ML20236R776
| ML20236R776 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/16/1987 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4879 OL-6, NUDOCS 8711240023 | |
| Download: ML20236R776 (16) | |
Text
LILCO, November 16,1987 r-b{
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USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
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Before the Atomic Safety and Licensing Board Q
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)
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(Shoreham Nuclear Power Station,
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Unit 1)
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LILCO'S REPLY BRIEF ON 25% POWER QUESTIONS l
On November 6,1987, the parties filed responses to the Board's October 6 Memo-
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randum to the Parties (hereinaf ter, " Memorandum") requesting the parties' views on various questions concerning LILCO's July 14, 1987 Motion for Authorization to In-l crease Power to 25% at Shoreham (hereinaf ter, " Motion"). This pleading responds to the views offered by the NRC Staff and by Interveners.I To avoid unnecessary dupli-cation, where it is appropriate this reply references LILCO's initial brief in response to the Board's Memorandum.E General Discussion All parties have generally grouped the Board's questions into three categories:
(1) whether LILCO's Motion includes all elements necessary for issuing a 25% power
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NRC Staff Response to Board Memorandum Requesting Parties' Views on Ques-tions Raised by LILCO 25% Power Authorization Motion, November 6,1987 (hereinaf-ter, " Staff Brief"); Views of Suffolk County, the State of New York, and the Town of Southampton in Response to Licensing Board's October 6,1987 Memorandum Concern-ing LILCO's Request to Operate at 25% Power, November 6,1987 (hereinaf ter, " Inter-venors' Brief").
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LILCO's Brief on 25% Power Questions, November 6,1987 (hereinaf ter, "LILCO Brief").
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4 o license under 10 CFR S 50.57(c); (2) whether LILCO's initial motion of April 14, 1987, filed under S 50.47(c)(1),M contains the evidence necessary for resolving questions under S 50.47(c)(1) in favor of LILCO; and (3) whether issues raised by LILCO's Motion are sufficiently discrete to warrant expedited consideration, including assignment of the Motion to a separate Licensing Board.
In summary, neither Interveners' nor the Staff's response materially advances the Board's analysis of LILCO's Motion. Interveners' Brief is rendered largely useless because of its single-minded, incorrect insistence that S 50.47(c)(1) is not available to LILCO absent some form of independent exemption. The Staff Brief acknowledges the applicability of 5 50.47(c)(1) to LILCO's Motion but fails to consider whether the Motion meets the requisite standards. Ultimately, neither response challenges the sufficiency of LILCO's present Motion to operate at 25% or its request for expedited cor61deration before a separate Licensing Board.
LILCO continues to believe that its motion to increase power to 25% of rated power is valid procedurally and that it has stated a valid prima facie case for it, thus putting the burden on the other parties to respond substantively. LILCO also believes that the substantive questions raised by its 25% power motion particularly those relating to the determination of a zone of risk at 25% power - are sufficiently distinct from those raised by the 100% emergency planning proceeding as to warrant the ap-pointment of a separate licensing board for their determination. LILCO also recog-nizes, however, that unless summary determinations in its favor are made on these is-l sues, a proceeding of considerable proportions and duration could ensue. Thus, in the 3/
LILCO's initial Request for Authorization to Increase Power to 25% and Motion for Expedited Commission Consideration, April 14,1987 (hereinaf ter, " Request"), was explicitly incorporated by reference into LILCO's July 14, 1987 Motion. The July 14 Motion also includes an updated affidavit by Adam M. Madsen treating the power supply situation on Long Island through 1992.
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4 1 event that this Board does not agree that a separate licensing board should be ap-i pointed, LILCO requests that this Board order the parties to take only those steps which will not divert its own resources from the most expeditious possible completion I
of the 100% power emergency planning issues remaining before it.
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I.
