ML20107J282
| ML20107J282 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/06/1984 |
| From: | Twana Ellis HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-055, CON-#484-55 OL, NUDOCS 8411090479 | |
| Download: ML20107J282 (23) | |
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UNITED STATES OF' AMERICA
,, I NUCLEAR REGULATORY COMMISSION 7/ --9 ffg,.gg Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING' COMPANY
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Docket No'.-50-322 (OL)
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(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S MOTION (A) FOR LIMITED SUPPLEMENTATION OF THE DIESEL GENERATOR ENGINE BLOCK RECORD AND (B) FOR LIMITED REOPENING OF THE DIESEL GENERATOR CRANKSHAFT RECORD This_ motion seeking a limited supplementation and reopening of the crankshaft and engine block records 1/ is prompted by a series of recent events and developments.
Chief among these are:2/
1.
Issuance of SER.
On August 20, 1984, LILCO received the Staff's Safety Evaluation Report (SER) 1/
The motion is limited to the crankshaft and engine blocks because negotiations are still underway concerning settlement of the AE piston contention.
Settlement may yet be achieved.
If not, LILCO will submit a motion concerning the AE pistons similar to this motion.
2/
A more complete description of these events and develop-ments is contained in LILCO's Status Report dated October 17, 1984.
Accordingly, only a summary appears.
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This SER established an interim basis for licensing.3/- Included among the elements for such li-censing were provisions for determining a " qualified load" and performing certain confirmatory testing in the event the qualified load exceeded 185 BMEP.
The "quali-fled load" was defined in the SER as a load which would meet or exceed the severity of the maximum emergency service load requirements for the set of diesel generator engines.
See SER at pp. 13-14.
2.
Determination'of Qualified Load.
On October 15, 1984, LILCO completed the tests, engineering review and analyses necessary to determine and confirm that the appropriate qualified load for the three Shoreham diesel generators is 3300 kw.4/
3/
A permanent basis for licensing the TDI diesels must await the Staff's full evaluation of the complete TDI Owners Group Program.
Review of the full program is not expected to be completed for at least 18 months.
4/
The Integrated Electrical Test, completed in late August 1984, enabled LILCO to conclude that the service loads during a LOOP /LOCA event are lower than the then current FSAR design loads..LILCO believed that 3300 kw would bound the maximum emergency service load for all three diesel generators and so advised the NRC Staff.
See SNRC 1077.
However, additional tests and analyses remained to be performed in order to confirm r
this belief.
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' 3. --
' Confirmatory Tests and Inspections.
Concurrent with the effort to establish theLqualified load, LILCO
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conferred with the Stafffconcerning-aspects of the con-firmatory testing. recommended by the Staff in the SER and in its testimony.
By mid-October, essential agreement had been reached, the~ details of which were set forth.by.
LILCO in SNRC-1094, a letter dated October 18, 1984 from J. D.
- Leonard, Jr.,
Vice President-Nuclear Operations, to Harold R. Denton, Director-Office of Nuclear Regulatory Regulation.
The principal confirmatory test requirement was an endurance run for 10 7 cycles at the qualified load for specified key components for which operating experi-ence at the qualified load did not already exist.
In the context"of this litigation, the 10 7 cycles confirmatory.
testing is relevant only to the crankshafts.5/
5/
The Staff has already determined that the R-5 engine expe-rience with the AE piston, which far exceeds 10 7 cycles, is ap-plicable to the Shoreham AE pistons.
Accordingly, the 10 7 cycle confirmatory testing is not required for the Shoreham AE pistons.
The Staff also determined that certain specific tests and inspections (but not including 107 cycle endurance testing) would be appropriate for the diesel generator engine block.
These tests and inspections are described in SNRC-1094.
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LILCO began the confirmatory tests and inspections on diesel generator.103 prior to reaching' final agreement with the Staff and prior to final confirmation of the
. qualified load on the basis of preliminary results then available and in~ light of the substantial amount of time the testing would require.s/
The endurance run has been completed at the qualified load of 3300 kw and the post-test inspections are now underway.
LILCO expects to have the results of these inspections available sometime be-tween November 15 and 20, as reported to the Board during the hearing on November 1,-1984.
