ML20138B528
| ML20138B528 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/10/1985 |
| From: | Lanpher L, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#485-447 ALAB-824, OL, NUDOCS 8512120325 | |
| Download: ML20138B528 (26) | |
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.1 UNITED STATES OF AMERICA
'65 CE 11 #1:29 NUCLEAR REGULATORY COMMISSION Before the Commission 1
)
i In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
2 (Shoreham Nuclear Power
)
I Station, Unit 1)
)
)
I l
SUFFOLK COUNTY AND STATE OF NEW YORK PETITION FOR REVIEW OF APPEAL BOARD DECISION I.
INTRODUCTION l
Pursuant to 10 CFR $ 2.786, Suffolk County and the State of j
i New York (" Petitioners").hereby petition the Commission to review l
the November 21, 1985, Decision of the Atomic Safety and
.i l
Licensing Appeal Board (ALAB-824), affirming the June 14, 1985, Partial Initial Decision of the Licensing Board (LBP-85-18, 21 i
NRC 1637), which held that the three Transamerica Delaval, Inc.
("TDI") emergency diesel generators ("EDGs") installed at the Shoreham nuclear facility satisfy the requirements of General Design Criterion 17, 10 CFR Part 50, Appendix A ("GDC 17") for the first fuel cycle.
8512120325 851210 DR ADOCK 05000322 PDR
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a The Licensing Board's decision permits the EDGs at Shoreham to operate at a maximum load of 3300 kW (the " Maximum Permitted Load"),1 which is only 46.7 kW, or 1.4%, higher than the highest maximum emergency servica load ("MESL") that any EDG would experience during a design basis accident at Shoreham.2 Following the failure of a TDI EDG at Shoreham and numerous problems with TDI EDGs at Shoreham and elsewhere,3 this decision, for the first time ever, approved EDGs which were not evaluated in accordance with the standards of the IEEE and NRC Regulatory Guides.4 Petitioners asserted that the Maximum Permitted Load of 3300 kW for the Shoreham EDGs was insufficient to meet the requirements of GDC 17, as previously interpreted and applied, because the margin of only 1.4% above the MESL previded an inadequate capacity and capability to handle additional loads which an operator might add intentionally or erroneously.
The Licensing Board, however, blocked each of Petitioners' attempts to demonstrate that their assertion as to the appropriate IEach EDG may also be operated at up to 3400 kW for a total of two hours during the entire first fuel cycle.
LBP-85-18 at 3-4, 21 NRC at 1641.
2 LBP-85-18 at 91-92, 21 NRC at 1692.
3 See LBP-85-18 at 1-2, 18, 21 NRC at 1640, 1654.
4LBP-85-18 at 18, 21 NRC at 1654. l
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interpretation and application of GDC 17 was correct.
These matters were the subject of Petitioners' July 17, 1985, appeal, 1
which the Appeal Board Decision rejected.
A.
Petitioners proposed a contention that the 3300 kW Maximum Permitted Load did not provide sufficient capacity and capability to meet the requirements of GDC 17 because there is little or no margin between 3300 kW and the [MESLs] for the EDGs, in sharp contrast to emergency diesel generators at other nuclear plants where a substantial margin provides adequate assurance of requisite reliability under GDC 17.
The admission of this proposed contention, which was supported by evidence of how GDC 17 had been interpreted and applied at other nuclear plants, would have permitted Petitioners to engage in discovery and develop further testimony and evidence from other sources, including the NRC Staff.
However, the Licensing Board refused to admit the proposed contention on grounds that it was unnecessarily redundant of admitted contentions and would lead to litigation " irrelevant or at least so remotely collateral to the material issues before us as to be digressive without any redeeming usefulness."6 5January 18, 1985, Memorandum and Order Ruling on Admissibility of Emergency Diesel Generator Load Contention (unpublished), at
- 8. l
B.
Petitioners, in support of the admitted portions of their EDG contentions, attempted to introduce expert testimony and evidence supporting their position as to the proper interpretation and application of GDC 17 (see Attachment hereto).
