ML20154L230
| ML20154L230 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/16/1988 |
| From: | Matt Young NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#388-7127 OL-3, OL-5, NUDOCS 8809260126 | |
| Download: ML20154L230 (19) | |
Text
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UNITED ST ATES OF AMERIC A NUCLE AR REGUL ATORY C O MMIS SIO N
'M SEP 22 P 2 :21 B E FO R E T H E, A T O MIC S A F E T Y _ A N D LIC E N SIN G A PPE A L B O'A R D, In the Matter of LONG ISL AND LIGHTING COPP Ah Y D oc ket tio. 50-322-O L-5
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(EP Exercise)
(Shoreham Nuclear Power Station,
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)
1: R C S T A F F R E S P O N S E T O I fl T E R V E N O R S' MOTION FOR APPOINTMENT OF LIC E tiSIN G B O A R D T O H E A R 1988 E X E R CISE R E S UL T S Fitzi A. Y ou n g C ou n sel for NRC Staff ScMember 16, 1988 h!k 00 2
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UNITED ST ATES OF AMERIC A NUCLE AR REGUL ATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BO ARD 4
In the Matter of LONG ISL AND LIGHTING COMP ANY
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Docket No. 50-322-OL-5 (Shoreham Nuclear Power Station, Unit 1)
)
f!R C S T A FF R ESPO NSE T O IN T E R V E N O R S' MOTION FOR APPOINTMENT OF LIC E NSIN G S 0 A R D T O H E A R 1988 E X E R CISE RES ULT S Pit:1 A. Young C ou n sel for NRC Staff Septem ber 16, 1988
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION m
BEFORE THE ATOMIC SAFETY, AND LICENSING APPEAL BOARD Ir. the Matter of LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-5 (EP Exercise)
(Shoreham Nuclear Power Station, Ur.it 1)
NRC STAFF RESPONSE TO INTERVENORS' MOT!0N FOR APPOINTMENT OF L!C.ENSING BOARD TO HEAR 1988 EXERCISE RESULTS
- 7. INTRODUCTION By motion dated September 9,1988 ar.d filed before the Licensing Board in the OL-3 proceeding, the Staff requested that a schedule be established for litigation of the results of the June 7-9, 1988 Shoreham emergercy pla.nning exercise. NRC Staff Potion for Schi ule for Litigation
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of Jure 198P. Exercise ("Staf f Motion").
On September 13,198P, Suffolk County, the State of New York.md Town of Southampton ("Intervenors")
filed e rnotion before the Appeal i. 3rd requesting that the Appeal Board "direct the Chairman of the atomic Safety and Licensing Board Panel to converr a Licensing Board with jurisdiction to hear issues related to LILCO's latest exercise."
Suffolk County, State of New York and Town of Southampton Motion for Appointment of Licensing Board with Jurisdiction TO Fear Exercise Issues ("Motie:.').
For the reasons stated below, the Appeal Board should deny the Potian, i
II. DISCUSSION Intervenors argue th6t the Appeal Board in this OL-5 proceeding has jurisdiction aver exercise-related ratters because (1) "the creation of
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[the OL-53 Board had the effect of divesting the previously existing Shorehan energency planning Licensing Board (the "0L-3 Licensing Board")
i of jurisdiction over exercise-related matters" and (2) appeals from the rulings of the OL-5 Licensing Board, which "was established for the express purpose of considering exercise-related matters," place exercise-related tratters before the Appeal Board. Motionat1-2.1/
Contrary to Intervenors' belief, the OL-5 proceeding Doard was not created to hear all pending and future exercise-related matters.
On 3
May 11, 1983, the Chairman of the Atomic Safety and Licensing Board (ASLB)
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Panel constituted the OL-3 Board in Shoreham 'to preside over the p
proceeding on all emergency planning issues."
