ML20080R538

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Objections of Governor Cuomo to Util 840206 Motion to Compel Expedited Production of Documents by State of Ny.Util Possesses Complete Document Listing Responsive to Town of Southampton.Certificate of Svc Encl.Related Correspondence
ML20080R538
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 02/23/1984
From: Zahnleuter R
NEW YORK, STATE OF
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL-3, NUDOCS 8402280322
Download: ML20080R538 (18)


Text

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RELATED CORRESPONDENCE UNITED ST TES OF AMERICA UiC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

'84 FEB 27 N0 34 Before Administrative Judges

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James A. Laurenson, Chairman q'-'

Dr. Jerry R-Kline Mr. Frederick J. Shon In the Matter of Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning Proceeding)

(Shoreham Nucicar Power February 23, 1984 Station, Unit 1)

OBJECTIONS OF GOVERNOR MARIO CUOMO, REPRESENTING THE STATE OF NEW YORK, TO LILCO'S MOTION TO COMPEL EXPE-DITED PRODUCTION OF DOCUMENTS BY NEW YORK STATE I.

Background

This is in response to LILCO's motion to compel expedited production of documents by New York State, dated February 6, 1984. The State of New York opposed this motion in a memorandum of February 13. 1984. On February 15, 1984, the Board held a telephone conference and ordered the State of New York to provide LILCO with a complete list of documents that were responsive to the Town of Southampton's request for documents from the New York State Disaster Preparedness Commission ("DPC") under the New York State Freedom of Infot1 nation Law. The Board also ordered the State of New York to provide LILCO with all documents that the State of New York did not object to releasing. On February 16, 1984, pursuant to the Board's order, the State of New York provided LILCO with the first four pages of the document listing; LILCO now possesses a complete document listing.

II.

Documents Uhich Have Been Provided to LILCO For your reference, attached hereto is the complete document listing that the DPC prepared in response to the Town of Southampton's Freedom of Information 8402280322 840223 o

PDR ADOCK 05000322 C) g PDR

Law request. The document listing is entitled " Inventory of Responsive Documents" and it is marked Exhibit A.

The State of New York has provided LILCO with a substantial number of documents, despite the documents' lack of relevancy to this proceeding.

These documents are identified on the document listing by a single handwritten asterisk.

III. Documents Llhich Have Not Been Provided to LII CO and k'hich Have Not Been Submitted to the Board for an In-Camera Inspectio,n Several documents have not been provided to LILCO or to the Board for various reasons. These documents are identified on the document listing by two handwritten asterisks. A brief explanntion, according to the order in which the documents appear in the document, follows:

Document Date Explanation Undated the chart is unidentifiable and thus could not be located 9/10/E2 Christman is a cember of LILCO's law firm and thus LILCO already has the document 6/8/82 this document is a letter to Cordaro of LILCO and thus LILc0 already has the document 5/17/82 the documents ate letters to and from Cordaro of LILCO and thus LILCO al-ready has the documents 4/26/83 the handwritten note from Stasuik to Axelrod could not be located in the files 4/26/83 the document could not be located in the files Undated same as directly above Stamped received same os directly above 3/11/83 1/30/82 the month is an error; it should be "11" - the excetpt from KUKEG-0654 and the completed review sheet could not be located in the files.

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l Document Date Explanation Undated the document could not be located in the files 9/15/82 LILCO attached this document to its motion for leave to reply, and reply, to memorandum of Governor Mario Cuomo, representing the State of New York in opposition to LILCO's motion to compel expedited production of documents by New York State, dated February 14, 1984.

and thus LILCO already has the document 11/30/E2 as noted above, this is an inadvertent duplication in the document listing IV.

Documents Ubich Have Not Been Provided to LILCO Due to New York State Objections and Which are Being Submitted to the Board for In-Camera Inspection Several documents have not been provided to LILCO due to objections by the State of New York. These documents are identified on the document listing by three handwritten asterisks. Pursuant to the Board's telephone conference of February 15, 1984, the State of New York is submitting the documents to the Board for an in-camera inspection. The documents are attached hereto. A brief explanation of objections, according to the order in which the documents appear in the document listing, follows. The objections supplement any objectionr.

which are raised in the document listing. The State of New York objects to dis-closure of all of these documents because they all are irrelevant to the issues in this proceeding; therefore, LILCO has no,need for any of the documents.

Document Date Explanation of Objections 6/1/82 The document is irrelevant because it concerns a plan prepared by LILCO in the spring of 1982, which plan relied on the County and the State for implementation.

