ML20077P100

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Motion for Protective Order Re Util Notice of Deposition of F Jones & L Koppelman.Individuals Are Not Witnesses.Areas of Inquiry Irrelevant to Emergency Planning Proceeding. Certificate of Svc Encl.Related Correspondence
ML20077P100
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 08/29/1983
From: Brown H
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20077P097 List:
References
ISSUANCES-OL-3, NUDOCS 8309130298
Download: ML20077P100 (16)
v • d • e


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00CKETED UNITED STATES'OF AMERICA l NUCLEAR REGULATORY ~ COMMISSION Pi:i6-Before'the' Atomic--Safety and Licens g

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In the' Matter of

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LONG ISLAND LIGHTING COMPANY Docket No. 50-3 2 2--OL-3 (Shoreham Nuclear Power Station,

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(Emergency Planning)

Unit -1)

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SUFFOLK COUNTY MOTION FOR A PROTECTIVE ORDER LILCO.has noticed the deposition of Mr. Frank Jones,

' Deputy'Suffolk County Executive, and Dr. Lee Koppelman, Director of the County Planning Department.

Neither person has

~been.{dentified by the County as a prospective witness.

Never-

-theless, LILCO desires to depose Mr. Jones and Dr. Koppelman on six subjects:

(1) the aspects of radiological emergency response planning at Shoreham that led the (Suffolk l

' County] Steering Committee to the conclusion that it was-infeasible,.

(2) the bases on which the Steering Committee reached that' conclusion, (3)

[Dr. Kopy3 man's/Mr. Jones'] views on the feasibility of radiological emergency response planning:at Shoreham, 8309130298 830907 DR ADOCK 05000322 PDR m w g

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[Dr. Koppelman's/Mr.' Jones'] views ~on the role of-the~Suffolk County governmenu in the'. event of a' radiological emergency at Shoreham assuming that?the LILCO Transi-tion Planlis'in effect, (5)

Suffolk County's' emergency planning for nonradiologicaliemergencies, e.g., hurricanes,

blizzards, and (6) suffolk-County's emergency planning for radiological emergencies at other nuclear facilities, e.g., Brookhaven National Laboratory, Northeast Utilities' Millstone Station.1/

For reasons discussed below,-Suffolk County submits that m.

Lthese areas of inquiry are not relevent to the emergency I

planning-proceeding.

Accordingly, Suffolk County requests this LBoard.to issue'a protective-order'barring the depositions.

To i

t put'the instant motion in perspective, some background data i

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LBackground-L-

Prior'to March 1982, several County employees in the s

. County Planning' Department worked on a draft'Suffolk County

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emergency plan.

In early 1982, the County found the ongoing o

emergency planning' work to be inadequate, and in March 1982 discarded.the work to date.

In place of that, the. county embarked (ni. a new greatly ~ upgraded planning effort through a i;

team of nationally recognized experts.

'l/_-See Notices of Deposition, dated August 25, 1983.

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.The discarded--emergency planning work was subscquently revised and completed by LILCO over County objections, and was called the "LILCO-County plan" in LILCO's May 26, 1983,

' Memorandum of Service of-Supplemental Emergency Planning Information.: By Order Limiting Scope of Submissions, dated June 10, 1983, this Board ruled that the LILCO-County plan was'not to be litigated in this proceeding unless the County first agreed'to implement that Plan.

The post-March 1982 County planning effort was directed by the Suffolk County Radiological Emergency Response Plan Steering Committee.

Mr. Jones and Dr. Koppelman (as well as other persons) were members of the Steering Committee.

The County's_ consultants produced a draft County-plan in December 1982.' The County Legislature considered the draft plan during eight days of hearings in January 1983 and rejected it in I

February 1983.

456-1982 and 111-1983, / the Suffolk County 2

In Resolutions Legislature resolved the following:

-- In Resolution 456-1982, the Legislature resolved that

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no County personnel or resources would be used to test or L

implement any emergency response plan for Shoreham unless the l

plan had first been. approved by the County Legislature; and

-- In Resolution 111-1983, the Legislature resolved not l

to approve or implement any emergency response plan for Shoreham.

