ML20082G897
| ML20082G897 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/09/1991 |
| From: | Reveley W HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#391-12112, CON-#391-12113 OLA, OLA-2, NUDOCS 9108210223 | |
| Download: ML20082G897 (14) | |
Text
_-
L' 73// b f]
LILCO, August 9,1991 UNITED STATES On AMERICA qga NUCLEAR REGULATL.i COMMISSION YC Before the Atomic Safety and Licensing Board
.cj r p p*fR in the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OLA and
)
Docket No. 50-322-OLA-2 (Shoreham Nuclear Power Station,
)
Urit 1)
)
LILCO'S RESPONSES TO PETITIONERS' HLINGS OF AUGUST 5 AND 6 On August 5 and 6, Petitioners filed Gree pleadings variously styled, " Motion for Official Notice to Correct Representation," " Peti ioners' Response to LILCO's Letter of July 29 Regarding Physical Security Plan," and " Notice of Relevant Decision and Significance." In the interest of economy, LILCO rephes to all of them here.
1.
Resoonse to " Motion for Of'icial Notice to Correct Reoresentation" Petitioners' August 5 motion ostensibly seeks "to correct a representation" made by counsel for LILCO concerning the operating license fer the Wolf Creek plant, NPF-42.
LILCO's representation was accurate at the time made and remains so. Rather, it is Petitioners' August 5 motion which requires correction, in two respects.
Petitioners now concede that licensees of operating plants, as well as of those headed for decommissioning, may be authorized only to possess, rather than to " possess, use and operate" the plant. The original Wolf Creek operating license, excerpted in their motion, makes the point: one of the three Wolf Creek owners (Kansas Electric Power Cooperative, or KEPCO) was licensed only to possess. That was LILCO's point at the prehearing conference.1' l'
indeed, Amendment 4 to the Wolf Creek license, dated November 4,1986, limits all three Wolf Creek owners -- Kansas Gas & Electric Company (KG&E) and Kansas City Power and (continued...)
910e21o22a 910o09 3
)
PDR ADOCK 05000322 h
0 PDR
2 Itaving conceded that an operating plant licensee may be authorized only to " possess" but not "use and operate," Petitioners try to conjure a distinction between a " possession" license and a " possession-only" license, asserting that it is "not a choice between homonyms without signincance." However intriguing linguistically, this unsupported distinction simply finds no basis in the record of the decommissioning rule. 53 Fed. Reg. 24,024 (June 27,1988),
2.
Reolv to Response to LILCO's Letter of July 29 Regarding Physical Security Plan Petitioners' August 5 " Response" argues that LILCO's documentation of the Suffolk County Police Department's consent to the modification of the Shoreham Physical Security Plan (which LILCO believes is an essentially irrelevant issue) opens the issue rather than closing it.
Petitioners cre wrnng.
The " quest ons" raised by Petitioners confirm that their objective is a nshing expedition i
on security matters. Petitioners have never tried to show how their complaints about the Security Settlement Agreement relate to protection of health and safety at Shoreham. Nor have they raised any affirmative basis to doubt that the Suffolk County Police Department consented to the modi 5 cation of the Shoreham Physical Security Plan.
LILCO has es:ablirhed an i
unrebutted prima facie case on the issue. Indeed, the availability of record (and supporting i
internal) documentation on LILCO's compliance with that agreement have driven Petitioners now to allege, in effeu, that a misrepresentation must have been made at some point along the way I'
(... continued)
Light Company (KCPL) as well as KEPCO -- to possession only. A jointly owned subsidiary, Wolf Creek Nuclear Operating Corporation, is the only entity authorized to "use and operate" the facility, as well as " possess" it. Amendment 4 is attached. Attention is invited to page 2, i B for the identification of Wolf Creek Nuclear Operating Corporation; to 1 F for the statement of the possession-only powers of the three owning corporations, KG&E, KCPL and KEFCO; and to 11 E and G-V for a speci6 cation of the duties attendant upon the powers to "Inssess, use and operate the facility" vested solely in the subsidiary " Operating Corporation."
i
3-by either LILCO personnel under oath in an affidavit, by Captain Cosgrove of the R ffolk County Police Department, by the NRC Staff (also a party to the Security Settlement Agreement), or by LILCO counsel. Petitioners have laid no basis for their allegation about this irrelevant contention. There is none. Their contention should be dismissed.