LILCO has no need for the document because the subject matter sas addressed in the letter of 6/8/82 to Cordaro of LILCO from Hennessy, which is attached to this 6/1/82 document for the Board's information. The document is i tctetted Ly executive privilege because it is merely an advisory rating by DPC staff. The rating was a recommendation

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Document Date Explanation of Objections 6/1/82 (Cont'd.)

by the DPC staff to the DPC, and the DPC never even net to censider or review the DPC staff's rating or the plan which was the subject of the rating. Such a rating is deliberative and should be protected from dicciosure in order to avoid the chilling effect disclosure would have on the ability of the DPC staff to rate this plan and others without inhibition.

Undated This document is a Summary cf Comments..."

and should not be disclosed for the reasons stated directly above.

5/17/82 and 5/14/82 These documents pertain to a meeting which LILCO attended. The documents are protected by executive privilege because they are ad-visory and deliberative and constitute in-ternal recorzendaticos, analysis and inter-pretations.

4/26/83 This document is prctected by executive privilege due to its deliberative character.

3/4/83 same as directly above 3/7/83 same as directly above, except that this document is also protected by attorney work product and attorney client privilege 2/23/83 same as directly above. The factual material already has been disclosed; see 4/18/83 document on page 3 ef the document listing 1/19/83 This document has been released in its redacted form. The unredacted portion consists of the last 2 items, which are protected by executive privilege.

2/16/83 same as 3/7/83 memo above.

2/11/83 The document is protected by executive privilege.

It contains staff analysis and advice.

1/30/82, error, This document is protected by executive privilege should be 11/30/82 because it is merely an advisory rating by DPC staff. The rating was a recommendation by the DPC staff to the DPC, and the DPC never even met to consider or review the DPC staff's rating or the plan which was the subject of the rating.

Such a rating is deliberative and sheuld bc pro-tected from disclosure in order to avoid the chilling effect disclosure would have on the n!iltty ef the DPr neeff to rete this plan and others without inhibition..-

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-Document Date Explanation of Objections 12/6/82 This document is protected by c_xecutive privilege.

7 The meeting referred to in the document never was convened.

Various dates This draf t letter is protected by executive privilege. The final version has been released, 8

see 11/29/E2 document on page 4 of the document l

listing.

g 11/24/82, 11/23/82, same as "1/30/82, error, should be 11/30/82" i

11/19/82, 11/15/82, document above 10/25/82, 9/16/82, 9/13/82, 9/8/82, and 5/17/82 11/9/82 This draft is protected by_ executive privilege.

I The final has been released, see 11/12/82 docu-ment on page 4 of the document listing.

7/23/83 This draft is protected by executive privilege and the final has been released, see 7/29/82 document on page 5 of the document listing.

In I

addition, this document is protected by attorney client privilege, see handwritten instruction on the third bucks 11p.

5/18/82 Mr. Phillips is a staff attorney reporting to l

Mr. Millock, the Departrent of llealth's General Counsel. This document is protected by attorney i

work product, attorney-client privilege and executive pr_ivilege.

7/18/83 Mi. Zahnleuter is an attorney, the unredacted portion of this document is protected by attorney work product, attorney-client privilege and executive privilege. The redacted version has

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been released. See document directly below for relevancy objection too.

7/1/83 This document is protected by executive privilege.

It is a part of the internal review process before a regulation is noticed to the public for comunent.

The document is also irrelevant to this proceeding because the DPC's proposed rules and regulations regard DPC procedures at its meetings. The regu-lations have nothing to do with this proceeding.

This argument has been eadc more fully on page 7 of the MEMORANDt'M OF COVERNOR MARIO CUOMO, REPRE-SENTING TIIE STATE OF NEW YORK. IN OPPOSITION TO LILCO'S MOTION TO COMPEL EXPEDITED PRODUCTION OF

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DOCUMENTS EY NEW YOKK STATE, dated February 13, 1984.

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Document Date Explanation of Objections 6/27/83 same as directly above, except that the docu-ment is also protected by attorney work product and attorney-client privilege.

6/20/83 same as directly above,except that the attach-ments are protected for the reasons set forth for the "1/30/82, error, should be 11/30/82" document above.

5/17/83 same as 6/27/83 document above 5/11/83 same as 7/1/83 document above 4/29/83 same as 6/27/83 document above 4/29/83 same as 6/27/83 document above 5/18/83 same as 7/1/83 document above Undated same as 6/27/83 document above.