Adequacy of LILCO's Motion Under S 50.57(c) l Interveners and the Staff raise several arguments challenging LILCO's compli-ance with the requirements of S 50.57(c). First, Interveners and the Staff assert that i
LILCO's Motion fails to show that the requisite findings can be made under S 50.57(a) as I
required by S 50.57(c).O Second, Interveners and the Staff criticize LILCO's Motion for 1
allegedly failing to address adequately contentions which may be relevant to that Mo-tion. Finally, Interveners and Staff challenge LILCO's proposed use of material sub-mitted to satisfy S 50.47(c)(1). to assist in making relevant findings required by S 50.57(c). As discussed below, these criticisms should be disregarded because they mis-construe LILCO's Motion and therefore mischaracterize its procedural posture.
I a)
Findings Required Under S 50.57(a) Pursuant to S 50.57(c) l To authorize a less than full power license under 10 CFR S 50.57(c), the presiding i
officer must make those findings specified in S 50.57(a) about which there is a contro-versy. Se S 50.57(c); LILCO Brief at 4-5.
Interveners and the Staff complain that 4/
Interveners explicitly contend that LILCO's Motion fails to address the require-ments of S 50.57(a). Interveners' Brief at 3. The Staff Brief does not specifically refer to the findings required by S 50.57(a) but asserts that LILCO's Motion "does not address the reasons why, under (S 50.57(c)], the relief sought should be granted." Staff Brief at 5. The Staff further contends that since LILCO carries the burden of proof,its mo-tion should state with particularity the action sought to be approved. I_d.
This argu-ment is clearly misapplied: there can be no genuine question that LILCO's July 14 Mo-tion, with its earlier motion incorporated by reference, see supra note 3, couplies with all of the Commission's pleading requirements.
4.-
LILCO fails to show that the requisite findings can be made under S 50.57(a) and there-1 fore fails to comply with the requirements of S 50.57(c). Interveners' Brief at 3,7 (al-leging that findings must be made under S 50.57(a)(2), (3), and (6)); Staff Brief at 5-6 (not specifying which findings the Staff believes are required under S 50.57(a)).EI These complaints are not well taken, for the reasons shown below.
I 1
Both the Staff and Interveners fall to recognize that, with the limited exception of certain matters arising under 10 CFR S 50.57(a)(3), all S 50.57 findings have already been made dispositively and without limitation as to the power level for Shoreham. On July 3,1985 the Commission issued a facility operating license to LILCO for operation of the Shoreham faellity.
NRC License No. NPF-36. While that license is currently limited to 5% of rated power, as a prerequisite to its issuance the Commission made all I
of the findings required by the six subdivisions of S 50.57(a). With the sole exception of the " reasonable assurance" finding required by S 50.57(a)(3) (which is limited by the 11-i cense to 5% power operation),EI none of the findings in LILCO's low power operating i
license is conditioned upon or quallfled by the limits imposed on the license. See LILCO Brief at 5 n.3. Thus each of them, except for the S 50.57(c)(3) finding, is valid for any l
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It is possible to infer from the Staff's Brief, however, that the Staff believes the only finding required by LILCO's Motion is the finding pursuant to S 50.57(a)(3). ' Staff Brief at 10.
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10 CFR S 50.57 reads in pertinent part:
(a)
Pursuant to S 50.56, an operating license may be is-sued by the Commission, up to the full term authorized by S 50.51, upon finding that:
(3)
There is reasonable assurance (1) that the activities authorized by the operating license can be conducted with-out endangering the health and safety of the public, and (11) that such activities will be conducted in compliance with the regulations in this chapter....
4.
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I power level - 5%, 25%, or 100% In criticizing LILCO's Motion for insufficient detail, the Staff improperly fails to acknowledge these findings, which are of continuing valid-ity.
