ML20236E590
| ML20236E590 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/29/1987 |
| From: | Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#387-4140 OL-3, NUDOCS 8708030017 | |
| Download: ML20236E590 (5) | |
Text
.
91V6 July 29, 1987 OCt kE ';
.q,.,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 JUL 30 P1 :58
)
BEFORE THE ATOMIC SAFETY AND LICENSING BOARCf'JCF,i,<
r en m -
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Pcwer Station,
)
Unit 1)
)
NRC STAFF RESPONSE TO LILCO MOTION FOR AUTHORIZATION TO INCREASE POWER TO 25%
l.
INTRODUCTION l
On July 14, 1987, Long Island Lighting Company (LILCO) filed with this Licensing Board a Motion for Authorization ta increase Power to 25%
(" Motion" ), requesting the Board to take jurisdiction of LILCO's Motion I
pursuant to 10 C.F.R. 6 50.57(c) and the Commission's ci: cision in CLl-87-04, dated June 11, 1987.
Motion, at 1-2, 6, 8.
However, LILCO requests that no action be taken to activate this proceeding, pending disposition of a concurrently filed Motion for Designation of Licensing ucard and Setting Expedited Schedule, pending before the Commission.
The Staff supports LILCO's Motion insofar as it requests this Board to take jurisdiction of the pending Motion.
However, as set forth fully in the Staff's response to LILCO's concurrent motion before the Commission, appended hereto, LILCO's request for appointment of a new board and for expedited consideration of the 25% power authorization was required, under CLl-87-04, to be filed with this Licensing Board.
LI LCO's procedural and schedule proposals are matters appropriate for consideration by this Board, rather than. the Commission.
However, since 8708030017 97o799 1
{DR ADOCK 05000322
~hbD PDR
LILCO has requested this Board not to consider those proposals at this time, the Staff here takes no position thereon.
II.
DISCUSSION in its June 11, 1987 Memorandum and Order, CLl-87-04, the Commission denied L !LCO's April 14, 1987 Request for Authorization to increase Power to 25% and Motion for Expedited Commission Consideration based on its determination that it could not, consistent with the Commission's regulations in 10 C.F.R. 6 50.57(c) and 10 C.F.R. Part 2, Subpart G, resolve the new material factual issues raised by the 25%
power request in time to grant the relief LILCO sought:
authority to operate at 25% power before the end of Summer 1987.
Howeve r,. the Commission stated that "LILCO may refile its request under 10 C.F.R. 6 50.57(c) with the Licensing Board when and if it believes that some useful purpose would be served."
C LI-87-04, slip op. at 2.
The l
Commission's decision thus allows LILCO to refile its request at a later da te, and directs that such application be made pursuant to applicable Commission adjudicatory procedures.
Title 10 C.F.R. 6 50.57(c) authorizes an appi! cant in a pending proceeding to make a motion before the presiding officer for authorization of operation above 5% power but short of full power operation.
Any action by the presiding officer "shall be taken with due regard to the rights of the parties to the proceedings, including the right of any party to be heard to the extent that his contentions are relevant to the activity. "
10 C.F.R. 6 50.57(c).
Both that provision and CLl-87-04 suggest that the regulation of the 6 50.57(c) proceeding is left to the
4.
f discretion of the presiding officer in the pending proceeding.
Determinations as to the manner of pleading contentions, the scope of discovery, filing of testimony, and the schedule for consideration of procedural and substantive issues are appropriately made by the presiding officer.
The Staff has more fully explained its position in the context of the issues presented in this proceeding in t h'e attached pleading to the Commission.
In sum, CLl-87-04 expressly directs that further proceedings be l
l before the Licensing Board.
As a consequence, the Staff supports the LILCO Motion insofar as it requests the Licensing Board to accept jurisdiction.
Since LI LCO expressly asks the Licensing Board not to consider its procedural and schedule requests at this time, the Staff defers further discussion on those matters.
Ill.
CONCLUSION For the reasons given above, the Licensing Board should take jurisdiction of the LILCO Motion.
Respectfully st;bmitted, 1
George E.
ohr n
Counsel for NRC Staff i
l l
Dated at Bethesda, Maryland this 29th day of July,1987 l
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD j
l in the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
i Unit 1)
)
CERTIFICATE OF SERVICE I
hereby certify that copies of "NRC STAFF RESPONSE TO LILCO MOTION FOR AUTHORIZATION TO INCREASE POWER TO 25%"
in the above-captioned proceeding have been served on the following by deposit in the United States
- mail, first class, or as indicated by an esterisk, through deposit in the Nuclear Regulatory Commission's internal mall system, this 29th day of July,1987.
