ML20239A615
| ML20239A615 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/14/1987 |
| From: | Ross R KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| To: | Kline J, Margulies M, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20239A616 | List: |
| References | |
| CON-#387-4397 OL-3, NUDOCS 8709180005 | |
| Download: ML20239A615 (21) | |
Text
_-
ff j
- J; c,
- A KIRKPATRICK & LOCKHART SOUTH LOBBY,9TH FLOOR ExCHANGI FLACE 1800 M STREET, N.W.
^7E g
WASHINGTON, D.C. 200b5891 m h 2216000 i,
'87 SEP 15 P5 :12 u2, m m tAvENUE M AMI, FL 38til TELIMlONE G02) 77&9000 005) 3744til
==
f f y(.
1530 OUVER BUILDINO M
TELECOfTA G02) 77&9100 MTTSBURCH PA 19222 5379 E
WRITER 1 DIRfCT DIAL NUMBER 1412) 3554 500 (202) 778-9225
=
=
J
]
September 14, 1987
' y a
Morton B. Margulies, Esq., Chairman Dr. Jerry R. Kline
=
4 Mr. Frederick J..Shon Atomic Safety and Licensing Board i
United States Nuclear Regulatory Commissior.
~
East-West' Towers l
4350 East-West Highway Bethesda, Maryland 20814 l
Re:
Docket No. 50-322-OL-3 5
(Emergency Planning)
Gentlemen:
=
n Enclosed please find the SUFFOLK COUNTY, STATE OF NEW YORK, 3
AND TOWN OF SOUTHAMPTON PROPOSED FINDINGS OF FACT AND CONCLUSIONS j
OF LAW ON THE SUITABILITY OF RECEPTION CENTERS.
e
..In addition, we have enclosed a copy of a complaint filed against LILCO on August-14 = by the Town of Hempstead in the y
Supreme Court of the State of New York, Nassau County.
The com-2 plaint seeks to enjoin LILCO from using the Bellmore Operation Center as a reception center and is referenced in Section VI of y
the enclosed Proposed Findings.
{We bring this to the Board's attention pursuant to its February 9 Memorandum and Order.]
h'inally,wehaveenclosedonecertifiedcopyeachofthe resolutions of the Towns of Hempstead, North Hempstead, and 9
Oyster Bay (attached to the Proposed Findings as Appendices A, B
1;
~j B709100005 870914 fD/
PDR ADOCK 05000322 O
pg h=
y e;, '
,s f-Q.
m
im '
' KIRKPATRICK & LOCKHART s-JVl 1
Morton B. Margulies, Chairman-i,.
JDr. Jerry R. Kline P
Mr. Frederick J. Shon.
fl}
a.
4
- Septembee 14,'1987-p Page.'2-f
'and'C) bearing the seals of the respective Towns.
The n,
resolutions are referenced in Section VI of the enclosed hj ;,. m
?
L'-
Proposed' Findings.
e Very truly yours, p
y [ :.,,-
1 d le-
.g Ronald R. Ross b
- RRR/ mas
'g." '
'All Counsel (w/ Complaint)
- cc:
Service Liot (w/o. Enclosur'es )
L 1..,
}
_h L,
l-p
.o
,1 m
yr
w c,x:
...c..
- /-
/
v i
a f.
/
./
w-ot us(a: n elAH ETC.
Sim of Nei, LtL, C..uut fgggjr gg, a.
u.t SUPREME COURT: STATE OF NEW 1
be4ng daly...a n. Jep..w. an.J.43.; that de COUNTY OF NASSAU 4
a prey io d..
4.nou...... is > ears of...ponent is nct and,eside.
j Urpuneet aneiogra t.<,.. o.. wid.in summon.
TOWN-OF HEMPSTEAD, and BERT A.
L> per.e.J Jeb. cry upon the defendant MAYER, etc.
i sg Plaint >RS sgainst on tan.ng d.ca -
LONG ISLAND LIGHTING CO., etc.,
l Defendants.
Burntnana'ultil Nottre W. KENNETH CHAVE, JR., ESQ.,.
