ML20132B889
| ML20132B889 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/09/1984 |
| From: | Monaghan J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8404110493 | |
| Download: ML20132B889 (19) | |
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LILCO, April 9, 1984 UNITED STATES OF AMERICA DocNf3 P
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing */Doard "k11 977 _7 0 In the Matter of
)
)
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LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S MOTION TO STRIKE PORTIONS OF THE DIRECT TESTIMCNY ON BEHALF OF SUFFOLK. COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 39, 40, 41, 44, 98, 99 AND 100 --
TRAINING OF OFFSITE EMdRGENCY RESPONSE WORKERS Pursuant to 10 C.F.R.
l 2.743(c), the Long Island Lighting Company (LILCO) moves to strike portions of the " Direct Testimony
)
l of Deputy Inspector Peter S. Cosgrove, Lt. John L. Fakler and Pro-fessor Michael Lipsky in Support of Emergency Planning Contentions 39, 40, 41, 44, 98, 99 and 100 -- Training of Offsite Emergency Response Workers" on the grounds that they are outside the scope of the training contentions which have been admitted and, therefore, that these portions are irrelevant.
In all of the testimony detailed below, there is no discernible relation between the testi-mony and the admitted contentions and in virtually every case, the County makes no effort to establish any relationship.
The total absence of relevance to admitted contentions is strikingly evident in the portions of the testimony that attempt to resurrect issues which were raised in contentions rejected by this Board in its Order of March 19, 1984.
The fact that the County drafted and
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moved the admission of these new contentions indicates that the q,c b
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l County itself did not believe those issues were legitimately raised l
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by its original contentions.
The County should not now be permit-f I
ted to expand the admitted contentions beyond their intended scope i
t to include issues that have been denied admission.
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Moreover, the County should not be permitted to rely on the f
general language of its original contentions to establish the role-j i
j vance of issues that were raised and rejected in its new conten-4
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tions.
For example, Contention 40 raises the general concern that l
j persons without job-related experience will not be able to perform their LERO jobs in an emergency since LERO training will not com-l s
j pensate for their lack of experience.
It does not attempt to iden-e i
tify specific inadequacies in the LERO classroom training and drill I
and exercise program.
In Contentions 99 and 100 the County sought r
l to identify specific inadequacies in the LERO classroom training
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1 and drill and exercise program.
The alleged inadequacies in the
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l 1
LERO training program identified in Contentions 99 and 100 are dis-l i
t j
tinct from the issues of job-related experience and use of training
,l raised by Contention 40.
This Board should not sanction the at-1 l
tempt by Suffolk County to shelter the rejected portions of Conten-1 tions 99 and 100 under the umbrella of Contention 40.
I The specific portions of the County's testimony which should
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i be stricken and the grounds for striking those portions are set l
j forth below, in the order in which they appear in the County's tes-l
[
j timony:
I t
4
1 1.
Purposes and Conclusions and Contention 98 i
LILCO moves to strike the phrase in lines 4-5 on page 7 which states "either that those individuals would realize that LILCO has i
assigned them emergency roles, or" on the ground that it is beyond f
the scope of the contentions at issue in this testimony and, there-1 fore, is not relevant.
Nowhere in the contentions proffered by 1
intervenors is it stated or is the inference raised that individu-als who would perform emergency duties under the LILCO Transition j
Plan would not be aware that they were responsible for performing those emergency duties.
For the same reason, the testimony at page
-12, lines 14-15, on Contention 98 should be stricken.
II.
Contentions 40, 44.E, 44.F, 99 and 100 4
Suffolk County has chosen to group Contentions 40, 44.E, 44.F, 99 and 100 as a single entity and has then spent 58 pages address-i l
ing issues it believes are raised by these contentions.
The prob-lem with the County's approach is that it. fails to link the testi-I mony with issues raised by specific contentions; in many cases, no linkage is possible since the issues raised are outside the scope l
of the admitted contentions.
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LILCO cannot find any part of the contention. which involves the manner in which LILCO workers were selected for LERO.
Accord-4 ingly, LILCO moves to strike the phrase on page 18 at lines 6-9 which states 'and LILCO workers were selected for LERO in a manner that almont certainly did not identify individuals with relevant l
t 6
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l experience, aptitudes or skills" as beyond the scope of the conten-tions and, therefore, not relevant or material evidence.