Establishment of Atomic Safety 'and Licensing Board to Preside in Proceeding, May 11, 1983 ("May l
f 11, 1983 Appointrent")(Attachtrent 1). 2/ The Commission in CL1-86-11, 23 NRC 577, 579 (1986), directed that a hearing be conducted on the exercise l
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which had been held on February 13, 1986.
In their motions that gave rise i
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It is not clear that the Appeal Board has either the authority to act I
on, or the jurisdiction to consider, the Motion. Under Part ? of the J
Commissions Rules of Practice, licensing boards are established or recenstituted only b the Comission or the Chairman (or Chief Administrative Judge) yof the Atomic Safety and Licensing Board Panel.
_E.g., 10 C.F.R. Il 2.104(d)(2), 2.704(a), 2.717(a), 2,721, see also 10' C.F.R. Part 2. Appendix A.
While the Comission's rules provide that the Appeal Board is "authorized to exercise the authority and
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perfom the review fune.tions which would otherwise have been exercised end perforned hv the Commission," 10 C.F.R. I 2.705, it would apaar that the supervisory function of establishing licensing i
boards t ould require a specific delegation from the Comission.
See 10 C.F.R. 55 2.785(c), 2.787.
2/
The order states that the OL-3 Board was constituted at the request t
of the licensing board presiding over the Shoreham operating license
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proceeding and pursuant to the Comissien's notice for opportunity l
l for hearirg on the Shoreham operating license 3pplication, 41 Fed.
Reg. 11367-68 (March 18, 1976),
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4 to CLI-E6-11, Intervenors and LILCO only suggested that procedures relevant to litigation of the results of the February 1986 exercise be prescribed. See Motion of Suffolk County, the State of New York, and the Town of Southampton for Ruling Concerning Proceedings Related to the..
I Shoreham Exercise, March 7, 1986, at 1, 2; Long Island Lighting Company's Motion for Establishment of Licensing Board and Institution of Expedited e
Procedures for Litigation of Shoreham Emergency Planning Exercise issues, And Response to Intervenors' March 7,1986 "Motion Concerning Proceeding Relating to the Shoreham ixercise," March 13, 1986, at 1, 10 ("LILCO Motion for ASLB Fanel").
There is nothing in CLI-86-11 to suggest that l
the Comission was requesting that a proceeding be instituted to consider any matter other thin the specific matters raised by the motiens which only involved the February 13,, 198G exercise.
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ibe Chairman of the ASLB Panel clearly indicated that the CL-5 Board l
was established for that limited purpose.
The OL-3 Board was first designated pursuant to the provisions of CLI-86-11 "regarding motions from the Applicart and Intervenors concerning litigation of emergency planning l
l exercise results."
Establishment of Atomic Safety and Licensing Board
[0L-3), June 10, 1988, at 1 (J. Cotter) (Attachtrent ?).
At that time, there was only one exercise and the order could thus have referred only to the February 13, 1986 exerrise which was addressed in CLI-86-11.
Subsequently, ASLB Panel Chairman assigned litigation of the 1986 exercise proceeding a new docket number "[fjor nore effective docket management."
Change of Docket Nurber, July 24, 1988 (J. Cotter) (Attacheent 3).
The
, 'OL.5 Licensing Boa'rd was later recons'tituted 2/ and it was clear that the Board as reconstituted would preside "only on the proceedings ir.itiated pursuant to Commission Order, CLI-86-11, 23 NRC 577 (1986),"
that is, the February 1986 exercise.
Notice of Reconstitionfof Board:
l Clarification, October 17, lo86 (J.
Cotter)
(Attachment 5); Suffolk County and State of New York Motion to Rescind Reconstitution of' Board by Chief Administrative Judge Cotter (Shoreham Nuclear Power Station.
Unit 1), LBP-86-37A, 24 NRC 726, 727 (1986).
As ' stated in LBP-86-37A, the OL-3 docket concerned all other emergency planning issues, "namely:
(1) the adequacy o' the entire emergency plan remanded by the Comission; (2) issues remanded by the Appeal Board; and (3) new motions to reopen the record on several other issues." 24 NRC at 727.
