ML20087M472
| ML20087M472 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/27/1984 |
| From: | Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8403290377 | |
| Download: ML20087M472 (19) | |
Text
{{#Wiki_filter:I I RELATED CC.BZSFONDENCE 196 DOCKETED usuac UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION. g g g.y Before the Atomic Safety and Licensing Board ) In the Matter of ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 ) (Emergency Planning) (Shoreham Nuclear Power Station, ) Unit 1) ) ) SUFFOLK COUNTY SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO LILCO'S
SUMMARY
DISPOSITION MOTIONS ON CONTENTIONS 24.B, 33, 45, 46 AND 49 Pursuant to the Board's oral ruling of March 20, 1983 (Tr. 3904) Suffolk County hereby supplements its March 5, 1984 I l Memorandum in Opposition to LILCO's Summary Disposition Motions on Contentions 24.B, 33, 45, 46 and 49-(hereinafter, " County Memorandum"). The purpose of this supplement is to bring to the Board's attention certain matters contained in the Consolidated RAC Review submitted on March 15, 1983 by FEMA to the NRC (here- \\ inafter, "RAC Review") that support the County's position with respe t to the summary disposition motions. Pertinent pages of. the RAC Review are attached hereto. Contention ~.24.B The following'seven statements _ in the RAC Review support the ~ County's position that LILCO.has failedito. demonstrate that there- ^ are no genuine issues of fact material to'Contentionf 24.B in dispute, as discussed at pages 2-7 of the County Memorandum and' ~ @S03 8403290377 840327 PDR ADOCK 05000322 o PDR
..... _ = _. . ~.. _ - -. 4 i in the Statement of Material Facts as to which There Exist Genuine Issues to be Heard Concerning Contention 24.B annexed to the County Memorandum: 1. The letter of agreement from DOE on page APP-B-1 does not specify the degree of i response to be provided. Shoreham's requirement is closer to that of..a " compensating measure" rather.than radio-logical assistance, as is stated ~in the letter. DOE's role, in this case, is that of the offsite response agency, providing independent dose assessment capabilities. This..is not clearly stated in the generic let,ter from DOE which limits' DOE's role to ". advice and emergency action essential for the con-trol of the immediate hazards to health and safety." RAC Review at 9, relating-to NUREG 0654 element.A.3. See
- hereto.
2. Letters of agreement could not be located for the following support organizations /' persons or Representative Outside Agencies (see Procedure OPIP 2.1.1, page l
- 12) identified in the plan.
- Laboratories which provide environmental sample. analysis - Radiological Health Coordinator (outside' consultant) Letters of agreement with support organi-zations which-provide laboratory and environmental sample. analysis could not ( be located in-the plan. E 0
~ d , The resources LERO expects to use to support the federal responses which are identified in Attachment 3.11.1 should be supported by letters of agreement from those organizations. RAC Review at 10, relating to NUREG 0654 element A.3. See hereto. 3. Written letters of agreement are incomplete. Letters of Agreement were not found in Appendix B for all organiza-tions listed in Sections 2.2, 3.5 and.11.1 of the plan (also see analysis comments for element A.3). RAC Review at 13, relating to NUREG 0654 element C.4. See hereto. 4. [T]he letter of agreement between DOE and LILCO' limits DOE radiological assistance to " advice and emergency action essential for the control of immediate hazards to health and safety" (i.e., in an actual' emergency) - see Appendix B, page APP-B-1. 4 RAC Review at 53, relating to NUREG 0654 element N.2.d. See , hereto. 5. Figure 2.1.2 shows the LERO Radiation Health Coordinator as having primary responsibility-for accident assessment, while Figure 2.1.1, page 2 shows this-position as being filled by "other personnel." The discussion on page 2.1-3 line 36 implies that-this position is a-LERO function..2.1, page'2, lines 24-25 states that DOE will perform accident assessment. From the' language on page 2.1-1, it appears that-the Radiation Health Coordinator is provided by DOE /BHO, but this is not confirmed by the LERO chart- (Figure 2.1.2) under L Health Services Coordinator..Clarifica-tion should.be provided in the.planDas to l l the role of the "outside consultant (s)" in performing the accident assessment function. RAC Review at 3, relating to NUREG 0654 element A.l.c. See hereto. 