Respcctfully submitted, MARIO CUOMO, Governor of the State of New York FABIAN G. PALOMINO, ESQ.

Special Counsel to the Governor of the State.of New York s'

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BY:

RICHARD J. ZAl%1"rER[ESQ.

l Assistant to the'Speel31 Counsel for the Governor February 23, 1984 Hauppauge, New York l.

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INVENTORY OP RESPONSIVE i

DOCUMENTS l

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6 1)' The fo' flowing document'is 'not being provided because it has already been. transmitted to Mr. ?.,atham s

,.DATE DOCUMENT _

4/14/83

-k letter from Axelrod to Latham

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A copy of each of the following documents is being provided at this time:

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_DATE DOCUMENT 4/18/83 g

testimony of Axelrod 5/10/83

.K press release of Cuomo 4/26/83 h

unidentified factual material headed by "Shoreham"

,f unidentified factual material headed by "This h

undated memorandum summarizes the recent events concerning the Shoreham Nuclear Power Station."

3/22/83 'k press release concerning Axelrod's statements to i

NRC with attachments (2/28/83 memo from Brenner to Axelrod and 3/18/83 letter to Brenner from Axelrod) t 3/5/83 p

memo to DPC members from McQueen 2/23/83 4'

letter to Cohalan from Axelrod with attachments (letter of 2/2/83 to Axelrod from Jones and letter of 3/1/83 to Axelrod from Cohalan) 12/15/82 g stipulation of settlement in Cohalan v. New York State Disaster Preparedness Commission 2/17/83

,k press release of Cuomo undated gd chart 1/19/83 g

memo to Castellano from Davidoff is being released but portion containing opinion, belief and conjecture is being redactedt attachments (letter of 1/6/83 frca Howard to Davidoff, testimony of 1/17/83, newsclip of 11/8/83) are being released 12/14/82

,,g letter from Davidof f to Jones with attachments (buck slip of 12/3/83 and letter of 12/2/82 from

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I Cohalan to Hennessy) i 12/9/82 g

motion to dismiss in Cohalan v. New York State l

i Disaster Preparedness Commission, with attachment I

(af firmation of Alvy of 12/9/82 ~and affidavit of i

Davidoff of 12/10/82)

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12/6/82

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letter to Harenberg from Hennessy with attachment (letter of 11/23/82 to Hennessy frcm Harenberg) 12/7/82

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.elegram frop Hennessy to Cohalan with attachment (telegram to.Hennessy from Cohalan) 11/29/82 letter to Cohalan from Hennessy with attachments (letter of 11/22/82 to Hennessy from Jones, letter of 9/16/82 from Jones to Davidoff, letter of 9/9/82 to Joner from Davidoff, letter of 7/26/82 to Jones from Hennessy, letter of 6/30/82 from Jones tosHennessy) 11/12/82 jg letter to Cohalan from Hennessy 9/10/82 gI le'tter to Jones from Davidoff with attachments i-(letter of 9/3/82 to Davidoff from Jones and

.y(3.. letter of 7/21/82from Christman to Hennessy) 8/3/82 ja meno to Millock from D'avidoff with attachments

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(letter of 7/28/82 from Hennessy to La Valle, and letter of 7/8/82 from La Valle to Hennessy) 6/9/82 jf2 press release 7/28/82 g' -

meno to Millock from Davidoff with attachments (letter of -7/26/82 from Hennessy to Jones, letter s

of 6/30/82 to Hennessy from Jones, letter of 6/11/82 to Cohalan from Hennessy) 7/26/82 fpf letter to Halpin from Hennessy with attachment (letter of 6/10/82 from Halpin to Hennessy) 6/23/82

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letter to Berman from Axelrod with attachment (letter of 5/25/82 to Axelrod from Berman) 6/17/82

' q.4 letter to Newburger from Hennessy with attachment (letter of 6/9/82 to Hennessy from Newburger) 6/15/82 Jg7 letter to Berger from Davidoff with attachment (letter of 5/21/82 from Derger to Hennessy) 6/15/82 fft letter to DPC members from Davidoff 6/14/82 letter to Marten from Davidoff with attached 55 petition and letter of 6/1/82 to Hennessy from Marten

