning the crankshaft failure.
- , By the way, I should remind you that we have not yet i received from LILCO the documents which were th,e subject of a the County's August 12 Renewal of Motion to Compel Discovery, I and which the Board in a conference call suggested be supplied
- to the County.
i Very truly yours, Alan Rov Dvnner - -
?
- ARD/dk Enclosure cc
- Bernard M. Bordenick, Esq.
(By Telecopier) ? 4
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, EXHIBIT 5 EIRKPATRICK LOCKHART, lITT T., CHRISTOPHER & PHILLIPS A PasrrwsmsETF INC3%Dawo A Paorsestowat Common.arsom
- 1900 M Srazzr, N. W.
WASHINGTON, D. C. 20006 TELaFaroNE (aoe) maa.rooo IN Fr:Tsattmot MLE: W1FK1 11EEPATR3CE.im*T.J0ENtoN & ETRI1 SON TEIGA 4eosos mFM C3 3500 olmes acTLDIso v.mm . ===c? m2 2. wcx.m. August 18, 1983 cm..e.oa. rey,m m .u 202/452-7044 == : => *=o (BY TELECOPIER) Bernard M. Bordenick, Esq. U.S. Nuclear Regulatory Commission, Washington, D.C. 20555
Dear Bernie:
Attached is a Request for Discover 3 which we telecopied today to Mr. Ellis concerning the crankshaft failure in diesel generator No. 102 at Shoreham. For the reasons stated therein, Suffolk County also is requesting the cooperation of the Staff concerning that failure and the attempt to deterr.ine its cause;or causes, as follows:
- 1. That the Staff promptly notify the County of its plans (if any) to determine or assist in determining the cause (s) of the crankshaft failure, including what it intends to do and when.
- 2. That the Staff inform the County of, and permit County representatives to witness, examinations, tests or analyses carried out or witnessed by Staff personnel in l connection with the attempt to determine the cause (s) of i the crankshaft failure.
- 3. That the Staff promptly provide the County with copies of all documents, reports, analyses, and other data pertaining to the crankshaft failure or the attempt to deter-mine its cause (s) .
- 4. That the Staff give the County reasonable advance notice of all meetings with LILCO or its consultants concerning the c~rankshaft failure to be attended by Staff personnel, and that County representatives and consultants be invited to attend such meetings as observers.
t
- 5. That the Staff notify the County promptly by telephone of any and all significant developments in the l
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L_=- L.... KIREPATRICK, IX)CKHART, Hu.I., CuRI2Torxza & PnII.I.rrs Bernard M. Bordenick, Esq. August 18, 1983 < Page 2 attempt to determine the cause (s) of the crankshaft failure. Your cooperation in these reports will be greatly appreciated. Very truly yours, Alan Roy Dynner ARD/dk . Enclosure cc: T. S. Ellis, Esq. (By Telecopier) - 1 y- - -m=-m--- 3,r- --wgs-r-yt yyw-- u - -
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4.. . -- . - . UNITED STATES OF AMERICA "r" - NUCLEAR REGULATORY COMMISSION KETED Di.; BEFORE THE ATOMIC SAFETY AND LICENSING B
) 83 Am 23 A11:25 In the Matter of )
) ..: .c snat.iM LONG ISIAND LIGHTING CCMPANY )
) DocketN(o.ClifTI5G 50* #24 (O. L. ) & SEE#
(Shoreham Nuclear Power Station, ) Unit 1) )
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) _
CERTIFIC ATE OF SERVIC E I hereby certify that copies of SUFFOLK COUNTY'S ANSWER AND OPPOSITION TO LILCO'S MOTION FOR A PROTECTIVE ORDER, and SUFFOLK COUNTY'S NOTICE OF POTENTIAL MOTION TO ADMIT NEW CONTENTION ON DIESEL GENERATORS, dated August 22, 1983, have been served to the following this 22nd day of August, 1983 by U.S. mail, first class, except as otherwise noted. (*) Lawrence J. Brenner, Esq. Ralph Shapiro, Esq. Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U. S. Nuclear Regulatory Commission New York, New York 10016 Washington, D. C. 20555
- Howard L. Blau, Esq.
(*) Dr. George A. Ferguson 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board School of Engineering (#) W. Taylor Reveley III, Esq. Howard University Hunton & Williams 2300 6th Street, N. W. P.O. Box 1535 Washington, D. C. 20059 707 East Main St. Richmond, Virginia 23212 (*) Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board I U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C. 20555 New York State Energy Office Agency Building 2 l Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company . l 250 Old Country Road Mineola, New York 11501 Stephen B. Latham, Esq. l Twomey, Latham & Shea Mr. Brian McCaffrey P. O. Box 3 98
- Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 l
Hicksville, New York 11001
-w - - - - - - -,.%-. -%. - . , , - - - - - - - - - - , , , , .---.# w..- , - - .-- , . - - -
, ~ . . . -. - . . . . . _ , . . . ..--. - - .. .. - - - Marc W. Goldsmith Mr . Je f f Smith Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 - Waltham, Massachusetts 02154 North Country Road Wading River, Ne'w York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rocke feller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York _12223 Hon. Peter Cohalan Suffolk County Executive David J. Gil martin, Esq. H. L'e e Dennison Suffolk County Attorney Building H. Lee Dennison Building Veterans Memorial Highway Veterans Aemorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik; Esq.
' Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D. C. 20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D. C. 20555 Appeal Board U.S. Nu clear Regulatory
(*) Bernard M. Bordenick, Esq. Commission David A. Repka, Esq. Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Jonathan D. Feinberg, Esq. Staff Counsel, New York Stuart Diamond State Public Service Comm. Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223 Long Island, New York 11747 Stewart M. Glass, Esq. Daniel F. Brown, Esq. Regional Counsel Atomic Sa fety and Federal Emergency Management Licensing Board Panel Agency / U. S. Nuclear Regulatory Commission ' 26 Federal Plaza , Washington, D.C. 20555 New York; New York 10278 James B. Dougherty, Esq. 3045 Porter Street, N. W. Washington, D. C. 20008
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Alan Roy D%ner' KIRKPATRIW , LOC KH A RT, HTLL, CHRISTOPHER & PHILLIPS DATE: August 22, 1983 1900 M Street, N.W., 8th Floor Washington, D. C . 20036
.(*) By Hand
(#) By Federal Express
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