Morton B. Margulies, Chairman
- Joel Blau, Esq.
Administrative Judge Director, Utility Intervention Atomic Safety and Licensing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 Jerry R. Kline*
Fabian G. Palomino, Esq.
Administrative Judge Richard J. Zahnieuter, Esq.
Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 Frederick J. Shon*
Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, DC 20555 Albany, NY 12223 Philip McIntire James N. Christman, Esq.
Federal Emergency Management Donald P. Irwin, Esq.
Agency Hunton & Williams 26 Federal Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771
Stephen B. Latham, Esq.
Twomey, Latham & Shea Christopher M. McMurray, Esq.
Attorneys at Law David T. Case, Esq.
33 West Second Street Kirkpatrick & Lockhart Riverhead,- NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel
- U.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, DC 20555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel
- Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.
Martin Bradley Ashare, Esq.
General Counsel Suffolk County Attorney,,
Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq.
North Shore Committee Attorney General of the State P.O. Box 231 of New York Wading River, NY 11792 Attn:
Peter Bienstock, Esq.
Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center 195 East Main Street Room 46-14 Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr.
William R. Cumming, Esq.
General Counsel Office of General Counsel Long Island Lighting Company Federal Emergency Management 175 East Old Country Road Agency i
Hicksville, NY 11801 500 C Street, SW l
Washington, DC 20472 Dr. Robert Hoffman Long island Coalition for Safe Docketing and Service Section*
l Living Office of the Secretary j
P.O. Box 1355 U.S. Nuclear Regulatory Commission -
Massapequa, NY 11758 Washington, DC 20555 Mary M. Gundrum, Esq.
Barbara Newman New York State Department of Law Director, Environmental Health 120 Broadway Coalition for Safe Living 3rd Floor, Room 3-116 Box 944 New York, NY 10271 Hunti ton, New York 11743 r
EeTrge E.jfohr/Kn Counsel f# NE Staff 1
L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION in the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
NRC STAFF RESPONSE TO LILCO MOTION FOR DESIGNATION OF i
i LICENSING BOARD AND SETTING EXPEDITED l
SCHEDULE TO RULE ON LILCO'S 25% POWER REQUEST l.
INTRODUCTION l
l On Ju!y 14,1987, Long Island Lighting Company (LILCO) served on the l
Commission its " Motion for Designation of Licensing Board and Setting 3e Expedited Schedule to Rule on LlLCO's 25% Power Request Motion" (" Motion").
This Motion followed the Commission's danial, June 11, 1987, of LiLCO's 1
April 14, 1987 request for 25% power operation and motion for expedited i
consideration.
That denial was based on the Commission's finding that there l
was no prospect for resolving the new material factual issues introduced by LILCO's 25% power request, consistent with normal adjudicatory requirements, in time to grant the relief LILCO sought.
C Ll-87-0 4, slip op. at 2.
The Commission noted,
however, that "LILCO may refile its request under 10 C.F.R. 9 50.57(c) with the Licensing Board when and if it believes that some useful purpose would be served thereby." Id.
In its Motion, LILCO notes that it has filed its 25% power motion with the Licensing Board in the OL-3 docket (the "Margulies Board").
Motion, at 1.
T
(
I) b l
iO'
c i
i However, L1LCO argues that it is not clear that the Margulies Board has jurisdiction over the issues raised, and, in any event, only a newly designated Licensing Board would be able to give the requested expedited consideration of its 25% power request.
Id.,
at 2.
As ' grounds for Commission designation of a new board, LILCO argues that both extant boards (O L-3 and OL-5) are "already fully engaged" and there is "llitle realistic prospect" of their early consideration of the 25% power request.
Id., at 6, 7-9.
In addition, LILCO argues that the Motion "does not clearly raise emergency planning issues", and there is no need for common membership between the emergency planning boards and a board which might be appointed to hear the 25% authorization request.
Id.,
at 7,
9-10.
LILCO also reiterates arguments made in its April 14, 1987 filing that expedition is needed, id., at 10-13, and proposes an expedited and truncated schedule for implementation by a newly designated Licensing Board, id., at 13-16. 1/
Because the instant Motion is inconsistent with the express instruction to LILCO to direct any further request for relief to the Licensing Board, the Motion should be denied.