At this stage in the Shoreham proceeding, the only issues remaining unresolved i
are those related to offsite emergency planning. Accordingly, the only finding of S 50.57(a) remaining at issue is S 50.57(a)(3). It is unnecessary to recite ritualistically findings which have been made by the Commission and which would be valid in a i
S 50.57(c) proceeding on LILCO's Motion. Instead, LILCO's Motion focuses on de-monstrating that by reference to S 50.47(c)(1), unresolved emergency planning issues do j
not prevent a finding of reasonable assurance of public health and safety as required by S 50.57(a)(3). Thus, LILCO's " failure" to recite already established findings does not render its Motion insufficient under S 50.57(c).
b)
LILCO's Treatment of Potentially Relevant Contentions In its Brief, the Staff contends that LILCO falls to address adequately potentially relevant contentions. Staff Brief at 7-9.
The Staff's proceeds from two premises:
first, that in a contested application the parties have a right to litigate those aspects of their contentions that are found to be relevant under S 50.57(c); and second, that l
LILCO errs in its characterization of the emergency plan as having been fully litigated, l
and (with the exception of legal authority-related issues) subject only to minor re-J maining open items. The Staff is correct in its first proposition, though that proposi-tion has no implications, without understanding of the 100% power record, for any pro-ceedings on a 25% application. The Staff is incorrect on its second proposition; and I
l that error does have implications for a proceeding on a 25% power motion.
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The Licensing Board order ultimately disposing of issues relating to the Shoreham emergency plan at the trial level is the Concluding Partial Initial Decision, LBP-85-31, 22 NRC 410 (1985). There, the Licensing Board rejected each of LILCO's theories as to implementation of its emergency plan for Shoreham without advance as-surances of cooperation from New York State and Suffolk County, and labeled these problems (lack of independent legal authority and lack of assured cooperation) as " fatal flaws" in the plan. Ld. at 431. By contrast, however, on factual issues the Board found no impediment to development of a fully adequate emergency plan for Shoreham. In-deed, on each of the miscellaneous f act-related areas where it found any problem with the plan, it concluded that the problem was "of a lesser magnitude" and "can be remedied." Id. at 429.
The rules for treatment of legal authority issues in offsite emergency planning have subsequently been modified substantially by the Commission in the " realism doc-trine." CLI-86-13; 52 Fed. Reg. 42,078 (November 3,1987). Thus, with the Licensing Board having already found that each of the f actual issues at Shoreham was remediable at 100% power using conventional analyses, LILCO's extended demonstration that such issues were inconsequential at 25% using analyses developed for Shoreham, Request at 21-40, Appendix 1, is not unresponsive at all.
LILCO believes that the proper framework for consideration of these issues is whether Interveners, who oppose granting LILCO's motion, have raised, in their two opportunities to respond to it, sufficient safety concerns that the motion needs to be treated by the usual hearing process rather than being considered eligible to be granted summarily in LILCO's favor. LILCO believes that the treatment in the motion of out-standing emergency planning contentions as applied at 25% power was sufficient to focus its views on the applicability of those contentions to 25% power operation. To the extent that Interveners may wish to raise additional issues that they contend are
valid at 25% but not 100% power, the time for them to do so is fast passing; and cer-tainly LILCO cannot be expected to respond to any such issues until they are raised by contention.
4 In the same vein, Interveners criticize LILCO's Motion for failing to address "the extent to which the outstanding existing contentions are relevant to the activity for which it seeks authorization." Interveners' Brief at 3. As noted above, Interveners al-lege in broadside fashion that all outstanding contentions are relevant to LILCO's Mo-tion.II In fact, LILCO anticipated Interveners' allegation regarding the outstanding l
emergency planning contentions and demonstrated the irrelevance or immateriality of these contentions in a long section in LILCO's original Motion. Request at 81-102.