Thus it is clear that the OL-5 proceeding was not instituted to consider ary end all exercise hearings, but only matter specifically relevant to the February 13, 1986 exercise. S/
Rather, the OL-3 and OL-5 phases of the Shorenan operating license proceeding were to expedite litigation over Shoreham consistent with the Comission's Stiterent of Policy,on Conduct of Lice,n, sing Proceedines, 13 NRC 452 I.
i 3/
Notice of Reconstitution of Board (October 7, 1986) (J. Cotter)
(Attechment 4).
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The OL-5 Board also recognized that there were limits on its juris-
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diction.
The OL-5 Board viewed its delegatien from the Comission was only to hold an expedited hearing and issue a d? cision on whether l
the February 13, 1986 exercise revealed fundamental flaws.
Memorandum and Order (Concerning Retention of Jurisdiction),
LBP-E7-7, 27 NRC 289, 291 (1988).
The Board did not believe it was given the authority to make a finding of recsonable assurance.
Jfd.
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, (1981).
Therefore, the OL-3 Board should preside over litigation of the 1988 exercise. 5,/
!!!. CONCLUSION i
The Appeal Board should deny the instant motion to designate a
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licensing board to preside over litigation of the 1988 exercise since, under the May 11, 1983 designation, the OL-3 Licensing Board has jurisdiction to consider matters stemming from the June 7-9, 1988 emergency planning exercise.
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Respectfully submitted, j
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Mitz
. Young Counsel for NRC Staff Dated at Rockville, Maryland this 16th day of September,1988 l
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The referral of possible future litigation on the 1988 exercise to i
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another Board would most likely delay the ultimate resolution of the emergency planning issues in Shoreham.
The OL-3 Board has before it all remaining admitted issues concerning the adequacy of emergency planning for Shoreham and, as a result, is cognizant of various revisions to the LILCO Plan.
In light of the amendment of the Comission's emergency planning rule (52 Fed. Reg. 42080, November 3, 1987) and considerations of judicial economy, the 1988 exercise should be evaluated in conjunction with the consideration of the adequacy of state and local government best-efforts responses. Thus, the OL-3 Board is best suited to preside over litigation of the 1988 exercise.
l If the Appeal Board determines that the OL-3 remanded emergency planning issues do not encompass matters raised by the recent full-scale
- exercise, see Carolina Power & Light Co.
(Shearon Harris l
Nuclear Power Plant', TJnits 1-4), ALAB-526, 9 NRC 122,124 n.3 (1979),
I or that it has jurisdiction to grant Intervenors'
- Motion, Duke Power Co.
(Perkins Nuclear
- Station, Units 1, 2,
and 3),
l ALAB-591, ll'NRC 741, 742 (1980), the licensing board should consist of the OL-3 Board members because that Board is charged with evaluating the adequacy of the LILCO emergency plan in accordance
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with the Realism Rule.
If the Appeal Board detennines that it has neither jurisdiction nor authority, it should refer this rnatter to the Comission.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
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LONG ISLAND LIGHTING COMPANY
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[DocketNo.50-322-OL-3]
[ASLBPNo. 83-488-03OL]
a ESTABLISHMENT:0FdTOMICSAFETYANDLICENSINGBOARD TO PRESIDE IN PROCEEDING Pursuant to delegation by the Comission. dated December 29, 1972, published in the Federal Register, 37 F.R. 28710 (1972), and Section:
2.105, 2.700, 2.702, 2.714, 2.714a, 2.717 and 2.721 of the Comission's Regulations, all as amended, and pursuant to the Statement of Policy on Ccnduct of Licersing Proceedings, 13 N.R.C. 452 (1981), and the request of the Atomic Safety and Licensing Board already established to preside in this operating license proceeding, a separate Atomic Safety and Licensing Board is being established to preside over the proceeding on all emergency planning issues:
LONG !$ LAND LIGHTING COMPANY Shoreham Nuclear Power Station, Unit 1 Construction Pemit No. CPPR-95 This Board is being constituted pursuant to a notice published by the Co,=ission or March 18, 1976 in the Federal Register entitled, "Receipt of Application for Facility Operating i.icense, Availability of Applicant's Environmental Report; Consideration of Issuance of Facility w
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2 Operating License; Oppertunity for Hearing." 41 Fed. Reg, 11367-68 (1976).