6. The plan does not specify whether LERO has accident assessment personnel who can weigh the plant's status from an opera-tional view in developing protective action recommendations. The choice of protective actions is apparently keyed almost entirely to radiation dose or projected dose. Consideration should be given to the plant's status including: prognosis for stabilizing, improving or worsening situations, or timing of releases so that preventive evacuation prior to a release is not overlooked when such releases may be imminent. The plan does not specify how protective action decisions would be made in the absence of an actual release. The plan should specify that protective actions such as sheltering, and especially evacuation, could be implemented prior to initiation of significant releases, if possible. RAC Review at 28, relating to NUREG 0654 element I.8. See hereto. 7. Section 2.2, Attachment 2.2.1 states that the DOE Brookhaven Area Office can pro-vide support to LILCO for airborne radio-iodine sampling and analysis to concen-trations as low as 5X10E-08. While the equipment listed is potentially capable of making the required measurements, the methodology shown in Procedure OPIP 3.5.1 (see Section 5.3.7b) would not give accurate results for most accident condi-tions. Even without core damage, radio-iodine may be collected on the particu-late filter if the iodine is in elemental form. Therefore, one cannot rule out activity on the particulate filter as not being iodine. Also, the nomogram which relates iodine to total fission products
f . for the calculation of thyroid dose (OPIP 3.5.2, Att. 11) may not be realistic in this aspect. Furthermore, the. amount of fission products collected from a core damage accident are highly dependent on a number of parameters, such as moisture in containment, filtration of release, l distance from the site, etc., and are not easily amenable-to the nomogram assumptions. i RAC Review at 29, relating to NUREG 0654 element I.9. See hereto. Contention 33 ) The following two statements in the RACEReview support the County's position that LILCO has failed to demonstrate that there 4 are no genuine issues of fact material to Contention 33-in dis-pute, as discussed at pages 7-11 of.the County Memorandum and in 4 the Statement of. Material Facts'as to which There Exist Genuine Issues to be Heard Concerning Contention 33 annexed to the County Memorandum: 1. Communications equipment on page 4.1-4 should include radio links between the field teams'and EOC. RAC Review at-26,_ relating to'NUREG 0654 element H.ll.- See 1 l Attachmen,t 8 hereto. 2. LERO has'not specified what. resources have-been identified by: federal' agencies hi .to support t e r effort (e.g., air-fields, command. posts,-telephone lines, radio frequencies and telecommunications centers). j .RAC. Review at 12, relating to.NUREG.0654 element C.~1.~c. -See I ,. hereto. i E' h g_g L:.- - ---2--- - L ~
. 4 ? Contentions 45 and 46 The following three statements in the RAC Review support the County's position that LILCO has failed to demonstrate that there are no genuine issues of fact material to contentions 45 and 46 in dispute, as discussed at pages 11-16 of the County Memorandum, a and in the Statements of Material Facts as to which There Exist Genuine Issues to be Heard Concerning Contentions 45 and 46 annexed to the County Mem'randum: o 1. Clarification should be provided in the plan as to the role of the "outside consultant (s)" in performing the accident assessment function. RAC Review at 3. See Attachment 5 hereto. 2. [T]he letter of agreement between DOE and LILCO limits DOE radiological assistance to " advice and emergency action essential for the control of immediate hazards to health and safety" (i.e., in an actual 4 emergency) - see Appendix B, page APP-B-1. RAC Review at 53. See Attachment 4 hereto. 3. LERO has not specified what resources + have been' identified.by federal agencies to support their effort (e.g., air fields, command posts, telephone lines, radio frequencies and-telecommunications centers). RAC Review at 12. See Attachment 9. hereto. ~ Contention 49 The following statement _in~the RAC Review support.the County's position that LILCO has failedJto demonstrate that there I are no genuine ~ issues of fact' material to Contention 49 in dis- .pute, as discussed at pages 16-18 of thecCounty Memorandum, and l l L
. in the Statement of Material Facts as to which There Exist Genuine Issues to be Heard Concerning Contention 49 annexed to the County Memorandum: [T]he nomogram which relates iodine to total fission products for the calcula-tion of thyroid dose (OPIP 3.5.2, Att.
