ML20236H353
| ML20236H353 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/30/1987 |
| From: | Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4723 OL-3, NUDOCS 8711040084 | |
| Download: ML20236H353 (19) | |
Text
. M3 10/30/87
, 00CKETED USNRC UNITED STATES OF AMERICA W 10 -2 P5 :25 NUCLEAR REGULATORY COMMISSION 0F E GF BEFORE THE ATOMIC SAFETY AND LICENSING BOR ctg $. ERVICE g cge,3g,,
in the Matter of )
)
l L.ONC ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 l ) (Emeroency Planning)
(Shoreham Nuclear Power Station, )
i Unit 1) )
NRC STAFF RESPONSE TO THE BOARD'S MEMORANDUM REQUESTING THE VIEWS OF PARTIES ON THE MATTERS TO BE DECIDED ON THE REALISM REMAND
- 1. INTRODUCTION in its October 8, 1987 Memorandum to the Parties (" Memorandum"),
the Licensing Board reviewed the Commission's decision in CLl-86-13, holding that LILCO's lack of legal authority to implement certain features of its plan did not render the LILCO Plan inadequate as a matter of law, and remanding the proceeding to the Licensing Board to make further factual findings on the realism and immateriality issues raised by LILCO.
As the Board noted at 2-3, CL1-86-13 directed the Board .to obtain more information about the shortcomings of the LILCO Plan in terms of possible lesser dose savings and foreclosed protective actions, " assuming that the l- State and County would in fact respond to an accident at Shoreham on a best-e(fort basis that would use the LILCO Plan as the only available comprehensive compendium of , emergency planning options." CLI-86-13, '
i 24 NRC at 33. Also noted was the Commission's direction that LILCO's Plan should be measured against a standard that would require protective '
8711040084 871030 PDR ADOCK 05000322 o PDR- p-DESIGNATED ORIGINAL Certified By 08 2 -
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measures that are generally comparable to what might be accomplished with governmental cooperation.
Observ'ing that the Commission did "not fully delineate the scope of the further Inquiry that must be made, including the questions that are l to be answered, the extent to which the existing record can be relied upon, and where additional evidence need be taken," the Board asked the parties to specify the issues and questions to be addressed on the Com-mission's remand, and to recommend a schedule for the prehearing and f l
hearing process. Id. at 3-4.
The Staff's views are presented below. O II. DISCUSSION ,
I A. The Requirement to Assume a Best-Effort Government Response l Using the LILCO Plan Restricts the Scope of the Proceeding to l Determining Whether the Governments' Best-E ffort Response on Such a Basis Would Provide Protective Measures Generally Comparable to Those Which Might be Accomplished With Governmental Cooperation.
In opposing LILCO's most recent motion for summary disposition of the legal authority issues, Interveners relied heavily on the affidavits of State and County officials stating that, whatever response the govern-l ments might take, they would not use any portion of LILCO's Plan.
Memorandum at 30-31, citing Interveners' answer at 50. While the
'-1/ This Response was prepared prior to the Commission's adoption of amendments to 10 C.F.R. s 50.47(c)(1), on October 29, 1987. As a result, the Staff's discussion herein does not address the amend-ments or the Commission's statements interpreting CLl-86-13, and providing further guidance to the Licensing Board. The Staff intends to address the Commission's recent action in its reply pleading due November 9, 1987. The Staff also Intends to forward a copy of the rulemaking to the Parties shcrtly.
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Commission, and this Board, may lack the authority to require the gov-ernments of New York State and Suffolk County to implement the LlLCO Pla n , it is 'nevertheless clear that in this proceeding this Board must assume that those governments "would in fact respond to an accident at Shoreham on a best-effort basis that would use the LILCO plan as the only available comprehensive compendium of emergency planning and I options . " CLI-86-13, 24 NRC at 33.
While CLi-86-13 also assumes that "LILCO is prohibited from per-formino the State or County roles" in the areas covered by Contentions 1-10 (id,. at 30), the Commission has contemplated that the governments, in an cmergency, would exercise their governmental powers , on a "best-effort" basis, using the LILCO Plan.