4.
FSAR Revision.
On October 22, 1984, LILCO sub-mitted to the Staff an FSAR revision reflecting the defi-nition of the new, qualified load and deleting operative (but not historical) references to the conservative de-sign loads of 3500 kw (maximum continuous) and 3900 s/
10 cycles equates to a total of 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> of engine op-eration at 3300 kw or above.
With the Staff's concurrence, credit is given for all hours accumulated at or above the qualified load since the installation of the replacement crankshafts.
At the time of the commencement of the tests, approximately 219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br /> had been accumulated-at or above the
. qualified load.since the installation of the replacement crankshaft.
Therefore, 521 hours0.00603 days <br />0.145 hours <br />8.614418e-4 weeks <br />1.982405e-4 months <br /> of operation at the qualified.
load remained for completion of the test.
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-S-(overload).7/
LILCO has provided answers to various Staff questions concerning the qualfied load and expects to supply all requested answers prior to November 9, 1984.
These four developments, LILCO believes, strongly support the record reopening and supplementation requested here.
The determination of the qualified load establishes that the maximum emergency service load requirements for the Shoreham diesel generators will not exceed 3300 kw during a LOOP /LOCA.
LILCO firmly believes that the record should include and reflect this reality together with the pertinent results of the confirmatory testing and inspections.
At the same time, LILCO 7/
See SNRC-1092.
The definition of a qualified load super-sedes the conservative design loads set forth in the FSAR and renders unnecessary any overload rating above the qualified load.
The original overload rating of 3900 kw was only neces-sary for diesel generator 103 for the first ten minutes of a LOOP LOCA event.
During this period, the conservative design load for diesel generator 103 was 3881 kw, some 381 kw above the nameplate continuous load rating.
Accordingly, while these conservative design loads were in effect, LILCO committed to the establishment of 3900 kw as an overload rating and tested all three engines at that rating as well as 3500 kw.
Now that 3300 kw has been determined to bound the maximum actual loads for any of the three diesel generators for any part of a LOOP LOCA event, the conservative design loads are no longer rele-vant and there is no need or requirement for an overload rat-ing.
The SER precludes testing above the qualified load.
o believes that it has already presented adequate evidence of
-analyses, calculations and inspections that demonstrate that the.13 X'12" crankshaft and the existing diesel generator en-
_gine blocks can perform'their intended functions at the cur-rently existing FSAR conservative design loads.
The. evidence already-presented by LILCO is also relevant'to a consideration of the adequacyLof these_ components at the new, qualified load of 3300 kw.
Accordingly, LILCO's proposal for a limited and-focused reopening and supplementation of the crankshaft and en-gine block records is designed to accommodate these realities-and-to give the' Board the option of finding the engines accept-able at 3300 kw, at 3500 or at 3900 kw.g/ More specifically, LILCO's proposal for a highly focused and limited reopening and supplementation of the record is as follows:
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As counsel for LILCO advised the Board, the Board may find the components qualified at 3500 kw or at 3900 kw, but require confirmatory testing.
In that event, a license would have to be limited to the load at which the confirmatory test was run, in this instance 3300 kw.
At the same time, however, if confirmatory testing were required, LILCO would have the option of additional testing at higher loads in the future in order to take advantage of the Board's favorable findings at loads above 3300 kw.
LILCO wishes to preserve this option for possible load growth.
As LILCO advised the Board (Tr. 23,105-06), it intends to retain the TDI diesels as a source of emergency power at Shoreham to be used in conjunction with the three Colt diesels currently being installed and the 20 megawatt gas turbine already installed and operating.
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1.
Reopening of Crankshaft' Record.
LILCO proposes that the reopening of:the crankshaft record be limited to evidence concerning:
.(a) the results of the 107' cycle endurance
' tests and'their significance toLthe record already developed;Jand
- (b). the results of DEMA forced torsional vibratory. stress' calculations at-3300 kw and the effect of the new qualified-load.on the various safety factors already ca.1.culated by the parties.
2.
Supplementation of Block Testimony.
LILCO proposes that the Board permit supplementation of the engine block record to include evidence'of the results and significance of the confirmatory strain gauge tests with respect to the cam gallery area.