The Legislature also terminated the County's planning process for Shoreham.

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2/ Copies of Resolutions 456-1982 and 111-1983 are attached hereto.

1

4-These. resolutions constitute' County law:

the County will not. train-for or respond to a Shoreham emergency.

That law is binding. conclusively upon the County and'its employees.

Discussion With the foregoing background in mind, the County next demonstrates that LILCO's proposed depositions should be barred.

(1)

Steering Committee Process.

In items 1 and 2 of the deposition notice, LILCO proposes to inquire into those

'" aspects of radiological emergency response planning at Shoreham that led the. Steering Committee to the conclusion that it was infeasible" amd "the bases on which the Steering Committee reached that conclusion." / Therefore, the clear thrust of 3

this inquiry.is to inquire.into the County's own planning process prior to'the February ~1983 decision of the Legislature to reject.the County's draft plan.

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-The-focus of the instant emergency planning proceeding is i

Enot on the County's planning process or the County's decision not to adopt a-plan.

Rather, the sole focus is whether the LILCO Transition Plan meets the NRC's emergency planning requirements.

Thus,.'just as the Board ruled that it would "not entertain certain contentions premised solely on the absence i

of a Suffolk County approved plan,"1/ and just as the Board in 3/ To correct a factual misstatement'in the Deposition Notices, 0

.the' Steering Committee did not say emergency planning was-

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" infeasible."

The Committee oversaw preparation.by the l

County's' consultants of a draft plan, and the Legislature

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then rejected that plan in Resolution 111-1983.

l 4/LMemorandum-and Order Denying-Suffolk County's Motion to

~' Terminate the Shoreham Operating License Proceeding, p. 62,

-~ April'20, 1983.

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, e LJune 1983 barred: litigation'of1the LILCO-County plan,_the Board

-also should now rule that the. factors or bases which led the

' County to reject its own plan are also not relevant here.

Put simply, the County's decision-making process is.not on trial'before the NRC.

Thus, this Board should issue a protective order barring inquiryDinto that process.5/

(2). Views on Feasibility.

LILCO.next proposes to inquire into the views'of Mr.' Jones and Dr.'Koppelman regarding "the

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' feasibility of radiological emergency response. planning at 1

Shoreham." - This inquiry again is not relevant.

The central issue is whether the LILCO plan meets regulatory requirements, includingLLILCO's capability to implement the. plan.

The

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" feasibility" of.' planning in Suffolk County as some sort of abstract matter.is not relevant.

(3)

County Response.

LILCO also proposes to obtain the

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r views of Mr. Jones and Dr. Koppelman regarding "the rolc of 1

the Suffolk County-government in the event of a radiological emergency _at Shoreham assuming that'the'LILCO Transition Plan is in'effect." ~The law (Resolutions-456-1982 and 111-1983) presently is clear that the County will not respond to a shoreham I

_ emergency, and.thatylaw is conclusive. 'There is no factual

~ dispute lon that issue'.-

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L5f The County.does not object to LILCO inquiry into substantive emergency planning matters which are at-issue in the immediate proceeding 'and-were -considered in the County's planning i

effort..Such issues include'the evacuation shadow phenomenon L

and. role conflict problems.

The proper inquiry, however, is.

i how these matters may' affect-the LILCO' Transition Plan.

l LILCO, however, wishes to inquire into these matters within L

the. context of the County planning effort -- something which j

is not an' issue in this proceeding.

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_(4) JCountyEPlanning for Nonradiological Emergencies.

lLILCO next proposes to inquire ~about County " emergency planning Tfor nonradiological emergencies, e.g.,

hurricanes, blizzards." '

First, nonradiological emergencies have no relevance to this

. proceeding.

More important, however, the County planning-for usuch1 emergencies clearly is-irrelevant.~ This proceeding concerns LILCO's planning, not the County's.

-(5)

County Planning for Other Nuclear Facilities.

Finally, LILCO proposes to depose Mr. Jones and Dr. Koppelman concerning I

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"Suffolk County's planning for' radiological emergencies at other nuclear facilities,.e.g., Brookhaven National Laboratory, North-east Utilities Millstone Station." 'Again, the County's planning processes are not at issue here'.