^ [
Town Attorney and L
A ttorney06) for PlaintidS 05ce and Post 06ce Address. Telephone Number Hempstead Town Hall Town Hall Plaza, Main Street Hempstead, New York 11550 516-489-5000
'n..I prr.on51 J his r
.i nur ivuld not be made with due dshgence upvu d.. na>J J.h ant...t end therefor depunent on the dap ui 39 SERVICE SY DElIVENY TO IND. OR CORP. DETEhDAN
.c rved. up>..t it......n...n.
un aed defenJ.ut L) i n b...uv. sne an a po.tpaad esled State of New York. County of u.:
wrapper prwpsd>
JJi.. J iu nd def endant ~ at de.
lendant'.!.aLh..isa h nica v, b.
being duly sworp, deposes and sayst that deponent is not 4 party to the action, is over 18 pears of age and resides
.nd de pouni.;...!
m i
..p.
at n.
a pv.t ofbestf.oal de.
That on the d o of 19 punitory und.a H.. -
.s tu.n.
. are.end custody of the st No.
L nia.' si.ne. p.. 4 uu..
- 4. pan...n withan New YorL State
.v. 6 vs..t' Ta s l>. p..~...is....a....c. of..nic to the door of depor.cnt.eneJ the unlun sammons t L s Dep.... > t J. l.. e. J.. py of same to e,.a.. e ea., v., w res mbun..b p.......a kn.
- a. Le i4)d.-fer Jan therein r.arned. by delisering a arue cop > of each i,..d defendent person 4Hy; deponent knew the per.on to
.cssed to be the person de.cribed as said defend nt shcrein.
and 4 p.
...u..:.u.t 14 age r.J de.cretion at
' als a eurporation, e defendant d.cre.n n.med, by drinenng a true copy of e..h tu per.on ally,
.. J pri n...r.
i,..,..t. t... J.n i, -. place of burene dep..ncr.t knew
- aid e.rporauon so sened to be the 4:orpo.
deelbus Lui. :
ser.wn de.cnbrd an. aid sun mons as said dsfendant u u t..t,.....i. Lod. - i. iiL4n d.c. tate.
Lnew s..J.nJmdoal su be l
and thereof.
i Smura.av bef...... th.,
J.y ul di. van to before me this es d,.> ul 19
\\
- - - - - - - - = - - - - - -
H
/
w
/
. j. /
7 N 1 '4 6J 3 U
.F' C 106-M *,, g t',' g ? 'a-l "
e-SUPREMECOURTOFTHEk!ATEOFNEWYORK '"' ' "* * W.*. =,A*, u c.,Tg,, g COUNTY'0F NASSAU fndex No.
TOWN OF HEMPSTEAD, and BERT A. MAYER, PI' "'I#8 ##'I " "
f
- Commissioner of the Department.of Nassau Buildings of the Town of Hempstead, county as rhe plect of,ilal 7 !.e b:~i. Of the vcriur i-Principal office of Pl*;nsins Plcintifis against LONG ISLAND LIGHTING CO., and any of its agents, officers, servants, employees, fummans miti; Nottrr successors and assigns, and anyone acting by, through, or under the Long Island Plaint /Bs vasaKxnmaintain their Lighting Co.,
office at Town Hall Plaza 3
Hempstead, New York Defendants j
Cour>ty of Nasgau
{
. To the above named Defendants kDL1 lll*C $ Cl*C$1Q BLill\\\\\\lD11Cb to answer the complaint in this a copy of your answer, }or, if the' complaint is not served with thi appearance, on the PlaintiR's Attorney (s) within 20 days alter the service of this summons, exclusive delivered to you within the State of New York): and in cas ment will be taken against you by default for the relief'demandedin the complaint.
-Dated, Hempstead, New York W.
KENNETH CHAVE, JR., ESQ.,
August 14, 1987 Town Attorney and A ttort;ey(%) for PlainttAS o5ee and Post o5ce Addres Hempstead Towm Hall Towm Hall Plaza, Main Street Hempstead, New York 11550
. Notice is hereby ginn to you that, upon your default to strear, or answ er th. mthir. sn.mmons, j i
be taken egainst ycuXuNKJXKNJ.5 XKkW Kla W Y.N3ty.
and rhe costs ot tais ection. The object of this act$on is a permanent injunction to XX restrain Building and Zoning violations.