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~5-6/8/82 gggp letter to Cordaro from Honnessy with attachment (review of Shoreham plan) 6/11/82 letter to Trunzo from Davidoff with attachment (letter of 5/17/82 to Davidoff from Trunzo) varicus dates yy(

letters from McQueen to various persons 7/29/82 gpf letter to Pachman from Hennessy 6/1/82 gg.34

" Analysis of Shoreham Offsite Emergency Plan" undated '4',.4 4_

" Summary of Comments on Sections A, C, and J of the Shoreham-Suffolk County Off-site. Plan" 5/26/82 m#t letter from Hennessy to Wolosin 5/17and19/82,(

legislative contact reports 5/17/82 J(44 letter to Cordaro.from Hennessy with attachments (letter of 5/10/82 from Cordaro to Hennessy) 5/17/82;p3;4s meno to Stasiuk from Davidoff 5/14/82 y :kA handwritten notes 4/19/83 and press release, statement by Governor Cuomo 5/16/83 3)

The following materials may be responsive documents, but they are being withheld on the grounds specified. The New York State Disaster Preparedness Commission and/or the New York State Department of Health reserve the right to amend or expand the grounds for withholding documents which are protected by privileges, exemptions or objections.

Mr. Millock, Mr. Phillips and Mr.

Zahnleuter are attorneys employed by the State who function as attorneys.

The following privileges, exemptions or objections are referenced by the following code system:

1)

"A" refers to inter-agency materials which are not (i) statistical or factual tabulations or datas (ii) instructions to staff that affect the public, or (iii) final agency policy or determinations l

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"B" refers to intra-agency material which are nots (i) statistical or factual tabulations or data (ii) instructions to staff that affect the public, or (iii) final agency policy or determinations:

3)

"C" refers to material prepared for litigationt 4)

"D" refers to attorney work product:

5)

"E" refers to materials protected by attorney-client privilege.

DATE DOCUMENT 4/26/83

'qefsN( ' ~ transmittal skip to Axelrod/DPC from Davidoff/DPC

~~_with two attachments (" suggested questions for consideration by the Shoreham panel" and a

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~3 handwritten note from Stasiuk/DOH to Axelrod/DPC

'concerning questions which should be emphasized):

these materials contain preliminary suggestions, recommendations. opinions, conjecture and deliberations pertaining to the consequences of radioactive materials releases, A, B.

4/26/83 N-document is being released but portion containing opinion, conjecture and beliefs concerning possible Atomic Safety and Licensing Board decisions is being redacted, A, B.

undated non-final, draf t, working copy of essay headed by "this memorandum summarizes the recent events concerning the Shoreham Nuclear Power Station.",

A, B.

stamped received 3/11/83 non-final, draft, working copies of a letter to gg p the New York Times concerning a 2/27/83 editorial re:

Shoreham, A, B.

3/4/83 M(7hth2 memo to Millock/DOH from Davidof f/DPC concerning 6

a draft reply to Brenner's 3/28/83 meno, with 7

attachment (draft, non-final response dated 3/3/83); this is deliberative material, A, B, E.

3/7/83pg_jc4-memo to Axelrod/DPC from Millock/DOH concerning b

resolution of Cohalan v. New York State Disaster Preparedness Commission with attachments (draft, j

non-final working copy of a stipulation of dicontinuance) A, B, C, D, E.

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2/23/83 5

memo from Millock/DOH to Axelrod/DPC concerning events pertaining to Shoreham, A, B, C, D, E.

1/19/83 4

meno to Castellano/DPC from Davidoff/DPC is being released butyportion pertaining to interpretation g Q ___ --e..a opinion of the hearing and news coverage is being redacted, A, B.

2/16/83 memo to Axelrod/DPC from Millock/DOH concerning

,,7'M,g failure of Suffolk County to prepare a response plan, A, B,C, D,E.

2/11/83

' memo from Slocum/DOH to Axelrod/DPC concerning an

, / :' editorial written by M. Patterson in Newsday on 2/7/83: this memo contains opinions, conjecture, evaluations, recommendations and deliberative material, A, B.

1/30/82.

memo to DPC members from Davidoff/DPC YN, transmitting DPC's staff's review of the adequacy d *.

of LILCO's plant this memo contains non-final, J..

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opinions, conclusions, evaluations and recommendations by staff which have not been acted upon the the DPC members: these documents constitute deliberative materials; attachments gy ' are ar4xcerpt from NUREG-0654 and a ccmpleted review sheet, A, B.

undated non-final, draft working copy of a DPC resolution

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B.