Indeed, if LILCO thinks the

_ County's processes are relevant, it had an obligation to submit contentions thereon.

For'the foregoing reasons, Suffolk County respectfully urges

that the Board issue a protective order.barring the proposed

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depositions.of Dr. Koppelman and Mr. Jones.

' Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law f

Veterans Memorial Highway Haup auge, New York 11788 arr fw ou..

i Herbert H. Brown

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Lawrence Coe Lanpher' Karla J. Letsche ~

KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,

Suite 800 Washington, D.C.

20036 DAugust.29,-1983 Attorneys for Suffolk County 4

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'. Intro. Ris,

o.,,1516-82 Introducsd by Legislators Blass, Rosso, Folsy, Caracappa, Giese, A11 grove, f

nichards, Wehecnberg, Rizzo, Nolan, Hariton, Noto, Howard, Prorpect, LaBut,

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Dovine, Meazek-I RESOLUTION NO.

fe 56 ' -19 8 2, ESTABLISHING THE

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RADIOLOGICAL EMERGENCY RESPONSE PLANNING POLICY OF THE COUNTY OF SUFFOLK

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'w'HEREAS, County of Suffolk has.the primary responsibility for the j

protection of its residents in the event of a radiological emergency at the Long Island Lighting Company's,shoreham Nuc1 car Power Stations and hy WHEREAS,- Suffolk County takes this responsib.11ty seriously and intends, l

through good faith and sound planning ef forts, to an sce that the best possible er,orgency plan and preparedness are developed to protect the citizens of Suffolk County; and

p'i WHEREAS, Suffolk County's Emergency Planning Task Force,. composed of y

nationally recognized experts drawn from a range of pertinent disciplines, is

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. now conducting a detailed planning e ffort viable radiological emergency plan for Suffolk County; andin order to attempt to develop a-WHEREAS, The Long Island Lighting Company, in an unwarranted and arrogant 1 !

act, has gone beyond its powers as a private corporation in an attempt to

,j; the rightful powers of usurp Suffolk County by submitting county planning resource' material to the New York State Disaster Preparedness Commission for its approval

- ry as the efficial radiological emergency response plan for Suffolk County; and WHEREAS, said planning resource material

.'.3 personnel, is preliminary data which in no way constitutes thedeveloped in part by county Suffolk County-

. # ' approved RADIOLOGICAL EMERGENCY RESPONSE PLAN and will not in the future

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constitute such County plan; and V '

WHLREAS, Suffolk County will submit its RADIOLOGICAL EMERGENCY RESPONSE 4@ PLAN to the New York State Disaster Preparedness Commission only when that plan:

has been fully prepared and approved by Suffolk County and is thereby integrated je J' with the planning efforts of both LILCO and New York States therefore, be it

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RESLLVED, that Suffolk County hereby established the following.

Radiologice.1 Emergency Response Planning Policy:

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Suffolk County shall not assign funds or J

j personnel to test or implement any I

radiological emergency response plan for the Shoreham Nuclear Plant unless that

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plan has been fully developed to the best of the County's ability.

Suffolk County shall not assign funds of perconnel to test or implement any i'

radiological emergency response plan for -

.i the Shoreham Nuclear' Plant unless that b

plan has been the subject of at lease two.

7 public hearings, one to be held in River-head, and one to be held in Hauppauge.

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personnsl to test or impicment any radiological em<rrgency respor=ue plan for the shoreham Nuclear Plant unitess that k

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Plan has been approved, after public hearings, by the Suffolk County Legislature

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'and, be it further 4y RESOLVED, that copies of 7g Speaker of the Assecbly, the Majority Leader of the Senate andthis resolution be sen the of the State of New York.

the Legislaturo i

DATED: May 18, 1982

' 3 BY 4

APPPC'. k W s Cour).y Executive of Suf folk County

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Date of Approval:

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ty. w i. g.,,tiggy,3, William H. Rogers. Clerk of the f

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County Legislature of the County of Suffolk, have compared the RIVEltilEAD N. Y. i foregoing copy of resolution with the original resolution now on file in q

this office, and hich was duly adepted by the County legislature of said County on

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and that thesame a true and correct transcrip t of said resolution and of f

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the whole thereal k

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r. pan.pp,.f.,3 have hereunto set my hand and the official sealof the County legislature of the County of Suffolk.

