ML19261A651

Motion for Time Extension Until 790207 to Reply to Applicant Request for Summary Disposition of Suffolk County,Ny, Contentions Dtd 781218.Extension Sought Due to Length & Complexity of Pleading.W/Certificate of Svc Encl

ML19261A651
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/28/1978
From:	Like I SUFFOLK COUNTY, NY
To:
References
NUDOCS 7902050284
Download: ML19261A651 (5)

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BEFORE THE ATOMIC SAFETY A'ID LICE! SING

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docl:et No. 50-322

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(Shoreham Nuclear Power Station, )

Unit 1) )

MOTION FOR TIME EXTENSION TO REPLY TO " APPLICANT'S REQUEST FOR

SUMMARY

DISPOSITION OF SUFFOLK COUNTY CONTENTIONS 4a(vii), (x)' , 7a(11) - (iii),

(vi) - (vii); 12a(viii); and 14a By pleading dated December 18, 1978, Applicant, pur-suant to 10 CFR S2.749, moves for summ.ry disposition of various of the County's contentions. The County's response is due January 8, 1979 Applicant's entire pleading, in-cluding motions and affidavits, totals 78 pages. The supporting affidavits and attachments contain technical analyses and documentation which purport to provide a f' actual basis for dismissal of the contentions addressed.

For reasons which follow, the County requests an additional thirty (30) days, or to February 7, 1979, to respond to Applicant's motions. First, Applicant 's pleadinr; was received by the County on December 20, 1978, right a' the beginning of the holiday season. Thus, it was timed to 7902030;2.82/

arrive at a period of shortened work weeks and when much 3

of the office clerical staff is on year-end vacation.

Second, the County Legislature, on December 12, 1978, approved a resolution to engage a new technical consultant, Energy Research Group, Inc. (ERC), as replacement for MHB. Inas-much as there is a thirty day period within which the County Executive can act to veto this resolution, the County has not as yet executed a contract with ERG which would formalize its retention as technical consultant for the Shoreham proceedings.

In addition, the transition of the case to new technical con-sultants will itself involve a period of weeks. The Shoreham FSAR, ER and relevant technical doc 1ments must be shipped to ERG. Once received, ERG will require time to review and analyze this material in order to provide technical input to the County's response to Applicant's motion. Third, even were the County not faced with the logistical problems des-cribed above, substantial cause would still exist for granting the requested time extension. Applicant's pleadin,gs are lengthy, contain technical analyses which require careful review and evaluation, and, in view of the importance of the issues addressed to the safe operation of the Shoreham plant, are not susceptible to hasty response.

For all of the foregoing reasons, and for good cause shown, the County respec'f lly requests that it be granted an additional thirty (30) days to respond to Applicant's motions for summary disposition. The County also requests that its new technical consultant, ERG, be added to the service list for this proceeding (Address: Energy Research Group, Inc., 400-1 Totten Pond Road, Waltham, Mass. 02154).

Respe lly Subm t ,

Irvin /Like Special Counsel for the County of Suffolk Dated: December 28, 1978 Babylon, New York

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UNITED STATES OF AMERICA - '

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NUCLEAR REGULATORY SgW4ISSION BEFORE THE ATOMIC SAND AND UENSING BOARD

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C N 1, ' }-3; In the Matter of -

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8 ll LONG ISLAND LIGHTING COMPANY 27 (Shoreham Nuclear Power Station, N g))DC Docket No. 50-322 .

TUjT Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that on December 28, 1978 a copy of MOTION FOR TIME EXTENSION TO REPLY TO " APPLICANT'S REQUEST FOR

SUMMARY

DISPOSITION OF SUFFOLK COUNTY CONTENTIONS 4a(vii),.(x);

7a(ii)-(iii), (vi)-(vii); 12a(viii); and 14a was sent to each of the following by postage pre-paid, first class mail:

Elizabeth S. Bowers, Esq. Edward M..Barrett, Esq.

Chairman General Counsel.

Atomic Safety & Licensing Board Long Island Lighting Company U.S. Nuclear Regulatory Comm. 250 Old Country Road Washington, D.C. 20555 Minecla, New York 11501 Dr. Oscar Paris, Member Edward J. Walsh, Esq.

Atomic Safety & Licensing Board Long Island Lighting Company U.S. Nuclear Regulatory Comm. 250 Old Country Road Washington, D.C. 20555 Mineola, New York 11501 Frederick J. Shon, Member Atomic Safety & Licensing Board W. Taylor Reveley, III, Esq.

U.S. Nuclear Regulatory Comm.

Hunton & Williams Washington, D.C. 20555 P.O. Box 1535 Richmond, Virginia 23212 Docketing and Service Section Office of the Secretary Jeffrey C. Cohen, Esq.

N.Y. State Energy Office U.S. Nuclear Regulatory Comm. Swan Street Bldg. - Core 1 Washington, D.C. 20555 Empire State Plaza Albany, New York 12223 Atomic Safety & Licensing Appeals Board Howard L. Blau, Esq.

U.S. Nuclear Regulatory Comm. Blau & Cohn, P.C.

Washington, D.C. 20555 380 North Broadway Jericho, New York 11753 Richard Hoefling, Esq.

Atomic Safety & Licensing Board T. J. Burke U.S. Nuclear Regulat ory Comm. Project Manar;er Washington, D.C. 20555 Shoreham Nuclear Power Station P.O. Box 618 r1HB Technical Associates North Country Road -

366 California Ave. - Suite 6 Wading River, New York 11742 Palo Alto, California 94306

Energy Research Group, Inc. s.

'k 400-1 Totten Pond Road Waltham, Mass. 02154 Ralph Shapiro, Esq.

Cammer & Shapiro, P.C.

9 East 40th Street New York, New York 10016 ObA0 fEh KE8 IRV7.1G LIKb