The Board should interpret the Commission's direction to assume a best-effort government use of the LILCO Plan to be a maximum use of the plan , consistent with retention by the governments of their inherent I
police powers, to try to achieve protective measures comparable to those i that would be achieved with governmental cooperation in planning. '
For example, where it can be determined that in the ordinary course of i business , the Suffolk County Police Department (SCPD) employs contractors to perform certain functions , such as the removal of road impediments, CLI-86-13 should be read to preclude a showing that
-2/ Rather than implying some empirical knowledge of what a government planned response would accomplish, this standard Indicates a com-parison of implementation of the LILCO Plan with a best-effort government response, on the one hand, with governmental coopera-tion in planning and implementation using the LILCO Plan, on the other.
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l Interveners would not use the LILCO Plan because the Plan allows LILCO to perform those functions, unless they show another response would be more efficacious. On the other hand, litigation of a best-effort use of the LILCO Plan should explore how, using their best-efforts, the police power to sound emergency sirens will be exercised consistent with the LILCO Plan.
The remanded hearings should therefore proceed from the premise that the focus will be on the manner in which the governments will use their best efforts to implement the r Ian and at what places in the plan LILCO/LERO must accommodate governmental interface, Input, and imple-mentation. In addition, the proceeding should focus on the particular areas, "such as making decisions and recommendations to the public on ;
protective actions, [which) are fundamental to emergency planning." 24 NRC at 31. As to some areas, such as ingestion pathway interdiction (Contention 7), dispensing fuel (Contention 9), and access control (Con-tention 10), detailed examination of iriterface between the governments and the Plan may not be required, based on the fact that such actions -
are not required by pertinent regulations or because of the immateriality of LILCO's lack of authority to enforce certain actions.
The individual legal authority contentions are addressed below in the order they were treated by the Board in its September 17, 1987 Memoran-dum and Order.
4 B. Consideration of Individual Legal Authority Contentions
- 1. Contention 5 (Sirens)
Under the LILCO Plan (Plan at 3.3-4, OPIP 3.3.4), the decision to activate the prompt notification system and to sound the sirens generally
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, rests with the Director of Local Response. LERO is responsible for eva!-
uation of the scope of an accident-and preparation of recommendations as to protective actions to be taken. Plan at 3.5-1, 3.6-3, 3.6-4. See l
ALAB-847, 24 NRC 412, 426-27 (1985). The stren system can be activat-ed from the LERO Emergency Operations Center (EOC), from the Shoreham Control Room, or from LILCO's Brookhaven Substation. Admit-ted Fact 7. A communications network exists to link LERO and the Con-trol Room to government control points. Admitted Facts 8, 13. The j existence and operability of the strens are not challenged. Memorandum i
and Order at 30. The following questions therefore must be addressed: ]
- a. If Shoreham were licensed , how long would it take for LILCO/LERO to inform the State and County of an emergency at Shoreham?
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- b. If LILCO/LERO informed the governments of the magnitude l of an accident and recommended activation of the sirens, would the gov-ernments require more information before activating the sirens? What is the nature of this information, eg , is it more than the information I needed to make the activation decision? What "best efforts" would the '
governments make to obtain this information?
- c. Would LILCO/LERO communicate to the-governments within 15 minutes of declaring an emergency? Should Shoreham be licensed, would the State, using its "best efforts," receive the message of an emer-gency at Shoreham? ,
- d. Would the activation of the system by or under the author-ity of the appropriate government official likely be accomplished within the regulatory timeframe? If not, how much additional time would be
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required if LILCO recommended activation 'of the system than if LILCO acted alone? j i
in the 'decisionmaking process contemplated by the above questions, I the Board may treat as established, as a matter of law, that the technical )
l information necessary for making the activation decision is the same as j that contemplated under the LILCO Plan. See ALAB-847, supra, at 427.
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- 2. Contention 5 (EBS Messages) I i
Under the LILCO Plan, the Director.of Local Response, through the )
Coordinator of Pubile Information, is responsible for providing instruc-tions to the pubile in the event of a Shoreham emergency. Plan at -
3.3-4,-5, OPI P 3.3.4. The Plan provides for coordination of the release I of information with the County Executive or his designee, if he chooses to participate. Plan at 3.8-4. However, the availability of the Plan's EBS primary station is still an open question, pursuant to CL1-87-05, reopen-ing the record on this issue. As noted in the September 17,1987 Memo-randum and Order, however, a New York State Emergency Broadcast
,1 System independent of the LILCO system exists, having a' Common Pro-gram Control Station and a large number of stations - including those in the LILCO plan - covering the entire Shoreham EPZ. Memorandum and Order at 31.