)
'TAf14090 EKF/cb
.i-l SUPREMZ COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU
x TOWN OF HEMPSTEAD, and BERT A. MAYER, Commissioner of the Department of Buildings of the Town of Hempstead, Plaintiffs, VERIFITD COMPLAINT Index No.
- against LONG ISLAND LIGHTING CO., and any of l
its agents, officers, servants, employees, successors and assigns, and anyone acting by, through, or under the Long Island Lighting Co.,
Defendants.
x The plaintiffs, by their attorney, W. Kenneth Chave, Jr., Town Attorney of the Town of Hempstead complaining of the defendants respectfully allege as follows:
FIRST.
That at all times hereinafter mentioned, the plaintif f, Town of Hempstead, was and still is a domestic municipal corporation with its principal office at Hempstead Town Hall, Town Hall Plaza, Main Street, Hempstead, New York.
SECOND:
That at all times hereinafter mentioned, the plaintiff, Bert A. Mayer, was and still is the Commissioner of the Department of Buildings of the Town of Hempstead, duly appointed and acting in such capacity and as such official is charged with the enforcement of the Building Zone Ordinance of the Town of Hempstead.
THIRD:
That upon information and belief at all
4 4
0 t
e4mes hereinaf ter mentioned the defendant, Long Island Lighting Company, hereinafter LILCO, was and still is a domestic corporation with its principal office at 175 i
East Old Country Road, Hicksville, New York.
FOURTH:
That upon information and belief the defendant LILCO generally operates as a utility which supplies electricity and gas to its customers within the County of Nassau and
^
the Town of Hempstead.
FIFTH:
That upon.information and belief the defendant LILCO by virtue of its corporate capacity and contractual obligations does have, and may have, officers, agents, servants, employees, successors and assigns, and those acting by, through, and under LILCO all of whom are named as defendants herein so that the plaintiffs may have complete relief in the event of a judgment in plaintiffs' favor.
SIXTH:
That upon information and belief the defendant LILCO is the owner of the premises located at the southwest corner of Newbridge Road and Sunrise Highway in the unincorporated hamlet of Bellmore, New York which is also known as Section
)
1 56, Block W, Lot 1295 on the Land and Tax Map of Nassau f
Crunty and which is known also by street address 2400 j
' Sunrise Highway, Bellmore, New York.
SEVENTH:
That upon information and belief the f
above-described real property and improvements thereon I
1 1
are popularly known as the "LILCO-Bellmore Operations Center".
EIGHTH:
That the legislative body of the Town of Hempstead, to wit: the Toen Board, has heretofore enacted a certain ordinance known as the " Building Zone Ordinance of the Town of Hempstead" which was first effective on January 20, 1930 and which has.been subsequently amended, revised, and reenacted and which.is hereinafter referred to as the " Building Zone Ordinance."
NINTH:
That the above-mentioned " Building Zone Ordinance" has divided the unincorporated areas of the I
Town of Hempstead into certain enumerated use districts i
i the boundaries of which are shown on the " Building Zone l
Map of the Town of Hempstead, Nassau County, New York" I
which Official Map is part of the zoning ordinance.
TENTH:
That pursuant to the above-mentioned ordinance and map the defendants' parcel herein is in two different use districts. The frontage along Sunrise Highway up to a depth of 100 feet is in " Article XVI - X Business Districts (X)" and the balance of the parcel is in " Article VII B Residence Districts (B)."
ELEVENTH:
That the legislative body of the Town of Hempstead, to wit: The Town Board, has heretofore enacted and has from time to time amended a certain ordinance i
1 L ____ _ _ _
.c e.
I, s
known as _ the " Code of the Town of Hempstead,"
TWELFTKt That the applicable portions of the " Building Zono' Ordinance of the Town of Hempstead" and the " Code of. the Town of Herpstead" were and are in full force and effect on the dates hereinafter complained of.
