ML20108B098
| ML20108B098 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/13/1984 |
| From: | Lanpher L, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-143 OL, NUDOCS 8411150309 | |
| Download: ML20108B098 (20) | |
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November c:193 1984 84 mi 15 All :08 UNITED STATES OF AMERICA r U;E G 1;dRE Us q NUCLEAR REGULATORY COMMISSION h0CdF.TC 4 SEis Mf.
E R;.h0N Before the Atomic Safety and Licensing Board 4
)
In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station,
)
Unit 1)
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JOINT RESPONSE OF SUFFdLK COUNTY AND NEW YORK STATE TO LILCO'S MOTION TO SUPPLEMENT AND REOPEN THE RECORD ON EDG CONTENTIONS On November 6, 1984, LILCO filed its Motion (A) for Limited Supplementation of the Diesel Generator Engine Block Record and (B) For Limited Reopening of the Diesel Generator Crankshaft Record.
The Motion is in the guise of one simply to reopen and supplement the record with allegedly specific new material evi-dence; in reality, however, the Motion seeks to re-litigate the contested EDG issues under a changed and lower standard for EDG performance.
h 8411150309 84;113 PDR ADOCK 05000322 G
It is clear that the current performance standards for the
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EDGs established by the'Shoreman FSAR are 3500 kw continuous
( 8,760. hours ), 2,000 h'ours,. and 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />, and 3900'kw for~2
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hours per 24 hour-period and for 30 minutes. 1!
The litigation of~the. County's EDG_ contention'has been carried on and is nearly completed under those FSAR standards.
The record on the crank-shaft issues has been cicsed, and-the records on cylinder block and piston issues ~are nearing completion after extensive hearings.
which commenced on September 10, 1984.
LILCO recently completed testing of EDG 103 at a continuous
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load of 3300 kw as. measured using normal plant instrumentation (i.e., + 100 kw).2/ - The' Motion seeks to reopen the record on the crankshaft issues to introduce only evidence concerning the re-sults'of this testing, the results of calculations under DEMA at 3300 kw, and the effect of operation at 3300 kw on safety factors.
LILCO also seeks to supplement the record on cylinder block issues only with evidence of strain gage. tests on the cam gallery area of EDG 103 made during the testing at 3300 kw.
The proper standard for reopening the record has been sufficiently stated by this Board as requiring that:
(1) the motion be timely; (2) the new evidence be significant from a 77__FSAR Section 8.3.1.1.5.
2/
See letter dated October 18, 1984 (SNRC-1094) from J.D.
Leonard, Jr. (LILCO) to H.R. Denton (NRC Staff).
p.
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1 safety-(or environmental) perspective;'and'(3)_ the new evidence-might' materially affect the. outcome. $/
Clearly, LILCO has not met these standards..
1.-
The Motion is Untimely.. The testing of any EDG for an aggregate of'about 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> at any' load level is and has always
-been a matter solely within-LILCO's control.
LILCO could have tested EDG 103 or any other EDG for 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> with the replace-ment crankshafts, and could have performed strain gage tests on the crankshaft gallery area, before the hearing began.
- Instead, LILCO, and LILCO alone, chose to wait until after the hearing had started and the-crankshaft record was closed before LILCO even began the additional. testing.
Therefore, LILCO's own delay in' carrying out the additional tests ensured that evidence from these tests would necessarily be too late to be included in the hearing record.
Accordingly, the Motion is per se untimely.
Any contrary conclusion would permit LILCO to purposely delay producing evidence until after the record closes, and then argue successfully that a motion to reopen the record to permit the evidence is timely because the evidence only became available after the record was closed.
That f
kind of " boot-straping" and circular reasoning clearly cannot prevail.
Long Island Lighting Co.
(Shoreham Nuclear Power Station, Unit 1), LBP-83-57, 18 NRC 445, 476 (1983).
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LILCO's Motion states that it'"is prompted by a series of recent events and developments."A/
It then lists four factors, L
none of which prevented or restrained LILCO from performing the 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> of EDG testing _or the cam gallery strain gage tests before the hearing started.
(a)
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-The^ Staff's SER on the TDI Owners Group Program Plan.
