ML20141H172
| ML20141H172 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/22/1986 |
| From: | Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20141H170 | List: |
| References | |
| ALAB-832, OL-3, NUDOCS 8604240141 | |
| Download: ML20141H172 (17) | |
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UNITED STATES OF AMERICA 'ec NUCLEAR REGULATORY COMMISSION 86
'?22 Before the Commission A3,$$
GFF;r 00 0, i
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON ANSWER TO LILCO'S PETITION FOR REVIEW OF ALAD-832 In its Petition for Review of ALAB-832 dated April 10, 1986 (hereafter,
" Petition") LILCO requests review of five purported errors allegedly embodied in that decision. Suffolk County, the State of New York, and the Town of Southampton (hereafter, " Governments"), hereby respond to LILCO's allegations and demonstrate that there is no basis or need for Conmission review of the matters raised by LILCO.
I. General Objections to LILCO Petition as a Whole A. LILCO Failed to Comply with Section 2.786(b)(2)
The Commission's regulations require that a petition for review "shall contain," among other things, "[a] statement (including record citation) where the matters of fact or law raised in the petition for review were previously 1
The Governments have separately set forth in their own Petition for Review dated April 15, 1986, particular aspects of ALAB-832 which do require Commission review.
8604240141 860422 PDR G
ADOCK 05000322 PDR
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2-raised before the Atomic Safety and Licensing Appeal Board and, if they were not, why they could not have been raised . . . ." 10 CFR $ 2.786(b)(2)(ii).
LILCO's Petition is devoid of any reference to LILCO briefs or other presenta-tion to the Appeal Board of the arguments made in the Petition. Thus , LILCO's Petition is defective on its face and must be denied as failing to comply with Section 2.786.
B. LILCO's Petition Amounts to an Impermissible Attack on the Commission's Regulations LILCO makes several arguments which boil down to a suggestion that the Commission should suspend its regulations, accord special treatment to LILCO, and deprive the Governments of their rights. Thus, LILCO argues that the reasonable assurance requirements of Section 50.47 should not apply to the NRC's licensing decision for Shoreham, that Section 50.47(c)(2) should not apply to LILCO's emergency plan, and that Section 189(a) of the Atomic Energy Act and the Commission's regulations implementing that section's mandated hearing right should be ignored.
LILCO. provides no legal basis or meaningful analysis concerning its asserted entitlement to special treatment and abrogation of the regulations and i
due process requirements. It merely asserts, as if repetition will make it so, 1
2 In fact, LILCO never did raise with the Appeal Board many of the arguments upon which its Petition is based. For example, the argument concerning the applicability of 10 CFR $ 50.47(c)(1) is not raised in LILCO's briefs either concerning LILCO's Plan as a whole or with respect to the issues addressed in ALAB-832. In fact, the only reference to Section 50.47(c)(1) in LILCO's briefs filed with the Appeal Board is a footnote reference to an NRC Staff argument concerring Contention 81 (relating to the ingestion pathway). LILCO's Brief in Opposition to the Intervenors' Appeal of the ASLB's Partial Initial Decision on Emergency Planning (December 13, 1985) at 92, n.126. Its Petition is further defective in failing to state why these issues could not have been raised before the Appeal Board. See also 10 CFR $ 2.786(b)(4)(iii) (petition for review will be denied on issues that could have been raised before Appeal Board but were not).
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that the Appeal Board was wrong, that the issues addressed in ALAB-832 are not material, and that it does not want to go through any more litigation.
LILCO's ipse dixit form of argument does not establish a basis for review of the Appeal Board's decision, paticularly when, as discussed below, LILCO fails to address the Appeal Board's stated rationale and legal bases for its rulings.
The rulings to which LILCO objects were premised upon the Commission's regulations and the due process standards embodied in them. LILCO's bald assertions that those regulations should not be applied are wholly lacking in basis and do not justify review of the Appeal Board's decision.