The facts admitted by the September 17, 1987 order establish the method by which the State EBS could be used in an emergency at -
Shoreham to broadcast messages to the pubilc. Admitted Facts 14-29. n Specifically established are those government officials authorized to activate the State EBS system and possessing the authentication codes
necessary to accomplish activation, and the procedures by which LERO would contact an appropriate State or County official to obtain authorizatiori to activate the sirens, to broadcast an EBS message, and to use the State EBS network. Admitted Facts 26, 29.
The only factual questions required to be further addressed are those enumerated above in connection with activation of the sirens. Inas-much as Facts 14-33 are admitted, the availability of at icast the State EBS system is established, as is the availability of pre-written EBS l messages for broadcast. The questions to be answered involve those enumerated above concerning the process of interaction between the LERO Director and the authorized government official or officials, and how much time it will take for the authorized official to decide which message would .
1 be broadcast, using the LERO message forms. Although the Board in its Memorandum and Order (at 31) treated as an open matter the question of what system cnd what messages would be used, it should be enough to i 1
establish the process by which either system will be activated and how much time that would take. Under the assumption that the governments will employ best-efforts to use the LlLCO Plan, whether the governments would work from the LERO message forms should not be litigable.
- 3. Contention 6 (Decisions and Recommendations)
The LILCO Plan designates the Director of Local Response as the person authorized to make the final decision regarding which protective action will be implemented, albeit based on input from the plant, the LERO Radiation Health Coordinator, DOE-RAP, and advice from FEMA, NRC, and State and County representatives should they choose to
participate. Plan at 3.6-4. Procedures regarding obtaining and using information to arrive at protective action recommendations are contained in l
the Plan and these have previously been found to be adequate. Plan at !
3.6; 21 NRC 644, 775-81. Interveners have recently demonstrated i
familiarity with those procedures. See Testimony of Gregory C. Minor on '
Contention EX 36, ff. Tr. 2612. Fu rther , New York State has both qualified personnel and plans to use dose projections and other data to make protective action recommendations and decisions. Admitted Facts 36,
- 37. It is also established that in the event of a radiological emergency, l
including one at Shoreham, New York State would maintain contacts with licensee . personnel for purposes of ongoing consultation and assessment.
Admitted Facts 46, 47.
However, as the Board observed in its Memorandum and Order (at 33), the use of LILCO procedures does not automatically translate into precisely the same decisions. As noted above, the authority to make de-cisions also carries with it the discretion to choose among alternatives i I
available. The LILCO Plan provides that LERO personnel will make those ,
decisions. The Commission's realism assumptions require the Board to determine what will be the likely effect of introducing into the response best-effort actions by government decisionmakert,. The Board suggested that this requires obtaining answers to the following questions:
- a. Which government official or officials will assume charge in the event of a Shoreham emergency?
- b. Which government official or officials will make the neces-sary decisions regarding the type and timing of protective action recom-mendations to be issued to the public?
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- c. What criteria will the decisionmaker use to determine the appropriate protective actions? l
,l d , at 33. However, the assumption that government officiais will use .
their "best efforts" to implement the LILCO Plan consistent with retention )
l of their governmental powers means that such officials will make their i decisions based on the information and options presented under the Plan. j Thus, Interveners may not, for example, depart from basic options con- l l
tained in the Plan, such as that evacuation sectors around the plant ex- i tend to a distance of 20 miles, rather than the 10 miles provided in the 1 1
Plan. This would be contrary to CLl-86-13, and the Board's Memorandum
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and Order, at 46.
in addition to the questions stated by the Board, it would also be necessary to determine the process by which government officials would be integrated into the protective action decisionmaking mechanisms set up under the LILCO Plan:
- d. What means of communication would be employed for con-sultations among offs!te officials and LERO . personnel at the EOC, or elsewhere? I i
- e. What would be the mechanism for transmitting plant and ,
other data used in the protective action recommendation process directly between State or County technical and command personnel and their LERO counterparts?
- f. Would there be delays resulting from introduction of gov- .
ernment evaluotors and decisionmakers into the process which would lead to delays in issuing warnings or recommendi.tions to the public?