Simi-I larly, LILCO moves to strike the testimony on page 28, lines 4-19, an answer for which there is no apparent question, on the ground that it, too, deals with LILCO's process for selecting LILCO per-sonnel to serve in LERO.
LILCO moves to strike the footnote on page 19-20 which con-cerns the ability of traffic guides to direct traffic.
This testi-mony is repetitive and cumulative of testimony on Contention 65, see Testimony of Roberts, et al..cnt Contention 65 (as amended) at 39-44, see also Board Order of January 23, 1984 at 4 (denying LILCO motion to strike the referenced pages from the Roberts, et al. Tes-timony, but stating that "we will scrutinize testimony filed for Group II and may strike any testimony that is cumulative with this testimony.").
Beginning with the question at the bottom of page 28, line 20, and continuing through page 32, line 12, suffolk County's testimony addresses the motivation of LILCO employees in volunteering for the LERO organization and whether or not a proper skill-matching or selection process was engaged in by LILCO when it assigned LILCO employees to specific positions in the LERO organization.
All of this testimony is beyond the scope of the contentions and should be stricken as irrelevant.
The testimony beginning on page 32, line 13, and ending on i
page 33, line 2, contains a number of assertions concerning the
This testimony ability of persons to function under pressure.
apparently relates to the ability of individuals to function under an issue which was denied admission by the stressful situations, Accordingly, this testimony Board when it struck Contention 100.C.
should be stricken as irrelevant to any issue in this proceeding.
The County's testimony beginning on page 33, line 3, and line 6, should be stricken in its entirety; the ending on page 34, issue of whether or not LILCO attempted to select certain LILCO persons to fill particular LERO jobs or of the adequacy of any selection process which may have been employed by LILCO is beyond the scope of the contentions and, therefore, is not relevant to the The fact that all of this issues presented in this proceeding.
testimony relates to LILCO's selection process is highlighted by the phrase in lines 10-12 of the testimony on page 33 which states:
"LILCO's inadequate selection process has resulted in at least three adverse consequences."
The remainder of that paragraph lists all of which, as stated in the County's own tes-the consequences, timony, relate to the County's concern with the adequacy of LILCO's selection process.
At page 34, lines 14-15, the County's testimony alleges that there are serious deficiencies in LILCO's classroom and drill pro-These issue were specifically raised by contention 99.3, grams.
which was denied admission.
This sentence should be stricken as outside the scope of the contentions and irrelevant.
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The County's testimony at page 36, line 21, through page 37 line 2, raises the issue of the ability to develop skills through i
watching videotapes and the alleged need for hands-on practice and experience.
The County specifically alleged in Contention 99.J, i
j which was denied admission by the Board, that the LERO training program did not provide sufficient opportunities for trainees to l
i gain hands-on experience in performing their emergency functio ns.
Rejected contention 99.8 dealt with the adequacy of the vid i
i eotapes and workbooks used in the LERO training program.
An attempt to
- expand, i
through testimony, the scope of prior contentions to include the issues raised by Contentions 99.8 and 99 J should not be sanctioned, and this portion of the testimony should be stricken as not relevant to the admitted contentions.
i The County's testimony on classroom training beginning on pa 38, line 20, and ending on page 39, line 9, addresses teachin ge l
g objectives.
The County's contention concerning LERO instructors is
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i 99.C which states:
LILCO's classroom training sessions have been conducted by individuals who were neither ex-perienced in, nor knowledgeable about, subject areas they are assigned to teach.
the addition, the teachers are not experienced or In j
trained in teaching methods.
Nothing in this contention involves teaching objectives or goal s
for instructors.
This testimony should be stricken as beyond the scope of the contentions and, therefore, not relevant to issues in this proceeding.
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LILCO also moves to' strike the Suffolk County testimony en i
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page 40, lines 5-8, which states "but the LILCO training program does not include such information for instructors.
Neither lesson
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plans nor the other training materials contain references to authority." and the phrase "and because they are given no extra materials except inadequate lesson plans" at page 40, lines 15-16.
j This testimony seeks to resurrect the issues of the adequacy and j
substantive content of lesson plans, videotapes, and workbooks; i
these issues were denied admission by the Board when it denied Contentions 99.A and 99.B.
The testimony should be stricken as beyond the scope of the contentions and, therefore, not relevant to issues in this proceeding.
c In its Order of March 19, 1984, the Board denied admission to l
Contention 99.I which stated:
Because training materials had been written j
for large groups of trainees assigned to sev-l eral different emergency job categories, trainees receive much general and in many cases irrelevant information rather than suf-ficiently detailed information concerning their individual job functions.