These limitations on the reopening and supplementation of the record are justified in light of the extensive testimony already received, most of which is pertinent to the new, qualified load as well as to the former conservative design loads.
Thus, the extensive testimony concerning the material 1
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and engine test results, the various analyses and methodologies used, the conservatism of the' finite element analyses, the fracture mechanics analyses, the cumulative damage analyses and all the results of the analyses and-testing, as well as other matters, are all pertinent to assuring reliable operation at the new' qualified load because they demonstrate reliable
. LOOP /LOCA operation at the higher conservative design loads.
With respect to the crankshaft,.the'results'and significance of the 10 7 cycle endurance tests are manifestly relevant and important to this hearing.
If inspection of the 13 X 12" replacement crankshaft following the completion of 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> of operation at 3300 kw or above discloses no cracks, then LILCO believes this will be. conclusive evidence of the crankshaft's adequacy at this load.
By the same token, LILCO agrees that evidence of cracks developing in the crankshaft in the course of the 740 hour0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> run would be relevant to the Board's consideration of this contention.
Also, in LILCO's view, it is appropriate to limit the reopening to permit those parties who previously performed DEMA forced torsional vibratory stress calculations the opportunity to reperform the same calculations for a load of 3300 kw.
But
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L LILCO firmly believes that this reopening of the record should not be an opportunity for a party to introduce calculations not previously included in its testimony.
Thus,.the County, which did not previously perform and introduce any DEMA forced tor-sional vibratory stress calculations at 3500 or 3900 kw, should not now be able to introduce the results of any calculations at 3300 kw.
The limitation of the reopening to DEMA forced torsional vibratory stress calculations is warranted because DEMA is the standard stated in the LILCO specification and the FSAR, and it is the only standard stated to be applicable by the Staff.
While there has been subatantial testimony concerning other standards (e.g.,
ABS), there is no compelling reason to permit new calculationu relating to any of these.
In any event,-
should the Board conclude otherwise, LILCO firmly believes that.
no new calculations should be permitted concerning the crank-shaft by any party unless that party'can demonstrate that it had previously performed and introduced into evidence the same calculation based upon the former conservative design loads.
With respect to the engine blocks, evidence concerning the strain gauge tests and results relating to the cam gallery
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' is manifestly relevant and' material.
The Staff requested the tests to confirm its consultant's and FaAA's conclusion that-the vertical stresses which would drive growth of the cracks in the cam gallery if. growth were to occur are compressive throughout the operating range of the engine.
Significantly, the parties have had this data in their possession for.more than ten days and there should therefore be little or no delay in the ability of all-parties to present testimony concerning the results of this data.
As counsel for LILCO advised the Board (and as reflected in SNRC-1094), inspections of the cam gallery and block top areas will also be performed at the conclusion of the endurance run.
LILCO does not currently believe that it is necessary to supplement the record with the results of these inspections.
With respect to the cam gallery, the prior analysis already-presented in testimony at great length, supplemented by the confirmatory strain gauge data, demonstrates and confirms that-stresses in the cam gallery area are compressive and that even deep cracks in the original 103 block have not propagated and the much shallower indications in the 101, 102 and replacement 103 blocks will not propagate.
Similarly, results of the block top inspection do not now appear necessary to the record.
The
=n FaAA analysis already in the record at' great length conserva-tively assumes the, existence of ligament cracks and, on this assumption, demonstrates that the blocks can perform their in-tended function during a LOOP LOCA event with-very substanti:1 margin.
Should the inspection detect ligament cracks,-this would not affect ~the analysis or margins already demonstrated in the testimony presented.
Should ligament cracks not be present, this would only serve to demonstrate the conservative nature of the~ analysis and to increase further the substantial margins already demonstrated in the record.
In any event, LILCO:will make.available to the parties the results of both inspections so that any party may present a focused request for supplementation to the Board should they believe the results-demonstrate relevant new information.
LILCO's litigation schedule set forth below assumes that evidence of these inspec-tions will be offered by some party.
LILCO proposes the following pre-hearing and hearing schedules based on its proposal for limited supplementation and reopening of the record described above.