3.
LILCO's Response to Petitioners' " Notice of Relevant Decision and Sienificance" Petitioners' August 6 " Nod m" recognizes that the United States Supreme Court has now twice concurred with this Board,.:e Commission, and the Court of Appeals for the District of Columbia Circuit in denying their requests for emergency orders to prevent the effectuation of the possession-only license for the Shoreham plant. Each tribunal has heard and rejected Petitioners' arguments. Yet Petitioners' " Notice" persists in reasserting to this Board the "need" for such relief, without any new bases. To the extent that this latest " Notice" constitutes an unacknowledged renewed motion for such relief, this Board should refuse it again, for the same reascns already found persuasive by it, the Commission, and reviewing courts.
Respectfully submitted (f
s N
WMaylor Reveley, Ill Donald P. Irwin David S. Harlow Counsel for Long Island Lighting Company Hunton & Williams Riverfront Plaza, East Tower 951 East Byrd Street Richmond, VA 23219 DATED: August 9,1991
____.-_.__...._m._._
't.
- oig
( [g='
UMITED STATES
,1..
n' NUCLGAR REGULATORY COMMISSION i
3-i WASMNOTON, D. C. 2%86 November 4, 1986 L ROESTtyt MOTIVCD Docket No.:
50-482 M 10198S i
Mr. Glenn L. Koester Vice President - Nuclear Xansas Gas and Electric Company 201 North Market Street Post Office Box 208 Wichita, Kansas 67201
Dear Mr. Koester:
Subject:
Wolf Creek Generating Station - Amendment No.4 to Facility Operating License NPF-42 The Comission has issued the enclosed Amendment do. 4 to Facility Operating License NPF-42 for +5e Wolf Creek Generating Station. The amendment is in respgnse to your application dateddp18!81'19;"1986, and supplemented JtPlyr.29, 1986.
This amendment modifies the operating license and Technical Specifications to pennit licensed activities to be under the control of the Wolf Creek Nuclear Operating Corporation.
The amendment is effective January 1,1987.
A copy of our related Safety Evaluation is enclosed. Notice cf issuance will be included in the Commission's next bi-weekly Federal Register notice.
Sincerely.
04u]. Q Paul W. O'Connor, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A
Enclosures:
1.
Amendment No. 4 to I-License No. NPF-42 2.
Safety Evaluation-L cc w/ enclosures:
See next page 4
r.
_...,,._,._,._m
.,.,,.m_-.-,
m.-
y
.,_m.
y.m,
..r-
,y.-.v,'
4 4
4 Mr. Glenn L. Kocster Wolf Creek Generating Station Kansas Gas and Eiectric Company Unit No. I cc:
Mr. Nicholas A. Petri;k Mr. Gary L. Haden, Of rector Executive Director, SMJPPS Research & Energy Analysis 5 Choke Cherry Road Kansas Corporation Commission Rockville, Maryland 20850 4th Floor - State Office Building Topeka, Kansas 66612-1571 Jay Silberg, Esq.
Shaw, Pittman, Putts & TrowSridge Regional Administrator, Region IV
?300 N Street, NW U.S. Nuclear Regulatory Commission Wcshington, D.C.
20037 Office of Executive Director for Operations Mr. Donald T. McPhee 611 Ryan Plaza Drive, Suite 1000 Vice President - Production Arlington, Texas 76011 Kansas City Power & Light Company 1330 Baltimore Avenue Mr. Allan Mee Kansas City, Missouri 64141 Project Coordinator Kansas Electric Power Cooperative,Inc.