THIRTEENTH:
That up:On information and belief the
[ defendant LILCO has designated its' Bellmore Operations Center as a General Population Reception Center for evacuees in the event of a radiological emergency at the Shoreham Nuclear Power Station.
i FOURTEENTH:
That upon information and belief as a consequence of the abovementioned designation, the defendant has included its Bellmore property in its emergency etesponse plans which will include and have included drill (s) or exercise (s) and the location and storage of related equipment, structure, and supplies.
And, in the event of-a radiological
~
accident, the subject parcel will be site of the reception of Suffolk County residents for the purpose of radiological assessment and the decontamination of persons and vehicles.
FIFTEENTH:
That upon information and belief sometime prior to July 27, 1987 the defendant LILCO installed or caused to be installed on its Bellmore property near its southerly property line a trailer with stabilizer bars with connections to electrical and water supplies; with said utilities being intermittently connected or disconnected by LILCO, l _
e o
l SIXTEENTH:
That upon information and belief the trailer is located in the "B-Residence Zone" of the Town of Henpstead.
SEVENTEENTH:
That upon information and belief the trailer contains decontamination facilities consisting of nine sinks and twenty showers.
_ EIGHTEENTH:
That the siting of the trailer, the addition of stabilizing bars, and the actual connection to utilities constitute the commencement of work for the erection of a structure within the meaning of $256.C of the Zoning Code.
NINETEENTH:
That pursuant to 5256.C of the Zoning Code such activity should not take place "until a permit has been duly issued therefor."
TWENTIElH:
That the defendants have not been issued any building permits as provided for in $86-9 and i86-13 of the Town Code.
TWENTY-FIRST:
That the defendants LILCO's construction end improvement of the structure-trailer without the benefit of a building permit is illegal.
AS AND FOR A SECOND CAUSE OF ACTION TWENTY-SECOND:
That the plaintiffs repeat and reallege paragraphs "FIRST" through " SEVENTEENTH" as if more fully set forth herein.
TWENTY-THIRD:
That upon information and belief _
~
4 '-
i'
,i In~~ connection with the siting of the within described i
structure-trailer,-the defendants have installed plumbing and/or drainage and a water supply.
TWENTY-FOURTH:
That $86-10 A and B of the Town Code require that plumbing, drainage and water supply all be installed in a structure pursuant to a permit.
TWENTY-FIFTH':
That no plumbing permits have been issued by the Town to sanction the work performed by the defendants in connect!.on with the structure-trailer herein.
TWENTY-SIXTH :
That in consequence of the foregoing, the~ defendant L1LCO's installation of plumbing or drainage, and water cupply without the benefit of a permit is illegal.
AS AND FOR A THIRD CAUSE OF ACTION TWENTY-SEVENTH:
The plaintiffs repeat and reallege
!eachandeveryallegationcontainedinparagraph"FIRST" through " SEVENTEENTH" as'if more fully set forth herein, TWENTY-EIGHTH:
That $63 of the Building Zone Ordinance provides that a lot or premises in a Residence "B" District may be used for certain enumerated purposes and no other.
TWENTY-NINTH:
That the use of the structure-tlailer in a Residence B zone as a decontamination unit is not an expressly provided for use.
THIRTIETH:
That in view of the foregoing, because the decontamination structure-trailer use is not expressly _ _ _ _ _ _ - - - _ - - _ _ _ _ _
provided for the defendant LILCO's use as such is deemed to be prohibited and illegal.
AS AND FOR A FOURTH CAUSE OF ACTION THIRTY-FIRST:
That the. plaintiffs repeat and reallege
/
each'and every alleg; tion contained in paragraph "FIRST" through " SEVENTEENTH" as if more fully set forth herein.
THIRTY-SECOND:
That $63 of the Building Zone Ordinance provides that a lot or premises in a Residence "B". District may be used for certain enumerated purposes and no other.
THIRTY-THIRD:
That the use of any property in a Residence "B" District as a. general population reception center for evacuees in the event of a radiological emergency including use as a decontamination and radiological assessment facility is not an expressly provided for use.
THIRTY-FOURTH:
That in view of the foregoing, because the use as an evacuation reception area including radiological assessment and decontamination operations is not expressly provided for defendant LILCO's use as such is deemed to be prohibited is illegal.