- 11) may not be realistic in this aspect.
Furthermore, the amount of fission-products collected from a core damage accident are highly dependent on a number of parameters, such as moisture in con-tainment, filtration of release, distance from the site, etc., and are not easily amenable to the nomogram assumptions. RAC Review at 29. See Attachment 7 hereto.- Conclusion forth in 'ull in the County Memorandum, For the reasons set f LILCO's Summary Disposition Motions on Contentions 24.B, 33, 45, 46 and 49 should be denied. Respectfully submitted, Martin Bradley Ashare. Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 Her'bert H. Brown /" Lawrsnce Coe Lanpher Karla J. Letsche-KIRKPATRICK, LOCKHART,. HILL, CHRISTOPHER & PHILLIPS 1900 M Street,- N.W., Suite 800 Washington,-D.C. 20036-Attorneys for Suffolk County Dated: March 27, 1984 -w,
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review - Dated February 10, 1984 Page 9 of 50. NUREG-0654 Element Review' Comment (s) Ratinc A.3 Letters of intent from bus and ambulance Cont. suppliers are included in Appendix B for the following resources : e Bus companies - (1559/? vehicles #) Ambulance companies - (224/? vehicles ##) e Bowever, these letters of intent do not commit the bus and ambulance companies to supply equipment to LERO in the event of a radiological emergency at the Shoreham site, because contracts have not as yet been finalized with the bus or ambulance suppliers. The contract revisions requested by several of the ambulance companies could limit the number of ambulances and ambuletts that will be available. The LERO Transportation Support Coordinator is responsible for driver support. The LILCO plan states that the utility will provide trained licensed 'LILCO employees as a major source of bus drivers (Appandix A, III-36). The plan should specify the number of drivers that have been trained and licensed to respond to a radiological emergency at SNPS. The letter of agreement from DOE on page APP-B-1 does not specify the degree of response to be provided. Shoreham's requirement is closer to that of a " compensating measure" rather than radio-logical assistance, as is stated in the letter. DOE's role, in this case, is that of the offsite response agency, providing independent dose assessment capabilities. This is not clearly stated in the generic letter from DOE which limits DOE's role to advice and emergency action. essential for the control of the immediate hazards to health and safety." t Includes buses, vans, coaches, flexetts, etc. !! Includes ambulances, ambuletts, etc.
ATTACHMENT 2 L2LCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 10 of 60 80 REG-0654 Element Review Comment (s) Ratine A.3 Letters of agreement could not be located for Cont. the following support organizations / persons or Repreeentative.Outside Agencies (see Procedure OPIP 2.1.1, page 12) identified in the plan. e Stony Brook Hospital e Central Suffolk Hospital e SUNY Stony Brook BOCES Central Islip e e SCCC Selden e Local law enforcement agencies Local fire departments e Local snow removal organi:ations e Federal Aviation Administration e e Laboratories which provide environmental sa=ple analysis e Radiological Health Coordinator (outside consultant) e Relocation center coordinator e Nursing support e Counselling coordinator Letters of agreement with support organ-i:ations which provide laboratory and en-vironmental sample analysis could not be located in the plan. The resources LERO expects to use to support the federal responses which are identified in Attachment 3.11.1 should be supported by letters of agreement from those organizations.itt
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details ).
- itLetter of intent with Coram Bus Service is included in Appendix 3, pages APP-3-30 and 30A.