The SER, which was released on August 13, 1984,5/ stated the Staff's position that as a prerequisite to interim licensing, LILCO must demonstrate that an EDG has " operated successfully for 7
at least 10 loading cycles under loading conditions which meet or exceed the severity of the maximum emergency service load requirements
.,.the qualified load.
."5!
The " qualified load" for the Shoreham EDGs was (and still is) a minimum of 3881 kw.1/
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LILCO could have, and should have, promptly moved to post-pone the incipient commencement of the hearing and begin the required EDG testing.
It did not do so.
Indeed, LILCO even opposed the Staff's request for a few extra days to file its testimony on the EDGs.
The Staff's written testimony, filed on 1
August 30, 1984, stated the position that EDG testing at full g7__LILCO Motion at 1.
EI Letter dated August 13, 1984, from D.G. Eisenhut (NRC Staff) to J.B. George (TDI Owners Group).
b!
SER at 13-14.
1!
See FSAR Table 8.3.1-1.
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n load and overload for 10 cycles should be performed by LILCO prior to interim licensing.
Nevertheless, LILCO chose to ignore this injunction and begin the hearing.
(b)
Determination of Lower Load Requirements.
LILCO uni-laterally decided to perform tests and analyses to attempt to reduce the " maximum emergency service load requirements", or
" qualified load", from 3881 kw to some lower load.
The qualified-load for the EDGs has been 3881 kw (enveloped at 3900 kw "over-load" and 3500 kw continuous) for over eight years.
LILCO states that it did not complete its evaluation until October 15, 1984.
There is no reason to justify L'ILCO's waiting so long to perform 1
this load reduction evaluation.
A reasonable utility would have
. begun such an evaluation no later than when the crankshaft on EDG 103 broke in August 1983.
Clearly,'LILCO could have and should 2
have completed any tests and analyses justifying a lower quali-i fled load before the EDG hearing began.
Indeed, on July 3,
- 1984, LILCO notified the Board and parties that it intended to try to reduce the EDG load rquirements. !
Suffolk County referred to this matter in its prefiled EDG testimony on July 31, 1984, but i
LILCO chose to ignore the issue and push for an expedited hearing a
schedule.
Clearly, LILCO's unwillingness to address the issue.of g,..................
See letter dated July 3, 1984 (SNRC-1065) from J. D. Leonard, Jr. (LILCO) to H. R. Denton (NRC Staff).
d 1
-;.. i a lower qualified 1oad did'not prevent LILCO from testing EDG 103
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-before the hearing began, or at least before the~ record was-closed on the crankshaft issue.
(c)
" Confirmatory" Tests and Inspections.
These tests and inspections could have been carried out by LILCO before the-EDG hearings began.
LILCO's Motion makes no showing to the contrary.
(d).FSAR Proposed Amendments.
LILCO waited until October 22, 1984, to submit a proposed FSAR amendment reflecting LILCO's belated re-analysis of the EDG qualified loads.
For the same reasons as discussed in subparagraph (b) above, LILCO's decision to delay the re-analysis and proposed FSAR revision until after the hearing commenced and the crankshaft record was closed is unjustified.
i In short, LILCO's Motion is cearly untimely.
As LILCO has stated elsewhere, l
It is settled that the test for time-liness is whether th issues could have l
been raised earlier.gj LILCO unquestionably could h. ave tested an EDG for 10 cycles and performed strain gage tests on the cam gallery area before the EDG hearing began.
Thus, LILCO could have raised the issues and evidence resulting from that testing earlier and on a timely basis.
It did not.
g,..................
LILCO's Opposition to Suffolk County's Motion to Add an Emergency Diesel Generator Contention, May 16, 1983, at 10 (emphasis supplied).
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b 2.
The Evidence Which LILCO Seeks to Admit Is Not Signifi-cant and Cannot Materially Affect the Outcome.
.As to the crank-shafts, the results of the 740 hour0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> test of EDG 103 at 3300 kw have no significance-to the litigated issues of whether the crankshafts are adequate for EDG operation at the FSAR rated and actual loads of 3500 kw continuous operation and 3900 kw over-load.. LILCO in fact appears to concede that'the tests at 3300 kw are significant only to "the crankshaft's adequacy _at this load."1E/
Nor do DEMA or other calculations of crankshaft stresses at 3300 kw have any significance to the current liti-gation.
