ML20236R758
| ML20236R758 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/16/1987 |
| From: | Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTH HAMPTON, NH, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4880 OL-6, NUDOCS 8711240013 | |
| Download: ML20236R758 (18) | |
Text
4 9'ffd 00LXETEE-U5hRC November 16, 1987 17 MN 19 P3 :45 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFlCL GF ght g y DOCKETmG r SvevtC(.
Before the Atomic Safety and Licensina Board BRANCH
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-6
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(25% Power) i (Shoreham Nuclear Power Station,
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I Unit 1)
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1 REPLY OF SUFFOLK COUNTY, THE STATE OF NEW YORK, AND THE I
TOWN OF SOUTHAMPTON TO LILCO'S BRIEF ON 25% POWER OUESTIONS l
As provided by the Board's Order of October 27, 1987, Suffolk County, the State of New York, and the Town of Southampton (the
" Governments") hereby reply to "LILCO's Brief on 25% Power Questions," dated November 6, 1987 (hereafter, "LILCO's Brief").
The Governments reply primarily to the points made in LILCO's Brief because in general, the NRC Staff's position on the ques-tions presented by the Board's October G, 1987 Memorandum to the Parties (the " Memorandum") is consistent with that of the Govern-ments.
Egg NRC Staff Response to Board Memorandum Requesting Parties' Views on Questions Raised by LILCO 25% Power Authori-zation Motion (November 6, 1987) (hereafter, " Staff Response").
8711240013 871116 ADOCK05000gg2 PDR G
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We note at the outset that LILCO's Brief, in large part, fails to address the matters raised by the Board in its Memorandum.
That Memorandum was explicit in presenting and explaining several specific questions; the NRC Staff and the Governments addressed, and provided responses to, each of those j
questions.
LILCO, on the other hand, discussed issues of its own design and, in large measure, never responded meaningfully to the matters raised by the Board.
Instead, LILCO reiterates positions and arguments it has espoused in previous filings even though it was precisely those positions and arguments which gave rise to the Board's questions in the first place.
Since LILCO, the proponent of the 25% Power Motion, failed to address the threshold issues identified by the Board as requiring resolution before the motion can be considered (agg Memorandum at 1), the LILCO Motion should be summarily denied for that reason, as well as those set forth in the Governments' November 6, 1987 Views.1/
Furthermore, because many of the arguments in LILCO's Brief j
are repetitious, irrelevant, or not responsive to the questions raised by the Board, the Governments do not " respond" to them all; instead, mindful of the Board's admonition that these filings should not reargue matters already decided or otherwise pending (Memorandum at 1), the Governments continue to stand by the responses and explanations set forth in their November 6 Views.
1/
Egg Views of Suffolk County, the State of New York, and the Town of Southampton in Response to Licensing Board's October 6, 1987 Memorandum Concerning LILCO's Request to Operate at 25% Power (November 6, 1987) (hereafter, " Governments' Views"). t
I.
LILCO IGNORES AND MISCHARACTERIZES THE PROVISIONS OF SECTION 50.57(c)
In purporting to address the " Adequacy of LILCO's Motion under S 50.57(c)" (LILCO's Brief at 2-7), LILCO mischaracterizes that regulation and ignores its most essential provisions.
For example, there is no basis for LILCO's assertion that Section 50.57 is nothing but " essentially a procedural provision."
LILCO's Brief at 4.
Clearly, it is the Commission's operative substantive provision governing the issuance of operating li-censes, and the one under which LILCO was expressly directed by the Commission to file its 25% power license request.
Egg CLI-87-04.
LILCO's argument in essence asks this Board to assume that the Commission had no purpose in directing LILCO to file any subsequent motion for authorization to operate at 25% power under Section 50.57(c).
Obviously, this Board cannot assume that the
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Commission intended its language to have no meaning.
