ML20237E510
| ML20237E510 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/16/1987 |
| From: | Latham S, Letsche K, Palomino F HAMPTON, NH, KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-5150 OL-3, NUDOCS 8712290036 | |
| Download: ML20237E510 (19) | |
Text
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4 00CKEiED USNRC 17 00018 R2:20 December 16, 1987 UNITBITFSTATESi OF A AMERIC A NUCLEARg{kjugoj3tdOMMISSION O
T Before the Atomic Safety and Licensina Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-r. 3
)
(Emergency Planni., ;
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
GOVERNMENTS' MOTION FOR
SUMMARY
REJECTION OF NEW LILCO PROPOSAL FOR IMPLEMENTING EVACUATION OF SCHOOL CHILDREN In its October 22, 1987 Moti6n for Summary Disposition of Contention 25.C,l/ LILCO put forth a new proposal for the evacu-ation of school children during a Shoreham emergency.
As pre-sented in that Motion and subsequent filings, LILCO's proposal purports to address only the bus driver availability issues raised by Contention 25.C.
We demonstrate below that the new LILCO proposal in fact seeks Board review and rulings on much broader issues -- including the overall concept of how to imple-ment a school evacuation (e.a.,
single wave versus multiple wave)
-- as to which the evidentiary record has long since been closed, and over which this Board no longer has jurisdiction.
1/
LILCO's Motion for Summary Disposition of Contention 25.C
(" Role Conflict" of School Bus Drivers) (Oct. 22, 1987).
8712290036 871216 PDR ADOCK 05000322 6
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1 <
l The Governments' views concerning the propriety of LILCO's summary disposition motion on contention 25.C, and the reasons it must be denied, were stated in the Governments' Answer, and will not be repeated here.2/
The point of this Motion is to focus the Board's attention on the scope of the substance of LILCO's new proposal, particularly when viewed in light of this Board's prior rulings on Contentions 70 and 71.
The Board has already ruled against LILCO on the adequacy and implementability of the school evacuation proposal contained in the LILCO Plan.
As a result of several defects in LILCO's proposal, the Board found that there was no reasonable assurance that adequate school evacuation measures could be taken.
Sge Lona Island Lichtina Company (Shoreham Nuclear Power Plant, Unit 1), LBP-85-12, 21 NRC 644, 860, 872, 874 (1985) (the "PID").
LILCO did not appeal these adverse decisions, and they have long since become final.
Now, however, in the guise of responding to the contention 25.C remand, LILCO has conceived of an entirely new scheme for school evacuation.
Although LILCO has attempted to argue that its new proposal should be considered only as a response to the bus driver availability issue presented by the remand, in fact such consideration inherently involves consideration of the new 2/
Answer of Suffolk County, the State of New York and the Town of Southampton to LILCO's Motion for Summary Disposition of Contention 25.C
(" Role Conflict" of School Bus Drivers) (Nov. 13, 1987).
See also Response of Suffolk County, the State of New York and the Town of Southampton to NRC Staff Response in Support of LILCO's Motion for Summary Disposition of Contention 25.C (" Role Conflict" of School Bus Drivers) (Nov. 25, 1987).
O LILCO proposal as a whole, including those aspects of it which effect a complete change in LILCO's approach to, and its proposed methods of accomplishing, school evacuations.
Yet, LILCO has not even attempted to meet the NRC's criteria for reopening the record on school evacuation issues.
We demonstrate below that this Board cannot consider LILCO's new proposal for school evacuation regardless of the rubric under which LILCO offers it, unless and until LILCO seeks, meets the requirements for, and obtains from the appropriate NRC adjudica-tors a reopening of the record on the school evacuation conten-tions previously heard and decided by this Board.
Since LILCO has not sought such reopening, its new proposal must be rejected.
I.
LILCO'S PRIOR SCHOOL EVACUATION PROPOSAL AND THE RULINGS CONCERNING IT All previously-litigated versions of the LILCO Plan proposed that the protective action of evacuation for school children would be implemented by individual schools or school districts, using their own resources.1/
Specifically, until recently, LILCO 2/
It should be noted that LILCO's new proposal purports to address only the protective action of evacuation for school children.