ATTACHMENT 3 LILCO Transition Plnn for Shoreham - Rovicion 3 Consolidated RAC Review Dated February 10, 1984 .Page 13 of 60 NU REG -06 5 4 Element Review Comment (s) Ratine C.2.a LERO representatives are already at the A SNPS site and may be dispatched to the near-site Emergency Operations Facility (EOF). C.3 Page 3.5-2 of the plan identifies two ORS A teams from DOE-RAP for monitoring services and several other organizations for analyses. C.4 Written letters of agreement are incomplete. I* Letters of Agreement were not found in Appendix a for all organi:ations listed in Sections 2.2, 3.5 and Attachment 3.11.1 of the plan (also see analysis comments for element A.3). "This element is inadequately addressed in the plan. In addition, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details). 1
ATTACHMENT 4 LILCO Trancition Plan for Shorcham - Revision 3 w Consolidated RAC Review Dated February 10, 1984 .A. Page 53 of 60 4 ) NU REG - 06 5 4 Element Review Comment (s) Rating N.2.d The referenced section of the plan A provides for radiological monitoring drills. The plan is adequate in addressing this element provided that it is clarified in the plan whether DOE-RAP personnel will participate in the radiological monitoring exercises. This clarification is requested since the letter of agreement between DOE and LILCO limits DOE radiological assistance to " advice and emergency action essential for the control of im=ediate ha:ards to health and safety" (i.e., in an actual emergency) - see Appendix B, page APP-B-1. N.2.e.(1) Page 5.2-2 of the plan and Brocedure OPIP A 5.1.1, Section 5. 2. 2.1. d. adequately provide for health physics drills to be conducted semi-annually. N.3.a-f The referenced section of the plan A adequately provides for exercise scenarios to include the following: The basic object.ives; e The date(s), time period, place (s) e and participating organi:ations; e The simulated events; e A time schedule for real and simulated initiating events; A narrative summary describing the-e conduct of exercises or drills; e Arrangements for scenario material to be provided to official observers. Provisions for, and the use of, protective clothing should be added to Section 5.2 page 5.2-1, line 12. i i l l l l
ATTACHMENT 5 LILCO Trnnsition Plan for Shoreham - Revision 3 Consolidated RAC Review, Dated February 10, 1984 Page 3 of 60 NUREG-0654 Element Review Comment (s) Ratinc. A.l.c The organi:ational components of LERO are I illustrated in Figure 2. 2.1. The block diagram assumes that New York State and Suffolk County will communicate with LERO. Figure 2.1.2 shows the LERO Radiation Health Coordinator as having primary responsibility for accident assessment, while Figure 2.1.1, page 2 shows this position as being filled by "other personnel." The discussion on page 2.1-3 line 36 implies that this position is a LERO function..2.1, page 2, lines 24-25 states that DOE will perform accident assessnent. From the language on page 2.1-1, it appears that the Radiation Health Coordinator is pr'vided by DOE /BBO, but this, is o not confirmed by the LERO chart (Figure 2.1.2) under Health Services Coordinator. Clarification should be provided in the plan as to the role of the "outside consultant (s )" in performing the accident assessment function. Figure 2.2.1 should be revised to depict missing agencies (e.g.,
- EPA, USDA) in a clearer manner.