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l Similarly, LILCO's assertion that with respect to its appli-cation, SS 50.57(c) and 50.47(c)(1) are " functionally synonymous" and "present identical standards for satisfying them," (LILCO's I
Brief at 3) is plainly incorrect.
As the Commission, this Board, the NRC Staff and the Governments have pointed out, the two sections clearly have separate and different " functions," separate and different purposes, and separate and different criteria to be l
applied to determine their applicability.
We will not repeat here the discussion on this subject contained in the Governments'
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Views, but refer the Board to that filing.
Suffice it to say that for the reasons stated therein, as well as those stated by the j
Board in its Memorandum and by the Staff in its Response, LILCO's i
assertion that its 25% Power Motion "is complete," premised on
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LILCO's self-serving mischaracterizations of the regulations, must be rejected.
Furthermore, LILCO's argument that "by demonstrating com-pliance with S 50.47(c)(1), LILCO has also demonstrated its com-plete compliance with S 50.57(c)," (LILCO Brief at 6) is without basis.
In the first place, the implication that in its 25% Power Motion LILCO " demonstrated" compliance with S 50.47(c)(1) is patently false and contrary to holdings of this Board and the Commission.
Moreover, LILCO's reasoning which allows it to
" equate" the showings necessary to demonstrate compliance with the two regulations, ignores the plain provisions of the regulations themselves.
First, in " equating" the two regulations and the necessary demonstrations thereunder, LILCO ignores the fact that only one of them -- Section 50.57(c) -- exists as a vehicle for the issuance of licenses to operate at levels short of full power.
As the Board itself observed, Section 50.47(c) "on its face has nothing to do with applying for a license and authorizing operations at less than full power."
Memorandum at 4.2/
If LILCO wishes to 2/
Moreover, Section 50.47(c)(1) deals with full power opera-(footnote continued) _ _ _ _ _ _ _ _ _ _.
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apply for authorization to operate at greater than 5% but less
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than 100% power, clearly it must address its application to, and must comply with, the requirements of the only regulation on point
-- S 50.57(c).
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Second, it cannot be disputed that before a license can be issued under Section 50.57(c), there must first be.an initial decision on the matters identified in subsection ~(a), including whether "the facility will operate in conformity with the.
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provisions of the Act, and the rules and regulations of the Commission," whether "there is reasonable assurance (i) that the activities authorized by the operating license can be conducted without endangering the health and safety of the public, and q
(ii) that such activities will be conducted in compliance with'the regulations," and whether "the issuance of the license will not be l
l inimical to the health and safety of the public."
S 50.57(a)(2), (3), (6).
In arguing that only the second of these is required for Shoreham, LILCO simply reads out of existence --
with no basis whatsoever -- subsections (a)(2) and (a)(6) of I
I Section 50.57, and ignores the requirement in Section 50.57(c) for 1
(footnote continued from previous page) tions; the only provision in S 50.47 relating to operation short of full power is S 50.47(d), which is limited to operations up to 5% power. >
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findings, on the matters specified in paragraph (a) "with respect to the contested activity sought to be authorized" -- here, operation at 25% power.2/
Third, LILCO fails to acknowledge, much less to address, the significance of the Section 50.57(c) provision concerning the l
rights of the parties to be heard on relevant contentions, and the l
obligation of the Board to issue an initial decision resolving them, before any action can be taken on a motion for authorization to operate short of full power.A/
This failure, alone, requires 1/
LILCO's assertion that in its 5% power license the Staff did not expressly condition findings under SS 50.57(a)(2) and (a)(6)
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to operation at 5% power, even if literally true, does not eliminate the requirement for findings on all " matters specified in paragraph (a) as to which there is a controversy.
I with resDect to the contested activity soucht to be authorized."
10 CFR S 50.57(c) (emphasis added).
Clearly, regulatory requirements, including those for offsite emergency preparedness, j
are different for operation at 5% power and for operation at J
higher power levels; accordingly, Section 50.57(c) requires findings under SS 50.57(a)(2) and (6) with respect to operation at 25% power regardless of the wording of the license authorizing operation limited to 5% power.