For these reasons, none of the evidence concerning crankshafts in the EDGs during operation at 3300 kw can possibly materially affect the outcome of the litigation.
Nor has LILCO demonstrated th't the strain gage tests of the a
cam gallery area of the replacement cylinder block of EDG 103 are significant or will materially affect the outcome of the liti-gated block issues. In fact, the strain gage tests were performed at loads only up to 3300 kw and did not take into account residu-al stresses in the area.
Moreover, the evidence on the record establishes that, because there were no crack indications in the cam gcliery areas of the replacement EDG 103 block when it was del'vered to LILCO, the cracks could only have resulted from EDG operation.
Accordingly, there must be tensile stresses in the area.
The strain gage test data which LILCO now seeks to 737__LILCO Motion at 8.
e 3
).
introduce are, for all of the above= reasons, of no significance and cannot materially affect the Board's decision concerning the blocks at the current qualified. loads.
In fact, the only significance of the additional testing and
. inspections _of EDG 103 to the ongoing litigation is whether they disclose deficiencies in the crankshafts, the replacement cyl-inder block of EDG 103, or the AE pistons.
If any deficiencies' have occurred at continuous _ operation at only 3300 kw, they would clearly be significant to the safe operation of the EDGs at the continuous load of 3500 kw, at overload of 3900 kw, and at the qualified load of 3881 kw, and might affect materially the out-come of the litigation.
As this Board has pointed out, in case of such deficiencies the Board would have the responsibility to i
determine whether to raise such matters'sua sponte.
And, of t
l course, the County and State would also seek to bring any such deficiencies tc the Board's attention.
To be granted, LILCO's Motion must meet the reopening criteria in all respects.
There is no lesser standard for late supplementation of the record.
LILCO agrees that its Motion fails to meet the applicable criteria.
LILCO asserts that to
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meet the reopening standards, either the Board must have deter-mined that the evidence already submitted does not justify licensing the EDGs at 3500 kw, or LILCO must have conceded that
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such evidence is insufficient.11!
In order to avoid this result
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and "have its cake'and eat it too,"~LILCO suggests that a new, different and lesser reopening standard be applied to-LILCO.
.There'is no authority in the law and no justification in the
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facts-of this case for the proposed special LILCO standard.
None of the cases relied upon by LILCO are applicable.
In the Perry decision,12/ a portion of which'is quoted by LILCO,12! the Licensing Board did suggest that the reopening criterion of having a material effect on the outcome need not be applied to issues not yet decided.
However, this singular exception to the applicable reopening criteria was made where the Board determined that there was new evidence of critical potential safety import-ance.
As discussed above, the evidence which LILCO' seeks to introduce is of no safety significance.
Moreover, LILCO has elsewhere argued vigorously that the reopening standard of whether an issue will affect the outcome must be applied in any decision to reopen the record, including in cases where there has been no initial decision.
See LILCO's Reply to Suffolk County's Response on Proposed Diesel Generator Contention, June 9, 1983, at 8-9 and cases cited therein.
777__LILCO Motion at 15.
12/
Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant, Units 1 & 2), LBP-83-52, 18 NRC 256 (1983).
11!
LILCO Motion at 14-15.
n- ' '
LILCO'also cites'the Comanche PeakbA! and.Byronb5! decisions l
for the unconstitutional assertion that a different and lower standard for reopening the record should be applied for utilities than is applied to intervenors.
In Comanche Peak the Licensing Board made no attempt to apply any of the reopening criteria to the applicant.
Acknowledging "the burden imposed by our decision and the lack of precedent for failing to apply the standard for-
-reopening the record to Applicant,"b5! the Board invited the
-parties to seek review from the Appeal Board.
The Comanche Peak decision was based solely on that Board's assertion that "it does not seem to us logical or proper to close down a multi-billion-dollar nuclear plant because of a deficiency of proof."b1!
- Thus, this decision does not interpret the law and NRC regulations; rather it finds them inapplicable because of the utility's finan-cial interests.
Clearly this case is an aberration which should r
not be followed.
Moreover, denial of LILCO's Motion would neither close down a nuclear plant, nor prevent the opening of Shoreham (which still has other significant hurdles precluding an operating license).
yzy__ Texas Utilities Electric Co.