Chris R. Rogers, P.E.
P. O. Box 4877 Manage, Electric Department Gage Center Station Public 5ervice Commission Topeka, Kansas 66604 P. O. Box 360 Jefferson City, Missouri 65102 Resident Inspector / Wolf Creek NPS c/o U.S. Nuclear Regulatory Commission i
Regional Administrator, Region III P. O. Box 311 U.S. Nuclear Regulatory Commission Burlington, Kansas 66893 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Brian Moline Chief Legal Counsel Senior Resident Inspector / Wolf Creek Kansas Corporation Commission c/o U. S. Nuclear Regulatory Commission 4th Floor - State Office Building i
P. O. Box 311 Topeka, Kansas 66612-1571 r
Burlington,. Ka nsas 66839 Mr. Robert Elliot, Chief Engineer Utilities Division Kansas Corporation Commission 4th Floor - State Office Building Topeka, Kansas 66612-1571 l
Mr. Gerald Allen Public Health Physicist 8"reau of Air Quality & Radiation Control Division of Environment Kansas Department of Health and Environment Forbes Field Building 321 Topeka, Kansas 66620 1
j
/
UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
{
f WASHINoToN. D C,20565 y
gl' '
i
- KANSAS GAS & ELECTRIC COMPANY KANSAS CITY POWER AND LIGHT COMPANY KANSAS ELECTRIC POWER COOPERATIVE, INC.
WOLF CREEK GENERATING STATION DOCKET NO. 50-482 AMENDMENT TO TACILITY OPERATING LICENSE Amendment No. 4 License No. NPF-42 1.
The Nuclear Regulatory Commission (the Commission) has found that:
I The application for amendment to the Wolf Creek Generating Station A.
(the facility) Facility Operating License No. NPF-42 filed by Kansas Gas and Electric Company acting for itself and Kansas City Power and 4
Light Company and Kansas Electric Power Cooperative, Inc., (the licensee) dated April 15, 1986, and supplemented July 29, 1986, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended-(the Act),- and the Commission's rules and regulations set forth in 10 CFR Chapter I 8
8.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is-reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health r
and safety of the public; and (ii) that such activities will be conducted in compliance with the Commission's regulations; 0.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. -The issuar.ce of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, Facility Operating License No. NPF-42 is changed as follows:
[
A.
Change paragraph 1.E. to read as follows:
i
-vt-y yn-y-w----e---->c,vw,,r-,,--,---e.ew---v---r--
=
.-w.
e-em--
-=e4-e er
=---:
. - =
2-Wolf Creek Nuclear Operating Corporation
- is technically qualified to engage in the activities authorized by this license in accordance with the Commission's regulations set forth in 10 CFR Chapter 1; B.
Change the footnote related to paragraph 1.E. to read as follows:
- Wolf Creek Nuclear Operating Corporation is authorized to act as agent for the Kansas Gas and Electric Company, Kansas City Power &
Light Company, and Kansas Electric Power Cooperative, Inc., and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.
C.
Change paragraph 2. A. to read as follows:
The license applies to the Wolf Creek Generating Station, Unit No.1, a pressurized water nuclear reactor and associated equipment (the facility), owned by Kansas Gas and Electric Company, Kansas City -
Power & Light Company, and Kansas Electric Power Cooperative. Inc.,
and operated by the tilf Creek Nuclear Operating Corporation. The facility is located in Coffey County, Kansas, approximately 28 miles cast-southeast of Emporia, Kansas, and is described in the licensees'
" Final Safety Analysis Report," as supplemented and amended, and in the licensees' Environmental Report, as supplemented and amended.
D.
Change paragraph 2.B. to read as follows:
f Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Wolf Creek Nuclear Operating Corporation (the Operating Corporation), Kansas Gas and Electric Company (KG&E),
Kansas City Power & Light Company (XCPL), and Kansas Electric Power Cooperative, Inc. (KEPCO):
E.