Among other things, that evidence shows that for EDGs at 27 4
boiling water reactors ("BWRs") licensed by the NRC from 1969 j
through 1984, the Maximum Permitted Load exceeds the MESL by from 7% to 100.6%, or an average of 33%, in contrast to the 1.4%
differential for the Shoreham EDGs.
The Licensing Board re fused to admit this evidence and testimony, because they "would lead to consideration of the margin at other nuclear plants" and I
litigation "so remotely collateral to the material issues before j
us as to be digressive without any redeeming usefulness."6 C.
The Licensing Board refused to permit counsel for Suffolk County to cross-examine witnesses of LILCO and the NRC 1
Staff concerning the difference between the Maximum Permitted Loads and the MESLs of other EDGs and at other nuclear plants.
i Thus, Petitioners were prevented from obtaining testimony of these witnesses concerning the appropriate interpretation and application of GDC 17.
6February 11, 1985, Memorandum and Order Ruling on Motions to Strike Portions of Suffolk County and LILCO Testimony l
(unpublished), at 3.
- 7See, e.g.
Tr. 27,247; 28,366-67.._.
--..,.-.~, -_ -_.-_. -..- - -
i 8
In their Appeal Brief Petitioners urged reversal of the Licensing Board's decision on the ground that the Licensing Board erroneously prevented Petitioners from addressing the issue of the proper interpretation and application of GDC 17.
Petitioners specifically raised each of the particular matters referred to in subparagraphs A through C above.9 II.
DISCUSSION OF APPEAL BOARD DECISION.
The Appeal Board Decision that the Licensing Board properly blocked Petitioners' attempt to elicit and adduce evidence as to the proper interpretation and application of GDC 17 has two fundamental bases:
first, that the testimony and evidence excluded by the Licensing Board do not in fact show that GDC 17 has, for EDGs at all other BWR nuclear plants, been interpreted.
and applied to require a substantial margin between the Maximum Permitted Load and the MESL;10 and second, that even if GDC 17 does require such a substantial margin for the EDGs at Shoreham, those EDGs are adequate because under the " single failure" criterion of GDC 17, only one EDG failure may be postulated.
8Suffolk County and State of New York Brief in Support of Appeal of June 14, 1985, ASLB Decision, July 17, 1985 (" Appeal Brief").
Appeal Brief at 8-10, n. 8 at 8, n.
10 at 10.
10Appeal Board Decision at 7-11.
11 Id. at 12.
m Inexplicably, the Appeal Board did not address the Licensing Board's rejection of Petitioners' proposed contention on the interpretation and application of GDC 17, the admission of which would have allowed Petitioners to conduct discovery on this issue (as discussed in paragraph I.A above).
Rather, the Appeal Board erroneously stated that Petitioners, "if interested," might have used discovery to obtain answers from the NRC Staff.
In fact, such discovery was barred by the Licensing Board, since the contention on which it would have been based was ruled inadmissible by the Licensing Board.
The Appeal Board also ignored the fact that the Licensing Board did not permit Petitioners to cross-examine LILCO or NRC Staff witnesses on the interpretation and application of GDC 17 (as discussed in paragraph I.C above).
Instead, the Appeal Board erroneously stated that Petitioners "had ample opportunity.
.to test on cross-examination the evidence presented by other parties."13 A.
The Appeal Board's support for its decision that Petitioners' testimony and evidence were properly excluded by the j
Licensing Board is as follows:
1.
The Appeal Board asserted that the excluded testimony and evidence do not contradict the NRC Staff's statement in a post-hearing pleading that GDC 17 has not been 1
12 Id. at 10.
13 Id. at 11.._
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construed to require a substantial margin.14 It is completely improper for the Appeal Board to rely at all on this statement, which is not in evidence and was not subject to cross-examination by Petitioners.
2.
The Appeal Board argued that the evidence in tabular fcerm showing EDG load margins for 27 other BWRs (see Attachmen; hereto) does not show a pattern of substantial margins between Maximum Permited Load and MESL.
Instead of allowing this table to be explained by Petitioners' expert witnesses at the hearing, and testified to by NRC Staff and LILCO witnesses if they disagreed with Petitioners' conclusions, the Appeal Board has attempted to intepret the table itself and has done so erroneously.