A/
LILCO's only mention of this provision, on the next-to-last l
page of LILCO's Brief, consists of the following conclusory statement in response to the Board's question about the need to appoint a new licensing board:
(W)hile LILCO agrees that S 50.57(c) gives all parties the right to be heard to the extent that they have contentions, that right is not l
without limit.
Instead, a party's right to a j
hearing is limited "to the extent that his j
contentions are relevant to the activity to be j
authorized."
10 CFR S 50.57(c).
The issues relevant to LILCO's 25% motion are different l
than those remaining in the emergency plannir.g I
portion of LILCO's application for a full power license.
I (footnote continued) i R
summary rejection of LILCO's Motion, particularly since the matter was clearly focused, and the parties were directed to address it, in the Board's Memorandum.5/
The Staff also highlights this LILCO failure, after having addressed the issue and concluded, as did the Governments, that LILCO's 25% Power Motion is fatally defec-tive.
Egg Staff Response at 8, 18-20.5/
(footnote continued from previous page)
LILCO's Brief at 15.
This assertion follows LILCO's quotation of its Appointment Motion, containing the same conclusory assertions which gave rise in the first place to the Board's questions about the need to resolve outstanding contentions orior to addressing the 25% Power Motion.
Egg Memorandum at 5-7.
Furthermore, the 4
I error of this LILCO position, and why the issues of LILCO's non-compliance with the emergency planning regulations are the same l
for purposes of 25% power operation and full power operation, are I
discussed in the Governments' Views at 8-10.
l 5/
Egg Memorandum at 4-5 ("the Applicant in attempting to make a case ignored and did not address major requirements of 10 i
CFR 50.57(c)
Applicant did not modify the motion to address the requirements of 50.57(c) even after the Commission
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I advised that the motion could be refiled under that section if it continued to want the license."); 5
(" Applicant presented no meaningful discussion of the extent to which the existing con-tentions are relevant to the activity to be authorized"); 7
(" matters to be briefed" include "if the parties are to address unresolved contentions before a license for operation at less that full power may be granted under 50.57(c) can the contentions be resolved short of hearing them in the full power emergency planning proceeding?"); 9 ("brief the Board taking into con-sideration.
the requirement of 50.57(c) that due regard must be given to the rights of the parties to be heard to the extent that their contentions are relevant to the activity to be author-ized").
5/
The Governments disagree with the Staff's suggestion that l
LILCO should be given yet another opportunity to correct the deficiencies in its 25% Power Motion.
Egg Staff Response at 9
(" Applicant should be given an opportunity to address the criteria and other matters appropriate for consideration by the Board under Section 50.57(c)").
While it may not be possible to prohibit LILCO from filing a different motion at some future date, given the many opportunities it has already had to correct the j
defects in its original 25% power motion, the motion should now be definitively rejected so the Board and parties can stop expending valuable resources addressing it.
l 1 i r
l II.
LILCO IGNORES THE FACT THAT ITS MOTION CONSTITUTES AN IMPERMISSIBLE CHALLENGE TO THE REGULATIONS LILCO's Brief ignores the clear challenge to the NRC's regulations which its 25% Power Motion presents, despite repeated references to that issue in previous filings by the Governments and the NRC Staff, and in the Board's Memorandum itself.
LILCO's Motion constitutes an impermissible challenge to the regulations because in it LILCO seeks authorization to operate Shoreham at greater than 5% power absent full compliance with the emergency planning regulatory requirements, without having first sought and obtained an exemption from such compliance.
- Egg, e.o.,
j Governments' Views at 8-10, 11, 13, 15-16.
We discuss below several arguments made in LILCO's Brief which must be rejected.
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We emphasize, however, that none of LILCO's arguments address the dispositive fact that LILCO's Motion is an attack on the l
Commission's regulations.