II. Responses to Specific Errors Alleged by LILCO A. The Appeal Board Was Obligated to Apply Section 50.47(b) in this Proceeding; There is No Basis to Suggest that Section 50.47(c)(1) is Applicable or Would Lead to any Different Result i
LILCO asserts that the Appeal Board made a " fundamental error" by
" applying the wrong legal framework" in reviewing the ASLB's decision on the adequacy of LILCO's proposed emergency plan. This LILCO asserted " error" must be rejectef because LILCO's argument is premised on three incorrect propos itior.s :
(1) that because LILCO has proposed a utility-implemented emergency plan, Section 50.47(b) should not govern the 3
For example, LILCO asserts repeatedly that the issues on which the Appeal Board ruled against LILCO have no major safety significance. See, e.g.,
Petition at 3, 6, 12. That is untrue. For example, Contentions 22.B and 22.C involve LILCO's ability to protect persons endangered by a Shoreham accident --
a matter of direct safety significance. Similarly, the role conflict issue involves critical issues of whether school children can be protected -- a matter which again has direct safety significance. And, LILCO's assertion that the adequacy of the Nassau Coliseum is an issue with "little or no effect on the radiological health and safety of the public" (Petition at 12) is ridiculous.
What could have more impact on the radiological health and safety of the public than whether the facility at which radiological monitoring and decontamination will take place is adequate for the accomplishment of those functions?
NRC's decision as to the adequacy of emergency preparedness at Shoreham; (2) that Section 50.47(c)(1) should be the only criteria for judging the adequacy of LILCO's Plan, and should in effect supplant all the licensing standards in Section 50.47(b); and (3) that the application of Section 50.47(c)(1) to the LILCO Plan as a whole, and/or to the issues addressed in ALAB-832, would result in a finding in LILCO's f avor.
First, there is no basis in Section 50.47(c)(1) itself or elsewhere in the Commission's regulations or the legislative history, to suggest that a licensing decision, or the Appeal Board's review of one, should evaluate a proposed emergency plan against any standards other than those set forth in Section 50.47(b) and NUREG-0654. Indeed, LILCO's Petition does not even purport to justify or support its conclusory statement that the Appeal Board
" applied the wrong legal framework." Petition at 4.
Second, Section 50.47(c)(1) does provide a mechanism for an applicant to attempt to overcome a failure to meet Section 50.47(b) standards under specific, limited circumstances, and if particular factual demonstrations are made. It is clear from the plain words of Section 50.47(c)(1), however, that such an opportunity does not even arise until after the Section 30.47(b) standards have been applied and the plan at issue is found deficient. Thus, Section 50.47(c)(1) does not supplant Section 50.47(b); it may be applied following the application of Section 50.47(b).
Third, the suggestion that Section 50.47(c)(1) could be applied to render the LILCO Plan adequate is baseless. Contrary to LILCO's assertion (Petition at 4), the LILCO Plan cannot be characterized as "an interim compensating action" which could be cognizable under Section 50.47(c)(1). There is no
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evidence to support the suggestion that the decisions of Suf folk County and the State of New York not to adopt or implement an emergency plan for Shoreham, are temporary or likely to change after some " interim" period. The County's position, and the resolutions which articulate that position, have been held valid by state and federal courts. The State's position is similarly definite and unequivocal. Neither position can be characterized as being conditional, contingent, or temporary. Moreover, there is no indication in LILCO's license .
application that it intends its plan to be in effect for only an " interim" period. Therefore, the suggestion that the " interim compensating action" l provision of 50.47(c)(1) could apply in this case is wrong.
Fourth, there has been no demonstration that any of the criteria set forth in Section 50.47(c)(1) are met with respect to any of the deficiencies discussed in ALAB-832. Section 50.47(c)(1) contemplates an evidentiary showing ,
by an applicant, "to the Commission's satisfaction," that deficiencies "are not significant," that there exist compensating actions that are " adequate," or that there are "other compelling reasons to permit plant operation." LILCO cites no such demonstrations made to the Licensing Board, the Appeal Board, or to this Commission. In fact, none have been made, nor could they be made with respect to the issues addressed in ALAB-632. Thus, there is no basis for 4 '
LILCO's reference to Indian Point, and its suggestion that that case (where l Section 50.47(c)(1) was applied) is analagous to this one, is also without I basis. The Commission applied the " interim compensating action" provision at Indian Point in a situation where (1) one out of four counties had not yet completed its plan, but was working on it and had a scheduled completion date, and (2) the NRC had reviewed a State " compensating" plan and found it adequate to substitute for the response of that one County during the defined completion period. Thus, at Indian Point there was a defined " interim period," and the Commission had a basis to find that the proposed " compensating" plan was adequate and met the standards of Section 50.47(b). None of these conditions are present in this case.