It does not address the LILCO Plan's proposed method of implementing the separate protective action of early dismissal (which was the subject of Contentions 68 and 69), even though Contention 25.C alleges that the unavailability of school bus drivers would make it impossible to implement that protective action as well as evacuation.
See Governments' November 13 Answer.
Accordingly, the discussion in this Motion is limited to LILCO's new proposal for implementing an evacuation of school children, rather than its apparently unchanged proposal concerning the separate protective action of early dismissal.
Obviously, however, in considering whether LILCO's new proposal adequately (footnote continued) i i
4 asserted that the public schools' regular bus drivers would use their own $uses to make the number of multiple bus trips neces-sary to transport all the children from schools to unidentified reception centers outside the EPZ.
Plan, Appendix A at II-19 to II-21;_OPIP 3.6.5.
LILCO's response to the fact that no schools
~
had prepared, adopted, approved, or agreed to implement any plan to evacuate children in the event of a Shoreham emergency was to assert that its evacuation proposal would nonetheless be imple-mented by the schools through some kind of' school-implemented ad hqq modification of early dismissal plans the schools had adopted to transport children _from schools to their homes during snow storms (called "take-home" plans).
Egg cenerally Cordaro et al.~,
ff. Tr. 9154 (1984 OL-3 trial transcript).
In response to this original LILCO proposal for evacuation of school children, the Governments submitted Contentions 70 and 71 which are set forth below, as admitted'by the Board.1/
Contention 70.
Although the LILCO Plan states that schools will be advised to evacuate if evacuation or a combination of sheltering and evacuation is recommended for the general public,'the Plan does not identify relocation centers for, or the means or procedures to evacuate, any of the schools. (Appendix A'at II-20.)
Thus, the LILCO Plan has no provision concerning how its proposed evacuation and relocation of children, or the safe reuniting of children with their families, could or (footnote continued from previous page) addresses the issues raised by Contention 25.C, the impact of missing bus drivers on LILCO's ability to implement early dismissals would have to be examined.
A/
The text of these contentions is also set forth in the PID, 21 NRC at 1016-17. _ _ __ _ _ __ _ _ _____
would be implemented.
And, contrary to i
,LILCO's assumption, there is no evidence in
)
'the Plan that. school officials have conducted j
" preplanning" for a Shoreham emergency. (See
{
OPIP 3.6.5 at 10a).
Interveners contend that in failing to provide for an implementable evacuation of the school children in the school districts in the EPZ the LILCO Plan fails to comply with 10 CFR Sections 50.47(a)(1), 50.47(b)(10), and NUREG 0654 Sections II.J.9 and II.J.10.
Contention 71.
Interveners contend that the Plan's proposed evacuation of school children (Appendix A at II-19 to II-21; OPIP 3.6.5) could not and would not be implemented for the following reasons:
Contention 71.A.
Assuming the availability of relocation centers for evacuated nursery school children (the Plan fails to identify any such centers), under the LILCO Plan, a timely evacuation of the nursery schools in the EPZ (see Appendix A at II-20, II-21; OPIP 3.6.5) could not be implemented because:
1.
Even if LILCO had agreements with companies to provide a sufficient number of buses and agreements with schools or parents permitting children to ride in buses being driven by LILCO employees in an evacuation of nursery schools (see Contention 24), many of the busec in fact would not be accessible to LILCO employees because they would be in the custody of the normal school bus drivers, or the buses would be located substantial dis-tances away.
2.
The LILCO Plan has no provision for supervision of children at schools, on buses or at relocation centers.
Contention 71.B.
An evacuation of nursery and other schools, even if buses and bus drivers were available (see Contention 24) would take too long and children would not be adequately protected from health threatening radiation doses because:
1.
Evacuating buses would encounter
' congestion from other mobilization and evacua-tion traffic, and thus would be substantially delayed in traveling from schools to reloca-tion centers (the Plan fails to identify any such relocation centers).
2.
Normal school dismissals require substantial numbers of multiple bus runs as well as staggered dismissal times.
In the event of an evacuation, an even larger number of multiple bus runs (requiring several hours) would be necessary to transport all children out of the EPZ.