That fact remains unchallenged, and requires the summary rejection of LILCO's 2',% Power Motion.
l LILCO argues, under the misleading heading "The Adequacy of LILCO's Motion under Section 50.47(c)(1)," that there is no need to resolve the outstanding emergency planning issues in this l
proceeding in order to grant its 25% Power Motion.
See LILCO's Brief at 9.
LILCO also flatly asserts that "the underlying premise of a number of the Board's questions -- that the pendency of emergency planning issues prevents the Board from. authorizing any operation above 5% power -- is not correct."
Id.
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These LILCO statements are wholly lacking in basis or author-ity.
As LILCO well knows, the regulations require compliance with the emergency preparedness requirements -- which are the basis of the outstanding existing emergency planning contentions -- for operation at any power level above 5%.
The Board was correct in premising its questions on that fact, as acknowledged by the Governments in their Views, and by the Staff in its Response.
Egg Staff Response at 10, 13, 14, 17.
And, the Commission's new rule does nothing to change that fact.
- Egg, e.o.,
Staff Response at 11, n.4.7/
Clearly, in light of the Section 50.57(c) requirement 7/
Although LILCO discusses the Commission's new rule in its Brief (agg pages 10-11), according to the Board's direction the impact of that rule in this case is properly addressed in the context of the CLI-86-13 remand.
Egg the Brief of Suffolk County, the State of New York and the Town of Southampton on the Effect of the Commission's October 29, 1987 Rule on the CLI-86-13 Remand Proceeding, to be filed November 17, 1987, and the Board's Order dated November 9, 1987.
The Governments note, however, their strong disagreement with LILCO's stated " beliefs" about this l
Board's September 17, 1987 ruling on LILCO's summary disposition motion, and the impact of the Commission's rule upon that ruling.
Sag LILCO's Brief at 10-11.
First, it is clear on the face of the new rule, and from the Commission's explanation, that it is up to individual Licensing Boards to judge, on a case-by-case basis, "what form" the ad hgg best efforts government response to an emergency would take, based upon the particular facts and evidence presented in each case.
This is completely consistent with the Board's September 17 ruling.
Furthermore, contrary to LILCO's suggestion, the " presumption" mentioned in the new rule about the nature of an ad hoc government response is optional, not manda-tory; it is one that a Board "may" or "may not" adopt.
Egg 52 Fed. Reg. 42085.
In this case, based upon uncontroverted sworn affidavits of the actual responsible authorities -- that is, the Governor of the State of New York, the Executive of Suffolk County, and the Presiding Officer of the Suffolk County Legislature -- this Board has already found that it can not presume that the Governments of New York and Suffolk County would implement the LILCO Plan, or act in partnership with LILCO, in the event of a Shoreham emergency.
The new rule simply has no impact on that case-and fact-specific ruling by this Board.
- Moreover, given the facts and the uncontroverted evidence in this case no (footnote continued) a
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that outstanding contentions must be resolved before any action can be taken on a motion, like LILCO's, for authorization to I
operate short of full power, and given that each of the existing outstanding contentions is relevant at any power level above 5%,
the outstanding emergency planning contentions must be resolved as a prerequisite to this Board's taking any action on LILCO's Motion.$/
LILCO's argument that its proposal to limit operations to 25%
power was contemplated as an " interim compensating action" when the Commission adopted Section 50.47(c)(1), is also baseless and, in essence, a challenge to the Commission and its regulations.
l See Staff Response at 11-13; Governments' Views at 11-14.
- Thus, in its attempt to distinguish the Indian Point case cited by the Board in its Memorandum, LILCO ignores the Commission's own pronouncements upon adopting S 50.47(c)(1) (in determining the significance of " adequate interim compensating actions," the Commission will determine "whether features of one plan can (footnote continued from previous page) other ruling on whether the Governments would implement the LILCO Plan could possibly be made.
$/
The Staff and the Governments discuss this matter further in the context of the Board's question about LILCO's request for appointment of a new Licensing Board.