However, in the event the Commission determines to re-visit the substance of LILCO's arguments for designation of a new board l
-1/
While conceding that authority to appoint new board may rest with the Licensing Board Panel Chairman, LILCO questions whether he could impose or recommend the expedition LILCO seeks.
LILCO argues that, in any event, action by the Commission is euthorized, and would avoid delay in resolution of these matters.
Motion, at 2, n.4.
Given the express direction to LILCO to refer further requests to the Licensing
- Board, there can be little doubt that the Licensing Board has jurisdiction of this matter.
)
- and for expedition, the Staff sets forward below a number of reasons which
)
warrant denial of such reconsideration.
1 11.
DISCUSSION 1
A.
The Commission Has Already Decided that Relief Related to the 25%
Power Request is to be Sought before the Licensing Board Pursuant to 10 C.F.R. 6 50.57(c).
By its June 11, 1987 Memorandum and Order, the Commission determined I
that the 25% power request must be considered under the provisions of 10 C.F.R. 6 50.57(c) and Subpart G to 10 C.F.R. Part 2.
As noted in the Staff's April 29, 1987 response to the original LILCO motion for expedited consideration, 5 50.57(c) contemplates that such motions are to be directed to the presiding officer;, who, after giving any party the right "to be heard to the extent that his contentions are relevant to the activity to be authorized... ", will make appropriate findings in the form of an initial decision.
The Commission's June 11, 1987 Memorandum and Order expressly stated that LILCO "may refile its request under 10 C.F.R. 6 50.57(c) with the IIcensing Board when and if it believes that some useful purpose would be served thereby",
id., at 2.
Thus, the Commission has already decided that I
under Commission regulations, further consideration of a 25%
power authorization request should be upon application to the Licensing Boa rd,
pursuant to " normal adjudicatory procedures."
implicit in that decision is the determination that, under 10 C.F.R. 6 50.57(c), the Licensing Board which has considered the contentions still pending, should hear from the parties concerning the relevance of such contentions to the activity sought to be authorized.
Also implicit is the determination that procedural questions, such l
_y_
as the use of expedi'.ed procedures, are properly addressed to the presiding officer.
As a result, LILCO's Motion is contrary CLI-87-04, and should have been directed to the Licensing Board.
B.
The Procedural issues Raised in LILCO's Motion are Properly Referred to the Licensing Board In support of its request for a new Licensing Board, LlLCO argues that disposition of its 25% power request "neither require (s) further litigatlon of outstanding emergency planning issues ' nor depend (s) on their prior dispositive resolution." Motion, at 9.
However, it must be remembered that the very relief that LILCO seeks depends on an affirmative demonstration, based on at ' east one of the three criteria contained in 10 C.F.R. 9 50.47(c)(1), that notwithstanding failure to meet one or more of the emergency planning standards in 10 C.F.R. 9 50.47(b), "there is reasonable assurance that adequate protective measures can and will be taken..." under 10 C.F.R. 650.47 (a) (1 ).
Conversely, under 10 C.F.R. 6 50.57(c), a party contesting an application for operation short of full power is given an opportunity to demonstrate that there are indeed contentions pending before the ilcensing board that are relevant to the activity sought to be authorized.
It follows that interveners here must be given the opportunity "to be heard" concerning whether deficiencies in emergency planning currently being litigated in the O L-3 and O L-5 proceedings are relevant and material ~ to operation of Shoreham at 25% power, and whether such deficiencies prevent making the necessary finding of " reasonable assurance".
As a result, LILCO's argument that the issues raised in its 25% power request are so distinct from pending issues as to obviate the regulatory policy that the
1 j
- licensing board hearing evidence on contentions preside over the,3 50.57(c) application is without merit.
Since there are evidentiary matters to be decided, the Commission's rules and policy dictate allowing the Licensing Board to initially deal with the difficult practical and legal questions which must be addressed at
~
the threshold of consideration of the 25% power request.
Ventilation of such matters before the Licensing Board will permit efficient disposition of procedural and evidentiary matters, while allowing any important questions of fact, law or policy to be concisely framed for Commission consideration if and when Commission review is necessary.
(See 10 C.F.R. 6 2.786)
LlLCO argues extensively that expedition in the conduct of any procceding on its Motion is essential, given (1) the completion of the facility, (2) the record of delay in completion of the licensing proceeding, (3) the need for electric power on Long Island, (4) national security considerations, and (5) the current availability and ongoing analysis of applicable technical and legal underpinnings for the 25% power request.