Change paragraph 2.B.(1) to read as follows:
Pursuant to Section 103 of the Act and 10 CFR Part 50 " Domestic Licensing of Production and Utilization Facilities," the Operating Corporation, to possess, use and operate the facility at the designated location in Coffey County, Kansas, in accordar.ce with i
the procedures and limitations set forth in this license; F.
Change paragraph 2.B.(2) to read as follows:
KG&E, KCPL and KEPC0 to possess the facility at the designated location in Coffey County, Kansas, in accordance with the procedures and limitations set forth in this license; G.
Change paragraph 2.B.(3) to read as follows:
The Operating Corporation, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended;
-wi-m-
-%m,-%,,,yy,
, _ -. - - -. ~. - - -. - - -. - -
3 H.
Change paragraph 2.B.(4) to read as follows:
t The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealeo sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; I.
Change paragraph 2.B.(5) to read as follows:
The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any by-product, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibra-tion or associated with radioactive apparatus or corrponents; and J.
Change paragraph 2.B.(6) to read as follows:
The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct end special nuclear materials as may be produced by the operation of the facility.
K..
Change paragraph 2.C.(1) to read as follows:
I The' Operating Corporation is authorized to operate -the facility at reactor core power levels not in excess.of 3411 megawatts thermal (100%
a power)-in accordance with the conditions specified herein and in Attach-ment I to this license. The activities identified in Attachment 1 to this license shall be completed as specified. Attachment 1 is hereby incorporated into this license.
L.
Change paragraph 2.C.(2) to read as follows:
Rchnical specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through AmerJment Nc. 4, and the Environmental Protection Plan con-tained in Appendix B, both of which are attached hereto, are hereby_
l incorporated into the license. The Operating Corporation shall cper-ate the facility in accordance with the_ Technical Specifications and l
the Environmental Protection Plan.
i i
L M.
Change paragraph 2.C.(5) to read as follows:
Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5)
(a) The Operating Corporation shall maintain in effect all provisions' i
of the approved fire protection program as described in the SNUPPS I
Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, and as approved in the SER through Supplement 5 subject to provisions b & c below, i
I
4
}
r
/
4 (b) The Operating Corporation may make no change to the approved _
fire protection program which significantly would decrease the l
level of fire protection in the plant without prior approval of the Comission.
To make such a change the licensee must submit l
an application for license amendment pursuant to 10 CFR 50.90.
l (c) The Operating Corporation may make enanges to features of the l
approved fire protection program which do not significantly de-l crease the level of fire protection without prior Comission.
approval, provided:
l (1) such changes do not otherwise involve a change in a l
Ifcense condition or technical specification or result i
in an'unreviewed safety question (see 10 CFR 50.59).
l (ii) such changes do not result in failure to complete the l
fire protection program approved by the Comission prior.
l to license issuance.
l The Operating Corporation shall maintain, in an auditable fonn, a current record of all such changes including an analysis of the effects of the change on the fire protection program and shall make such records available to NRC inspectors upon request.
All changes to the approved program shall be reported to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR j
(-
revisions required by 10 CFR 50.71(e).
l
- N. - Change paragraph 2.C.(6) to read as follows:
)
-Qualification of Personnel (Section 13.1.2, SSER #5, Section 18, 55ER #1) i g
The Operating Corporation _shall have on each shift operators who i
meet the requirements _ described in Attachment 2.
i 0.
Change paragraph 2.C.(7) to read as follows:
HUREG-0737 Supplement 1 Conditions (Section 22. SER) i The Operating Corporation shall complete the requirements described l
in Attachment 3 to the satisfaction of the NRC..These conditions reference the appropriate items in Section 22, "TMI Action Plan Re-quirements for Applicants for Operating Licenses," in the Safety Evaluation. Report and Supplements 1, 2, 3, 4, and 5 of NUREG-0881.
L P.