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6-LILCO's assertion that Section 50.47(c)(1) requires reversal of ALAB-832 or a finding that "the LILCO Plan is adequate to support the issuance of a full-3 power license." Petition at 5.
B. The Appeal Board Correctly Ruled on the Issues it Reversed and Remanded in ALAB-832 In asserting that the Appeal Board " abused" the record and committed errors of fact and law in its substantive rulings in ALAB-832 (Petition at 6-12), LILCO mischaracterizes the Appeal Board's rulings and ignores its analyses and stated bases for those rulings. Instead, LILCO merely asserts that different conclusions should have been reached, and repeatedly complains about 4
the burdens involved in the additional litigation ordered by the Appeal Board.
LILCO's failure ever, to address, much less demonr+ rate any error in, the Appeal Board's analyses, requires denial of its Petition.
- 1. The Appeal Board Ruled Correctly in Remanding Contentions 22.B and 22.C There is no discussion in LILCO's Petition of the basis for the Appeal Board's ruling on Contentions 22.B and 22.C. That basis was that the Ccmmission's own regulation -- 10 CFR $ 50.47(c)(2) -- requires that the Governments be given an opportunity to contest whether local conditions were taken into account in arriving at LILCO's proposed EPZ. See ALAB-832 at 19-22.
LILCO's conclusory discussion -- and incorrect characterization -- of this LILCO's characterization of the EPZ issue as "must there be still more litigation over whether the 10-mile plume exposure EPZ should be expanded because of certain " local conditions" (Petition at 2, n.3) is incorrect, since there never was any litigation concerning the EPZ boundary impact of the local conditions identified in Contentions 22.B and 22.C. Similarly, LILCO's assertion that certain " minor adjustments" in the EPZ were already considered by the ASLB under Contention 22.D is irrelevant. The particular conditions discussed in that contention (e.g. , dividing communities and splitting school districts) are very different f rom those conditions identified in Contentions (footnote continued)
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issue thus provides no basis for the Commission to determine that review is necessary: LILCO's Petition fails to address what the Appeal Board said, or why it ruled as it did, on Contentions 22.B and 22.C. LILCO's request for review of this portion of ALAB-832 a.ust be rejected.
- 2. The Appeal Board Correctly Held that the Record Below did not Permit a Finding that a Sufficient Number of School Bus Drivers Would be Available in the Event of an Accident In arguing that the Appeal Board erred in its ruling related to the availability of school bus drivers to accomplish an early dismissal or evacuation of school children from the EPZ, LILCO again mischaracterizes ALAB-832. It is true that the Appeal Board ruled that the ASLB erred in refusing to admit evidence concerning a survey of volunteer firemen; however, LILCO neglects to mention the remainder of the Appeal Board's ruling.
The Appeal Board recognized that LILCO "does not have any agreements with the school bus companies to ensure that the bus drivers will respond during a radiological emergency," and that "a survey of school bus drivers in the EPZ indicated that significant role conflict might occur." ALAB-832 at 29. In addition, the Appeal Board held that "no evidence was presented to establish that [any surplus bus drivers normally available) would likely compensate for 22.B and C as to which the Governments were denied the opportunity to present any evidence. Finally, LILCO's assertion that the Appeal Board's decision "is directly contrary to the Commission's judgment," referring to the NUREG-0654 statement that a 10-mile zone should prcvide "a sufficient planning base and sufficient flexibility to allow ad hoc protection beyond that distance if necessary," (LILCO Petition at 8) also mischaracterizes the Appeal Board's decision. In fact, in acknowledging that the Governments are entitled to present evidence concerning the impact of local conditions upon the size of the EPZ, the Appeal Board was enforcing, rather than contradicting, the proposition that under normal circumstances a 10-mile zone should permit ad hoc expansion.