Suffo3k County's testimony beginning at page 43, line 15, ending on page 45, line 16, is a clear attempt to raise issues covered by Contention 99.I.
LILCO moves to strike this testimony on the i
ground that it is irrelevant and immaterial to the issues pre-r l
sented in this proceeding.
Beginning on page 45, line 17, and continuing through page 46, line 17, the County's testimony alleges that the videotapes used in LILCO's training program contain contradictory and mis-leading information.
This assertion goes directly to the substan-l tive content of the videotapes which was an issue that was expressly rejected by the Board when it denied Contention 99 B in its Order of March 19, 1984.
This portion of Suffolk County's i
testimony should be stricken as not relevant and not material to the issues presented.
In the testimony beginning on page 46, line 18, and continu-i ing through page 49, line 15, Suffolk County alleges that the l
LILCO training materials frequently downplay the importance of training and the need to retain the material being taught and that i
this provides little incentive or motivation for LILCO personnel i
to learn or to retain the emergency training provided to them.
i Suffolk County relates this testimony to Contention 40 which i
states, in pert, simply that:
J Following their training, LILCO personnel will be expected to perform their regular job
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functions, which have no relation to their r
emergency roles, rather than applying or using their emergency training.
This will minimize any benefits gained through the emergency training, especially since general classroom training, exercises, and almost all 4
drills are only repeated on an annual basis, job-specific classroom training is only re-peated on a semi-annual basis, and there are l
no incentives for LILCO personnel to learn or i
retain the emergency training provided to them.
A comparison of the language of Contention 40 with the County's testimony demonstrates that while both begin with the premise that U
there are no incentives for LILCO personnel to retain the l
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l emergency training provided to them, the reasons behind the lack of incentive are markedly different.
Contention 40 focuses solely on the frequency with which training will be provided and on the frequency with which LERO personnel will practice their LERO job I
responsibilities.
Absent frequent classroom retraining and drills and exercises, contention 40 alleges that there will be no incen-tive for LILCO employees to retain their LERO training.
In con-l trast, the testimony in question addresses what the County consid-era a downplaying of the importance of the training and the remote likelihood that the training will ever need to be put to use.
The County's testimony raises a new and different issue concerning the i
motivation for LERO workers to retain their training.
The testi-mony appearing on page 40, line 18, through page 49, line 15, should be stricken as not relevant to the isstes presented by Con-i tention 40.
Beginning on page 50, line 14,.auxi continuing through page 51, line 12, Suffolk County attempts to resurrect through its tes-i timony the issues rejected by the Board when it denied admission 1
of Contention 99.J concerning tabletop discussions and hands-on experience.
Therefore, the testimony should be stricken as not t
relevant or material.
Beginning on page 51, line 13, and continuing through page
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l 52, line 17, the County makes a similar attempt to reraise the is-l suas covered by rejected Contention 99.E, which stated:
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i The LILCO training program has no provisions for meaningful and graded testing of LERO personnel following classroom training ses-I sions to determine if the classroom training i
information was absorbed, correctly under-stood, or retained by trainees.
I The thrust of this portion-of the County's testimony is that there should be testing in the classroom training program.
This is clearly an issue that was raised by Contention 99.E and therefore, i
the testimony should be stricken as beyond the scope of the con-tantions and not relevant.
The County also attempts to revive Contention 99.L in its testimony at page 52, line 18, through page 53.
Contention 99.L, alleged that the review exercises attached to the workbooks did f
not correspond to the learning objectives in the training work-I books.
The testimony in question merely restates this concern.
j This testimony should be denied as beyond the scope of the conten-tions at issue in this proceeding and, therefore, not relevant.
Moreover, as the Board noted in its Order of March 19, 1984, con-i sideration of the correspondence between review exercises and workbooks would require the Board to " delve much more deeply into l
implementing procedures than is intended by the Commission, as l
stated in Waterford."
Board Order of March 19, 1984, at 17.
Ac-cordingly, this testimony should be rejected on the basis of the Waterford decision.
See Louisiana Power Light Co. (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076, 1107 (1983).
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~11-On page 54, the County's testimony summarizes the testimony i
on the LERO classroom training program.
LILCO moves to strike as jl irrelevant the following portions of the summary:
1.
"because trainees are not tested on classroom l
training" (lines 9-10) on the ground that the issus of testing was raised in Contention 99.E, 2.