The 1984 litigation on school evacuation was premised upon LILCO's mutiple-wave evacuation proposal, to be implemented by the schools by some unidentified ad hoc adaptation of their early dismissal "take home" procedures.
That was what FEMA reviewed.5/
That was what the parties discussed in their testimony.6/
The record was closed on that proposal on August 28, 1984.1/
The parties thereafter addressed that' proposal in their proposed findings.8/
And, on April 17, 1985 the Board ruled on Contentions 70 and 71 based upon that proposal and the parties' 5/
Egg Consolidated RAC Review (Feb. 10, 1984).
i 4
6/
See Cordaro et al.,
ff. Tr. 9154; Jeffers and Rossi (Schools), Petrilak (Schools), Muto and Smith (Schools), ff.
Tr. 11,001; Baldwin et al.,
ff. Tr. 12,165.
1/
Sea PID, 21 NRC at 651.
8/
Reg LILCO's Proposed Findings of Fact and Conclusions of Law on Offsite Emergency Planning (Oct.
5, 1984); Suffolk County and State of New York Proposed Findings of Fact and Conclusions of Law on Offsite Emergency Planning (Oct. 26, 1984); NRC Staff's Pro-
]
posed Findings of Fact and Conclusions of Law in the Form of a i
Partial Initial Decision on Emergency Planning (Nov.
5, 1984);
)
LILCO Reply Findings on Offsite Emergency Planning (Nov. 14, 1984).
j l _ ___________
l
e evidence concerning it.
ggg PID, 21 NRC at 869-74.
Those Board
- rulings.were not disturbed upon appeal.
Egg Lona Island Lichtina Comoany (Shoreham Nuclear Power Station, Unit 1), ALAB-832, 23 NRC 135 (1986).
In the PID, the Board found for LILCO on a portion of Contention 70.1/
The Board ruled it unnecessary for schools to have adopted, approved, or agreed to implement LILCO's proposed multiple-wave evacuation plan, or otherwise to have pre planned for an evacuation.
In so ruling, the Board accepted LILCO's assertion that its proposed evacuation plan would somehow be implemented by the schools through the use of the schools' early dismissal "take home" plans and procedures, and maps provided by LILCO.
The Board ruled as follows on Contention 70:
The procedure for evacuation of schools under the LILCO Plan is different from the procedure for implementing early dismissal, in that buses will take students to relocation centers rather than to their homes.
The schools would use their own resources LILCO will prepare maps for each school in the EPZ, providing a recommended best route between the school
. and its designated reception cen-ter If schools refuse the maps, then LILCO will deliver them to the bus drivers at the schools at the time of an emergency.
Schools will call upon their buses in the same way as for early dismissal because of snow emergencies or natural disasters.
i The Board finds that LILCO has made available the information necessary for schools to im-plement an evacuation.
In addition, schools 2/
The Board addressed the portion of Contention 70 dealing with LILCO's failure to identify relocation centers for school children under the rubric of Contention 24.N.
PID, 21 NRC at 869.
The Board found for the Governments on that issue.
Id. at 860.
LILCO did not appeal that ruling. - _ _ _ _ _ _
have plans for early dismissal which can be used for evacuation.
The Board finds that
, schools' existing plans combined with infor-mation provided by LILCO make the plan for school. evacuation workable.
PID, 21'NRC at 870 (citations omitted).
It is clear that the Board's " workability" ruling was directly tied to the original LILCO proposal that schools would be able to, and would, use their early dismissal "take home" plans and procedures, and their own resources, to implement the multiple-wave evacuation proposal which was then the basis of'LILCO's Plan.
As we demonstrate below,-the assumptions which formed the factual predicates of the Board's 1985 ruling on Contention 70 are significant because LILCO's new school evacuation proposal proceeds from an-entirely-different set of assumptions.
While the Board also found for LILCO on subpart A of Conten-tion 71 (dealing with nursery schools), the Board found for the Governments on Contention 71.B.