The issue presented by Contention 22.C is whether given the particular local conditions presented by Long Island and LILCO's Plan, the ad hoc expansion presumed by the Commission to be available would in fact exist.
any abandonment caused by role conflict of the dimensions suggested by the drivers' survey." Id. at 30. Thus, the Appeal Board held:
On the record now before us, we . . cannot make a finding that a sufficient number of school bus drivers can be relied upon to perform their duties if an acci-dent occurred at Shoreham. Therefore, we are remanding this matter to the Licensing Board for further explora-tion. All parties will be free to adduce additional evidence on the issue; at minimum, the Licensing Board is to accept the testimony related to the survey of volunteer firemen. Upon review of the evidence pre-sented at the reopened hearing, the Licensing Board .
should reconsider its prior findings and conclusions regarding the potential for role conflict among school bus drivers.
Id. at 32-33 (emphasis added). Clearly, LILCO's assertion that ALAB-832 amounts to a requirement of " litigation on a minor piece af evidence that can have no effect on the outcome of the proceeding and no real bearing on any alleged defect in the LILCO Plan," Petition at 9, is a gross mischaracterization.
6 Indeed, the Appeal Board explained why the volunteer firemen survey was relevant, although L1LCO neglects even to mention, much less dispute, the Appeal Board's analysis:
While the applicant does not rely on volunteer firemen to implement protective actions in the event of a Shoreham emergency, that fact alone is insufficient to deny admission of the testimony. In our view, the results of the survey as to the potential for role crmflict among firemen, if they had been part of the en rgency response, would provide insight into the likely course of conduct of school bus drivers.
Stated in its simplist terms, if a trained professional emergency worker such as a fireman would put family obligations ahead of the discharge of any Shoreham emergency duties that might be assigned to him or her, it is a fair inference that an individual not in such a line of endeavor would encounter at least as great role conflict. It is thus unsurprising that, in the consideration of emergency planning in (footnote continued)
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4 Furthermore, LILCO's assertions that the volunteer firemen survey "could not have affected" the ASLB's ultimate decision because that Board " concluded that opinion pells would not be useful" and that "the Appeal Board did not reverse" that finding, also ignore the plain language of ALAB-832. The Appeal i Board did reverse that finding: it expressly referenced the survey of school bus drivers and LILCO's failure to submit evidence to counte the facts re-vealed by that survey in holding that the record did not support a finding that a sufficient number of drivers would be available; it held that the results of ,
i the volunteer firemen survey constitute material evidence; and, it referenced its own Zimmer decision in which it relied on surveys of workers expected to act in an emergency and affirmed the Licensing Board's order of additional i surveys as a condition of licensing. Thus, LILCO's Petition distorts the Appeal Board's holding and fails to address its analyses and conclusions. It states no basis for review or reversal of the Appeal Board's rulings concerning the availability of school bus drivers.
- 3. The Appeal Board Correctly Rejected LILCO's Reliance Upon Ad Hoc Measures for Evacuation of Hospital Patients In discussing the Appeal Board's rulings concerning evacuation of hos-r Zimmer, we found that surveys of volunteer life squadsmen and firemen concerning the role conflict they would encounter raised 'a serious question as to 2
whether bus drivers could be depended upon to carry i out their responsibilities' in the event of an accident at that plant. We further determined there
! that those surveys precluded, on the evidence of record, a finding that the school bus drivers would respond promptly.
ALAB-832 at 31-32 (emphasis added, footnotes omitted).
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See Cincinnati Gas & Elec Co. (Zimmer Nuclear Power Station, Unit 1) LBP 48, 15 NRC 1549, 1571-72, 160e-607, aff'd, ALAB-727, 772, 17 NRC 760 (1983).
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pital patients, LILCO continues to mischaracterize ALAB-832. Thus, LILCO refers primarily to the Appeal Board's ruling concerning LILCO's failure to obtain agreements from hospitals outside the EPZ stating how many hospital patient evacuees they could accommodate in the event of a Shoreham accident.