"because they are given almost no opportunity
.to practice the skills they need to develop" (lines 10-11) on the ground that the issue of practicing job-skills in the classroom setting was raised in Contention 99.J, 3.
"and because the classroom instructors never i
j evaluate the abilities of trainees to perform their emergency jobs" (lines 11-13) on the i
ground that it raises the issue of testing in the classroom that was covered by Contention 99.E, and 4.
"in fact without testing and evaluation" (lines 15-16) on the ground that it is cov-j ered by Contention 99.E.
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On page 55, lines 8-21, LILCO moves to strike the County's testimony on the training of rookie policemen on the grounds that f
it is cumulative and repetitive of the County's testimony on Con-tantion 65, see Testimony of Roberts gt 3. on Contention 65 (as 1
amended) at 39-44).
j On page 56, lines 18 and 19, the county inserts the phrase "and the repeated suggestion that the training will never have to be put to use."
As noted above, testievny concerning whether or l
not the radiological emergency response training provided to LERO workers will have to be put to use and the effect that that notion might have on the motivation of LERO workets is beyond the scope l
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of Contention 40 and, therefore, should b e stricken as not role-Vant.
t LILCO moves to strike the portion of th on page 57, line 1, and ending on page 58e testimony beginning i
that the regulations specifically st t
, line 12, on the ground i
programs do not require public particip tia e that drill and exerc i
a on.
Appendix E, IV.F.1 states:
10 C.F.R. Part 50, much of the licensee, State, and local eme"A full-sca sonably achievable without mandatory publi rgency plans as is rea-conducted."
c participation shall be LILCO moves to strike a portion of th
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contained within the above objecilon on e County's testimony testimony beginning at page 57 an additional ground.
The asserts that the LERO drill program is i, line 17, through pa I
not provide experience in dealing with membneffective because it its Order of March ers of the public.
19, 1984, In k
tantion 100.E which stated "despite ththe Board specificall n-workers will have to interact with variouse fact that many LERO
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cnd special facility administrators) and the p blofficials (e.g., s drill program includes no activities i ic, the LILCO u
In its ruling the Board stated that thnvolving such interaction."
tne basis of the Waterford decisie contention was denied on on.
tootimony both on the basis of the )L LILCO moves to strike this i
th3 Board's order of March aterford decision, as noted in 19, 1984 cause the issue raised by the testimony wa, and on the ground s covered by Contention s
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1 100.E it is outside the scope of the contentions and, therefore, is not relevant.
In addition, LILCO moves to strike the passage on page 57, I
lines 17-19, which states "according to LILCO, these personnel t
were selected because they were familiar with driving large vehi-l cles"; as noted above, a selection process or lack thereof is be-yond the wcope of the admitted contentions and, therefore, is i
irrelevant.
j The portion of the County's testimony beginning at page 60, i
j line 5, and ending on page 62, line 19, speculates that due to a i
variety of reasons any group of trainees might not learn to per-form their jobs properly despite training, that "the key deficien-4 l
cy with LILCO's drills.
. is that they involve far too little realism," and that a multiplicity of events could take place for i
which the LERO training program does not prepare trainees.
The i
admitted portions of contention 100, which address the specifics
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of the LERO drill and exercise program, do not presage this con-Therefore, the Board should strike all of this testimony as cern.
j not relevant.
The sentence on page 60, lines 13-15, should also 1
be stricken as irrelevant on the ground that the Board specifical-r ly rejected Contentions 99.E and 99.F concerning the need for graded testing in the LILCO training program.
At page 63, lines 1-9, the County attempts to resurrect, through testimony, contention 99.3, which was rejected by the Board in its order of March 19, 1984.
The testimony in question
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- 1 concerns the substantive adequacy of the videotapes which are part of the LERO training program.
This issue was specifically raised q'
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and rejected in Contention 99.5, and, therefore, is beyond the scope of the admitted contentions and not relevant.
At page 64, line 3, through page 65, line 10, the County's testimony deals with stress training during the drill and exercise 4
As the Board stated in its Order of March 19, 1984, when l
program.
l it rejected Contention 100.C, "there is no regulatory requirement that drill scenarios provide training on how to deal with stress, nor can the Board see any basis for implying such a requirement."
i j
Board Order of March 19, 1984, at 18.