Thus, there is no basis for Interveners' claim that LILCO's Motion fails to address the extent to which outstanding contentions are relevant.
c)
Relationship Betw n SS 50.57(c) and 50.47(c)(1)
Finally, Interveners challenge LILCO's reliance on S 50.47(c)(1) to meet the re-quirements of 5 50.57(a). Specifically, LILCO seeks to show that by meeting one or more of the standards of S 50.47(c)(1), the Commission can make the necessary finding of reasonable assurance pursuant to S 50.57(a)(3). See LILCO Brief at 7-8.
Interveners argue that S 50.47(c)(1) is not available to any applicant seeking to operate at less than full power. According to their Brief, the NRC regulations include no provision for the issuance of operating licenses above 5% power absent full compli-ance with 5 50.47 and Appendix E. Interveners' Brief at 8. Thus, according to Interve-nors, the only way for LILCO to operate at 25% is to first obtain an exemption from I/
Whether or not Interveners would still seek to raise, in the 25% power context, contentions not currently pending before the Board, it is clear that they have not sought to do so despite at least two distinct opportunities.
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t emergency planning requirements.EI Id.
l The errancy of Interveners' view is revealed by considering its practical effect.
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if 5 50.47(c)(1) applies only to applicants operating at full power, then no applicant l
with unresolved emergency planning issues could ever seek a less than full power 11-cense under S 50.57(c) because no such applicant could make the showing required by S 50.57(a)(3) without reference to S 50.47(c)(1). However, the Commission itself di-rected LILCO to file its 25% Motion under S 50.57(c). Thus, the Commission does not agree with Interveners' interpretation of 5 50.47(c)(1) and therefore S 50.47(c)(1) is not limited solely to applicants operating at full power.
l The Staff agrees with LILCO that the finding required by S 50.47(a)(3) can be l
l met by reference to S 50.47(c)(1). The Staff states that:
[ A]t least under certain circumstances, findings on the criteria of Section 50.47(c)(1) may be made in connection with an application under Section 50.57(c), and reed not await l
pri6r authorization of operation under the later provision.
Staff Brief at 10 (emphasis added). According to the Staff, Shoreham "is the very situa-tion" in which these circumstances arise. I_d. Thus, it is fully appropriate for LILCO to i
comply with 5 50.57(c) by reference to the standards of S 50.47(c)(1).
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3/
Interveners have already fully aired, and lost, their argument that LILCO must obtain a separate exemption from emergency planning requirements to operate at 25%
power. Suffolk County, State of New York, and Town of Southampton Response in Op-position to LILCO's Motion for Expedited Commission Consideration, April 27,1987, at 13-17. LILCO has responded to Interveners' argument, LILCO's Reply to 'ntervenors' Opposition to Expedited Consideration of LILCO's 25% Power Request, May 12,1987,at 3-9, and the Commission has found in LILCO's favor, ordering LILCO to file its motion l
under S 50.57(c), CLI-87-04, June 11,1987. Thus, Interveners' argument is not relevant to the questions posed by the Board and therefore should be disregarded, i
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_g.
IL The Adequacy of LILCO's Motion Under S50.47(c)(1)
Section 50.47(c)(1) provides an applicant with the opportunity to comply with the requirements of S 50.47(a) by showing either that deficiencies in offsite emergency plans are not significant, that adequate interim compensating actions have been or will be taken, or that there are other compelling reasons to permit plant operation. Inter-venors and the Staff challenge LILCO's evidence both that offsite emergency planning deficiencies are not significant and that adequate interim compensating actions have been or will be taken.
a)
Offsite Emergency Planning Deficiencies Are Not Significant for the Plant in Question In its Motion, LILCO offers detailed probabilistic risk assessment (PRA) evidence to show that remaining offsite emergency planning deficiencies are not sufficiently sig-
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nificant to prevent a finding that existing emergency planning provides reasonable as-surance of the public health and safety from operation at up to 25%. Request at 21-40, l
4 Appendix 1.
at 3-4.