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^ ' Pre-Hearing-Schedule Endurance test Completed. November 2, 1984 Cam gallery strain Completed and distributed.
gauge data to the Board and parties October 29, 1984 Post-test inspection To be completed November 15-on crankshaft 20, 1984
. Cam gallery and block-To be completed November 15-top inspections.
20, 1984 Documents reflecting To be made available to the basis for 3300-kw parties by November 12, 1984 qualified load Hearing Schedule Discovery cutoff December 5, 1984 LILCO's additional testimony December 12, 1984 due County's additional testimony December 19, 1984 due Staff's additional testimony January 4, 1985 due Hearings commence January 14, 1985 As counsel for LILCO advised the Board, LILCO currently believes that this additional litigation should take no more than two or three weeks in light of the limited and focused purpose of the additional testimony and in light of the fact
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'that there;is already?a-very substantial record on-these. issues relevant to the new, qualified load as well as to the former conservative design loads.
LILCO's request for a limited reopening and supplementation of the crankshaft and block records meets the appropriatei-legal standard, timeliness and importance.9/
The record on blocks has not yet' closed.
Indeed, only LILCO's panel has'been fully cross-examined;.-cross-examination of Staff-and County panels on this issue remains to be completed.
While-the crankshaft record is. closed, only LILCO's findings have been filed and no decision has been written.
Under these circumstances and.given that it is the applicant who seeks the reopening, th'e cases setting forth and applying the familiar
-reopening standard are not entirely applicable.10/
Rather, the 9/
NRC cases do not establish a clear standard for supple-mentation of the record.
Since supplementation involves mat-ters which are the subject of ongoing hearings, it makes sense to apply a lesser standard than for reopening where litigation of the case or a major part of'it has been completed.
For present purposes, however, it is a distinction without a dif-ference since, as demonstrated below, the reopening standard is met.
10/
The familiar reopening standard requires that (1) the mo-tion be timely, (2) new evidence of a significant safety or environmental question exist, and (3) the new evidence might (footnote continued) t I
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p more appropriate standard is that the request be timely and that the supplementary'information or evidence be of substance and importance.
This point was well stated by a Licensing
. Board faced with a' request to reopen a record after findings had been filed but before a decision had been reached:
Many of.the cases cited to us by the parties are addressed to motions to reopen the record of a case after an initial'de-cision ~on all or a portion of the record has been written.
Those precedents are not applicable here.
Instead,-we need only find that OCRE's motion is timely and that it raises an issue of substance.
We need not find that it would changeLthe re-sult of an issue that we have not yet de-cided, even though findings of fact have already been filed.
(footnote continued) materially affect the outcome.
See Long Island Lighting Co.
(Shoreham Nuclear Power Station, Unit 1), LBP-83-57, 18 NRC 445, 476 (1983); Duke Power Co. (McGuire Nuclear Station, Units 1 and 2), ALAB-569, 15 NRC 453, 465 (1982); Kansas Gas and Electric Co. (Wolf Creek Generating Station, Unit 1), ALAB-462, 7 NRC 320, 338 (1978).
This standard is met here only if the-Board were to determine that the evidence already submitted was not adequate to warrant the issuance of a license at 3500 kw.
Given that the Board has not yet reached its decision, LILCO believes that the appropriate and efficient course of action is to proceed now to supplement the record to include this important new evidence, even if the traditional standard applies.
Cf. Tr. 19,353-62 (this Licensing Board received copies of Budnitz deposition but deferred final judgment on re-opening and admitting this testimony until the time of deci-sion).
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3 e Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant, Units 1 & 2), LBP-83-52,?18 NRC 256, 257 (1983)~.
The reopening of the record by an applicant also presents
- important policy questions that need to be considered by~the Board in ruling on such a request.
Under the traditional reopening standard, the movant must show that the issue is-significant and is likely to have an effect on the outcome of-the case.
Where an' applicant-has developed new information which relates to an important matter in dispute, it is faced with a.significant dilemma.
Under traditional analyses, to meet the reopening standard, the applicant must essentially concede that its proof to date is insufficient in order to argue that the new information is likely to affect the re-sult.11/
On the other hand, the applicant may defer any at-tempt to inject the new information until after the Board rules on 'he merits.