AS AND FOR A FIFTH CAUSE OF ACTION j
THIRTY-FIFTH:
That plaintiffs repeat and reallege each and every allegation contained in paragraphs "FIRST" through " SEVENTEENTH" as if more fully set forth herein.
THIRTY-SIXTH:
That $310 of the Building Zone Ordinance l <
L o
meu
,v '
. o.
}.
~~ permits'public utility buildings or structures in any residence or businese district when permitted by the Board of Zoning Appeals.
THIRTY-SEVENTH:
That the defendant LILCO has a Special Exception permit for its entire parcel under Zoning
. Board Case No. 553 of 1961 which permits the " construction and maintenance of an operations headquarter consisting of an. office and assembly room, warehouse, garage, storage-platforms, storage rooms, truck parking, and storage areas"-
to be " constructed.
in accordance with the plot plan received by the Board of Zoning Appeals."
THIRTY-EIGHTH:
That the installation, use, and maintenance of the trailer on any portion of the Bellmore property and the use of any portion of the Bellmore property as a general population reception center for evacuees including radiological assessment and decontamination activities was never presented to nor passed upon by the Board of Zoning Appeals.
THIRTY-NINTH:
That in view of the foregoing, the presence of the trailer-structure and its use as a decontami-nation unit and the use of any portion of the entire premises as an evacuation reception-assessment area all as done by, or permitted by,the defendant LILCO'is beyond the scope of the existing Special Use Permit and as such is illegal.
I
\\
j j'
f 1
.s 1
AS AND FOR A SIXTH CAUSE OF ACTION FORTIETH:
That the plaintiffs repeat and restlege each and every allegation contained in paragraphs "FIRST" through " SEVENTEENTH" as if more fully set forth herein.
FORTY-FIRST:
That $196 of the Building Zone Ordinance provides that a lot or premises in a " Business" District may be used for certain enumerated purposes and no other.
FORTY-SECOND:
That the use of any property in a " Business" District as a general. population reception center for evacuees in the event of a radiological emergency including radiological assessment and decontamination operations is not an expressly provided for use.
FORTY-THIRD:
That in view of the foregoing, the defendant LILCO's use of its business zoned property as general population reception center for evacuees in the event of a radiological emergency including radiological assessment and decontamination operations is not expressly provided for and is deemed to be prohibited and is illegal.
AS AND FOR A SEVENTH CAUSE OF ACTION:
FORTY-FOURTH:
That the plaintiffs repeat and reallege each and every allegation contained in paragraphs "FIRST" through " SEVENTEENTH" and " TWENTY -EIGHTH" as if more fully set forth herein.
FORTY-FIFTH:
That the present use of the subject premises which is in the Residence "B" District and which 9-
"i "
s in'at/way advar.ces, impicments, or prepares for the designated use as a general population reception ares for evacuees by such items as but not being limited to the designation of the Bellmore. site in the emergency response plan, the conducting of a drill or exercise, the storage of supplies or equipment, and the installation and/or the capability to introduce the trailer-structure is not an expressly permitted use.
FORTY-SIXTH:
That in view of tha foregoing, because the present conduct outlined in paragraph " FORTY-FIFTH" is not expressly provided for in a Residence "B" District the defendants' use as such is deemed to be prohibited and is illegal.
AS AND FOR AN EIGHTH CAUSE OF ACTION FORTY-SEVENTH:
That the plaintiffs repeat and reallege each and every allegation contained in paragraphs "FIRST" through " SEVENTEENTH," THIRTY-SIXTH" and " THIRTY-SEVENTH" as if more fully set forth herein.
FORTY-EIGHTH:
That the present use of the subject premises which in anyway advances, implements or prepares for the designated use as a general population reception area for evacuees by such items as but not being limited to the designation of the Bellmore site in the emergency l
response plan, the conducting of a drill or exercise, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ -
- y 7
- 1,.
~
the storage of supplies or equipment, and the installation and/or the capability to introduce the trailer-structure was never presented to nor passed upon by the Board of
]
Zoning Appeals.
j FORTY-NINTH:
That in view of the foregsing, the present conduct outlined in paragraph " FORTY-EIGHTH" is not expressly provided for on the subject premises pursuant-q to the existing Special Use Permit and the defendants'
~
use as suc'h is beyond the scope of the existing Special Use Permit.and as such is illegal.