Interveners and the Staff object specifically to the use of PRA.
l Interveners argue that the offer of such proof is "a blatant attack on the NRC's generic findings upon which the emergency planning regulations are based," Interveners' Brief at 15, and is, in essence, a veiled attempt to have the Shoreham EPZ reduced to one mile. Id. The Staff admits that the Board may consider PRA evidence in connection with a request pursuant to S 50.47(c)(1) but concludes, without further explanation, that LILCO has not introduced the " substantial evidence" that would be required to show that emergency planning deficiencies are not significant for the level of operation for which a license is sought. Staff Brief at 17-18.
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e.
Interveners' objections to LILCO's proposed use of PRA on the grounds that it would reduce the Shoreham EPZ to one mile are without merit. It is simply wrong to suggest that LILCO has proposed a reduction in the size of the Shoreham EPZ. LILCO's proposal explicitly presumes retention of the 10-mile-radius EPZ and of the plan and the organization to meet that planning basis. Request at 84. What it shows is that at 25% power operation the risk in fact is sufficiently lowered that any deficiencies re-maining at 100% operation are either insignificant for Shoreham or have been ade-quately compensated for. Indeed, the essential purpose of S 50.47(c)(1) is to allow a showing that reasonable assurance is met for the 10-mile EPZ despite certain planning deficiencies or with the help of interim compensating actions. Thus, Interveners' claim that LILCO's motion represents a " blatant attack" on the Commission's generic emer-gency planning regulations is baseless.
The Staff's objections to LILCO's proposed use of PRA is the result of an errone-ous conclusion drawn from accurate premises. The Staff begins by making the useful observation that promulgation of S 50.47(d) in 1982 allowing issuance of a low power 11-cense without approved offsite emergency plans was a " codification" of previous case law in which the Commission used PR A to determine that any emergency planning defi-ciency was ever significant for operation at or below 5% power.
Staff Brief at 18.
The Staff also recognizes that nothing in the 1982 amendments precludes the use of PRA to show that planning deficiencies are not significant. Ld. at 17. Despite these statements, the Staff nevertheless opines, without articulation, that the rationale embodied in S 50.47(d) "may not be applicable to power operations of an indefinite na-ture, but rather only to low power testing of relatively short duration." Id. at 18.
In fact, the Staff provides absolutely no support for its claim that there may be substantial distinctions between low power testing and sustained power operations at 25% power. The Staff simply states that " substantial evidence" would have to be i
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Introduced to demonstrate that emergency planning deficiencies are not significant. I_d.
Thus, the Staff implicitly reaffirms its view that S 50.47(d) does not prevent the use of PRA but actually encourages such use on a sufficient showing.
b)
Whether Operations at Less Than Full Power Can Constitute
" Interim Compensating Actions" In response to a Board question, Interveners and the Staff both contend that op-eration at 25% power cannot constitute an " interim compensating action" under S 50.47(c)(1). These responses mischaracterize LILCO's motion and thus f all to shed any light on the fitness of LILCO's request.
In LILCO's original motion for approval to operate at 25%, two actions are de-scribed which, "[tlaken together with the present licensing status of Shoreham,...
permit the requisite finding to be made... authorizing operation at power levels up to 25E" Request at 10. These " compensating actions" are the existence of a LILCO-sponsored emergency plan a_n_d the operation of the plant at 25% power. LILCO's mo-n tion clearly proposes that these actions be "taken together" to demonstrate the neces-l sary interim compensating action. It is therefore irrelevant to LILCO's Motion to l
i discuss whether operation at 25%, standing alone, is sufficient to constitute an interim compensating action.
The Staff asserts that LILCO should " demonstrate the existence of features of l
l the LILCO Plan which would compensate for the absence of State or local emergency plans." Staff Brief at 12. LILCO has done exactly that. In its Motion, LILCO describes I
an offsite emergency plan which compensates for the refusal of New York State and 1
Suffolk County to participate in advance in offsite emergency planning for Shoreham.E l
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The Licensing Board, in its concluding PID on offsite emergency preparedness at Shoreham, LBP-85-31, 22 NRC 410 (1985), rejected Interveners' contentions about both 1
(footnote continued) 1 I
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Request at 10-18,89-102.