Petition at 10. The Appeal Board's holding concerning the lack of preparedness for hospital patients was substantially broader. The Appeal Board recognized that LILCO's " plan" for evacuation of hospital patients is to make the necessary arrangements on an ad hoc basis during an emergency. Thus, LILCO not only has no agreements with reced ving hospitals concerning their ability to accommodate and care for the number of hospital patients who may have to be evacuated, but LILCO also has no evacuation time estimates for the evacuation of hospitals, no arrangements concerning how vehicles would be diverted from the evacuation of other EPZ residents to deal with the needs of hospital patients, and there is no basis for determining whether a sufficient number of such vehicles would become available so as to make timely hospital evacuations achievable. In response to LILCO's ad hoc proposal for hospital evacuation, the Appeal Board stated:
With respect to the necessity that the emergency resplUse plan concern itself with the transportation of hospital patients to reception hospitals outside of the EPZ, the regulations do come into play and counter any thesis that such transportation requires no preplanning but can be left to ad hoc resolution once the emergency has occurred. Specifically, in connection with its emergency plan, an operating license applicant must provide "an analysis of the time required to evacuate and for taking other protective actions for various sectors and distances within the plume exposure pathway EPZ for transient and permanent populations." Such an analysis cannot be made for the hospitals without an 8
See, e.g., Plan, App. A, at II-28, IV-172-73; Long Island Lighting Co.
(Shoreham Nuclear Power Station Unit 1) LBP-85-12, 21 NRC at 842, 829-31, 845-46 (1985).
awareness of the extent of the transportation that might be required to remove the patients from the EPZ, as well as an understanding of how and when the evacuation would be accomplished. Yet the proposal to deal with transportation requirements only after the need arises supplies no insight on either score. . . .
The ad hoc evacuation does not provide a foundation for ascertaining evacuation time estimates in conformity with [NUREG-0654] criteria.
ALAB-832 at 38-39. LILCO's assertion of Appeal Board " error" thus completely ignores the fatal deficiency found by the Appeal Board in LILCO's proposal to rely upon ad hoc measures during an emergency to accomplish an evacuation of hospital patients.'
- 4. The Appeal Board was Correct in Holding that the Governments are Entitled to Discovery and Litigation Concerning the Adequacy of the Nassau Coliseum for Monitoring and Decontaminating Evacuees Once again, LILCO mischaracterizes the Appeal Board's ruling: in this instance, LILCO ignores the Board's finding that the Governments were deprived of their right to conduct discovery and to present evidence concerning the issue presented by LILCO's proposal to use the Nassau Coliseum as a reception l center. ALAB-832 at 45-51. In its Petition, LILCO merely argues that testimony proffered by the Governments and expressly held by the Appeal Board to be relevant (ALAB-832 at 50, n.105) would lead to " protracted litigation" 9
Furthermore, LILCO's argument that hospitals "will do the best they can in an emergency," (Petition at 10) completely misses the point highlighted in ALAB-832. Pre-emergency preparedness implies knowing before the emergency that there will be sufficient and adequate protection for hospital evacuees if and when an emergency occurs. A belief that people will do their best does not demonstrate that an evacuation could be accomplished or that evacuees could be appropriately accommodated and cared for in the event of an accident, as re-quired by the regulations and Guard v. NRC, 753 F.2d 1144 (D.C. Cir. 1985).
LILCO's failure to mcke any plans for evacuation of hospital patients beyond a listing of possible receiving hospitals, was the basis of the Appeal Board's reversal of the ASLB's ruling.
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and would have " broadened the record." Petition at 11-12. LILCO thus ignores the Appeal Board's analysis of the ASLB's errors in denying the Governments discovery and rejecting their proffered testimony; in essence, LILCO simply complains that it doesn't like the result.10 LILCO's Petition provides no basis for reviewing, much less reversing, the Appeal Board's decision on the Nassau Coliseum issues.
- 3. LILCO's Assignment of " Blame" for a Disjointed Proceeding is Misplaced LILCO's argument in Section III of its Petition -- that the Appeal Board is somehow responsible for what it characterizes as " fragmented," " piecemeal,"
" disordered" and " disjointed and incoherent decisionmaking," (Petition at 3,
- 13) -- again mischaracterizes the facts. It is true that this proceeding is complex and has become even more so as the appeal process has progressed. But, '
LILCO's attempt to blame the Appeal Board for that fact is off base.
As both the ASLB and the Appeal Board have acknowledged, and as the Governments have consistently urged, the so-called legal authority issues are dispositive of this proceeding. In light of the state court, federal court, ASLB and Appeal Board rulings that LILCO's Plan is illegal and that LILCO lacks authority to implement that plan, and the ASLB and Appeal Board's denial of a license, it has never made any sense to expend time and resources litigating all the other " factual" issues concerning LILCO's Plan. The legal authority issue has been pending before the Commission since October 18, 1985, when O
Moreover, LILCO's complaint that the remand would result in additional, or even " protracted" litigation is the result of LILCO's own actions. The Governments sought to conduct the discovery and litigation ordered in ALAB-832 during the reopened hearing in early 1985; LILCO fought those ef forts at every turn, and urged the Licensing Board to commit the very errors which have now been reversed.