i l
/ ATTACHMENT 6 LILCO Trnnaition Plan for Shorehnm - Revision 3 y Consolidated RAC Review 6C Dated February 10, 1984 Page 28 of NUREG-0654 Element Review Comment (s) Ratinc j I.8 The capabilities, equipment and expertise for I accident and dose capabilities are found in i Procedure OPIP 3.5.2. Field team composi-tion, communication, monitoring equipment and estimated deployment times are found in Section 3.5 and Procedure OPIP 3.5.1. Page 3.5-2 of the plan gives field team composition. Pages 3.1-2 and 4.1-2 of the plan specify that the LERO Director of Local Response, with the Radiation Health Coordinator, is responsible for formulating the protective action decisions. The plan does not specify whether LIRO has accident assessment personnel who can weigh the plant's status from an operational view in developing protective action recommendations. The choice of protective actions is apparently keyed almost entirely to radiation dose or projected dese. Consideration should be given to the plant's status including, prognosis for stabilizing,. improving or worsening situations, or timing of releases so that preventive evacuation prior to a release is not overlooked when such releases may be-imminent. The plan does not specify how protective action decisions would be made in the absence of an actual release. The plan should specify that protective actions such as sheltering and especially evacuation, could be implemented prior to initiation of significant releases, if possible. The NORIG-0654~cr'ess-reference should be revised to include the following citations for element I.8: Section 2.1, Figure 2.1.1, page 2 of 4 e e Section.2.2, Attachment 2.2.1 e Section 4.4, page 4.4-3 (means of . transportation for field teams ). w-p we, r-- --m n-w=r, yn g-y =eep e ,-m-yr g
/ / ATTACIIMENT 7 LILCO Trnnaition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 .Page 29 of 60 NUREG-0654 Element Review Comment (s[ Ratine f I.9 Section~2.2, Attachment 2. 2.1 sta tes I that the DOE Brookhaven Area Office can provide support to LILCO for airborne radiciodine sampling and analysis to concentrations as low as 5X10E-08. While'the equipment listed is potentially capable of making the required measurements, the methodology shown in Procedure OPIP 3.5.1 (see Section 5.3.7b) would not give accurate results for most accident con-ditions. Even without core damage, radiciodine may be collected on the particulate filter if the iodine is in elemental form. Therefore, one cannot rule out activity on the particulate filter as not being iodine. Also, the nomogram which relates iodine to total fission products for the calculation of thyroid dose (OPIP 3.5.2, Att. 11) may not be realistic in this aspect. Furthermore, the amount of fission products collected from a core damage accident are highly dependent on a number of parameters, such as moisture in containment, filtration of release, distance from the site, etc., and are not easily amenable to the nomogram assumptions. The heading of attachments 5 and 6 Procedure OPIP 3.5.2 should be changed to read " Multiply results by 10E-6." 9 --s7 -pn --ev 4y --,egrw w n~ om- -e-g e -w. m e-e, m-- g
ATTACHMENT 8 LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 26 of 6C NUREG-0654 Element Review Comment (s) Ratine H.10 Cection 5.3 of. the plan provides that A LILCO will inspect, inventory and operationally check emergency response equipment at least once each calendar quarter. Calibration of instruments will be done at intervals recommended by manufacturers. The plan also makes provision for reserve equipment. Survey meters compatible with the GM1 probes should be included on the equipment list. The availability of backup equipment for the additional field monitoring teams from LILCO should also be specified in the plan. H.ll A detailed list of equipment to be used in A the emergency response by LERO is located in the portions of the plan listed in the NUREG cross-reference. The plan is adequate provided that the modifications outlined below are incorporated in the plan. The equipment list on page 4. 4-1 includes only one air sampler. The plan should state whether back-up samplers are available at the staging area. It should be taken into consideration that radiciodine sampling capability is lost in the event of pump failure. How does the list on page 4. 4-1 i relate to the list in Procedure OPIP 5.3.1, which includes multiple air samplers?