Thus, the Board made the fol-lowing finding on the overall inadequacy of LILCO's proposal for evacuation of school children:
[O]n the record before us, we find that the LILCO Plan does not provide reasonable assur-ance that adequate protective measures can and will be taken in.the event of an evacuation of schoolchildren from the Shoreham EPZ.
PID, 21 NRC at 874.
This conclusion was based on the Board's review of LILCO's proposed multiple-wave, school-implemented evacuation proposal, and LILCO's failure to present evidence or j - _ _ _ _ _ _ - - _ _
I.
y l
l provide any basis to support a finding that such an evacuation could be accomplished in a timely manner, or that there would be a sufficient number of buses available to permit such an evacua-tion to be accomplished.
Egg id. at 872-74.10/
LILCO did not 1
l appeal the Board's ruling against it on the school evacuation l
l implementation issues raised in Contention 71.B.
II.
THIS BOARD HAS NO JURISDICTION TO CONSIDER LILCO'S NEW SCHOOL EVACUATION PROPOSAL We have included this historical review because it is essen-tial to have it in mind when considering LILCO's new school l
evacuation proposal.
LILCO characterizes the new proposal as one which addresses the bus driver availability issue raised by Contention 25.C and the Appeal Board's remand of that issue.
And, the new proposal does purport to address the situation presented by the fact that regular school bus drivers are likely 10/
As already noted, the Board found the LILCO Plan defective in that it failed to identify any reception centers for school children.
As a result, it also held with respect to Contention 71.B that it is not possible to calculate how long an evacuation might take without knowing the location of reception centers.
LILCO has admitted that the delay in evacuation may be extensive but claims that this will not endanger the children because they can shelter in the school buildings while awaiting the return of buses for evacuation.
. We do not find this acceptable.
We find that the lack of a reasonable estimate of the time to evacuate is a defect in the LILCO Plan.
PID, 21 NRC at 872 (citations omitted).
LILCO did not appeal that ruling.
' * ~
to resolve role conflict in ways which would make them unavail-able to. par'ticipate in implementing school evacuations.11/
In addressing the Contention 25.C bus driver availability issue, however, LILCO's new proposal also embraces an entirely new approach to school evacuation (single versus multiple wave), as well as an entirely-new organizational, personnel, and operation-al structure and method of implementing such an evacuation.
l l
Thus, LILCO's new school proposal differs, in many signif-icant respects, from the proposal it put forth for evacuating school children during the 1984 litigation, and upon which the Board's rulings in the PID were based.
In the absence of a ruling reopening the evidentiary record on the school evacuation issues already litigated. decided, and not remanded, this Board I
has no jurisdiction to consider any such new proposal.
We will not belabor here thd differences between LILCO's original and already-litigated school evacuation proposal, and its new one.
The differences were described in the Governments' November 13 Answer to LILCO's summary disposition motion, to the extent possible given the lack of specifics provided by LILCO 11/. We do not detail here why, in the Governments' view, the new proposal ineffectively and inadequately addresses that situation.
In the Governments' November 13 Answer, we discussed the matter to the extent possible and appropriate, given the sketchy information provided to date by LILCO concerning its new proposal.
A more detailed analysis will be possible only after LILCO has provided additional information about its new school evacuation proposal and there has been an opportunity for the parties to conduct necessary discovery. - _ - _ - _ - _ _
concerning its new proposal.
We highlight below, however, the
. major differences between LILCO's proposals, based upon that information which thus far has been provided by LILCol2/:
Already Litigated Evacuation Proposal New ProDosal Multiple-wave evacuation Single wave evacuation Schools to implement themselves LILCO to implement at least 39%, and as much as all, of the evacuation Schools to use "take home" LILCO to use up to 562 LILCO plans and procedures to obtain drivers, dispatched and di-and dispatch buses driven by rected by LILCO to and from regular school bus drivers LILCO-selected bus yards, from the schools to (uniden-then to schools, and then to tified) reception centers (still unidentified) reception centers Children to be transported by Children to be transported by regular school bus drivers, at least 222, and up to 562, licensed and approved by school LILCO-employed " bus drivers" officials, in buses normally not approved by school dis-used by schools tricts, apparently in buses not used by schools, but to be obtained somehow by LILCO There is no basis upon which this Board could properly con-sider this entirely new and different proposal for implementing school evacuations, in light of the history of this litigation and LILCO's failure to seek a reopening of the record.