The Board is comprised of the following Administrative Judges:
James A. Lat renson, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington. 0.C.
20555 Dr. Jerry R. Kline Atemic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. M. Stanley Livingston 1005 Calle Largo Santa Fe, New Mexico' 87501 I
i ji s B. Paul Cotter, Jr.
Chief Administrative Judge i
Atomic Safety and Licensing t
Board Panel 4
Issued at Bethesda, Maryland.
this llth day of May, 1983.
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UNITED STATES OF A"ERICA
.lVCLEAR REGULATORY COMH!SSION I
P LONG ISLAND LIGHT!hG COMPANY r
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(Ast,BP No. 86-533-01-OLJ P
I ESTABL!SHMENT OF ATOMIC SAFETY AND LICENSING BOARD I
Pursuant to delegation by the Comissioe. dated December 29, 1972, published in the Federal Register, 37 F.R. 28710~(1972), and Sections t
2.1C5, 2.700, 2.702. 2.714, 2.714a 2.717 and 2.721 of the Cocrission's t
Regulations, all es amended, an Atomic Safety and Licensing Board is being established..
following proceeding:
i t.ONG ISLAND LIGHTING COMPANY I
Shoreham Nuclear Power Station. Unit 1
(
f Construction Pemit No. CPPR 95 i
This Atomic Safety and Licensing Board is being designated pursuant to the provistor.s of a Memorandum and Order issued by the Comission on
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t June 6, 1986 regarding motions from the Applicant and Interver. ors i
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concerning litigation of emergency planning exercise results.
i CLI-86-11, 23 hRC _ (1986).
In its Order the Comission directed the I
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irradiate initiation of the exercise hearing to consider evidence which t
Intervenors might wish to of fer to show that the e is a fundacental flaw I
in Applicant's eFergency plan.
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s_a The Board is corprised of the following Administrative Judges:
Morton B. Margulies, Chairran Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Jerry 0.. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Frederick J. Shon Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comission Washington. 0.C.
20555 31/ d#r z
. F ul Cotter, r.
Chief At-inistrative Judge Atomic Safety and Licensing Board Panel Issue: at Beti asda, %ryland, this 10th day of June, 1955.
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NUCLEAR REGULATORY COMMISSION u-LONG ISLAND LIGHTING COMPANY Shoreham Nuclear Power Station Unit 1 (EP Exercise)
(DocketNo.50-322-OL-5)
[ASLBPNo. 86-533-01-OL]
'HANGE OF DOCKET NUMBER i
Ir response to motions filed by Applicant and Intervenors in Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), Occket No. 50-322-OL-3 the Comission, in a Memorandum and Order, CLI-86-11, 23 NRC 1986, issued June 6,1986, directed the imediate initiation of the exercise hearing to consider evidence which Intervenors might wish to offer to show that there is a fundamental flaw i
in Applicant's emergency plan.
The Atenic Safety and Licensing Board Panel, by Order of June 10, 1986, designated an Atomic Safety and Licensing Board to preside in this l
matter, which continued to bear Docket No. 50-322-OL-3, issued for the emergency planning proceeding. For more effective docket management, it is necessary to assign a new docket nunber for this phase of the application proceeding.