Suffolk County's improper attempt to revive this issue through its testimony should be stricken.
l LTLCO. oves to strike the portion of the County's testimony begin Ang on page 65, line 11, ending at page 67, line 10, which concerns the need for LERO workers to be familiar with their field j
work locations, as beyond the scope of the contentions admitted
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and, therefore, not relevant.
In addition, thia testimony is i
duplicative of testimony on Conteation 65, 333 Testimony of.
i Roberts, 33 31. on Contention 65 (as amended) 'at 27 and 39-44; 333 l
313o Board Order of January 23, 1984, at 4 [ denying LILCO motion i
l to strike the referenced pages from the Roberts, 21 A1. Testimony, l
but stating that "we will scrutinise testimony filed for Group 11 and may strike any testimony that is cumulative with this testi-mony.").
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LILCO moves to strike the portion of Suffolk County's testi-line 4, mony beginning at page 67, line 11, and ending at page 68, 4
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on the ground that it is beyond the scope of the admitted conten-tions and, therefore, not relevant to matters at issue in this i
proceeding.
In that portion of the Suffolk County testimony, it i
is alleged that the drills are not training mechanisms but merely 1
devices for testing portions of the plan.
This issue is not I
raised in Contentions 40, 44.E, 44.F, 99 and 100.
Beginning on page 69 through page 71, Suffolk County summa-l rizes its prior testimony.
Consistent with the preceding motions to strike, LILCO moves to strike the following sections of that I
j summary:
a 1.
At page 69, lines 14-18, the Suffolk County testimony states that LILCO's personnel are not experienced in dealing with emergency l
i situations 'anut have no prior experience role-l vant to their emergency functions in LERO.
LILCO moves to strike this testimony on the ground that it apparently raises the issue of l
whether or not LERO personnel were selected i
I for their LERO jobs through some sort of se-Such an issue is not raised lection process.
by the contentions and, therefore, is not relevant.
2.
LILCO moves to strike the phrase 'almost exclusively lectures" on page 69 at lines l
20-21 on the ground that this issue was raised by contention 99.K which was denied admission by the Board and is irrelevant.
LILCO moves to strike as irrelevant the l
3.
phrase "with no testing or evaluation," which begins at line 21 on page 69 and carries over Contention 99.E, which specif1*
r to.page 70.
r cally addressed the lack of a " meaningful and l
graded testing" in the LERO classroom training program, was denied admission by the 8
l Board.
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l 4.
The issue of few practical.or " hands-on" der.-
onstrations was raised by rejected Contentior.
99.J.
LILCO moves to strike this phrase on the ground that it is not relevant to issues i
raised by the contentions admitted.-
5.
The phrase " includes simulated interaction with the public" found at page 70, lines 3-4, and the phrase " subject trainees to stress,"
at page 70, line 4, were issues specifically raised in Contention 100.E and 100.C, respec-tively, and were denied admission by the Board.
On that basis the phrases should be stricken as irrelevant.
In addition, the phrases should be stricken because, as the Board stated in its Order of March 19, 1984, there is no regulatory requirement that drill scenarios provide training on how to deal with stress and also that inquiry into how LERO workers will be trained to interact with officials and with the public is not admissi-ble on the basis of the Waterford decision.
III.
Cg.tentions 41 and 44.D l
LILCO moves to strike Suffolk County's testimony beginning on page 72 at lina 23 and ending on page 73, line 6, on the ground that the discussion of the impr.ct of stress and anxiety on a radio user is beyond the scope of Contentions 41 and 44.D and, there-l fore, is not relevant to the issues presented by those conten-tions.
I l
The portion of Suffolk County's testimony beginning on page 74, line 22, and carrying over to page 75, line 6, concerns the training provided to all emergency workers concerning notification and alleges that the general overview provided does nothing more than cause the attention of trainees to lapse.
This issue was specifically, raised in Contention 99.I which was rejected by the l
o 17 i
Board in its Order of March 19, 1984, and should be stricken as t
irrelevant.
LILCO moves to strike lines 5-8 of page 76 on the grounds that the testimony is beyond the scope of the contentions and, therefore, is not relevant to the issues presented in this pro-l i
caeding.
The testimony allegen that much of the communications ~
related information provided to trainees is confusing or incor-Neither of these issues is raised by Contention 41 or 44.D.
rect.
In fact, the adequacy of LILCO's videotapes was an issue that was specifically raised in contention 99.B which was rejected by the t
Board.
IV.