(Comanche Peak Steam Electric Station, Units, 1 a 2), LBP-84-10, 19 NRC 509 (1984).
Ab!
Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1& 2), ALAB-770, 19 NRC 1163 (1984).
bb!
Comanche Peak, supra, 19 NRC at 531.
11/ 'Id. at 530.
The Chairman of the Board in Comanche Peak was also CEairman of the Board in Perry.
,,11_
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Similarly,. Byron-does-not: deal'with the criteria for re-opening'the_ record, nor does it conceivably stand for the proposition that a lesser reopening standard should be applied
.for a utility than for other parties, as. alleged by LILCO.
Byron.
simply. remanded the record to-the Licensing Board for a1further evidentiary. hearing'on quality assurance, where the QA issue was' incomplete, and the Board'had noted that the. utility was " catch-'
c.ing up" with its QA problems.
Henc'e, there was an implicit w
acknowledgment that additional. evidence would necessarily be 4
4 -significant and determinative of the outcome of the case.
As discussed above, none of the evidence sought to be introduced by LILCO has any significance,to the EDG litigation.
s.As discussed above, there is no applicable legal authority to support LILCO's proposal for special lower reopening criteria.
Moreover, neither the equiti9s of this case nor policy matters support LILCO's request for special treatment.
Indeed, both factors demonstrate that LILCO must make a choice now either to concede that the evidence is insufficient to prove safe and reliable EDG operation at 3500 kw or higher, and proceed with supplementary litigation of the Adequacy of'the 3300 kw qualified load, or to proceed with the current litigation and, after this Board's decision, decide whether and on what basis to apply for a license at the lower qualified-load.
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--g7__ Byron, supra, 19 NRC a't 1169.
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First, as discussed.above,-the equities are'against LILCO.
Despite a'mple opportuniy to do :so ' earl'ier, LILCO decided not to
. perform reanalyses of the-FSAR requirements for the EDGs, not'to perform additional testing of anLEDG, not to perform cam gallery' strain gage. tests, and;not to propose amendments to the FSAR as to'EDG requirements.until after the EDG hearing had begun.
LILCO continually and aggressively advocated the.most rapid litigation schedule possible, always opposing requests by Suffolk County and the Staff'for modest and reasonable time extensions.
While LILCO' knew at least by early July 1984 that it intended to attempt to reduce the qualified load of the EDGs, LILCO avoided addressing this issue until November 1984, despite repeated invitations by-Suffolk County and the Board to do so.
LILCO's selfish and arro-gant behavior forced'the parties and' Board to expend much time, effort and money on litigation of the EDGs at qualified load levels which LILCO itself has now abandoned.1E/
This Board has acknowledged these matters at several times during the hearing.
See, for example, Tr. 24,064-69, 25,191-97.
Second, permitting LILCO to litigate the adequacy of the EDGs at the new qualified load of 3300 kw, while preserving its position that the Board should approve the abandoned qualified
--g ___It is significant.that LILCO's proposed FSAR amendments provide at Section 8.1.4: "Each diesel generator has a qualified load of 3,300 kw.
The nameplate' ratings are retained in the FSAR as these ratings were '; sed in the design and initial testing phases.
In the futurs 'aowever, the new qualified load will be used for all purposes.
(Emphasis added).
loads of 3500, 3881, or 3900 lag, would be bad policy.
It would encourage utilities to proceed with hearings on issues before they have made' final decisions on safety, adequacy or suitabil-ity, because the utility would know that if the Staff's or
.intervenor's-evidence proved difficult, _the utility would always have the option of making changes, reopening the record, and litigating the changed facts under different. criteria.
The utility.could thus always preserve all options, while forcing other parties to engage in ecstly piecemeal litigation with imprecise standards and " moving targets."
LILCO's special consideration proposal would be a precedent for inefficient, wasteful, delayed, and confusing litigation.
LILCO's apparent dilemma also is imaginary and self-inflicted.
LILCO could have postponed EDG litigation until after it decided on a maximum load level.
Instead, LILCO pushed forward with the EDG litigation at load levels which LILCO has now abandoned in its proposed revised FSAR.
LILCO should now forthrightly abandon its efforts to have this Board approve the abandone-d FSAR load requirements of 3500 kw and higher.