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, 4. Contentions 1, 2, and 4 (Traffic Control and Removal of Road Obstructions)
Facilitation of evacuation through traffic control and direction, and remeval of road obstructions is, under CLI-86-13, is a function to be performed by government authorities. 24 NRC at 30-31! Unlike the pre-
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vlously discussed governmental roles, it involves implementation'n' of protec-tive actions. CLi-86-13 assumes that offsite authorities. will use the .,
I LlLCO Plan in performing that function. Thus, interveners' argument that the LILCO Plan for evacuation is unworkable may not be maintained in this proceeding. See Memorandum and Order at 34, citing Interveners' answer to motion for summary disposition, at 68. Further, the times for )
l evacuation, using LERO Traffic Guides alone, rather than police officers, is established. See LB P-85-12, 21 NRC 644, 791-93, 805-09 (1985).
Civen these restrictions, the main issues resolve around the fundamental question, how those authorities charged with responsibility . for traffic control in an evacuation, principally the Suffolk County Police Department, will implement the Plan, and how this change would lead to a degradation of the evacuation times from those times using Traffic Guldes alone.
l First, a great many facts are already known or established. The ;
Suffolk County Police Department (SCPD) consists of about 2600 officers, i of whom about 1800 are assigned to the Patrol Division. Roberts, et al.
ff. Tr2 2180, at'7 (Suffolk County testimony on Contention EX 40). The -
t organization and responsibilities for various traffic control functions are set out in the OL-5 record. See, eg. , id. at 16, 25, 31-32, Roberts, et I
a l,. (Suffolk County testimony on Contention EX 41), ff. Tr. 1134, at 14-18. Provisions for participation of the SCPD in an emergency response i
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are set out in OPIP 3.6.3, Attachment 15. The SCPD has the equipment and training to perform traffic control functions during an emergency. I Roberts, et 'al. , ff. Tr. 218',, at 2-8, Attachments 1-4. Admitted Facts 59, 60. High-ranking SCPD officers testified at the OL-5 proceeding con-cerning thel.- familiarity with the Shoreham EPZ roadways and the proce-dures contained in the LILCO Plan for evacuation traffic management.
Roberts, et al. , ff. Tr. 2180, 1-9, 16, 25, 31, 32, Attachments 1-4, 8, 9; Roberts, et al. , ff. Tr. 1134, at 14-18. The ability of the SCPD to j implement a traffic control scheme, whether that of LILCO or another one, j cannot be seriously contested. Thus, as noted above, the principal question is how would a best-effort response by the SCPD lead to a degradation of the times for evacuation already established in this proceeding using LERO Traffic Guides alone.
Both CLI-86-13 and the Memorandum and Order call for consideration of the materiality of an uncontrolled evacuation insofar as estimates of evacuation times for uncontrolled evacuations may serve to foreclose 1
evacuation as a viable protective action under certain circumstances.
Should the Board find that SCPD implementation of the LILCO Plan does y
not entall significant delay in implementation of traffic control, discussion of an uncontrolled evacuation would seem unnecessary. However, should the Board determine that such inquiry is to be undertaken, the following questions posed by the Commisslor, are presented:
- a. How important would a delay of li to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in evacuation times be?
- b. Would this increase in time eliminate evacuation as a viable protective ar. tion for some scenarios?
- 5. Contentions 7 and 8 (Post-Emergency Functions) in remanding the realism and materiality issues to the Licensing Board, the Commission stated that it sought more information concerning the impact of a best-effort government response in making decisions and recommendations on recovery and reentry, but did not expressly raise the need for futher inquiry concerning decisionmaking and recommendations to the public concerning protective actions for the ingestion exposure I
pathway. 24 NRC at 31.
Moreover, 'n A LA D-847, 24 NRC 412, 431-32 (1986), the Appeal Board, in light of CLI-86-13, remanded the issue of the lack of a New l York State plan for Shoreham for the purpose of reconsidering whether the LILCO Plan , insofar as it addresses the four functions that would otherwise be performed under a State plan, could past muster without any government cooperation. ,l d . Two of those functions related to ingestion exposure pathway planning, id. at 430. The Appeal Board directed that if no identifiable deficiencies other than those cited in the PID were l found , that the Board must find for LILCO on this issue. 3,/ As a result, prior to any consirteration of protective actions assuming a best-effort government response, the Licensing Board should rule whether l the present record shows the LILCO-only plan, insofar as its addresses the four State functions, is adequate under the regulations.