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Clerk of the County 1,ristature

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Intro., Rec. No. 1196-83 Introduced by Legiolatoro Wahranburg, Caracopps, D' Andre, Geise, Allgrove, Bachat}

Prospect, Foley, Nolan, Blass, Rizzo, LaBua,- Devine, Hariton. Beck

' RESOLUTION NO. 111 - 1983, CONSTITUTING THE FINDINGS AND DETERMINATIONS OF SUFFOLK COUNTY ON WHETHER A LEVEL.OF EMERGENCY PREPAREDNESS TO RESPOND TO A TJLDIOLOGICAL ACCIDENT AT THE SHOREHAM NUCLEAR POWER STATION CAN PROTECT THE HEALTH, WELFARE AND SAFETY OF THE RESIDENTS OF SUFFOLK COUNTY WHEREAS, Suffolk County has a duty under the constitution of the State of N:w York, the New York State Municipal Home Rule Law, and the Suffolk County Charter to protect the health, safety, and welfare of the residents of Suffolk County; and

WHEREAS, the Long Island Lighting Company ("LILCO") is constructing and dacires to operate the Shoreham Nuclear Power Station ("Shoreham"),

located on tha north shore of Long Island near the town of Wading River, a location which is within the boundaries of Suffolk County; and

WHEREAS, a

serious nuclear accident at Shoreham could result in the rolcase of significant quantities of radioactive fission products; and

WHEREAS, the release of such radiation would pose a severe hazard to the health,. safety, and welfare of Suffolk County residents; and
WHEREAS, in recogr.ition of the effects of such potential hazard posed by Shoreham on the duty of Srffolk County to protect the
health, safety, and welfare of its citizens, this Legislature on March 23, 1982, adopted Resolution No. 262-1982, which directed that suffolk County prepare a " County Radiological

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Emargency Response Plan to serve the. interest of the safety, health, and welfare of the citizens of Suffolk County.."; and L

WHEREAS, in Resolution 262-1982, the Legislature determined that the plan dnvaloped by the County "shall not be operable and shall not be deemed adequate end - capable of being implemented until such time as it is approved by the Suffolk County Legislature"; and

WHEREAS, in adopting Resolution 262-1982, the Legislature found that earlier planning efforts by LILCO and County planners (the

" original planning

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were inadequate because they failed to address the particular problems L

poned by conditions on Long Island and further failed to account for human l

bah 2Vior during a

radiological emergency and the lessons of the accident at Three Mile Island; and l-

WHEREAS, on March 29, 1982, Peter F. Cohalan, Suffolk County Executive, l

ccting to ' implement Resolution 262-1982, by Executive Order established the Suffolk County Radiological Emergency

Response

Plan Steering Committee

.(" Steering Committee") and directed it to prepare a County plan for submittal to l

th3 County Executive and County Legislature; and l

WHEREAS, the Steering Committee assembled a group of highly qualified and nationally recognized experts from diverse disciplines to prepare such County plan; and I

Page 2 Intro,. Res. No. 11%-83 _...

,WHEREAS, cuch highly qualified expsrto. worked in a

diligent and

'cencciantious offort at a coct in excess of

$500,000 to prepare the best Possible plan for Suffolk County, and particularly to ensure that such. plan took into account.all particular physical and behavioral conditions on Long Island that af fect the adequacy of the emergency response plan; and WHEREAS, th'e analyses, studies, and surveys of such experts included:

(a)

Detailed analyses of the possible releases of radiation from Shoreham; (b)

Detailed analyses of the radiological health consequences of such radiation release on the por11ation of Suffolk

County, giventhe meterological, demographic, topographical, and other specific,

local conditions on Long Island; (c)

A detailed social survey of Long Island residents to determine and assess their intended behavior in the event of a

serious accident at Shoreham; (d)