First, the Appeal Board incorrectly read the table as showing a low margin of only 3% (a*. Millstone 1); in fact, the relevant margin is 13.6% (for the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating, which is the Maximum Permitted Load).
Second, the Appeal Board asserted that "several" other margins are "small (i.e.,
less than ten percent)."15 In fact, the lowest margin is 7%, the next lowest is 9.9%, and the third lowest is 13.6%.
The average margiri is 33%.
Third, the Appeal Board pointed out that the table only includes data as to BWRs (like Shoreham), and does not include data as to pressurized water reactors ("PWRs"); the Appeal Board then cites a single PWR (Catawba 1 and 2) with two EDGs having a 14 Id. at 8.
15 Id. at 8-9.
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margin of only 0.6%, less than at Shoreham.16 The Appeal Board's selective use of data not in evidence is improper.
The Appeal Board does not disclose how many PWRs have EDGs with substantial margins between Maximum Permitted Load and MESL (which might support Petitioners' position); moreover, the Catawba EDGs were j
manufactured by TDI, subjected to the Staff's recent special ad hoc evaluations for all TDI EDGs, and thus tells nothing about the standard historical interpretation and application of GDC 17.
I 3.
The Appeal Board argued that the tabular evidence alone would not show that the substantial margins between Maximum Permitted Loads and MESLs for EDGs at all other BWRs were required by the NRC Staff and " rooted in GDC 17."
That observation might ultimately be proved to be correct, but it overlooks the exclusion of the testimony of Petitioners' expert witnesses regarding the data in the table, as well as pertinent testimony which might have been obtained from NRC Staff witnesses t
had the Licensing Board permitted discovery and cross-examination on this issue.
In summary, the Appeal Board's decision to uphold the Licensing Board barring Petitioners from eliciting and presenting testimony and evidence on the interpretation and application of GDC 17 was erroneous and should be reviewed and reversed.
16 Id. at 9.
17 Id. at 10.
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The Appeal Board also determined that even if the i
Shoreham EDGs are of insufficient capacity and capability to meet
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i the requirements of GDC 17 because of inadequate Maximum Permitted Loads, they would nevertheless be accepted because even I
i if one EDG were lost, the other two would be sufficient to l
l perform the necessary safety functions.18 This is an erroneous i
i and dangerous interpretation of GDC 17 and of the " single
?
failure" criterion expressed therein.
Clearly, GDC 17 has two 4
l separate requirements:
first, that the EDGs shall have
" sufficient. capacity and capability" to perform their safety function; and second, that the EDGs "have sufficient independence, redundancy, and test ability to perform their safety functions assuming a single failure."
If the Shoreham EDGs have insufficient capacity and capability, as asserted by 1
i Petitioners, due to their inadequate Maximum Permitted Load, the t
i first critical requirement of GDC 17 is not met, and whether the inadequate EDGs provide sufficient independence and redundancy is f
irrelevant.
i 4
h III. NEED FOR COMMISSION REVIEW, 4
1 1
The Appeal Board Decision should be reviewed by the Commission because it presents two important and fundamental
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issues with far-reaching implications:
first, whether a party to a licensing proceeding may be. absolutely barred from discovering, t
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Id. at 12.
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o eliciting, and presenting testimony and evidence on how an NRC regulation has been interpreted and applied as to a critical matter before the Licensing Board, and whether cross-examination of Staff witnesses on such interpretation and application may be i
prevented; and second, whether EDGs which do not have sufficient capacity and capability to perform their safety functions under j
1 GDC 17 may nevertheless be approved, on the theory that GDC 17 i
only permits the postulation that a single inadequate EDG will fail in an emergency.
The Appeal Board Decision answers both of j
these questions affirmatively.
Its first determination denies Petitioners due process of law; its second eviscerates GDC 17.
For these reasons the Decision should be reviewed and reversed by the Commission.
l l
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3 Respectfully nubmitted, l
Martin Bradley Ashare l
Suffolk County Department of Law H. Lee Dennison Building
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1 Veterans Memorial Highway Hauppauge, New York 11788 l
i Herbert H. Brown l
Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK & LOCKHART 1900 M Street, N.W.,
Suite 800 j
Washington, D.C.