Change paragraph 2.C.(11) to read as follows:
l Steam Generator Tube Rupture (Section 15.4.4, SSER #5)
I t
Prior to restart following the first refueling outage, the Operating Corporation-shall submit for NRC review and approval an analysis which 1
demonstrates that the steam generator single-tube rupture (SGTR) analysis presented in the FSAR is the most severe case with respect to the release of fission products and calculated doses. Consistent i
with the analytical assumptions, the licensee shall propose all necessary changes to Appendix A to this license.
4 5
I
~ -.-
u - ;.
--.,_ m.-_ _ _
__.c,-.._~..-.-_-.-_~.-.-,,-
..--m..-
.. -.,, - - ~ _ -, -, - -, - - - -.
e :
s t
)
- l Q.
Change paragraph 2.C.(12) to read as follows:
LOCA Reanalysis (Section 15.3.7. SSER #5)
Prior to restart following the first refueling outage, the Operating i
Corporation shall submit for NRC review and approval a reanalysis for l
the worst large, break LOCA using an approved ECCS evaluation model, j
R.
Change paragraph 2.C.(13) to read as follows:
Generic Letter' 83-28 i
The.0perating Corporation shall submit responses to and implement the l
requirements of Ganeric Letter 83-28 on a schedule which is consistent i
with that given in their February 29, 1984 and February 6,1985 letters.
i S.
Change paragraph 2.C.(14) to read as follows:
[
Surveillance of Hafnium Certr.
Rods (Section 4.2.3.1(10),SER and 55ER #2)
.a The Operating Corporation shall perform a visual inspection of a sample i
of hafnium control rods during one-of the first five refueling outages.
A summary of the results of these inspections shall be submitted to the NRC _
f T.
Change paragraph 2.E. to read as follows:
The Operating Corporation shall fully implement and maintain in effect ell provisions of the Commission approved Physical Security, Guard Training and Qualification, and Safeguards Contingency plans, in-cluding all amendments and revisions made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), which are part of the license. These i
plans, which contain Safeguards Infonnation protected under 10 CFR 73.21 i
are entitled " Wolf Creek Generating Station, Physical Security Plan; Safeguards Contingency Plan and the Security Training and Qualification Plan".
i U.
Change Attachment 2 to read as follows:
}
L The Operating Corporation shall have a licensed senior operator on each l
shift who has had at least six months of hot operating experience on a i
same type plant, including at least six weeks at power levels greater g
-than 20% of full power, and who has had startup and shutdown experience.
For those shifts where such an individual is not-available on the-plant staff, an advisor shall be provided who has had at least four years of l
power plant experience, including two years of nuclear plant experience.
and who has had at least four years of power plant experience, including j
two years of nuclear plant experience, and who has ac least one year of experience on shift as a licensed senior operator at a similar type j[
facility.
Use of advisors who were licensed only at the R0 level will be evaluated on a case-by-case basis.
Advisors shall be trained on i
plant procedures, technical specifications and plant systems, and shall j
l t
i l
s
6
?
be examined on these topics at a level sufficient to assure familiarity in the role of the advisors. These advisors, or fully trained and qualified replacements, shall be retained until the experience levels identified in the first sentence above have been achieved. The names J
of any replacement advisors shall be certified by the Operating Corporation prior to these individuals being placed on shift.
The NRC shall be notified at least 30 days prior to the date the Operating Corporation proposes to release the advisors from further service.
V.
Charge Attachment 3 to rea e i<11ows:
NUREG-0737, SUN q.4T 1, REQUIREMENTS (1) Functional and Task Analysis (I.C.1, SSER #5)
Prior to startup following the first refueling outage, the Operating Corporation shall submit for staff review and approval, a description of the process used to complete the functional and task analysis, including a description and justification for all infonnation and control deviations from the Westinghouse Owners be s p Emergency Response Guidelines, Revision 1.