Conclusion For the reasons stated above, LILCO respectfully requests that this Board strike the testimony which is the subject of this Motion.
Respectfully submitted, LONO ISLAND LIGHTING COMPANY I
M/M M-j sy es M. Christaan se 5. Eeugin Jessine A. Monaghan i
t Hunton & Williams 707 East Main Street Fost Office Box 1535 Richmond, Virginia 23212 DATED:
April 9, 1984 l
LILCO, April 9, 1984 i
CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
(Emergency Planning Proceeding)
Docket No. 50-322-O'.-3 I certify that copies of LILCO'S MOTION To STRIKE PORTIONS OF THE DIRECT TESTIMONY ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 39, 40, 41, 44, 98, 99 AND 100 -- TRAINING OF OFFSITE EMERGENCY RESPONSE WORKERS were served this date upon the following by first-class mail, postage prepaid, or by hand (as indicated by cna asterisk),
or by Federal Express (as indicated by two asterisks).
James A. Laurenson,*
Herbert H. Brown, Esq.*
Chairman, Atomic Safety Lawrence Coe Lanpher, Esq.
and Licensing Board, U.S.
Christopher M. McMurray, Esq.
Nuclear Regulatory Commission Kirkpatri:k, Lockhart, Hill, East-West Tower, Rm. 402A Christopher & Phillips
[
4350 East-West Hwy.
8th Floor, 1900 M Street, N.W.
i Bethesda, MD 20814 Washington, D.C.
20036 Dr. Jerry R. Kline*
Stewart M. Class, Esq.**
Atomic Safet) and Licensing Regional Counsel, Federal Board, U.S. Nuclear Emergency Management Agency Regulatory Commission 26 Federal Plaza, Room 1349 East-We't Tower, Rm 427 New York, NY 10278 4350 East-West Hwy.
Bethesda, MD 20814 James B. Dougherty, Esq.**
3045 Porter Street Mr. Frederick J. Shon*
Washir.gton, D.C.
20008 Atomic Safety and Licensing Board, U.S. Nuclear Bernard M. Bordenick, Esq.*
Regulatory Commission David A. Repha, Esq.
East-West Tower, Rm. 430 Edwin J. Reis, Esq.
4350 East-West Hwy.
U.S. Nuclear Regulatory Bethesda, MD 20814 Commission (to mailroom) 7735 Old Georgetown Road Fabian C. Palomino, Esq.**
Bethesda, MD 20814 Special Counsel to the Governor Executive Chamber, Rm. 299 Stephen B. Latham, Esq.**
State Capitol Twomey, Latham & Shea Albany, New York 12224 33 West Second Street P.O. Box 398 Ralph Shapiro, Esq.**
Riverhead, NY 11901 Cammer and Shapiro, P.C.
9 East 40th Street Corald C. Crotty, Esq.**
New York, NY 10016 Counsel to the Governor Executive Chamber Eleanor L. Frucci, Esq.*
State Capitol Atomic safety and Licensing Albany, NY 12224 Board Panel, U.S. Nuclear Regulatory Commission East-West Tower, North Tower 4350 East-West Highway Bethesda, MD 20814
Martin Bradley Ashare, Esq.**
Atomic Safety and Licensing suffolk County Attorney Board Panel H. Lee Dennison Building U.S. Nuclear Regulatory Veterans Memorial Highway Commission Hauppauge, New York 11788 Washington, D.C.
20555 Spence W.
Perry, Esq.**
Mr. Marc W. Goldsmith Assoc. Caneral Counsel, Federal Energy Research Group Emergency Management Agency 4001 Totton Pond Road 500 C Screet, S.W.,
Room 840 Waltham, MA 02154 Washington, D.C.
20472 MHB Technical Associates Jonathan D. Feinberg, Esq.
1723 Hamilton Avenue New York State Suite K Department of Public Service San Jose, CA 95125 Three Rockefeller Plaza Albany, NY 12223 Mr. Jay Dunkleberger New York State Energy Office Secretary of the Commission Agency Building 2 U.S. Nuclear Regulatory Empire State Plaza Commission Albany, NY 12223 Washington, D.C.
20555 Ms. Nora Bredes Atomic Safety and Licensing Executive Coordinator Appeal Board Panol Shoreham opponents' Coalition U.S. Nuclear Regulatory 195 East Main Street Commission Smithtown, NY 11787 Washington, D.C.
20555 W Ye k & J. G Jessine A. Monag n
Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED:
April 9, 1984