20036 I
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i Attorneys for Suffolk County 1
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Fabian G.
Palomino
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Special Counsel to the Governor Executive Chamber, Room 229 State Capitol Albany, New York 12224 Attorney for Mario M. Cuomo, Governor of the State of New York December 10, 1985 1
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SUFFOLK COUNTY, January 25, 1985 s
5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board t
)
s In the' Matter of
)
)',
LONG ISLAND LIGHTING COMPANY
)'
Docket No. 50-322-OL
)
(Shoreham Nuclear Power' Station,
)'
t Unit 1)
)
)
TESTIMONY OF DALE G.
BRIDENBAUGH AND GREGORY C.
MINOR REGARDING SUFFOLK COUNTY'S
't E!!ERGENCY DIESEL GENERATOR LOAD CONTENTION Testimony, Attachment and Exhibits c
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A.14.
It in Gasontial thet snough margin io availablo, s
to ensure that all expected loads, including cyclic loads, can be accomodated, taking into account the modeling and other uncertainties inherent in predicting the accident condition, plus providing some margin so that the plant operators will not be restricted in their manual load transfers and manipulations
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in the later stages of the accident.
Moreover, as previously
.. testified to by the County's witnesses, it is industry practice to operate diesel engines at only about 75 to 85 percent of their maximum rated loads, in order not to overstress the en-gine and to enhance reliability.14/
It has been the standard practice in the licensing of all boiling water reactors
("SWRs") in the past to provide for a significant margin be-tween the MESL and the mar.imum rated load of emergency diesel generators, regardless of whether cyclic loads are included.
We have performed a survey of the onsite emergency power supply characteristics of all BWRs that have received their operating licenses as of December 31, 1984.
Our survey in-cludes some 27 BWRs licensed during the fifteen year period from 1969 through 1994 and a range of power ratings from 500MW 14/
Joint Testimony of Dr. Robert N. Anderson, et al.,
regarding Suffolk County's Emergency Diesel Generator Con-tentions, at 18.
t 15 -
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to 1300MW.
The avarage EDG rating exceeds tho expsetsd prak load (maximum emergency service load) by over 33 percent.
The lowest margin we have been able to find is 9.9 percent while the largest is more than 100 percent.
A listing of the plants and respective loads and ratings is presented in, Exhibit 3.
This data is extremely important because it demonstrates the accepted interpretation of the requirements of GDC 17 as to the sufficient capacity and capability to assure appropriate re-sponses to postulated accidents.
O.15.
Has the NRC Staff confirmed your view that all BWRs that have been licensed have had a substantial degree of margin between the naximum emergency service loads and the rat-ings of their EDGs?
A.15.
Yes, it has.
The Transamerica Delaval Diesel Generator Daners Group Program Plan, NRC Safety Evaluation Re-i port, August 13, 1984, at 9, states that i
the staff notes that for many plants, that the maximum emergency service load requirements for loss of off-site power or loss of worst case off-site power and Loss of Coolant Accidents are significantly less than the engine name plate rating."
further Berl,inger of the NRC Staff has In addition, Dr. Carl H.
I stated, with respect to the above-quoted SER language, that:
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'mtny plcnts' rpfore to juot.cbout cvory plant that I cm familiar with that is either in operation or under construction in the United States.
I don't know of any exception to that."15/
Q.16.
Are all of the emergency loads precisely known at Shoreham?
A.16.
No.
LILCO has attempted to measure individual loads and in fact used some of the measured loads to reduce or increase the contribution of that load to each EDG's MESL.
However, LILCO still proposes that name plate values be used for the majority of the MESL loads, thus providing little as-surance that the name plate values may not be exceeded under certain circumstances.
LILCO also performed an integrated electrical test ("IET") which apparently was an attempt to'ver-ify that the appropriate conservatism does exist in the maximum load that each EDG may experience.
The IET, however, did not measure individual equipment loads.15/
Moreover, this test contains a substantial amount of uncertainty as it was simply a measurement of combined loads of equipment assumed by LILCO to operate in a LOOP /LOCA.