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ALAB-818 was decided. Contrary to LILCO's assertion (Petition at 14), it is the Commission, not the Appeal Board, which has " sat on" the dispositive issue.
See Commission Order of December 19, 1985 deferring decision on legal authority issues.
The Appeal Board's characterization of the current status of this pro-ceeding and its suggestion as to how it should proceed from here (see ALAB-832 at 7-8) are logical and sensible. Unless the Commission reverses on LILCO's lack of legal authority to implement its Plan -- and the Governments submit that the law clearly does not permit the Commission to do so -- there is no rational justification for expending resources to decide subsidiary factual matters concerning that illegal plan.
Respectfully submitted, l
Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788
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Helber t. H. Brown /
Lawrence Coe Lan;5her Karla J. Letsche KIRKPATRICK & LOCKHART 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk County
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Fabian G. Pa16mino 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
/ Step p B. Latham
[ Twomey, Latham & Shea P.O. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton April 22, 1986 l
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
Before the commission l
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) i In the Matter of )
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) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
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)
Certificate of Service I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON MOTION FOR PAGE LIMIT EXTENSION ON ANSWER TO LILCO'S PETITION FOR REVIEW OF ALAB-832, and SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON ANSWER TO LILCO'S PETITION FOR REVIEW OF ALAB-832 have been served on the following this 22nd day of April 1986 by U.S. mail, first class, except as otherwise noted.
- Nunzio J. Palladino, Chairman Herzal Plaine, Esq.
U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.
Room 1114 10th Floor i 1717 H Street, N.W. 1717 H Street, N.W.
Washington, D.C. 20555 Washington, D.C. 20555
- Comm. Frederick M. Bernthal
- Comm. Lando W. Zech, Jr. U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Con.7. Room 1156 Room 1113 1717 H Street, N.W.
1717 H Street, N.W. Washington, D.C. 20555 Washington, D.C. 20555
- Comm. Thomas M. Roberts
- Comm. James K. Asselstine U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm. Room 1103 Room 1136 1717 H Street, N.W.
1717 H Street, N.W. Washington, D.C. 20555 Washington, D.C. 20555
i 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.
The Governor Nelson A.
Appeal Board 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 i Washington, D.C. 20555 26 Federal Plaza New York, New York 10278 Mr. William Rogers Anthony F. Earley, Esq. -
Clerk General Counsel
'< Long Island Lighting Company Suffolk County Legislature Suffolk County Legislature 250 Old Country Road Office Building Mineola, New York 11501 Veterans Memorial Highway i Hauppauge, New York 11788 **W. Taylor Reveley, III, Esq.
j' Hunton & Williams
- Bernard M. Bordenick, Esq. P.O. Box 1535 .
U.S. Nuclear Regulatory Comm. 707 East Main Street Washington, D.C. 20555 Richmond, Virginia 23212 1
Spence Perry, Esq. Mr. Jay Dunkleberger Associate General Counsel New York State Energy Office Federal Emergency Management Agency Building 2 Agency Empire State Plaza Washington, D.C. 20471 Albany, New York 12223 I Mr. L. F. Britt ** Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street
- North Country Road Riverhead, New York 11901
- Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C. 20555 I
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Mary Gundrum, Esq. Hon. Peter Cohalan New York State Department Suffolk County Executive of Law H. Lee Dennison Build:qg 2 World Trade Center, Rm. 4614 Veterans Memorial Highaay New York, New York 10047 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Ha"11 ton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792
- Martin Bradley Ashare, Esq. ** Fabian G. Palomino, Esq.
Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 David A. Brownlee, Esq. Atomic Safety and Licensing Kirkpatrick & Lockhart Appeal Board 1500 Oliver Building U.S. Nuclear Regulatory Comm.
Pittsburgh, PA 15222 Washington, D.C. 20555 Karla J. Letsc KIRKPATRICKOCKHART
& D)6' 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Date: April 22, 1986
- By Hand
- By Federal Express