12/6/82.g g g non-final, draf t, working copy of a DPC press release concerning proposed 12/8/82 DPC meeting, A, B.

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various datef g draftf of Hennessy's letter of 11/29/82 to Cohalan, A, B.

11/24/82 g g memo from Czech /DPC to Davidof f/DPC containing non-final, preliminary advisory comments, opinions, evaluations, beliefs, conjecture and deliberative material pertaining to the adequacy of LILCO's plan, A, B.

11/23/82 g'g meno from Czech /DPC to Davidoff/DPC containing same subject matter as described directly above, A, B.

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%w ll/19/83,j' ggf{. g, meno to Czech /DPC from Clemente/DPC containing same subject matter as described directly above for 11/24/82 memo A, B.

11/15/92pgjq,gg memo to " Larry"/DPC from " Jim P."/DPC containing same subject matter as described above for 11/24/82 meno, A, B.

II/9/82 g g draft, non-final working copies of letter to Cohalan from Hennessy, A, B.

10/25/82 memo to Czech /DPC from Lowery /DPC containing same subject matter as described directly above for 11/24/82 meno, A, B.

9/16/82.jp g,fg memo to Czech /DPC from Clemente, same as 11/24/82 memo A, B.

9/15/82

'*hIds memo to Dillenbeck/DPC from Albertin/ DOT, same as 11/24/82 memo, A, B.

9/13/82 hN memo to Davidoff/DPC from Czech /DPC, same as 11/24/82 memo, A, B.

9/8/82 gg-memo to Czech /DPC from Popile/DPC, same as 11/24/82 memo, A, B.

7/23/83 49). 44 darft, non-final letter from Hennessy to Pachman.

5/18/82 DN(+k memo from Phillips/DOH to Millock/ DOM concerning legal issues pertaining to LILCO's plan, A, B, D, E.

5/17/82 memo to "REPG Staf f" from Davidoff concerning assignments for Shoreham plan review, A, B.

11/30/82, ga4 meno to DPC members from Davidoff/DPC containing non-final, preliminary advisory comments, opinions, evaluations, beliefs, conjecture and' deliberative material pertaining to the adequacy of LILCO's plan, A, B.

7/18/83,gt memo to.Davidoff/DPC from Zahnleuter/DOH advising of the applicable comment period for regulations, g.g A,B,D,E.

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7/1/83 g< A

-meno to Abernsthy/DOH from Duncan/DOH circulating L

for internal review proposed, dra,ft, regulatiens and regulatory impact statement, this is deliberative material, A, B.

6/27/83 memo to Taylor /DOH from Millock/DOH transmitting a revised, proposed regulation transmittal form for further internal review, this is deliberative material, A, B, D,E.

6/20/83 gg,g memo to Millock/DOH from Zahnleuter/DOH with attachments (rating sheet for "Shoreham Offisite Emergency Plan" and pages 31-79 of an unidentified document) circulating non-final, draft, proposed regulation transmittal form for internal review, this ir, deliberative material, A,

B, D,E.

5/17/83 meno to Millock/DOH from Zahnleuter/DOH p p, q discussing and identifying several possible modifications of proposed regulation transmittal form, this is deliberative material, A, B,

D, E.

5/11/83 M-5'N slip from Slocum/DOH to Duncan/DOH expressing comments on proposed regulation transmittal form, this is part of the internal review process and is deliberative material, A, B.

' 4/29/83

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',Ijq memo to Millock/DOH from Zahnteuter/DOH l

requesting comments and opinions concerning draft l

proposed regulation transmittal form, this is i

part of the internal review process and is deliberative material, A, B,

D, E.

h' 4/29/83_p3gg same as meno directly above, but containing l

handwritten comments, A, B, D, E.

5/18/83 -yqjk.h[

memo to Duncan/DOH from Holohean/DOH expressing comments on proposed regulation transmittal form, this is part of the internal review process and is deliberative material, A, B.

g(g6hht handwritten meno from Millock/DOH to l

undated l

Axelrod/DPC/DOH concerning possible contents of t

l-the proposed draft regulations, this is deliberative material and part of the internal review process, A, B, D, E.

