ML19225A267

Responds to I Like 790606 Ltr Requesting NRC Require Util to Study Feasibility of Converting to Conventional or Alternative Fuel.Request Was Improperly Formed & Addressed. Certificate of Svc Encl

ML19225A267
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/21/1979
From:	Reveley W LONG ISLAND LIGHTING CO.
To:
References
NUDOCS 7907180718
Download: ML19225A267 (3)

Text

6/21/79

' N' '*

NRC PUBLiL' UUCUyguT Rooy d7 27 4[$o N 1% -

UNITED STATES OF AMERICA p ,

@ NUCLEAR REGULATORY COMMISSION

• l.'b n A

b \ 3efore the Atomic Safety and Licensinz Board a

m In the Matter of )

)

LONG ISLAND LIGFTING COMPANY ) -

Decket sJo. 20-32,,

)

(Shoreham Nuclear Power Station, )

Unit 1) )

APPLICANT'S REPLY TO MR. LIKE'S LETTER OF JUNE 6, 1979 Mr. Like has presented a request from tae Suffolk County Legislature "that the Nuclear Regulatory Coccission require that the Long Island Lighting Cocpany conduct a study of the feasibility and cost of converting the Shoreham Electric Generat-ing Station [ sic] from nuclear to conventional or alternative fuel." Letter frca Irving Like to Elizabeth S. 3cwers, June 6, 1979. The request is aisdirected.

In his letter, Mr. Like nade no effort to explain why Mrs. 3cwers (cr the 3 card as a whole) has authority Oc crder that the study in question be conducted. No related issue is pending before the 3 card. Even if there were such an issue, each party wculd renain free to shape i:s own response.

In any event, all that Mrs. Ecwers has received in a letter, not a notien requesting tha: the 3 card actually de n

cee. ' 7/3

. . something. As a lawyer who has practiced extensively at the NRC bar, Mr. Like knows that (a) , when an ASL3 's j urisdiction is not clear, you address the issue and (b) , when you want an ASLB to act, you file a =otion. His disregard of these re-quire =ents is telling.

The County Legislature would have been better served had Mr. Like recoc= ended that it approach the Applicant directly about the desired study. LILCO is presently analyzing the feasibility and cost of converting Shoreham frca nuclear to coal generation. The Company will be happy to nake its find-ings available to the Legislature.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY W.

kY Tayloy Reveley, III Ok Eunten 5, Williams -

707 Iast Main Street P. O. Ecx 1535 Rich =cnd, Virginia 23212 D.s.a -la :

June v., --

,1/9 345 080

nr

// QTh$

-- ,913 7 In the Matter of N ~

LONG ISLAND LIGHTING COMPANY epYdJ (Shorehan Nuclear Power Station, Unit 1) t Docket No. 50-322  %, y CERTIFICATE OF SERVICE I hereby certify that copies of APPLICANT'S REPLY TO MR.

LIKE'S LETTER OF JUNE 6, 1979 were served upon the following by first-class = ail, postage prepaid, on June 21, 1979.

Elizabeth S. Bowers, Esq. Richard K. Hoefling, Esq.

Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Co=nission U. S. Nuclear Regulatory Cocaission Washington, D. C. 20535 Washington, D. C. 20555 Jeffrey C. Cohen, Esq.

Dr. Oscar H. Paris New York State Energy Office Atomic Safety and Licensing Swan Street Building, Core 1 Board Panel Empire State Plaza U. S. Nuclear Regulatory Cocsission Albany, New York 12223 Washington, D. C. 20555 Howard L. Blau, Esq.

Mr. Frederick J. Shon 217 Newbridge Road Atomic Safety and Licensing Hicksville, New York 11801 Board Panel U. S. Nuclear Regulatory Cocsission Irving Like, Esq.

Washington, D. C. 20555 Reilly and Like 200 West Main Street Secretary of the Coc=ission Babylon, New York 11702 U. S. Nuclear Regulato: f Commission Washington, D. C. 20555 Ralph Shapiro, Esq.

Ca=ner and Shapiro, P.C.