A detailed survey of school bus drivers, volunteer firemen, and certain other emergency response personnel to determine whether '

emergency personnel intend to report promptly for emergency duties, or instead to unite with their own families, in the event of a serious accident at Shoreham; (e)

Detailed estimates of the number of persons who would be ordered to evacuate in the event of a serious accident at

Shoreham, as well as the number of persons who intend to evacuate voluntarily even if not ordered to do so; (f)

Detailed analyses of the road network in Long Island and the time l required to evacuate persons from areas affected by radiation,

releases; I

(g)

Detailed analyses of the protective actions available to Suffolk County residents to evacuate or take shelter from such radiation releases; and i

(h)

Analysis of the lessons learned from the accident at Three Mile Island on local government responsibilities to prepare for a

radiological emergency; and WHEREAS, on May 10, 1982, LILCO, without the approval or authorization of

.ths Suffolk County Government, submitted to the New York State Disaster i

Proparedness Commisssion

("DPC")

two volumes entitled "Suffolk County Radiological Emergency Response Plan" and containing the original planning data, l

eo' further revised and supplemented by LILCO, and requested the DPC to review land approve such LILCO submittal as the local radiological emergency response plcn.for Suffolk County; and l

WHEREAS, in Resolutions 456-1982 and 457-1982, the County further zcddressed the matter of preparing for a radiological emergency at Shoreham and L

emphasized that:

1 (a)

The LILCO-submitted document was not and will not be the County's Radiological Emergency Response Plan; and l

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Th3 Csunty 0 Radiological EmergIncy Racponce Plcnning Policy, CO Enunciatsd-in'Razolution 456-1982, is as follows:

Suffolk._ county shall not assign funds or personnel to test or implement any radiological emergency response plan for the*

Shoreham Nuclear Plant unless that. plan has been fully developed to the best of the county's ability.

Suffolk County shall not assign funds or personnel to test or implement any-radiological emergency response plan.for the shoreham Nuclear Plant unless that plan has been. subject of at least two ~ public hearings, one to be held in Riverhead, and one to'be held in Hauppauge.

Suffolk County shall. not assign funds or personnel to test or,

-implement any radiological emergency response plan for

the, Shoreham Nuclear Plant unless that plan has been approved, after public hearings, by the Suffolk County Legislature and the County Executive; and

_. WHEREAS, on June,9, 1982, the _ DPC rejected the LILCO-submitted document for the reason that it was deficient; and

WHEREAS, on October 6,
1982, LILCO, again without the approval or Euthorization of the Suffolk County Government,-submitted to the DPC an amended; varcion' of the previously submitted LILCO document which had been rejected by tha DPC; and.

- WHEREAS,_

on - Dece.nber.

2, 1982, the Draft County Radiological Emergency

- Rssponse Plan. authorized by Resolution 262-1982 was submitted to the County Lagislature for review and public hearings as specified in Resolutions 262-1982, 456-1982, and 457-1982; and.

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- WHEREAS, in January

1983, the. Legislature held hearings on the Draft

- CountyLplan, which hearinJs included:

(a)

More. than 1,590 pages of ' transcripts; (b)

Detailed written statements and oral testimony of County expert consultants who prepared the-Draft County plan; E

(c)-

Detailed -written statements and - oral testimony of LILCO officials and. expert consultants retained by LILCO; i

(d)

Detailed written statements and. oral testimony of the Suffolk l

County Police Department, -the County. Health Department, the County Social Services department, and the County Public Works Department, all of which would have indispensable roles in responding to a radiological emergency at Shoreham:

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'(e)

Detailed written statements and oral testimony of organizations in Suffolk-County-concerned with radiological emergency preparedness; and (f)

Extensive presentations-by hundreds of members of the general t

public; and w

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. intro. Res. No. 1196-83 Page 4