The Governments'and the Staff agree that the LILCO request should be_ denied because the emergency planning issues to be addressed for 25% power operation are the same as for full power operation, among other reasons.
Egg Governments' Views at 16-18; Staff Response at 19-20. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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compensate for deficiencies in another plan"), even though those Commission statements are cited in the Indian Point decision itself.
Sgg 45 Fed. Reg. 55,403.1/
In fact, there is no indication, in the regulations or elsewhere, that the Commission ever intended that " interim compensating actions" to make up for deficiencies in an offsite preparedness plan, could include operation at different power levels.
The regulation, and the NRC's guidance concerning it, clearly contemplate that compensating actions must be part of a resoonse plan, not methods or power levels of reactor operation.
Since LILCO can cite no authority for its position, and it failed to address, much less distinguish the Commission's guidance, the Board should reject LILCO's Motion as a challenge to the regula-tions.
Similarly, LILCO's attempt to justify its reliance on a PRA to support its 25% Power Motion amounts to yet another attack on the Commission's regulations and the generic judgments upon which they are based.
In the portion of its Brief purportedly addressing the Board's PRA question, LILCO once again fails even to address the Commission's generic findings which were cited by the Board in its Memorandum.
Egg Memorandum at 8-9; LILCO Brief at 12-14.
Furthermore, LILCO fails to address, much less l
E/
Egg also 47 Fed. Reg. 30234 (types of deficiencies to which Section 50.47(c)(1) is addressed are those "that only reflect the actual state of preparedness").
1 - _ _ _ - _ _ _ _ _ -..
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distinguish, the prior rulings in this case which precluded the use of PRA analyses to support safety-related conclusions, although those rulings were noted by the Staff in its " Response to LILCO Motion for Designation of Licensing Board and Setting Expedited Schedule to Rule on LILCO's 25% Power Request" (July 29, 1987), at 8.
Sgg also the Governments' Views at 14-16, and cases cited therein.
Indeed, LILCO's arguments, purportedly to " justify" its attempt to use its PRA, themselves highlight the challenge to the l
Commission's generic findings and to its regulations which LILCO's proposal embodies.
Thus, in asserting that the Board was
" inaccurate" in characterizing LILCO's reliance on its PRA as an effort to overcome or bypass the emergency planning regulations, LILCO essentially acknowledges that fact:
LILCO offers its PRA to demonstrate that at 254 power a much smaller zone is at risk and reduced emeraency response actions will suffice LILCO's Brief at 13 (emphasis added).
There can be no doubt that in requesting a one-mile EPZ, suggesting that it need not comply with the full complement (rather than a " reduced" version) of the emergency planning requirements, and asserting that the risk of LILCO's plant operation, as shown by LILCO's PRA data, is less than that shown by the "[p]robabilistic risk assessment data L
(which] played an important role in establishing the'10-mile EPZ,"
- 14. at 13-14., LILCO is clearly challenging'the regulations and the generic findings upon which they are premised.
In short, the responses of the Governments and the Staff to-the Board's question about LILCO's attempted use of its PRA are correct, essentially unchallenged by LILCO, and they should be adopted by the Board.
In the absence of an exemption fromlthe-l regulations, LILCO cannot be permitted to argue that Shoreham 4
should have a one-mile EPZ, that LILCO's assessment of acceptable
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risk is more valid than the Commission's, or that LILCO should be 1
able to operate its reactor at greater than'5% power without having complied with the emergency planning regulatory requirements, i
III. CONCLUSION Since March, 1987, LILCO has refused to acknowledge what every other party, including, apparently, the Commission and this-Board has recognized:
what LILCO seeks in its 25% Power Motion is unprecedented, not contemplated by the regulations in the absence of the grant of an exemption, and procedurally out of line.