- Also, are there radiation meters to go with the GM detectors listed in Procedure OPIP 5.3.1 as available at the local EOC7 1
Co=munications equipment on page 4.1-4 should include radio links between the field teams and EOC. l
ATTACEMENT 9 LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 12 of 60 NUREG-0654 Element Review Comment (s) Ratine C.l.b The DOE-RAP is specified to provide A radiological monitoring assistance and expected times for arrival are provided. The plan is adequate in addressing this element provided that specific resources and expected times of arrival are identified for the U.S. Coast Guard (see section 2.2, page 2.2-2). Any additional federal resources, including expected times of arrival to be furnished through the FRERP (see Section 3.11, page 3.11-1) or other arrangemen ts, should also be specified (e.,., EPA, NRC, USDA). C.l.c The LILCO transition plan identifies I resources that are available to support the federal response. LERO has not specified what resources have been identified by federal agencies to support their effort (e.g., air fields, command posts, telephone lines, radio frequencies and telecommunications centers). For example, the EPA response tea =s will also require: airfield for landing military e aircraft (C-130) four independent stationary electrical e outlets (110/120 volts 0 30 amperes AC) source of liquid nitrogen e e office, lab and storage space. l l l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I Before the Atomic Safety and Licensing Board ) In the Matter of ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 ) (Emergency Planning) (Shoreham Nuclear Power Station, ) Unit 1) ) ) 4 CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO LILCO'S
SUMMARY
DISPOSITION MOTIONS ON CONTENTIONS 24.B, 33, 45, 46 and 49 dated March 27, 1984, have been served to the following this 27th day of March, 1984 by U.S.. mail, first class, except as otherwise noted. James A. Laurenson, Chairman Ralph Shapiro, Esq. Atomic Safety and Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D.C. 20555 New York, New York 10016. O Dr. Jerry R. Kline Howard L. Blau, Esq. Administrative Judge 217 Newbridge Road Atomic Safety and Licensing Board Hicksville,. New York 11801 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 W.. Taylor Reveley,'III, Esq.. Hunton & Williams O Mr. Frederick J. Shon P.O. Box 1535 Administrative Judge-707 East Main Street Atomic Safety.and Licensing Board Richmond, Virginia 2321'2-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Jay Dunkleberger New York State Energy Office Edward M. Barrett, Esq. Agency Building 2 General Counsel Empire State Plaza Long Island Lighting Company-Albany, New York.12223 250 Old Country Road. i Mineola, New York 11501- - James B. Dougherty, Esq. 3045 Porter. Street, N.W. -Washington, D.C. 20008
Mr. Brian McCaffrey Stephen B. Latham, Esq. Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station P.O. Box 398 P.O. Box 618 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Marc W. Goldsmith Energy Research_ Group, Inc. a 400-1 Totten Pond Road Waltham, Massachusetts 02154 Joel Blau, Esq. MHB' Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter F. Cohalan Suffolk County Executive Martin Bradley Ashare, Esq. H. Lee Dennison Building Suffolk County Attorney _ ~ Veterans Memorial Highway H. Lee Dennison Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Stuart Diamond' Environment / Energy Writer . Atomic Safety and Licensing NEWDAY 4 - Board Panel Long Island,.New York 11747' U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary Atomic Safety and Licensing Docketing and Service Section Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory 1717 H Street, N.W. Commi'ssion Washington, D.C. 20555 Washington, D.C. 20555 Bernard M.-Bordenick,~Esq. David A. Repka, Esq. . Jonathan D. Feinberg,zEsq.: ' Staff Counsel U.S. Nuclear Regulatory Commission ~ New; York State Public Washington, D.C. 20555 Service Commission 3 Rockefeller Plaza Albany, New. York 12223
- Stewart M. Glass, Esq.
Nora Bredes Regional Counsel Executive Directors Federal Emergency Management Shoreham Opponents Coalition 1 Agency 195' East Main. Street-26 Federal Plaza, Room 1349-Smithtown,:New1 York 11787 New York, New York-10278 -- 2-- m .. m .. m _.,__.mu m. a ma
- Eleanor L. Frucci, Esq.
Spence Perry, Esq. Atomic Safety and Licensing Associate General Counsel Board Panel Federal Emergency Management U.S. Nuclear Regulatory Commission Agency Washington, D.C. 20555 Washington, D.C. 20472
- Fabian Palomino, Esq.
Special Counsel to the Governor Executive Chamber State Capitol Room 229 Albany, New York 12224 --n s Karla J. Letsche ,/ - KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 1 By Hand By Federal Express f l 9 ' . = =}}