Thus, taken together, LILCO's proposed interim compensating actions of a compensating plan and operation at 25% are sufficient to meet the standard of 5 50.47(c)(1).
IIL Expedited Consideration of LILCO's Motion LILCO's Motion requests expedited consideration, including assignment of the Motion to a separate Licensing Board. Interveners and the Staff disagree, arguing that j
the Motion falls to raise issues which are sufficiently discrete from issues in the full l
l power proceeding to justify a separate, expedited proceeding under S 50.57(c). Interve-nors' Brief at 3-10; Staff Brief at 13-15. Specifically, the Staff argues that the legal au-thority issues related to activation of the alert and notification system and the decision and recommendation process for protective actions require the same finding of regula-tory compliance at 25% power operation as at full power. Staff Brief at 14. Therefore, (footnote continued) the basic feasibility of offsite emergency planning in the Shoreham EPZ and the poten-tial adequacy of LILCO's basic plan. The Board's approval of any plan for Shoreham was contingent, however, on the existence of a legal-authority structure, and the Board believed that the refusal of New York State and Suffolk County to participate directly in the advance planning process lef t LILCO's plan without a viable legal framework and without the degree of confidence of effective governmental cooperation that the Board considered necessary. These problems - which the Board acknowledged are entirely of New York State's and Suffolk County's making and could be cured by them with a policy decision - were the defects the Board found in emergency planning for Shoreham, rather than anything relating to the objective circumstances around Shoreham or LILCO's plan for coping with them (the Board concluded that all other defects in the plan were "of lesser magnitude" and "can be remedied"). However, this legal-authority aspect of the Board's decision was subsequently reversed by the Commission's adoption, in CLI-86-13,24 NRC 22 (1986), of the " realism" doctrine. As codified in a recent revi-sion to the Commission's offsite emergency planning regulations, 42 Fed. Reg. 42,078 (Nov. 3,1987), that doctrine presumes that State and local governments, notwithstand-ing their advance positions on emergency preparedness, will make good-faith best-efforts responses in the event of.an actual emergency, and licensing boards may pre-sume that in such a response they will use the utility's offsite plan unless those State and local governments have rebutted that presumption by a timely good-faith proffer of their own plan. Id. at 42,086 cols.1-2.
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a,
according to the Staff, there would be no benefit to LILCO in undertaking a separate 25% power proceeding.
Interveners' and the Staff's views are incorrect because they f ail to account for 1
the evidence included in LILCO's Motion showing that the objective risks presented by operation at 25% power are significantly less than those at full power. As described in Section II above, this evidence, including the PRA, may be considered by the Board in determining whether, pursuant to S 50.47(c)(1), emergency planning deficiencies are in-significant to the plant in question. According to both CLI-87-04 and the Commission's recently promulgated amendment to S 50.47(c)(1), 52 Fed. Reg. 42,078 (Nov. 3,1987),
the question of whether a utility-sponsored emergency response plan provides reason-able assurance of public health and safety in the absence of State or local government participation should be considered on a case-by-case basis. As the Staff concedes, for example, the impact of possible delay in notifying the public may be different at 25%
than at full power. Staff Brief at 14 n.7. Contrary to the Staff's conclusion, however, the facts necessary to determine the impact of the possible delay are not the same: at 25% the Board should consider the data included in LILCO's Motion, which are differ-ent, understandably, from those relating to the speed of accident scenarios at 100%
Thus, LILCO's Motion to operate at 25% raises issues which are sufficiently dis-power crete to allow consideration of the Motion apart from the full power proceeding.