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WHEREAS, membero or tha Legiolatura cico trcvallcd to cnd held public hacringa in the vicinity of tha Three Milo Islcnd Nuclear Power Plcnt to gcin information on the lessons to be learned by local governments from the accident ct Three Mile Island; and
WHEREAS, the Draft County plan identifies evacuation and protective chaltering as the two primary protective actions which would need to be implemented in the event of a serious accident at Shoreham; and
WHEREAS, evacuation of Suffolk County residents in the event of a rcdiological emergency could take as much time as 14-30 hours because of various
fcctors, including:

the limited number of appropriate evacuation routes in Suffolk County; difficulties in mobilizing police and other emergency personnel; difficulties ensuing from spontaneous evacuation of large numbers of County rc2idents, thus creating severe traffic congestion; and unavilability of alternate evacuation routes for persons residing east of Shoreham and thus the ncc ssity for such persons during an evacuation to pass by the plant and porgibly through the radioactive plume; and

WHEREAS, evacuation times in excess of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> and certainly ovecuation times in the range of 14-30 hours will result in virtual immobilization of evacuation and high exposure of evacuees to radiation such that evacuees' health, safety, and welfare would not be protected; and
WHEREAS, protective sheltering is designed to protect persons from excassive radiation exposure by such persons staying indoors until radiation with the greatest danger to health has passed; and
WHEREAS, if protective sheltering were ordered for Suffolk County recidents, unacceptable radiation exposure would still be experienced by substantial portions of the suffolk County population, thus making it impossible to provide for the health, welfare, and safety of these residents; and
WHEREAS, the document submitted by LILCO to the DPC without County cpproval or authorization is deficient because it does not deal with the actual local conditions, physical and behavioral, on Long Island that would be encountered during a serious nuclear accident at Shoreham; and i
WHEREAS, the document submitted by LILCO to the DPC without County cpproval or authorization does not ensure that effective protective action by percons subject to radiation exposure, in the form of evacuation or sheltering, would be taken in event of a serious nuclear accident at Shoreham, and thus such document, even if implemented, would not protect the health, safety, and welfare of Suffolk County residents; and
WHEREAS, the extensive data which the Legislature has considered make clonr that the site-specific circumstances and actual local conditions existing on Long
Island, particularly its elongated east / west configuration which rcquires all evacuation routes from locations east of the plant to pass within a zona of predicted'high radiation, the ineffectiveness of protective sheltering, th3 severe traffic congestion likely to be experienced if a partial or complete cvncuation were
ordered, and the difficulties in ensuring that emergency parconnel will promptly report for emergency
duties, preclude any emergency racponse
plan, if implemented, from providing adequate preparedness to protect tha health, welfare, and safety of Suffolk County residents; now, therefore, be it l

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RESOLVED, th t tha araft C2unty 'plcn cubmittco to tho County Lcgiolatura an.Dechmber 2, 1982, if impicmentcd, would not protcct tha hsalth, welfara, and ccfoty of Suffolk County residents and thus is not approved and will not be,

implemented; and be it further

RESOLVED, that the document submitted by LILCO to the DPC without the County approval or authorization, if implemented, would not protect the health,'
welfare, and safety of Suffolk residents and thus will not be approved and will not be implemented; and be it further
RESOLVED, that since no local radiological emergency response plan for a carious nuclear accident at Shoreham will protect the
health, welfare, and enfety of Suffolk County residerats, and since the preparation and implementation of cny such plan would be misleading to the public by indicating to County recidents that their health, welfare, and safety are being protected when, in fcet, such is not the case, the County's radiological emergency planning process io hereby terminated, and no local radiological emergency plan for response to en cccident at the Shoreham plant shall be adopted or implemented; and be it further
RESOLVED, that since no radiological emergency plan can protect the hon 1th, welfare, safety of Suffolk County residents and, since no radiological emargency plan shall be adopted or implemented by Suffolk County, the County Ex cutive is hereby directed to take all actions necessary to assure that cctions taken by any other governmental agency, be it State or Federal, are concistent with the decisions mandated by this Resolution.

DATED: February 17, 1983 APP EY:

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Countf Executive of Suffolk County Date of Approval:

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' l 00LKETCO ji G UNITED STATES OF AMERICA NUCLEAR ' REGULATORY COMMISS*EI)N SEP 12 P1 :16 Before the Atomic Safety and Licensi_nq Board:7u,

YdC'ti$ Tire d S N W.