12/
The Governments provide this brief summary for the further reason that LILCO misled the Board when it asserted on November 27 that "[t]he only thing new about school bus drivers is that LILCO has now committed to recruit additional LERO bus drivers as backups."
LILCO's Answer to Five Recent Pleadings on Realism and Summary Disposition, Nov. 27, 1987, at 15 (emphasis added). _ _ _ _ _ _ _ _ _ _.
F.c The NRC's rules concerning the finality of decisions are clear.
It a well established that whenever an NRC litigant seeks to add new information to a closed record, it must first file a motion to reopen the record.
Indeed, the Commission amended its regulations to codify and refine NRC case law cri-teria for reopening a closed evidentiary record.
Egg 51 Fed.
Reg. 19,535 (May 30, 1986).
In adding Section 2.734 to its Rules of Practice, the Commission noted that the criteria for reopening a record are intended-to apply "when a record is closed with respect to a particular contention."
51 Fed. Reg. 19,538.
The Commission stated, further, that because "[p]rinciples of fi-nality.
attach equally to applicants and to interveners
" a motion to reopen "must be filed whenever a proponent seeks to add new information to a closed record, whether the information concerns a new contention or one which has already been heard."
Id. at 19,538, 19,539.
In this way, according to the Commission, "once a record has been closed and all timely-raised issues have been resolved, finality will attach to the hearing process."
Id. at 19,539.
Under the NRC's regulations, then, LILCO must seek and obtain a reopening of the evidentiary record on the school evacuation issues raised by its new proposal before this Board can consider that new proposal.
This is not to say that under the appropriate circumstances, and assuming it could meet the NRC's strict reopenin'g criteria, LILCO could not, as a theoreti-cal matter, attempt to correct defects in its Plan.
But, an
~
l applicant's choice to attempt to remedy one defect by means of a proposalwhichbyitsnaturereopensotherissues,cannotand does not confer jurisdiction upon the Board to consider new issues which are already closed and finally decided.
LILCO's new school evacuation proposal seeks to change the factual predicates upon which prior contentions and rulings were based.
The Board cannot consider the proposal as a vehicle for correcting one Plan.
defect while ignoring its ramifications on other aspects of the implementability of school evacuation and the LILCO Plan as a whole.
The NRC's rules of finality and basic principles of due process require that the reopening criteria must be addressed and fully satisfied by LILCO before this Board has jurisdiction to consider its new proposal.
Thus, the Board must reject LILCO's attempt to circumvent Section 2.734 and established procedure by trying to slide its new school evacuation proposal through the back door of the Contention 25.C remand.
The Appeal Board's remand decision may have opened the door for the submission of new evidence on the issues of bus driver availability and the related impact of driver unavailability on implementation of early dismissal and school evacuation, raised in Contention 25.C.
But, the Appeal Board did not purport to address, much less authorize LILCO to re-litigate, the separate and much broader issues concerning the nature, adequacy, and implementability of the entire approach to i
school evacuation, which were raised by Contentions 70 and 71,
and raised again by LILCO's recent new proposal.13/
Even W
' assuming'forythe sake of argument that its new proposal addresses issues legitimately raised by contention 25.C, that fact provides no basis for permitting LILCO to re-litigate other contentions and finally decided issues, unless LILCO can demonstrate its
~
entitlement to such an opportunity.
III. CONCLUSION' The bottom line is simple.
LILCO must face the fact that-its chosen method.of addressing a remanded issue also requires it to attempt to have.the record reopened on other issues.
In this case, with the-record having been closed for over three years and LILCO having failed even to appeal the decisions against it on school evacuation issues, the Governments submit that these criteria could not be met.
Nonetheless, LILCO must either at-tempt to meet the reopening' criteria and, if' successful, face the need to re-litigate Contentions 70 and 71 and other school evacu-ation issues raised by its new proposal, or it must come up with another way of addressing the Contention 25.C remand.li/
2/
.Even LILCO recognizes the limited scope of the remand.