Because there is no assurance that the a
15/
Deposition of Carl H.
Berlinger, December 13, 1984, at 5.
(Exhibit 4).
16/
SNRC-lO74, J.D.
Leonard Jr. to H.R.
Denton, NRC, August 22, 1984, at 2.
- 17
3 Tyon of'Leid EDG 101 EDG 102 EDG 103 Measured Loads 34%
35%
64%
Name Plate Loads 66%
65%
36%
If we conservatively assume that the measured loads are at best accurate to i 2-1/2 percent system error, and that the name we can conclude plate loads are at best accurate to +5 percent, that the total load defined for the MESL is no more accurate than 13.9 percent.
Thus, the peak load might well be 128kW higher than LILCO has specified.
O.20.
What is the margin for the EDGs at Shoreham?
A.20.
The difference between the highest EDG maximum emergency service load calculated by LILCO (3253.3kW) and the 3300kW maximum load at which the EDGs may operate is only 46.7%W, or 1.4 oercent of the maximum load allowed.
This small margin assumes no increases in the maximum emergency service
~
loads due to the factors discussed above.
O.21.
What then do you conclude as to the need for margin in onsite emergency power systems at BWRs in general and at Shoreham in particular?
A.21.
No BWR has ever been licensed by the NRC in the a substantial amount of margin between the expect-past without ed maximum emergency service load and the EDG continuous or short-term rating.
This history clearly establishes the ac-cepted requirements of EDG capacity and capability under GDC 17 I
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4 to provido cufficient reliability.
Tho proposal by LILCO at Shoreham, where essentially no margin is being provided between the qualified rating (3300kW) of the EDGs and the predicted MESL (peak of 3253kW), a margin of less than 1.5 percent, does therefore meet the requirements of GDC 17.
There is, ac-not cordingly, little or no margin available at Shoreham to accomodate the cyclic loads which are known to be approximately 5 percent of the EDG rating, none for the potential peak load measurement / calculational error of approximate 3.9 percent, and none to provide for the modeling, calculational, and other uncertainties inherent in the accident scenario forecast.
Q.22.
Are there concerns present in the onsite emer-gency power scheme proposed by LILCO other than the inadequacy of the qualified load you have described above?
A.22. '
Yes there are.
One such inadequacy is the fact that LILCO did not consider the potential effect of the inaccu-racy of the EDG load indicating instrumentation in the design and conduct of the load qualification test.
This deficiency relates to section (a)(ii) of the Contention which states:
" diesel load meter instrument error was not considered."
O.23.
How has the EDG load meter instrumentation error affected the " qualified" load of the EDGs?
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EXHIBIT S$I e
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, _, _ _ _.....~ ___ _ _ _ __. _ ___. _ _ _..., _ _ _ _., _.
_m.
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E Comparative DWR EDG Ratings end LOOP /_L_OC,A,Londcl_/
4 Margin EDG Rating (kW)
(1 of peak load)
Unit Continuous 2000-Ilour Peak Continous 2000-Ilc '
Plant Rating (MW)
In Serv 1ce Rating Rating Load (kW)2/
Rating Ratin!
Oyster Creek 650 1969 2500 4/
1950 28.2 Duane Arnold 597 1975 2850 3000 2480 14.9 21.0 Cooper 836 1974 4000 4700 3619 10.5 29.9 Dresden 2-3 828/828 1970/71 2600 2860 1950 33.3 46.7 Quad Cities 1-2 028/828 1973/73 2500 285'O 1900 26.3 43.9 i Pilgrim 678 1972 2600 2860 2398 8.4 19.3 j
Peach Bottom
]
2-3 1152/1152 1974/74 3250 4/
2560 7.0 l
Brunswick 1-2 867/067 1977/75 3500 3050 2311 51.4 66.6 Itatch 1-2 850/850 1975/79 2850 3100 2669 6.0 16.1 i
LaSalle 1-2 1078/1078 1984/04 2600 22505/
2860 15.6 27.1 i WPPS-2 1100 1984 4400 4650 3860 14.0 20.5 i Susquehanna i
1-2 1152/1152 1903/85 4000 4700 3542 12.9 32.7 6
Fitzpatrick 803 1975 2600 4/
1906 36.4 i
Browns Ferry 1,
2, 3
1152/1152/
1152 1974/75/73 3/
2850 2594 9.9 -
Nine Mile Pt.