Motion, at 10-13.
However, these arguments for expedition should not be considered in a Vacuum.
Implicit in the Commission's decision in CLI-87-04 is the recognition that the parties as well as the Commission have already committed enormous resources to this " complicated and prolonged proceeding."
CLI-87-04, slip op. at 1.
Even assuming LlLCO were correct that the issues presented by its 25% power request were completely segregable from the ongoing emergency i
- planning proceedings, 2_/ the resource issue goes not only to the availability of the sitting licensing boards, but to the availability of the parties.
Given the heavy commitment of litigation resources in the ongoing proceedings, it is not clear that the parties have the resources to proceed simultaneously with all the ongoing matters as well as a potentially complex and lengthy i
proceeding on the 25% power request, particularly where the same loues and l
witnesses are involved.
The Licensing Board is familiar with the procedural posture of each aspect of the proceedings on the OL-3 and OL-5 dockets.
Given this familia rity, it is most appropriate for the Licensing Board to evaluate whether its ov/n work load and priorities, and those of the parties warrant the procedural steps LILCO seeks. 3/
l LILCO's request for relief under 9 50.47(c)(1) also raises difficult legal l
Issues, the resolution of which may profit frcm first consideration before the l
Licensing Board. Two issues which are presented are:
(1)
Did the Commission, in adopting 9 50.47(c)(1),
j contemplate a showing that (a) emergency planning deficiencies are not significant for the plant in question, or (b) adequate interim compensatory actions l
have been or will be ta ken, based on reductions in j
accident risks associated with reduced power levels?
And if not, is an exemption from the requirements of i
10 C.F.R. 9 50.47 needed?
2/
As indicated above, that assumption is subject to substantial question.
l
~3/
It should be noted that the Staff is well along in its review of the technical support for LILCO's 25% power request.
Although recently suspended, the Staff is prepared to complete its evaluation in an expeditious manner.
However, interveners have already claimed the need for substantially greater time to conduct their accident analyses.
Suffolk County, State of New York, and Town of Southampton Response in Opposition to LILCO's Motion for Expedited Commission Consideration, at 22.
l l
l l
l
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ = _ _
_ _ - __________________=__
_7 (2) Did the Commission contemplate issuance of a full-power license based solely on a finding of "other compelling reasons to permit plant operations,"
where those reasons involve an urgcnt need for power?
Examination of the Statement of Consideration for the 1980 revisions to the Part 50 emergency planning requirements (45 Fed. M.
- 55402, August 19, 1980), the legislative history associated with those revisions, as well as the 1980 NRC Authorization Act (reviewed in LBP-83-22,17 NRC 608, 628 et seq.), and the decisions in ALAB-818, 22 NRC 651, 670-671 (1985),
and CLl-86-13, 24 NRC 22, 29 (1986), raises these substantial issues, which should be initially considered by the Licensing Board.
C.
Any Section 50.57(c) Hearing Should.Be Conducted Pursuant to Normal Adjudicatory Procedures Should the Commission decide to consider LILCO's request for expedition and proposed schedule, Motion, at 10-16, the Staff believes there is good ae reason not to depart from normal adjudicatory procedures.
1 in its Mot.'on, LILCO has proposed a truncated procedure, eliminating I
completely the contention phase of the proceeding, and, in addition, has argued that LILCO has already met its burden of going forward with its case and thus need not file testimer.y.
Motion, at 13-14.
The Staff believes LILCO's proposals are not workable, i
First, the 25% power request relies heavily on severe accident analyses to demonstrate that "very small risk (is] associated with operation at 25%,"
and "that emergency planning is unwarranted at distances 'beyond one. mile j
)
l l
' from the plant." 4/
Although LILCO does not request relief from the requirement to plan for emergency response for a 10-mile emergency planning zone, the burden of its presentation is that, for Shoreham, the planning bases on which the 10-mile zone was premised, are satisfied at one mile from the plant if power operation is limited to 25%.
While the issue of need for offsite emergency planning appears straightforward as a general matter, this does nct end the inquiry.
The analyses relied upon by LILCO, and which were under evaluation by the Staff, are new, and the use of these analyses to l
establish levels of accident risk from the Shoreham plant has not previously l
been acdressed. 5/
The factual issues which may be raised in response to the proffered analyses are not obvious, and contention pleading or the equivalent is needed to focus and narrow the issues.