If the ruling is adverse, the applicant can seek reopening.
But the applicant then risks being told that its motion is untimely and incurs substantial delay by waiting until the case is decided to present its new evidence.
11/
In the instant case, LILCO firmly believes it has met its burden of proof with the evidence to date.
The new information in question simply shows that there are greater margins of safety than the record already reflects.
,. At least.one licensing board has recognized that the j
reopening standard is not entirely symmetrical.
In Texas Utilities Electric Co. (Comanche Peak Gteam Electric Station, Units 1.and 2), LBP-84-10, 19 NRC 509 (1984), the Board applied a more lenient standard to an applicant's-request to reopen:
We are permitting Applicant to reopen the record without a showing of good cause be-cause it does not seem to us logical cn:
proper to close down a multi-billion-dollar nuclear plant because-of a defi-ciency of proof.
While there would be some " justice" to such a proposition, there would be no sense to it.
Furthermore, we note that intervenors receive several procedural advantages in our proceedings that also are not fully symmetrical and that compensate for the application of different standards for re-opening the record.
19 NRC at 530.
The application of a different standard to an applicant's motion to reopen is consistent with the approach taken by the Appeal Board in Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2), ALAB-770, 19 NRC 1163, 1169 (1984).
There, as here, additional inspections and other activities with the potential to affect the Licensing Board's decision were underway before the conclusion of the hearings.
That
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.- Licensing-Board declined to delay its' decision.to consider these significant activities.
The Appeal Board reversed, holding that the Licensing Board should have provided for further-proceedings to' allow that applicant to introduce additional-evidence.12/
In essence, the Appeal Board recog-nized the principle that licensing boards should befflexible in permitting applicante to introduce additional evidence of the sort here in issue.
Finally, policy considerations dictate-that the traditional' reopening standard is inappropriate here.
- First, its application would tend to discourage additional analyses or confirmatory tests.
If it is difficult to reap the benefits of:
such data, applicants may be unwilling to expend time and re-sources pursuing additional information.
This is particularly true since the applicant runs the risk that any unfavorable information which is developed would likely form the basis for reopening the record by the Board or other parties.
See Texas Utilities Electric Co. (Comanche Peak Steam Electric Station, Units 1 and 2), LBP-84-10, 19 NRC 509, 530-31 (1984).
- Thus, 12/ This decision is more fully discussed in LILCO's Status Report dated October 17, 1984, pages 5-7.
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_e sound' policy dictates that' applicants be given a reasonable op-
.portunity to.present such information if it is favorable.
Sec-ond,. strict application of the. reopening standard would tend to postpone all decisions about the use'of new information favor-able to the applicant until after a decision had been rendered.
This would introduce unnecessary delays into the licensing-pro-Cess.
As a consequence of the above, LILCO believes that the appropriate inquiry when an applicant moves to reopen.the record is whether the new information is timely and whether it-relates to a significant issue. 'Given that any reopening is likely to delay the licensing process, there should be a strong' presumption of significance when the applicant seeks to reopen.
The Board should permit reopening unless it is patently clear that the matter is cumulative or tangential.
LILCO's motion meets the appropriate standard for reopening.
First, LILCO's request is timely.
Indeed, much of the evidence LILCO believes should be added to the record is not yet even available, including specifically the results of the crankshaft endurance test.13/
Although development of the
_13/
In any event, as one Board has correctly noted, "the time-liness inquiry is clearly subsidiary to the significance of the (footnote continued)
'.- qualified load ~has been underway for several months, this11oad was'not finally determined until October'15.
LILLO-promptly submitted a status report to the Board and parties on October 17,.1984.and later advised the Board of'its proposal for hear-ing evidence related to the qualified. load.
This written mo-tion is being submitted pursuant to the discussions held before
-the Board on October-30 and November 1, 1984.
Thus, LILCO has kept the Board and parties apprised of the developments of the qualified load and informed all concerned of its intentions within a reasonable time.
Second, the subject matter of LILCO's motion is a sub-stantial issue.
The actual load to be carried by the diesel generators following an accident is central to conclusions con-cerning diesel generator reliability.
For example, it is un-disputed that the stresses experienced by the crankshaft are directly affected by the loading of the machines.