- Egg, e,c,, LILCO's-Answer to Five Recent Pleadings on Realism and Summary Disposition (Nov. 27, 1987), at 13, n.10, in which LILCO first mischaracterizes Contention 25.C (by asserting that it does not address the availability of buses) but then acknowledges that the~ Board's finding on Contention 71.B.2. "was not appealed, and, a fortiori, the issue was-not remanded in this proceeding.
14/1 LILCO's new school evacuation proposal not only requires LILCO to attempt to reopen the record on Contentions 70 and 71; it also raises new issues not covered by those contentions, since they were drafted in response to an entirely different LILCO plan.
(footnote continued) o For the foregoing reasons, and in the absence of a ruling I
that LILCO-is entitled to have the evidentiary record reopened, this Board has no jurisdiction to consider LILCO's new proposal j
for implementing school evacuations.
Accordingly, that proposal must be summarily rejected.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158' North County Complex Veterans Memorial Highway Hauppauge, New York 11788 Y
u/
Lawrepce Coe Lanpffr Karld J. Letsc W Michael S. Miller J
KIRKPATRICK & LOCKHART I
1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County (footnote continued from previous page) l The Governments addressed this matter in their November 13 Answer l
to LILCO's October 22 summary disposition motion, and will not l
repeat that discussion here.
It should be emphasized, however, that the argument herein concerning the need for LILCO to satisfy the reopening criteria with respect to the already-decided Contentions 70 and 71 is not intended to imply that should the record be reopened to consider LILCO's new proposal, future litigation-could be limited to those contentions.
Clearly, if the evidentiary record on school evacuation issues is reopened, the l
issues actually presented by the new LILCO proposal, including those in addition to, or different from, those raised by l
Contentions 70 and 71 (such as how LERO could manage and coordinate 562 additional school bus drivers), would have to be 1
identified and litigated, as was done with the reopening on the l
original reception center contentions to deal with a totally new l
LILCO proposal.
l l
1 l 1
l
o j
Fabian G. Palomino Richard J.
Zahnleuter Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorneys for Mario M. Cuomo, Governor of the State of New York M
St@ hen 3/ Latham Tw6mey, "4 tham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton 1
l i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
1 t. ; f, '
00CKETED t
USHHC
'87 DEC 18 Pl2:21 December 16. 1987 OFFICE OF 5ECfyJAgy UNITEDSEAW5.!@Q.)MBffCA NUCLEAR REGULAT6RTUOMMISSION Before the Atomic Safety'and Licensino Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING CDMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE i
I hereby certify that copies of GOVERNMENTS' MOTION FOR
SUMMARY
REJECTION OF NEW LILCO PROPOSAL FOR IMPLEMENTING EVACUATION OF SCHOOL CHILDREN have been served on the following this 16th day of December, 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 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C.
20555 James P. Gleason, Chairman
- William R. Cumming, Esq.
Atomic Safety and Licensing Board Spence W. Perry, Esq.
I U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C' Street, S.W., Room 840 Dr. Jerry R. Kline*
Washington, D.C.
20472 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
L-___________________-______._
n i
1-P Fabian G. Palomino, Dsq.
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 Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.-
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 Mary M. Gundrum, Esq.
Hon. Michael A. LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison. Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger Edwin J. Reis, Esq.*
New York State Energy Office George E. Johnson, Esq.
Agency Building 2 U.S. Nuclear Regulatory Comm.
Empire State Plaza Office of General Counsel Albany, New York 12223 Washington, D.C.
20555
- t '.
.s.
- 1 David A. Brownlee, Er/g.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial
- 1500 Oliver. Building NEW YORK TIMES Pittsburgh, Pennsylvania-15222 229 W.
43rd Street-New York, New York 10036
-Douglas J. Hynes, Councilman Mr. Philip McIntire Town Board of Oyster Bay Federal Emergency Management Town Hall Agency Oyster Bay, New York 11771 26 Federal Plaza New York, New York 10278 l
'l Ir By Hand KarkrJ. Letsc
'By Federal Express KIR$ PATRICK &
OCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 1
______ __-_-__ _ _- - _ _ -