Suffolk County and the State of New York therefore oppose LILCO's Motion in its entirety.
However, if LILCO concedes that the evidence so far adduced is insufficient to prove adequate EDG reliability at loads 3500 kw and higher and cancels its attemnpt to have the Board approve the abandoned load levels, the County and State will not oppose. orderly supplementary litigation of the
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m adequacy of the proposed? qual'ified load'of~33001kwtand the'ade-quacy:of:the EDGsJto perform'up}toiand including 3300 kw, as t
' follows.;
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- -l.
' Adequacy of23300'kw Qualified Load. : The-threshold issue-i under a new-litigation' focus'and schedule-is whether 3300:kw'is.
an adequate and proper qualified load fors.the/EDGs. 'Suffolk-
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County:consultantsfhave' received somel documents on this issue.
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from the Staff and have. commenced their' analysis'.
The County,is t
' awaiting; additional 3information fromiLILCO.
If the'NRC Staff.
approves LILCO's proposed FSAR revisions, the following schedule would seem appropriate.-
4 (a) - Fifteen days after receipt of the' final Staff approval of FSAR revisions, the' discovery period (including-depositions)' ends.
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j (b)
Fifteen days after the discovery period ends,-the If County and State either shall.have agreed with-the Staff, or will 1:
I file testimony.
t (c)
If such testimony is filed, LILCO and the Staff will file rebuttal testimony 10 days thereafter.
Fifteen days thereafter, the hearing will commence'on this issue.
The County and State believe strongly that this-threshold issue mustTbe decided before supplementary litigation commences -
on the? adequacy of the EDGs under the proposed revised FSAR.
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for example, it is determined that the appropriate qualified load is really 3400 kw, no additional time,, effort and expense should be wasted on useless litigation on EDG adequacy at a lower load.
2 '.
Adequacy of EDGs at New Approved Qualified Load.
Once a new qualified load is approved (by. agreement'of the parties or decision by the Board),. supplementary. litigation could proceed on the following additional evidence (assuming 3300 kw is the ap-proved qualified load): as to crankshafts,: pistons and cylinder blocks, evidence concerning the results of the additional testing and inspections of EDG 103 as to such components; and as to crankshafts, evidence concerning any DEMA stress calculations at the new qualified load, any other calculations at such load con-sistent with the County's crankshaft contention, and1 material responsive to the Staff's letter dated October 10, 1984, to the TDI Owners Group concerning the crankshafts on the Shoreham EDGs.
After approval of the new qualified load and receipt by the County and State of final inspection' reports (after quality assurance review) of LILCO and its consultants, and final Staff inspection reports or comments (if any) on reports of LILCO and its consultants,20/ the following schedule would seem appro-priate:
7g7__The County and State share the Board's concerns over the use of. preliminary or incomplete' documents by LILCO during the EDG hearing, and are anxious to avoid a repeat of this experience.
See Tr. 25,594.
e (a)
Fifteen days.afterTsuch' receipt, th'e discovery period:(including depositions)' ends.
(b)- Fifteen days thereafter, testimony will be due from the County,. State'and LILCO.
(c )..
Seven days thereafter,LStaff tetimony will be due.
(d)
Fifteen days thereafter, the hearing. commences.
As discussed above, we do not believe any evidence purport-ing to demonstrate 1the adequacy of the-EDGs at' loads below 3500 kw should be permitted unless and until LILCO abandons its-quest for Board approval of the abandoned qualified loads. However, if the Board nevertheless allows LILCO.to reopen'the record without meeting the applicable reopening criteria, then we.believe find-ings on the EDG components at 3500 kw and 3900 kw overload under the current litiga' tion should be 'eferred and consolidated with d
the findings with respect to the additional litigation of the lower qualified load.
This would present a more orderly record, and permit counsel most familiar with EDG matters to handle the supplementary litigation, rather than writing findings, thus enhancing the efficiency of the litigation.
If the Board per-mits LILCO to reopen the record without meeting the reopening criteria, we urge that the determination of the adequacy and appropriateness of the new lower qualified load be made prior to a
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any additional litigation on'the adequacy of the EDGs at the lower qualified load.
Respectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
/
H Lawrence Coe Lanpher "
Alan Roy Dynner Joseph J.
Brigati Douglas J.