1 AS AND FOR A NINTH CAUSE OF ACTION FIFTIETH _:
That the plaintiffs repeat and reallege each and every allegation contained in paragraphs "FIRST" through " SEVENTEENTH" and " FORTY-FIRST" as if more fully set forth herein.
]
FIFTY-FIRST:
That the present use of the subject'
, premises which is in the " Business" District and which in.anyway advances, implements or prepares for the designated use as a general population reception area for evacuees by such items as but not limited to the designation of the Bellmore site in the emergency response plan, the conducting of a drill or exercise, the storage of supplies or equipment, and the installation and/or the capability to introduce the trailer-structure is not an expressly 11 -
l
e l
i permitted use.
l FIFTY-SECOND:
That in view of tha foregoing, becauce l
the press ut conduct outlined fu peragraph " FIFTY-FIRST" l
is not exprecely provided for in a " Business" District, I
the defendants' use as such is deemed to be prohibited and is illegal, FIFTY-THIRD:
That the defendants, with knowledge of the aforementioned violations, continue and refuse to cease the illegal operation and use of its premises i
as an evacuation reception area including radiological assessment and decontamination operations.
FIFTY-FOURTH:
That the defendants threaten to continue and do continue to use and operate said premises and maintain said structure in violation of the Building Zone Ordinance and Town Code of the Town of Hempstead, all to the irreparable harm and injury ci the plaintiffs.
FIFTY-FIFTH:
That the plaintiff, Town of Hempstead, is authorized to institute these actions pursuant to the 3
provisions of Section 135 and Section 268 of the Town Law of the State of New York.
FIFTY-SIXTH:
That upon information and belief the acts complained of commenced on or about July 27, 1987, and continue to date.
FIFTY-SEVENTH:
That the plaintiffs have no adequate i
remedy at law for any of the causes of action.
i j
WHEREFORE, the plaintiffs respectfully pray for judgment as follows:
'1.
Permanently restraining and enjoining the. defendants LILCO, any of their officers, agents, servants, employees, successors or assigns or anyone claiming or acting by, through, or under them from using the trailer or permitting the trailer to be used in anyway in violation of the laws
'h and ordinances of the Town of Hempstead.
1 2.
Ordering the defendant LILCO to permanently temove the trailer and utility connections thereto from the subject premises and further ordering the removal from the premises of any other equipment, supplies, or structures relating tc the evacuation - reception - radio-logical tssessment and decontamination uses.
3.
Permanently restraining and enjoining the defendants LILCO, any of their officers, agents, servants, employees, f
successors or assigns or anyone claiming or ccting by, j
through; or under them from using any part of its premises or permitting the premises to be used in any way as a
)
general population reception center for evacuees in the event of a radiological emergency including radiological i
assessment and decontamination operations.
4.
Permanently restraining and enjoining the defendants LILCO, any of their officers, agents, servants, employees, a
i n..n L.'
1:
1 successors, or assigns or anyone claiming or acting by, through-or under them from using any.part of.its premises
~
or. permitting the premises to be.used in'anyway which' advances, implements, or prepares for the designated use as a general polulation reception center for evacuees in the event of a radiological 1' emergency including but not. limited to the conducting of drills or exercises, the storage of equipmerit and supplies, and the installation of and/or the capability to introduce the trailer-structure.
5.
Ordering the defendants to remove the Bellmore Operations Center from its planning documents and further restraining'and prohibiting the defendants from in anyway representing that the present-and proposed reception-evacuation 4
--radiological assessment and decontamination uses are permitted and lawful.
6.
Granting such further and different relief which the Court may deem just ana proper together with the cost and disbursements of this action.
Dated:
Hempstead, New York August'14, 1987 W. KENNETH CHAVE, JR., ESQ.,
Town Attorney and Attorney Plaintiffs Office and P.O. Address, Hempstead Town Hall Town Hall Plaza, Main Street, Hempstead, New York 11550 l
1 _ _ _ _ _
a --
]
s.