It is hereby ortiered that the docket nunber to O)
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be used henceforth for the proceeding instituted by the Comission on June 6,1985,isOccketNo.50-322-OL-5(EPExercise),
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)- (hv B. Paul Cotter, Jr Chief Administrative Judge Atomic Safety and Licensing Board Panel Issued at Bethesda, Maryland, this 24th day of July, 1986.
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4 McMnM Y UNITED STATES OF AMERICA NUCLIAR REGULATORY COMMISSION LONG ISLAND LIGHTING COMPANY Shoreham huclear Pcwer Station, Unit 1 (EPExercise)
(Do:ketNo.50-322-OL-5)
)
(ASI.8PNo.86-53401-OL)
NOTICE OF RECONSTITUTION OF BOARD 6
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Pursuant to the authority centained in 10 CFR ll 2.721 ano j
2.721(b). the Atonic Safety and Licensing Board for Long Island Lighting Company (Shoreham Nuclear Pewer Station, Unit 1), Docket No.
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50-322-OL-5, is hereby reconstituted by appointing Adninistrative Judge l
John H Frye, !!!, in place of Actinistrative Judge Morton B. Margulies I
and Administrative Judge Oscar H. Paris in place of Administrative Judge Jerry R. Kline because o' schedule conflicts. Administrative Judge John H Frye is anointed Chaiman of the Board, g
i As reconstituted, the Board is comprised of the follcwing
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Administrative Judges:
John H Frye, !!!, Chaiman j
Oscar H. Faris I
Frederick J. Shen I
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All correspondence, documents and other material shall be filed with the Board in accordance with 10 CFR I 2.701 (1980). The addresses of the new Board members are:
t Administrative Judsc John H Frye, !!!, Chairrr.an Atceic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Administrative Judge Oscar H. Paris Atomic Safety and Licensing Board l
U.S. Nuclear Regulatory Comission Washington, D.C.
20555 i
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B. Paul Cotter, Jr. /
Chief Administrative Judge Atomic Safety and Licensing i
Board Panel J
Issued at Bethesda, Maryland, i
this 7th day of October,1986.
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NUCLEAR REGULATOR) C M ISSION
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LONG ISLAND LIGHT!hG COMPANY
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Shoreham Nuclear Power 5tation, Unit 1 (EP Exercise)
(DocketNo. 50-322-01.-5)
(ASLBPho. 86-534-01-OL)
W NOTIClorAECONSTITUTIONOFBOARD:
CLARIFICATION By notice dated October 7,1986, the Atomic Safety and Licensing Board presiding in Long 1 i nd Lighting Company (Shoreham Nuclear Power i
Station, Unit 1), Oceket No. 50-322-OL-5 was reconstituted. Because of the multiple issues pending in this proceeding, there has been some l
confusion us to the intended scope of the reconstitution.
This is to ciarify that the reconstituted Board comprised of John H Frye, !!!, Chairman; Oscar H. Paris; and Frederick J. Shon will preside only in the proceedings related to the erergency planning exercise.
which are being heard under Docket No. 50-322-OL-5 (Emergency Planning inercise).
These proceedings were initiated pursuant to Comission L
l order, CL1-86-11, 23 hRC 577 (1986).
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The Board comprised of Morton B. M+rgulies Chatman; Jerry R.
Aline; and Frederick J. Shon will continue to preside in all othtr l-proceedings pertaining to emergency planning for the Shereham Nuclear Pcwer Station, which are being heard under Docket No. 50-322-OL-3 I.
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(Emergency Planning). These include issues remanded by the Corenisstor.-
l in CL1-83-13, 23 NRC___(July 24,1986) and by the Atomic Safety ar.d LicensingAppealBoardinALAB832,23NRC135(1986) and ALAB.847, 23 NRC___(September 19,1986).
e A4/dced
'B. P491 Cotter Jr. //
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4 Chief AdniinistrativvJudge Atomic $3fety and Licensing Board Panel Issued at Bethesda, Maryland, this 17th day of October,1966, e
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L UNITED STATES OF AMERICA U{[~
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY, AND LICENSING APPEAL BOA % EP 22 P2:21 Ir. the Matter of
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.DocketNo.50-32b$h[ikf LONG ISLAND. LIGHTING COMPANY (EPExercise)
(ShorehamNuclearPowerStation.