~3/ Although the Appeal Boa'rd did not expressly address whether the record need be reopened, its direction to " revisit its earlier decision in ilght of the Commission's determination that the lack of state cooperation does not per se render LILCO's plan inadequate" and to
" reexamine whether thm are identifiable deficiencies" in this respect suggests that reconsideration should be on the current record.
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The Staff had previously addressed this issue in two recent respon-sive pleadings, arguing that, given the Board's finding that LILCO was 1
able to impfement, without mandatory aumority, the four functions (in- )
i ciuding ingestion exposure pathway planning) which would otherwise be performed under a State plan, no legal authority issue in fact remains with respect to Contention 7. See, NRC Staff Response to LILCO Motion for Reconsideration and Referral of the Board's Ruling on Summary Dispo-sition of the Realism Issue, October 20, 1987, and NRC Staff Response in Support of LILCO Motion for Summary Disposition of Contention 92, Octo-ber 5, 1987. b i
There is nothing in CLl-86-13 regarding consideration of a ;
best-effort , government response based on the LILCO Plan, which pre-ciudes reconsideration of this matter, or which requires the Board to j determine, prior to such reconsideration, " exactly what would occur if LILCO proceeded independently while the State and local Governments did something unspecified to further the same ends." Memorandum and Order at 38. The premise of CLI-86-13 is the assumption that "LILCO is pro-hibited from performing the State or County roles. . ." in the specified areas. 24 NRC at 30-31. In the case of interdiction of the ingestion exposure pathway, the necessary protective actions can be accomplished without participation of the State. As argued in the Staff's previous
~4/ Interveners correctly note that Contention 92 is not merely an inges-tion exposure pathway contention. However, that observation is not material to consideration of Contention 7. See Response of Suffolk County, the State of New York and the Town of Southampton to NRC Staff Response in Support of LILCO Motion for Summary Disposition of Contention 92, October 2G,1987.
respons!ve pleadings, there is sufficient basis for the Board to find that LI LCO's lack of mandatory authority and the lack of information about what the Stste would do are not material. See, CLI-86-13, 24 NRC at 32 (the immateriality argument is "primarily factual rather an legal"). As a result, the Board may rely on its earlier findings to conclude that further information need not be adduced on Contention 7, and based on a finding that the LILCO Plan is adequate and implementable, that Contention 7 be dismissed. See ALAB-847, 24 NRC 412, 431-432 (1986). ,
With respect to recovery and reentry decisions and recommendations, it is questionable whether it is necessary to adduce further information to determine the extent to which a best-effort government response would result in a degraded response. The New York State Plan provides for appointment of a recovery committee, and the State has personnel qualified to address recovery issues. Admitted Facts 61, 62. The Board has interpreted its mandate on remand to be whether proper decisions, recommendations, or actions will be taken. Memorandum and Order at 38-39. Given the Board's findings in the PlD that "[ilt is not necessary to preplan at this stage for contingencies that a committee can resolve at the time of an accident when it has the necessary information for decisionma king . . . ", there would appear to be adequate opportunity to i resolve any coordination problems which might arise f rom the involvement of the State recovery committee, or other offsite authorities in the event of an accident. See 21 NRC 644, 880, 882 (1985). .
- 6. Contention 9 (Dispensing Fuel)
The Board noted that dispensing fuel is a material element in the LILCO Plan. Memorandum and Order at 39, citing PID, 21 NRC 644, at
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l l 917-918. The Board's ruling appears to be based on the theory that, since the Plan assumes that such facilities will be provided, other perhaps more critical elements proceed from their availability, and thus may be adversely affected by their unavailability.
This issue could be resolved in either of two ways. One would be to determine how a government-authorized dispensing of fuel would be different from that contemplated under the Plan. The other would be to obtain testimony on whether the unavailability of this feature would in fact have a material effect on evacuation.
- 7. Contentien 10 ( Access Control)
The Board observed that the only issue remaining on Contention 10 is "the control of access to the EPZ during the time when people are supposed to stay out." Memorandum and Order at 39. As the Board ack nowledg,ed , since the LILCO Plan does not rely on enforced access restrictions, the question is really whether the lack of mandatory authori-l ty over access to contaminated areas is material. ,lo. at 40. In the PID, the Board found that the LILCO Plan insofar as it calls use of signs and Traffic Guides to discourage entry into evacuated areas of the EPZ was reasonable. 21 NRC at 804-805. The Board found that "thcse who evac-uate unnecessarily because of fear of radiation would also have strong motivation not to enter the EPZ from the east..." and that citizens would not in significant numbers seek to enter an unsafe place in conflict with public information. Id.