- Moreover, the undisputed record establishes that the lower the load, the lower the stresses on the crankshaft.
Thus, establishing a (footnote continued) material to be considered."
Consumers Power Co. (Midland Plant, Units 1 & 2), 18 NRC 242, 249 (1983).
See also Vermont Yankee, ALAB-138, 6 AEC 520, 523 (1973).
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. qualified load level of 3300 kw, well below the'former_conser-vative design' load levels-of 3500 kw continuous.and 3900'kw overload, may have a direct and substantial bearing on th'e conclusion this Board must reach.14/
For all the reasons stated herein, LILCO respectfully' requests that the Board permit the reopening and supplementation of the record requested in this motion.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY l(l*b' _
CLrs
/
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E. Milton Farley, III John Jay Range Hunton & Williams P.
O.
Box 19230 Washington, D.C.
20036 T.
S.
Ellis, III Larla B. Tarletz Hunton & Williams P.
O.
Box 1535 Richmond, Virginia 23212 14/
See pages 1-11 for a more detailed discussion of the significance of the new evidence LILCO intends to submit.
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" Odes L. Stroupe, Jr.
David.Dreifus '
Hunton & Williams P..O.
Box,109 Raleigh,: North Carolina 27602' DATED:
November 6,-1984-I.
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4 LILCO, Nov;mbar 6, 1984 CERTIFICATE OF SERVICE
.In the Matter of LONG. ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of LILCO's. Motion (A) For Limited Supplementation of The Diesel Generator Engine Block Record And (B)
For Limited Reopening Of The Diesel Generator. Crankshaft Record were served this date upon the following by first-class mail,
-postage prepaid, or by hand as indicated by an asterisk:
Judge Lawrence Brenner*-
Martin Bradley Ashare, Esq.
Chairman Attn:
Patricia A. Dempsey, Esq.
Atomic Safety and Licensing County Attorney Board U.S. NRC Suffolk County Department of Law Veterans Memorial Highway 4350 East-West Highway Hauppauge, New York 11787 Fourth Floor (North Tower)
Bethesda, Maryland 20814 Edwin J. Reis, Esq.
Dr. Peter A. Morris
- Richard M. Goddard, Esq.*
Administrative Judge Office of the Executive Legal Director Atomic Safety and Licensing U.S. NRC Board U.S. NRC Maryland National Bank Bldg.
7735 Old Georgetown Road 4350 East-West Highway Washington, D.C.
20555 Fourth Floor (North Tower)
Bethesda, Maryland 20814 Alan R. Dynner, Esq.*
Kirkpatrick, Lockhart, Hill, Dr. George A.
Ferguson*
Christopher & Phillips Administrative Judge 1900 M Street, N.W.
School of Engineering Washington, D.C.
20036 Howard University 2300 6th Street, N.W.
Mr. Marc W. Goldsmith Washington, D.C.
20059 Energy Research Group 4001 Totten Pond Road Secretary of the Commission Waltham, Massachusetts 02154 U.S. Nuclear Regulatory Commission MHB Technical Associates Washington, D.C.
20555 1723 Hamilton Avenue Suite K Atomic Safety and Licensing i'
Appeal Board San Jose, California 95125 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
i d Atomic Safety and Licensing Stephen B.
Latham, Esq.
Board Twomey, Latham & Shea U.S. Nuclear Regulatory 33_ West'Second Street Commission Riverhead, New York 11901 l
Washington, D.C.
20555 James B. Dougherty, Esq.
Fabian G. Palomino, Esq.
3045 Porter Street Special-Counsel to the Washington, D.C.
20008 Governor Executive Chamber, Room 229 Jonathan D.
Feinberg, Esq.
State Capitol New York State Albany, New York 12224 Department of Public Service Three Empire State Plaza Robert E. Smith, Esq.
Albany, New York 12223 Guggenheimer & Untermyer 80 Pine Street New York, N.Y.
10005 Mr. Jay Dunkleberger New York State Energy Office
. Agency Building 2 Empire State Plaza Albany, New York 12223
~_
j cYC A nt_ v L
Hunton & Williams P. O. Box 19230 Washington, D.C.
20036 DATED:
November 6, 1984 e
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