642 1969 2560 29507/
1470 74.1 100.6 I Vermont Yankee 563 1972 3000 4/
2446 22.6 Millstone 1 662 1971 27656/
3042 2678 3.3 13.6 l 4
~
Monticello 569 1971 2500 4/
2002 24.9 l
AVERAGE 24.3 33.4 [
j NOTES:
(1)
All data taken from USNRC Public Document Room FSARs and USNRC NUREG 0020.
(2)
Peak load requirement based on auto-start loads listed in the FSARs.
[
(3)
FSAR does not provide a continuous rating.
The 7 day rating is 2950kW and the 30 minutef i
rating is 3050kW.
4 (4)
FSAR does not provide a 2000-hour rating.
l (5)
This peak load does not include the EDG dedicated to the HPCS.
is 2719kW.
(6)
The single Millstone EDG is backed up by a 12MW gas turbine.
4 (7)
This is actually the 1500-hour rating.
l 1
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EXHIBIT [bh O
em.
jur/ 0]s 1
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
x In the Matter of:
5 LONG ISLAND LIGHTING COMPANY Docket No. 50-322-1 (OL) 4 (Shoreham Nuclear Power Station) y
x I
DEPOSITION OF CARL H. BERLINGER 8
Bethesda, Maryland Thursday, December 13, 19'84 to Deposition.of CARL H.
BERLINGER, called for examination l
11 pursuant to agreement by counsel, at the Nuclear Regulatory 12 Commis'sion, Maryland National Bank Building, 7735 Old 13 Georgetown Road, at 12:45 p.m. before ANNE G. BLOOM, a Notary Public within and for the District of Columbia, when 14 15 were present on behalf of the respective parties:
ALAN ROY DYNNER, ESQ.
DOUGLAS SCHEIDT, ESQ.
17 Kirkpatrick, Lockhart, Hill, Christopher & Phillips 18 1900 M Street, N.W.
Washington, D.
C.
20036 19 On behalf of Intervenor Suffolk County.
20 2
21
-- continued --
22
$ce.5a' era l $por4m, $ne.
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please?
2 A
Got it.
In the last paragraph on that page you see there I
3 Q
4 is a reference or a statement as follows:
"The Staff notes that for many 5
6 plants the maximum emergency nervice load 7
requirements for worst-case loss of off-8 site power or loss of off-site power and 9
loss of coolant accidents are significantly i
less than the engine nameplate rating."
10 11 A
Yes, I see that.
12 Q
Can you tell me what are the "many plants" that 13 you are referring to in that statement?
a 14 A
"Many plants" refers to just about every plant 15 that I am familiar with that is either in operation or under 16 construction in the United states.
I don't know of an 17 exception to that.
l 18 Q
Could you tell me generally speaking what is the 19 difference in those many plants?
4 I am asking for an approximation or a percentage 20 between the continuous rating of the CDGs there on the one 21 hand and the maximum emergency service load recuirements on 22 i
UNITED STATES.OF AMERICA
-,,r NUCLEAR REGULATORY COMMISSION 7ts Before the Commission
'8_3 EC 11 TJ1 :29 In the Matter of
)
Sb di
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
Certificate of Service I hereby certify that copies of the SUFFOLK COUNTY AND STATE OF NEW YORK PETITION FOR REVIEW OF APPEAL BOARD DECISION, dated-December 10, 1985, has been served on the following this 10th day of December, 1985, by U.S. mail, first class.
Alan S. Rosenthal, Chairman Stuart Diamond Atomic Safety and Licensing Business / Financial Appeal Board NEW YORK TIMES U.S. Nuclear Regulatory Commission 229 W.
43rd Street Washington, D.C.
20555 New York, New York 10036 Mr. Howard A. Wilber Joel Blau, Esq.
Atomic Safety and Licensing New York Public Service Comm.