BRANCH

)

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322-OL-3

)

(Emergency Planning)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY MOTION TO COMPEL DISCOVERY and SUFFOLK COUNTY MOTION FOR A PROTECTIVE ORDER, dated September 7, 1983, have been served to the follow-ing by U.S. mail, first class, except where noted, this 7th day of-September 1983.

'

  • James A. ' Laurenson, Chairman Ralph Shapiro, Esq.

Atomic Safety and Licensing Board Cemmer and Shapiro

'U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D.C.

20555 New York, New York 10016

  • Dr. Jerry ~R.

Kline Howard L. Blau, Esq.

-Atomic Safety and Licensing Board 217 Newbridge Road U.S. Nuclear Regulatory Commission Hicksville, New York 11801 Washington, D.C.

20555

    • W. Taylor Reveley, III, Esq.
  • Mr. Frederick J. Shon Hunton & Williams Atomic Safety and Licensing Board P.O.

Box 1535 U.S. Nuclear Regulatory Commission 707 East Main Street Washington, D.C.-

20555' Richmond, Virginia 23212 Edward M. Barrett, Esq.

General' Counsel Mr. Jay Dunkleberger-Long Island Lighting Company

- New York State Energy Office 250 Old Country' Road Agency Building 2 Mineola, New-York' 11501 Empire State Plaza Albany, New York 12223 Mr. Brian McCaffrey-Long Island Lighting Company Stephen B.

Latham, Esq.

175 East Old Country Road-Twomey, Latham & Shea Hicksville, New York 11801 33 West Second Street Riverhead, New York 11901 By Hand

    • By Federal Express

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.a Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.

195 East Main Street Washington, D.C.

20555 Smithtown, New York 11787 Hon. Peter Cohalan Marc W. Goldsmith Suffolk County Executive Energy Research Group, Inc.

H.

Lee Dennison Building 400-1 Totten Pond Road Veterans Memorial Highway Waltham, Massachusetts -02154 Hauppauge, New York 11788 MHB Technical' Associates Eleanor L.

Frucci, Esq.

1723 Hamilton Avenue Atomic Safety and Licensing Suite K Board Panel

.95125 U.S. Nuclear Regulatory Comm.

San Jose, California Washington, D.C.

20555 Joel-Blau, Esq.

New York Public Service Comm.

Ezra I.

Bialik, Esq.

The Governor Nelson A.

Rockefeller Assistant Attorney General Building Environmental Protection Bur.

Empire State Plaza New York State Dept. of Law Albany,1New York-12223 2 World Trade Center New York, New York. 10047 David J. Gilmartin, Esq..

Suffolk County Attorney Atomic Safety and Licensing H.

Lee Dennison Building Appeal Board Veterans-Memorial Highway U.S. Nuclear Regulatory Comm.

Hauppauge, New York' 11788 Washington, D.C.

20555

~ Atomic Safety and Licensing Jonathan D.

Feinberg, Esq.

Board Panel Staff Counsel, New York State U.S. Nuclear Regulatory Commission Public Service Commission

' Washington, D.C.

20555 3 Rockefeller Plaza Albany,-New York 12223 9 Bernard M.

Bordenick, Esq.

David A.

Repka, Esq.

    • Stewart M. Glass, Esq.

U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C.

20555~

Federal Emergency Management Agency Stuart Diamond 26 Federal Plaza, Room 1349 l

Environment / Energy Writer New York, New York 10278 i

NEWSDAY Long Island, New York 11747 James B. Dougherty, Esq.

3045 Porter Street, N.W.

I Washington, D.C.

20008 L i.

l l

l

'e Spence Perry,.Esq.

Associate General Counsel Federal Emergency Management Agency Washington, D.C.

20472 Mr.-Jeff Smith Shoreham Nuclear Power Station P.O. Box 618

-North Country Road Wading: River, New York 11792 s?

Christopher M. McMurtaf KIRKPATRICK, LOCKHART, HILL, CHBISTOPHER & FHILLIPS 1900 M Street, N.W., Suite 80D Washington, D.C.

20036 DATED:

September 7, 1983

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