(2)
Emergency Response Capabilities (Generic 1.etter 82-33, Supplement 1 to NUREG-0737)
I Prior to restart followin the first refueling outage, the Operating Corporation sina 1 have a fully functional Technical Support Center and Emergency Operations Facility and a fully operable Emergency Response Facilities Information System (ERFIS).
(3) Regulatory Guide 1.97 (Section 7.5.2.3, SSER #3)
Prior to restart following the first refueling outage, the Operating Corporation shall have installed and operable the following i
instrumentation.
L j.
(a) Source rance instrumentation qualified to post-accident l
conditions 1
(b) Reactor vessel water level instrumentation (c) Subcooling monito.3 (d) Radiation monitors for releases from steam generator safety / relief valves or atmospheric dump valves, and (e) Auxiliary feedwater pump turbine exhaust monitor l
l l
l
s
~
7 3.
Facility Operating License No. NPF.42 is further amended 'oy changes to the Technical Specifications as indicated in the attachment to this license amendment.
4 This license amendment is effective January 1, 1987.
FOR THE NUCLEAR REGULATORY COMMISSION N.
Paul O'Connor, Project Manager PWR Project Directorate #4 Division of P!!R Licensing-A
Attachment:
Changes to the Technical Specifications Datt if issuance:
November 4, 1986 e
l
LILCO, August 9,1991 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
]}
Before the Atomic Safety and Licensint' Board
~
'91 AUG 12 P 4 :08 In the Matter of
)
,;t
)
1 ;y,,,
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OLA and
)
Docket No. 50-322-OLA-2 (Shoreham Nuclear Power Station,
)
Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of LILCO'S RESPONSES TO PETITIONERS' FILINGS OF AUGUST 5 AND 6 were served this date upon the following by fax as indicated by an asterisk, t
by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.
Morton B. Margulies, Esq., Chairman
- Mitzi A. Young, Esq
- Atomic Safety and Licensing Board Of5ce of the General Counsel l
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission i
East-West Towers, Fourth Floor One White Flint North 4350 East-West Highway 11555 Rockville Pike BeJiesda, Maryland 20814 Rockville, Maryland 20852 Dr. Jerry R. Kline*
James P. McGranery, Jr., Esq.*
Atomic Safety and Licensing Board Dow. Imhnes & Albertson U.3. Nuclear Regulatory Commission 1255 23rd Street, N.W., Suite 500 East-West Towers, Fourth Floor Washington, D.C. 20037 4350 East-West Highway l
Bethesda, Maryland 20814 Docketing and Service Section Of5ce of the Secretary Dr. George A. Ferguson" U.S. Nuclear Regulatory Commission i
Atomic Safety and Licensing Board Washington, D.C. 20555 5307 Al Jones Drive Columbia Beach, Maryland 20764 Nicholas S. Reynolds, Esq.
David A. Repka, Esq.
Thomas S. Moore, Esq., Alternate Winston & Strawn Chairman
- 1400 L. Street, N.W.
L Atomic Safety and Licensing Board Washingten, D.C. 20005 l
U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 i
l l
Q 2-Stanley B. Klimberg, Esq.
Stephen A. Wakefield, Esq.
Executive Director and General General Counsel Counsel U.S. Department of Energy long Island Power Authority 1000 Independence Avenue, S.W.
200 Garden City Plaza, Suite 201 Washington, D.C. 20585 Garden City, New York 11530 Gerald C. Goldstein, Esq.
Carl R. Schenker, Jr., Esq.*
Office of General Counsel Counsel, leng Island Power Authority New York Power Authority O'Melveny & Myers 1633 Broadway 55513th Street, N.W.
New York, New York 10019 Washington, D.C. 20004 Samuel A. Cherniak, Esq.
New York State Department of law Bureau of Consumer Frauds and Protection 120 Broadway New York, New York 10271 1
Donald P. Irwin Hunton & Williams Riverfront Plaza, East Tower 951 East Byrd Street Richmond, Virginia 23219-4074 i_
DATED: August 9,1991 l
1
...