LILCO's Motion to operate at 25% power is based upon an urgent need for power on Long Island documented initially last April. Request at 117-21; see also Madsen affi-davit, supra note 3. In light of this urgent need, LILCO's Motion should be considered expeditiously; expeditious consideration is most likely to occur if the additional re-sources represented by a new Licensing Board are made available. See Motion at 10-13.
P
If this Board declines, for whatever reason, to appoint an additional Board to hear the discrete !ssues arising out of the 25% power motion, it is imperative that con-sideration of those issues by this Board not impede its consideration of the issues re-maining to be resolved bef ore a 100% power license can be issued. Accordingly, in that event the requests in LILCO's motion should be considered to include those activities which will advance the substantive analysis of the issues raised by the motion, but do not consume the resources of the Board. These could include completion of the Staff's l
technical review of the 25% motion, and voluntary discovery among the parties, but would not encompass other activities which will divert the Board's definitionally limit-ed resourcesN from completion of the emergency planning issues now before it.
Respectfully submitted, 1
w
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Donald P. Irwin James N. Christman Lee B. Zeugin Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: November 16,1987 10/
By contrast, the resource limitations asserted on behalf of well-supported parties are not entitled to substantial consideration in assigning a proceeding's priorities. See Allied-General Nuclear Services (Barnwell Nuclear Fuel Plant Separations Facility),
ALAB-296,2 NRC 671,684-85 (1975).
I b..
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LILCO, November 16,1987 e
00LKETED UsNRC CERTIFICATE OF SERVICE 87 WJV 19 P3 :33 Of71CE D M ti h Y In the Matter of 00CKEl'Wi A ':L"VICI-LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station Unit 1)
Docket No. 50-322-OL-6 i
I hereby certify that copies of LILCO'S REPLY BRIEF ON 25% POWER QUES-I TIONS were served this date upon the following by Federal Express as indicated by an asterisk, or by first-class mall, postage prepaid.
James P. Gleason, Chairman
- Atomic Safety and Licensing A tomic Safety and Licensing Board Panel Board U.S. Nuclear Regulator Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers, Rm. 407 4350 East-West Hwy.
George E. Johnson, Esq.
- Bethesda, MD 20814 Richard G. Bachmann, Esq.
l U.S. Nuclear Regulatory Commission l
Dr. Jerry R. Kline
- 7735 Old Georgetown Road Atomic Safety and Licensing (to mailroom)
Board Bethesda, MD 20814 U.S. Nuclear Regulatory Commission East-West Towers, Rm. 427 Herbert H. Brown, Esq.
- 4350 East-West Hwy.
Lawrence Coe Lanpher, Esq.
Bethesda, MD 20814 Karla J. Letsche, Esq.
Kirkpatrick & Lockhart l
Mr. Frederick J. Shon
- South Lobby - 9th Floor Atomic Safety and Licensing 1800 M Street, N.W.
Board Washington, D.C. 20036-5891 U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 Fabian G. Palomino, Esq.
- 4350 East-West Hwy.
Richard J. Zahnleuter, Esq.
Bethesda, MD 20814 Special Counsel to the Governor Executive Chamber Secretary of the Commission Room 229 Attention Docketing and Service State Capitol Section Albany, New York 12224 U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Mary Gundrum, Esq.
Washington, D.C. 20555 Assistant Attorney General 120 Broadway Atomic Safety and Licensing Third Floor, Room 3-116 Appeal Board Panel New York, New York 10271 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 L_________________.____
n l.
i Spence W. Perry, Esq.
- Ms. Nora Bredes l
William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 -
Washington, D.C. 20472 Gerald C. Crotty, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York Stato Energy Office Executive Chamber i
Agency Building 2 -
State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq.
- Stephen B. Latham, Esq.
- Eugene R. Keny, Esq.
Twomey, Latham & Shea
. Suffolk County. Attorney' 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223
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Donald P. Irwin Hunton & Williams 707 East Main Street P.O. Box 1535 j
Richmond, Virginia 23212 j
DATED: November 16,1987 A.
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