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vz UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges James A. Laurenson, Chairman Dr. Jerry R. Kline

-Mr. Frederick J. Shen

)

In the Matter of

)

)

Docket No. 50-322-OL-3 LONG ISLAND LICHTING CONPANY

)

(Emergency Planning Proceeding)

)

(Shoreham Nuclear Power Station,

)

February 24, 1934 Unit 1)

)-

)

)

CERTIFICATE OF SERVICE I hereby certify-that one copy of the OBJECTIONS OF GOVSRNOR MARIO CUOMO, REPRESENTING THE STATE OF NEW YORK, TO I.ILCD'S Mor10N TO COMPEL EXPEDITED PRODUCTION OF DOCUMENTS BY NrW YORK STATE has been nerved to each of-the following this 24th day of February 1984 by U. S. Mail, first class, except as otherwise noted:

  • James A. Laurenson, Chairman Ralph Shaptro, Esq.

Atomic Safety and Licensing Board

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

20555 New York, Ucw York-10016

  • Dr. Jerry R. Kline

'Howard L. Blau, Esq.

Administrative Judge 217 Newbridge Read

'. Atomic Safety and Licensing Board Hicksville, New York 11801 U.G. Nuclear Regulatory Commission Washington, D. C.

20555

  • Mr. Frederick J. Shon
  • U. Taylor Revelcy itI, Esq.

' Administrative Judge.

Hunton & Williaris 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.

Mr. Jay Dunk 1cherger General Counsel New York Etate inergy Office Long Island Lighting Company Agency Building 2 250 Old Country Road Empire State Pinza Mincola, New York 11501 Albany, New Yorf 12223

f-6 Mr. Brian McCaffrey James B. Dougherty, Esq.

Long'. Island Lighting Company 3045 Porter Street, N. W.

175 East Old Country Road Washington, D. C.

20008 Hicksville, New York 11801 Jeff Smith Stephen B. f.athan, Eaq.

Shoreham Nuclear Power Station Twemey, Latham & Shen P. O. Box 618 P. O. Box 398 North Country Road 33 West Second Street' Wading River,_New York 11792 Riverhead, New York 11901

. Martin'Bradicy Ashare, Esq.

Marc W. Goldsmitti Suffolk County Attorney Energy Research Croun, Inc.

H.~ Lee Dennison Building 400-1 Totten Pond Road Veterans Memorini liighway Walthrus, Massachusett s 02154 Ilauppauge, New York 11788 Atomic Safety and Licensing MllB Technical Ast oci tt en

-Board Panel 1723 Hamilton Avenue

.U.S. Nuclear Regulatory Commission Suite K Washington, D. C.

20555 San Jose, On11fornia 95125 Docketing and Service Section lionorable Peter 1. Cthalan Office of the Secretary Suffolk County Erecutive U.S. Nuclear Regulatory Commission

11. Lee Dennison Euilding 1717 H Street, N. W.

Veterans Memorial llir,hway Washington, D. C.

20555 llauppauge, Mew Yerk 11788

'* Bernard M. Bordenick, Esq.

Ezra I. Bialik, Esq.

-David A. Repta, Esq.

Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Prctection Bureau

. Washington, D. C.

20555 New York State Department of Law 2 World Trade Center New York, New Yor k '0047 Stuart Diamond Atomic Safety and Licensing Appeal Environment / Energy Writer

. Board NEWSDAY U.S. Nuclear Regulatory Commission Long_ Island, New York 11747 Washington, D. C.

20555

  • Stewart M. Class, Esq.

Jonathan D. Feinierg. Esq.

Regional Counsel Staff Counsel Federal Emergency Management New York State Public Servi:e Agency Commission 26 Federal Plaza, Room 1349 3 Rockefeller Plaza New York, New York 10278 Albany, New York 12.'23 Nora Bredes

  • llerbert II. F.rown, Esq.

h Executive' Director Lawrence Coe Lant er. Esq.

Shoreham Opponents Coalition Koela J. Letsche, Esq.

195 East Main Street 1900 M Strent, N. Y., Suite 800 Smithtown, New York 11787 Washington, D. C.

20036

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    • Eleanor L. Frucci, Esq.

Spence Perry, Ecq.

Atomic Safety and Licer. sing -

Associate General Counsel Board Panel Federal Emergency }Mnagement Agency U.S. Nuclear Regulatory Commission Washington, D.'O.

20036 Washington, D. C.

20555

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.r (WA(,12.l

&,& Lpb?&fff Assistant to the(El:TEf/ /fip6 dial Counsel ITICIIARD J. ZAllh to the Governor of the State of New York Executive Chamber State Capitol Albany, New York 122?4

  • By Hand on February 23, 1984
    • By U. S. Express Mail on February 24, 1984 Ilauppauge, New York February 24, 1984