Early definition of the issues will speed and streamline both the discovery and hearing stag es.
Testimony addressing clearly defined issues will take less time to hear th an will testimony not focused on discrete issues.
- )resumably the issues ind the testimony must address not only the validity of LILCO's 1
analyses. but also whether there are specific aspects of currently unresolved
--"es y, hich may affect emergency response capabilities at the 25% power l
4/
Request for Authorization to increase Power to 25%, April 14, 1987, at
~
59.
-5/
In fact, litigation of such issues was precluded in this proceeding.
See ALAB-832, 23 NRC 135,146-148 (1986) (generic accident analyses "were condLcted to remove the need for site specific calculations....")
i l
l 1
- l. level.
Failure to follow standard NRC practice would likely further complicate and prolong such a proceeding, and certainly would not be expeditious.
Other aspects of a prehearing schedule should await definition of the issues by a Licensing Board.
However, as LILCO recognizes, meaningful discovery depends on the availability of analyses of the LILCO studies supporting its 25% power request.
Discovery of the positions of parties other than LILCO will need to be commenced.
No persuasive basis has been provided to depart from the general proposition that overall regulation of a 6 50.57(c) proceeding is appropriately left to the Licensing Board, consistent 1
with the regulations and the Commission's Statement of Power on Conduct of Licensing Proceedings, CLi-81-8,13 NRC 452 (1981).
in sum, the issues implicitly raised by LILCO's 25% power request are
]
not susceptible to resolution without normal adjudicatory procedures for refining and exploring the applicability of properly raised contentions to the l
l proposed activity, and LILCO's proposal to skip the contention phase and to treat LILCO as having already submitted opening testimony should be rejected.
Management of these matters is properly left with the Licensing
"
- rd.
111.
C O.N C L U SI O N For the foregoing reasons, LILCO's Motion should be denied.
l l
Respectfully submitted, b
rge E J son Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of July,1987
- _ - _ _ _ _ _ _ - _ _ _ _ _ = _ _ _ _ _ _ _ _ _
)
{
~
t UNITED STATES OF AMERICA N.7 NUCLEAR REGULATORY COMMISSION
'87 JUL 30 P138 q
BEFORE THE COMMISSION j
T..
In the Matter of
)
"Md-
)
i LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO LILCO MOTION FOR DESIGNATION OF LICENSING BOARD AND SETTING EXPEDITED SCHEDULE TO RULE ON LI LCO'S 25% POWER REQUEST" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 29th day of July,1987.
Morton B. Margul!es, Chairman
- Joel Blau, Esq.
Administrative Judge Director, Utility Intervention Atomic Safety and Licensing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 i
Jerry R. Kline*
Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor i
Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224 Frederick J. Shon*
Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, DC 20555 Albany, NY 12223 Philip McIntire W. Taylor Reveley til, Esq.
Federal Emergency Management Donald P. Irwin, Esq.
Agency Hunton 6 Williams 26 Federal Plaza 707 East Main Street Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771
_ _ _ =
l 2
i Stephen B. Latham, Esq.
Herbert H. Brown, Esq.
f Twomey, Latham S Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
33 West Second Street Kirkpatrick & Lockhart i
Riverhead, NY 11901 South Lobby - 9th Floor j
1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel
- U.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, DC 20555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel
- Empire State Plaza U.S. Nuclear Regulatory Commission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.
Martin Bradley Ashare, Esq.
General Counsel Suffolk County Attorney Federal Emergency Management H. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq.
North Shore Committee Attorney General of the State P.O. Box 231 of New York Wading River, NY 11792 Attn:
Peter Blenstock, Esq.
Department of Law Ms. Nora Bredes State of New York i
Shoreham Opponents Coalition Two World Trade Center i
195 East Main Street Room 46-14 Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr.
William R. Cumming, Esq.
General Counsel Office of General Counsel t ong Island Lighting Company Federal Emergency Management 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW Washington, DC 20472 Dr. Robert Hoffman Long island Coalition for Safe Docketing and Service Section*
Living Office of the Secretary P.O. Box 1355 U.S. Nuclear Regulatory Commission Massapequa, NY 11758 Washington, DC 20555 Mary M. Gundrum, Esq.
Barbara Newman New York State Department of Law Director, Environmental Health 120 Broadway Coalition for Safe Living 3rd Floor, Room 3-116 Eox 944 New York, NY 10271 Huntington, New York 11743 George E. 8ohnsQ Counsel for NRC Staff