Appeal Board The Governor Nelson A.
U.S. Nuclear Regulatory Commission Rockefeller Building Washington, D.C.
20555 Empire State Plaza Albany, New York 12223 Mr. Gary J. Edles Stewart M. Glass, Esq.
Atomic Safety and Licensing Regional Counsel Appeal Board Federal Emergency Management U.S. Nuclear Regulatory Commission Agency Washington, D.C.
20555 26 Federal Plaza New York, New York 10278
,'. 'o.
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i Morton B. Margulies, Chairman Anthony F. Earley, Esq.
i Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 250 Old Country Road l
Mineola, New York 11501 l
Dr. Jerry R. Kline W. Taylor Reveley III, Esq.
1 Atomic Safety and Licensing Board Hunton a Williams I
i U.S. Nuclear Regulatory Commission P.O.
Box 1535 Washington, D.C.
20555 707 East Main Street Richmond, Virginia 23212 4
l Mr. Frederick J. Shon Mr. Jay Dunkleberger i
Atomic Safety and Licensing Board New York State Energy Office U.S. Nuclear Regulatory Commission Agency Building 2 Washington, D.C.
20555 Empire State Plaza Albany, New York 12223 1
Mr. L. F. Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham a Shea i
Shoreham Nuclear Power Station P.O.
Box 398 P.O. Box 628 33 West Second Street North Country Road Riverhead, New York 11901 j
Wading River, New York 11792 Nora Bredes Docketing and Service Section Executive Director Office of the Secretary i
l Shoreham Opponents Coalition U.S.
Nuclear Regulatory Comm.
195 East Main Street 1717 11 Street, N.W.
i Smithtown, New York 11787 Washington, D.C.
20555 l
Ms. Donna D. Duer lion. Peter Cohalan Atomic Safety and Licensing Suffolk County Executive i
Board Panel 11. Lee Dennison Building i
U.S. Nuclear Regulatory Comm.
Veterans Memorial liighway Washington, D.C.
20555 IIauppauge, New York 11788 i
MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee f
i Suite K P.O.
Box 1231 l
San Jose, California 95125 Wading River, New York 11792 i
Martin Bradley Ashare, Esq.
Jonathan D. Feinberg Esq.
Suffolk County Attorn'y Staff Counsel, New York State H. Lee Dennison Building Public Service Commission i
Veterans Memorial Highway 3 nockefeller Plaza Ilauppauge, New York 11788 Albany, New York 12223 l
i l
i
Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Edwin J. Reis, Esq.
Fabian G.
Palomino, Esq.
Bernard M.
Bordenick, Esq.
Special Counsel to the Governor U.S. Nuclear Regulatory Comm.
Executive Chamber, Room 229 Washington, D.C.
20555 State capitol Albany, New York 12224 Spence Perry, Esq.
Mary Gundrum, Esq.
Associate General Counsel New York State Department Federal Emergency Management Agency of Law Washington, D.C.
20471 2 World Trade Center, an. 4614 New York, New York 10047 Mr. William Rogers Clerk Herzal Plaine, Esq.
Suffolk County Legislature U.S.
Nuclear Regulatory Comm.
Suffolk County Legislature 10th Floor Office Building 1717 H Streat, N.W.
Veterans Memorial Highway Washington, D.C.
20555 Hauppauge, New York 11788 Conn. Frederick M.
Bernthal Nunzio J.
Palladino, Chairman U.S. Nuclear Reg'ilatory Comm.
U.S.
Nuclear Regulatory Commission Room 1156 Room 1114 1717 H Street,
- t.. W.
1717 H Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Comm. Thomas M. Roberts Commissioner Lando W.
Zech, Jr.
U.S.
Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Commission Room 1103 Room 1113 1717 H Street, N.W.
1717 H Straat, N.W.
Washington, D.C.
20555 Washington, D.C.
20555 Commissioner James K. Asselstine U.S. Nuclear Regulatory Commission Room 1136 1717 H Street, N.W.
f, Washington, D.C.
20555
/
s tavJ N
Mh KIRKPATRICK 4 LOCKHART 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Date: December 10, 1985
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