Unit 1)
CERTIFICATE OF SERVICE 1 hereby certify that copies of "NRC STAFF RESPONSE TO INTERVENORS' MOT 10h FOP APPOINTPENT OF LICENSING B0am TO HEAR 1988 EXERCISE RESULTS" in the above-captioned proceeding were served on the following by deposit in the United States mail, fir!.t class or, as ind:cated by an asterisk, through Jeposit in the Nuclear Regulatory Comission's internal mail system, as indicated by double asterisk, by telecopier, this 16th day of Septenber 1988.
Christine N. Kohl, Chairman
- Joel Blau Esq.
Administrative Judge Director. Utility Intervention Atomic Safety and Licensing Appeal Suite 1020 Beard 99 Washington Avenue U.S. Nuclear Regulatory Comission Albany, NY 12210 Washington DC 20555 Fabian G. Palomino. Esq.**
Alan A. Rosenthal*
Special Counsel to the Governor Administrative Judge Executive Chamber Atomic Safety ind Licensing Appeal State Capitol Board Albany NY 12224 U.S. Nuclear Regulatory Commission Washington, DC 20555 Jonathan D. Feinberg Esq.
New York State Department of Dr. W. Reed Johnson
- Public Service Administrative Judge Three Empire State Plars Ateeic Safety and Licensing Board Albany NY 12223 board U.S. Nuclear Regulatory Comissier W. Taylor Reveley !!!. (sq.
Washington, DC 20555 Donald P. Irwin. Esq.**
Hunton & Williams Philip McIntire 707 East Main Street Federal Emergercy Manager.ent P.O. Box 1535 Agency Richmond VA 23212 26 Federal Plaza Room 1349 New York NY 10278
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Stepher B. Latham Esq.
Herbert H. Brown. Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher Esq.**
Attorneys at Law Karla J. Letsche Esq.
33 West Second Street Kirkpatrick & Lockhart Riverhead NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atocic Safety and Licensing Vashington, OC 20036-5891 BoardPanel(1)*
U.S. Nuclear Regulatory Comistict:
Jay Dunkleberger Washington, DC 20555 New York State Energy Office Agency Building 2 Atomic Safety and Licensing Empire State Plaza Appeal Parel (8)**
Albany, NY 12223 U.S. Nuclear Regulatory Comission Wcshington, DC 20555 Dr. W. Reed Johnson 115 Falcon Drive Colthurst l
Martin Bradley Ashare, Esq.
Charlottesville, VA 22901 Suffolk County Attorney H. Lee Dennison Building Ms. Nora Bredes Veteran's Perorial Highway Shoreham Opponents Coalition Hauppauge, NY 11700 195 East Main Street Smithtown, NY 11787 Arthony F. Earley, Jr.
General Counsel Barbara Newman Lerg Island Lighting Company Directo* Environmental Health 175 East Old Country Road Coalitioit for Safe Living Hicksville, NY 1180; Box 944 Huntington, New York 11743 Dr. Monroe Schneider North Shore Comfitee Alfred L. Nardelli, Esq.
P.O. Box 231 New York State Department Wading River, NY 11792 of Law 120 Broadway William R. Cuming, Esq.
Room 3-118 Office of General Counsel New York, NY 10271 l
Federt.1.Energency Panagement Agency l
500 C Street SP l
Washington, DC 20472 Dr. Rotert Hoffnen Long Island Coalition for Safe Living i
P.O. Box 1355 i
Massapequa, NY 11758 1'
Docketing and Service Section*
l Office of the Secretary l.
U.S. Nuclear Regulatory Comission l
Washington, DC 20555 l
D(.2/nm tzi A.
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Couns for NRC Staff I
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