Acccic Safecy and Licensing 9 East 40th Street Appeal Board New York, New York 10016 U. S. Nuclear Regulatory Cocsissirn Washington, D. C. 20555 Mr. Marc W. Golds =1th Energy Research Group, Inc.

AC )cic Safety and Licensing 4CO-1 Totten Pond Rcad Joard Panel Waltham, Y2ssachusetts 02154 U. 6 Nuclear Regulatory Co-~4ssion Washington, D. C. 20555 l -

/@M n W. Taylo/r Reveley, III DATED: June 21, 1979 345 081

6/21/79 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinz Board In the Matter of )

)

LONG ISLAND LIGFTING COMPANY ) Docket No. 50-32.9

)

(Shoreham Nuclear Power Station, )

Unit 1) )

A??L.'. CANT' S REPLY TO MR. LIRE ' S LET"'ZR OF JUNE '; . 1979 Mr. Like has presented a request from the Suffolk County Legislature "that the Nuclear Regulatory Cocmission require that the Long Island Lighting Cc=pany conduct a study of the feasibility and cost of convertirg the Shoreham Electric Generat-ing Station [ sic] from nucleur to conventional or alternative fuel." Letter frca Irving Like to Elicabeth S. Bowers, June 6, 1979. The request is misdirected.

In his letter, Mr. Like made no effor to e:glain why Mrs. Bowers (or tile 3 card as a whole) has authority to order tha: the study in questien be conducted. No related issue is pending before the 3 card. Even if there were such an _ssue, each party would renain free :o shape its own res; case.

In any event, all that Mrs. 3cwers has received is a letter, not a notien requesting tha: the Snard actually do 345 082

something.  !.s a lawyer who has practiced extensively at the NRC bar, Mr. Like knows that (a) , when an ASL3 's j urisdiction is not clear, you address the issue and (b) , when you want an ASL3 to act, you file a cotion. His disregard of these re-quire =ents is telling.

The County Lcgislature would have been better served had Mr. Like recocnended that it approach the Applicant directly about the desired study. LILCO is presently analyzing the feasibility and cost of converring Shoreham from nuclear to coal generation. The Cocpany will be happy to =ake its find-ings available to the Legislature.

Respectfully submitted, LONG ISLAND LIG"dTING COMPANY W. Taylcy Reveley, III M

Eunton & Willia s 707 East Main Street

?- O. Box 1335 Rich =cnd, Virginia 23212 DATID: June 21 1979 345 083

In the Matter of LONG ISLAND LIGHTING COM?ANY (Shorehan Nuclear Power Stacion, Unit 1)

Docket No. 50-322 CERTIFICATE OF SERVICE I hereby certify that copies of APPLICANT'S REPLY TO MR.

LIKE'S LETTER OF JUNE 6,1979 were served upon the following by first-class cail, postage prepaid, on June 21, 1979:

Elizabeth S. Bowers, Esq. Ric.ard K. Hoefling, Esq.

Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Coc=ission U. S. Nuclear Regulatory Cocmission Washington, D. C. 20555 Washington, D. C. 20555 Jeffrey C. Cohen, Esq.

Dr. Oscar H. Paris New York State Energy Office Atomic Safety and Licensing Swan Street Building, Core 1 Board Panel E=pire State Plaza U. S. Nuclear Regulatory Com 4ssion Albany, New York 12223 Washington, D. C. 20555 Howard L. Blau, Esq.

Mr. Frederick J. Shon 217 Newbridge Road Atomic Safety and Licensing Hicksvil?.e, New York 11801 3 card Panel U. S. Nuclear Regulatory Coc=ission Irving Like, Esq.

Washington, D. C. 20555 Reilly and Like 200 West Main Street Secretary of the Co= mission Ba'oylon, New York 11702 U. S. Nuclear Regulatorv Co= mission Washington, D. C. 20555 Ralph Shapiro, Esq.

Car er and Shapiro, P.C.

Arecic Safety . d Licensing 9 East 40th Stree:

Appeal Board New York, New York 10016 U. S. Nuclear Regulatory Coccission Washington, D. C. 20555 Mr. Marc W. Golds =i:h E"arzv Research Group, Inc.