It is-beyond dispute that:
seeking an operating license without ad-dressing, or satisfying, the criteria set forth in the regulatory provision designed for that purpose; seeking authorization to operate above 5% power without first complying with Section.50.47-I C
I and Part 50 Appendix E; proposing an " interim compensating action" l
under Section 50.47(c)(1) which has nothing to do with compensating for preparedness or plan deficiencies; seeking to q
substitute a utility's own risk assessment data and analyses for the generic ones adopted by the Commission; seeking a one-mile EPZ; and, asking for two duplicative proceedings -- all of which 3
1 are among the demands embodied in LILCO's 25% Power Motion -- are I
all contrary to the NRC's regulations and its Rules of Practice.
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Any further consideration of such a procedurally improper motion l
would violate the Governments' due process rights, as well as any common sense principles of efficient or productive use of
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I resources.
This Board must finally put an end to LILCO's blatant j
l disregard for the substantive and procedural requirements which l
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govern the actions of tnis agency.
LILCO's 25% Power Motion must I
be summarily denied.
Respectfully submitted, i
Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 O
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Hefberjt H. Brown / V
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Lawrence Coe La@her Karla J.
Letsche KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County 1 a
f
r Fabian G.
Palottino
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Richard J.
Zahnleuter 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 1
Stepp)ien B.
LathanV TwMey, Latham & Shea P.O.. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton.
a
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d 00CKETED USNRC 1
Novembehlb1 8
l OFFICE OF EEChilAn f j
UNITED STATES OF AMERICA 00CKEit% A SERVICf.
NUCLEAR REGULATORY COMMISSION O
2 Before the Atomic Safety and Licensina Board I
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4 In the Matter of
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i l
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-6
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(25% Power)
(Shoreham Nuclear Power Station,
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Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of REPLY OF SUFFOLK COUNTY, THE STATE OF NEW YORK, AND THE TOWN OF SOUTHAMPTON TO LILCO'S BRIEF ON 25% POWER QUESTIONS have been served on the following this i
17th day of November, 1987 by U.S. mail, first class, except as otherwise noted.
James P. Gleason, Chairman Mr. Frederick J. Shon Atomic. Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry R. Kline William R. Cumming, Esq.
Atomic Safety and Licensing Board Spence W. Perry, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel-Washington, D.C.
20555 Federal Emergency Management Agenc-2 500 C Street, S.W., Room 840 Washington, D.C.
20472 l
'.s Fabian G. Palomino, Esq.
W. Taylor Reveley, III,.Esq.
Richard J.
Zahleuter, Esq.
Hunton & Williams Special Counsel to the Governor P.O.
Box 1535 Executive Chamber, Rm. 229 707 East Main Street State Capitol Richmond, Virginia 23212 Albany, New York 12224 Joel Blau, Esq.
Anthony F.
Earley, Jr.,
Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 Martin Bradley Ashare, Esq.
Ms. Elisabeth Taibbi, clerk Suffolk-County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788-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 Survice Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
j 195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 Mary M. Gundrum, Esq.
Hon. Michael A.
LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison 3uilding Room 3-116 Veterans Memoria.1 Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Comm3ttee Suite K P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq.
New York State Energy Office Richard'G. Bachmann,'Esq.
Agency Building 2 U.S. Nuclear Regulatory Comm.
Empire State Plaza Office of General Counsel Albany, New York 12223 Washington, D.C.
20555 I
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David A.
Brownlee,'Esq.
Mr. Stuart Diamond
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Kirkpatrick & Lockhart Business / Financial 1
1500 Oliver Building.
NEW YORK TIMES Pittsburgh, Pennsylvania 15222-229.W. 43rd Street New York, New York 10036 i
j Douglas J. Hynes, Councilman Mr. Philip McIntire.
Town Board of Oyster Bay Federal' Emergency Management Agency" i
Town Hall 26 Federal; Plaza
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Oyster Bay, New York 11771 New York, New York -10278
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i KarlaqJ. Letsche f KIRKPATRICK & LOCKHART 1800 M Street',
N.W.
South Lobby - 9th Floor:
Washington, D.C.
20036-5891 1
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