However, the Board appears to have been concerned primarily with the possibility that, in a best-effort government response in the event of
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, an emergency, LILCO might advise one action, while the governments might try to enforce another action. Memorandum and Order at 40.
Although theoretically possible, such a confilet would not be material under the assumption of "best-effort" response unless the governmental action would be a more efficacious response than taking the actions in the LILCO Plan. This subject is discussed in connection with Contentions 5 and 6, above. Assuming on the one hand that such decisions rest with j
-l the governments, and such decisions will attempt to implement the LILCO l Plan (which the Board found to be adequate insofar as it calls for perimeter conto! short of mandatory enforcement), the only issues which 1
need consideration involve the coordination or decisionmaking and traffic control. These issues are subsumed within the other pertinent contentions.
C. Proposed Prehearing and Hearing Schedule The Board requested the parties propose a schedule for the prehear-ing and hearing stages of this proceeding. The Staff proposes the fol-lowing schedule:
Day 1 Prehearing Conference providing opportunity for oral l argument concerning scope of proceeding and ques-tions to be addressed Day 15,~ ,~
Memorandum and Order Specifying the Scope of Hearing, Issues, and Schedule for Discovery .
Day 15 Discovery' Opens Dav 60 Discovery Closes Day 70 Finai Prehearing Conference for' Clarifying and Nar-rowing issues, and Setting Schedule for Hearing i
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Day 90 Prefiled Testimony Filed l
Day 105 Hearing Commences l Dcy 130 Hearing Closes ,
q 111. CONCLUSION The Board should restrict the scope of the proceccing to determining whether a best-effort government response using the LILCO Plan will i
provide protective measures generally comparable to those which might be l accomplished with government cooperation in planning. The specific questions to be addressed should, as set forth above, examine the performance of government functions in implementing the LILCO Plan, and I l
whether such performance will result in significant delay in taking I protective actions. Where the LILCO Plan previously has been found to I be adequate without resort to governmental authority, or such finding 1
may be made pursuant to pending remand directions on the current record, no further hearings are required. )
1 The Board should adopt the proposed schedule for the prehearing l and hearing phases of this proceeding.
Res ctfully submitted ,
l George . Johnson Counsel for NRC Staff Dated at Bethesda, Maryland this 3&th day of . October,1987 l
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cocucico USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 37 NOV -2 PS:25 I
BEFORE THE ATOMIC SAFETY AND LICENSING BOAR g fi!vN in the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-O L-03
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO THE BOARD'S VEMORANDUM REQUESTING THE VIEWS OF THE PARTIES ON THE MATTERS TO BE DECIDED ON THE REALISM P,EMAND" in the above-captioned procccding 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 or, as indicated by double asterisks, by telecopier, this 30th day of October 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 Special Counsel to the Governor 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 ill, Esc.
Federal Emergency Management , Donald P. Irwin, Esq.**
Agency Hunton r, 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. Herbert H. Brown, Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.**
r Attorneys at Law Karla J. Letsche, 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 4 Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq. l North Shore Committee Attorney General of the State P.O. Box 231 of New York Wading River, NY 11792 Attn: Peter Bienstock, Esq. l Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center l 195 East Main Street Room 46-14 i Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr. William R. Cumming, Esq.
General Counsel Office of General Counsel l Long Island Lighting Company Federal Emergency Management j 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW ,
Washington, DC 20472 '
Dr. Robert floffman Long Island Coalition for Safe Docketing and Service Section* i Living Office of the Secretary .
P.O. Box 1355 U.S. Nuclear Regulatory Commission i Massapequa, NY 11758 Washington, DC 20555 Mary M. Gundrum, Esq. Barbara Newmar. l New York State Department of Law Director, Environmental Health !
120 Broadvray Coalition for Safe Living 3rd Floor, Room 3-116 -
Box 944 :
New York, NY 10271 Huntington, New York 11743 ;
<s (V i
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/beorge E. /]ohns I Counsel foV NR taff l
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