Atocic Safety and Licensing 400-1 Tot:en Ponc Rc.d Socrd Panel Wal: ham, Massachuset:s 02154 U. S. Nuclear Regulatory Coc=ission Washington , D. C. 20535

/ <2V /4'5' ._

W. Taylo,r Revele;, III DnTED: June 21, 1979 345 084

6/21/79 UNITED STATES OF MERICA NUCLEAR REGULATORY COMMISSION 3efore the Atomic Safety and Licensinz Board In the Matter of )

)

LONG ISLAND LIG'dTING COMPANY ) Docket No. as-32.9

)

(Shoreham Nuclear Power Station, )

Unit 1) )

APPLICANT'S REPLY TO MR. LIKE'S LETTER OF JUNE 6, 1979 Mr. Like has presented a request from the Suffolk County Legislature "that the Nuclear Regulatory Coccission require that the Long Island Lighting Company conduct a study of the feasibili:y and cost of converting the Shoreham Electric Generat-ing Station [ sic] from nuclear to conventional or alternative fuel." Letter from Irving Like to Elizabeth S. Bowers, June 6, 1979. The request is nisdirected.

In his letter, Mr. Like nade no effort to explain why Mrs. 3cwers (or the Scard as a whole) has au:hori:7 to order that the study in question be conducted. No rela:ed issue is pending before the 3 card. Even if there were such an issue, eacn party would renain :ree to shape its own response.

In any event, all that Mrs. 3cwers has received is a le: er, no a notion reques:ing tha: the Board ac:ually do 345 085

something. As a lawyer who has practiced extensively at the NRC bar, Mr. Like knows that (a) , when an ASL3 's j urisdiction is not clear, you address the issue and (b), when you want an ASL3 to act, you file a =otion. His disregard of these re-quirements is telling.

The County Legislature would have been better served had Mr. Like recoc= ended that it approach the Applicant directly about the desired study. LlLCO is presently analyzing the feasibility and cost of converting Shoreham from nuclear to coal generation. The Cocpany will be happy to =ake its find-ings available to the Legislature.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY ds/ W W. Tayloy Reveley, III 4

Hunton & Willim-s 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 DATED: June 21, 1979 345 086

In the Matter of LON ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 CERTIFICATE OF SERVICE I hereby certify that copies of APPLICANT'S REPLY TO MR.

LIKE'S LETTER OF JUNE 6, 1979 were served upon the following by first-class = ail, poscage prepaid, on June 21, 1979:

Elizabeth S. Bowers, Esq. Richard K. Hoefling, Esq.

Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Co=nission U. S. Nuclear Regulatory Co-~4 ssion Washington, D. C. 20555 Washington, D. C. 20555 . --

sq.

Je:: rey C. Co.nen, Dr. Oscar H. Paris New York State Energy Office Atomic Safety and Licensing Swan Street Building, Core 1 Board Panel E=cire State Plaza U. S. Nuclear Regulatory Commission Albany, New York 12223 Washington, D. C. 20555 Howard L. Blau, Esq.

Mr. Frederick J. Shon 217 Newbridge Road Atomic Safety xad Licensing Hicksville, New York 11301 Board Panel U. S. Nuclear Regulatory Cocsission Irving Like, Esq.

Washington, D. C. 20555 Reilly and Like 200 West Main Stree:

Secretary of the Co=nission Babylon, New York 11702 U. S. Nuclear Regulatory Co _.ission Washington, D. C. 20555 Ralph Shapiro, Esq.

Cancer and Shapiro, P.C.

Acccic Safety and Licensing 9 East 40:h Stree:

Appeal Board New York, New York 10016 U. S. Nuclear Regula: cry Cocnissicn Washing:cn, D. C. 20555 Mr. Marc W. Goldsci:P Energy Research Group, Inc.

A:ccic Safety and Licensing 400-1 Totten Pend Road Board Panel Walthan, Massachuse::s 02154 C. S. Nuclear Regula: cry Cocnission Washing:cn, D. C. 20555

,/ ,/

'l@ M W. Taylor Reveley, III

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3.1/c, 345 087