Scheidt KIRKPATRICK & LOCKHART 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Attorneys for Suffolk County
/
04%o e Fabian G.
Palomino Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for Mario M. Cuomo, Governor of the State of New York November 13, 1984 l
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UNITED l STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION Before the-Atomic Safety and Licensing Board'
)-
In1the Matter of
)
-)
4 LONG ISLAND ~ LIGHTING COMPANY
-)
Docket No. 50-322-OL
.)
(Shoreham Nuclear Power Station,
')
Unit'l)
)
-)
CERTIFICATE OF SERVICE I hereby certify that copies of the-JOINT RESPdNSE OF SUFFOLK COUNTY..AND NEW YORK STATE TO LILCO'S MOTION TO SUPPLEMENT AND REOPEN THE RECORD ON EDG CONTENTIONS, dated November 13, 1984, have been served on the.following this 13th day ofxNovember 1984
.by'U.S. mail, first class, except as otherwise indicated.
Lawrence J.
Brenner, Esq.*
MHB Technical: Associates Administrative Judge
'1723 Hamilton Avenue Atomic Safety and Licensing Board Suite K 1
U.S. Nuclear Regulatory Commission San Jose, California 95125 Washington, D.C.
20555 E. Milton Farley, III, Esq.*
Dr. George A.
Ferguson*
Hunton & Williams Administrative Judge P.O.
Box-19230 Atomic Safety and Licensing Board 2000 Pennsylvania Ave.,
N.W.
School of Engineering Washington, D.C.
20036 Howard University 1
2300 6th Street, N.W.
Odes L. Stroupe, Jr., Esq.
Washington, D.C.
20059 Hunton & Williams 333 Fayetteville Street Dr. Peter A. Morris
- Raleigh, North Carolina 27602 Administrative Judge Atomic Safety and Licensing Board Mr. Jay Dunkleberger U.S. Nuclear Regulatory Commission New York State Energy Office Washington, D.C.
20555 Agency Building 2 Empire State Plaza Edward M.
Barrett, Esq.
Albany, New York 12223 General Counsel Long Island Lighting Company James B.
Dougherty, Esq.
250 Old Country Road-3045 Porter Street, N.W.
Mineola, New York 11501 Washington,RD.C.
20008 C
3-- -
. ;. f. -
. Robert E.. Smith, Esq.'
Stephen:B. Latham,'Esq.
Guggenheimer--& Untermyer_
Twomey, Latham 8.Shea
-80 Pine Street P.O.
Box-398 New York, New York 10005-33 West Second Street Riverhead,.New York 11901 Mr.. Brian R..McCa'ffrey-Long Island Lighting Company Mr. Frank R.
Jones Shoreham-Nuclear Power Station Deputy County Executive P.O.. Box 618 H. Lee Dennison Building North Country, Road Veterans Memorial Highway Wading River, New York 11792 Hauppauge, New York 11788 Joel-Blau, Esq.
Mr. Stuart Diamond New York Public Service Commission Business / Financial The Governor Nelson A. Rockefeller NEW YORK TIMES Building New York, New York 10036
. 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 Fabian Palomino, Esq.#
Special Counsel to the Atomic Safety and Licensi'ng Board
. Governor Panel Executive Chamber U.S. Nuclear Regulatory Commission Room 229 Washington, D.C.
20555 State Capitol _
Albany, New York 12224 Docketing and Service Section Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board 1717 H Street, N.W.
U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Edwin J. Reis, Esq
- Bernard M.
Bordenick, Esq.
Jonathan D.
Feinberg, Esq.
Richard J.
Goddard, Esq.
Staff Counsel Office of Exec. Legal Director New York State Public U.S. Nuclear Regulatory Commission Service Commission Washington, D.C.
20555 3 Rockefeller Plaza Albany, New York 12223
......a'
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. Stewart.'M. Glass,.Esq.
Regional'. Counsel.
Federal. Emergency' Management-
- Agency
- 26-Federal. Plaza New' York,.New York 10278
- 1 M
N h
Lawrence Coe Lanphef ~
KIRKPATRICK &.LOCKHART 1900 M Street,-N.W., Suite 800 Washington, D.C.
20036 1
DATE:
November 13, 1984 1'
- - By Federal Express By Hand Delivery on 11/14/84
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