L September 14, 1987 l
l l
._7 SD 15 P5 :12 0
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j
1 Before the Atomic Safety and Licensino Board.
i l
I
)
l In the. Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning) i (Shoreham Nuclear Power Station,
)
l Unit 1)
)
)
I i
CERTIFICA7F,OF SERVICE I hereby certify that copies of the SUFFOLK COUNTY, STATE OF NEW YORK, AND TONN OF SOUTHAMPTON PROPOSED FINDING 3 OF FACT AND CONCLUSIONS OF LAW ON THE SUITABILITY OF RECEPTION CENTERS have been served on the following this 14th day of September, 1987 by United States mail, first class, except as otherwise noted.
l Morton B. Margulies, Esquire
- Joel Blau, Esquire Chairman Director Atomic Safety and Licensing Board Utility Intervention United States Nuclear Regulatory New York State Consumer Commission Protection Board Washington, D.
C.
20555 Suite Number 1020 Albany, New York 12210 Dr. Jerry R.
Kline*
William R.
Cumming, EsquirG*
Atomic Safety and Licensing Board Spence W.
Perry, Esquire United States Nuclear Regulatory Office of the General Counsel Commission Federal Emergency Management Washington, D.
C.
20555 Agency 500 "C"
- Street, S.
W.
Room Number 840 Washington, D.
C.
20472 l
Mr. Frederick J.
Shon*
Anthony F.
- Earley, Jr.,
Esquire
)
Atomic Safety and Licensing Board General Counsel United States Nuclear Regulatory Long Island Lighting Company l
Commission 175 East Old Country Road Washington, D.
C.
20555 Hicksville, New York 11801 J
-n c
l Q
Ms. Elisabeth Taibbi W.
Taylor Reveley, III, Esquire
- Hunton and Williams Clerk Suffolk County Legislature Post Office Box 1535 l
Suffolk County Legislature 707 East Main Street i
Office Building Richmond, Virginia 23212
]
Veterans Memorial Highway Hauppauge, New York 11788 Mr.
L.
F.
Britt Stephen B.
Latham, Esquire
- Long Island Lighting Company Twomey, Latham and Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Rivarhead, New York 11901 Docketing and Service Section Ms. Nora Bredes Wading River, New York 11792 Executive Director Office of the Secretary Shoreham Opponents Coalition United States Nuclear Regulatory Smithtown, New York 11787 Commission 1717 "H" Str'eet, N. W.
I Washington, D. C.
20555 Mary M. Gundrum, Esquire Honorable Michael A. LoGrande New York State Department of Law Suffolk County Executive 120 Broadway H.
Lee Dennison Building Third Floor Veterans Memorial Highway Room Number 3-116 Hauppauge, New York 11787 New York, New York 10271 MHB Technical Associates Dr. Monroe Schneider 1
1723 Hamilton Avenue North Shore Committee Suite "K" Post Office Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esquire Fabian G.
Palomino, Esquire j
Suffolk County Atto'rney
-Richard J.
Zahnleuter, Esquire **
{
Building Number 158 Special Counsel to the Governor j
North County Complex of the State of New York Veterans Memorial Highway Executive Chamber
)
Hauppauge, New York 11788 Room Number 229 Capitol Building j
Albany, New York 12224 j
Mr. Jay Dunkleburger Richard G.
Bachmann, Esquire
- New York State Energy Office United States Nuclear Regulatory Agency Building Number Two Commission Empire State Plaza Washington, D. C.
20555 Albany, New York 12223 i 4 m___________
, pb l
.s 1
David.A.:Brownlee, Esquire Mr..Stuart Diamond KIRKPATRICK.& LOCKHART Business / Financial' 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania-15222 229: West 43rd Street l
New York, New York 10036 Mr. Douglas'J. Hynes Councilman.
Town Board of Oyster Bay Town Hall
' Oyster Bay, New York 11771 1
I
~
1 Qek s
Ty
^
i Ronald R. Ross KIRKPATRICK & LOCKHART 1800 "M" Street,.N.
W.
South Lobby - Ninth Floor
'l Washington, D..C.
20036-5891 AVia. Hand Delivery
- Via Federal Express
'l September.14, 1987 i
i i
i e
1 =--:-__-________-