ML19263C555

County of Suffolk'S Request for Extension Until 790207 to Respond to NRC Motion to Compel Answers to Interrogatories. Request Due to Recent Retention of Technical Consultant to Review & Prepare Info.Certificate of Svc Encl

ML19263C555
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/31/1979
From:	Like I SUFFOLK COUNTY, NY
To:
References
NUDOCS 7902260548
Download: ML19263C555 (3)

Text

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NRC PUBLIC DOCgs RW ,

Connespovng\. ,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION q,

BEFORE THE ATOMIC SAFETY AMD LICENSING BOARD In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-

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(Shoreham Nuclear Power Station ) ~%

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County of Suffolk's '8^' , 7 Motion for Time Extension to y g 9. . L Respond to Staff's Motion w 9 q~

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• ~41 y s On May 15, 1978, Staff filed it's "First Set of Interrogatories to the County of Suffolk". The County provided response to these interrogatories by pleading entitled " County of Suffolk's Particularized Contentions".

Staff now seeks to compel more responsive answers to various of its interrogatories.

As indicated in a previous submission (see, " Motion for Time Extension to Reply to Appl #aant's Request for Summary Dist

• tion..."), the County is in the process

,of engagiag a new technical consultant for the Shoreham proceedings, Energy Research Group, Inc.(ERG). Although a contract has been submitted to the County Legislature to provide for ERG's retention, the Legislature has not 7 9 0 2 26 0 5L/I

. -e-yet. formally approved the contract. Such approval 1s ,

expected shortly. In addition to this contingency, ERG has only just recently received the Shoreham ?SAR and is now in the process of gathering and reviewing other techni-cal material relevant to the County's contentions. 'This

" catching up" process is a lengthy and time consuming one.

Although the County maintains that its previous response te Staff's interrogatories in general ~provides a legally sufficient response, it believes input from its technical consultant is necessary in order to properly frame its response to Staff's motion.

For the foregoing reasons, the County requests an extension of time to February 7, 1979 to rescond to Staff's motion to compel. Staff counsel was contacted this date and has no objection to this request for a time extension.

Respectfully submitted,

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Irvi.g Like Special Counsel for the County of Suffolk Dated: January 31, 1979

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .,

. e BEFORE THE AT0"1IC SAFETY AND LICENSING BOARD

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,N Qy In the Matter of ,

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LONG ISLAND LIGHTING COMPANY!- 3 Y ).. h[

Docket No. 50-32 1 i (Shoreham Nuclear Power Stati'on, cY)he.U'S,

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Unit 1)

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CERTIFICATE "GILS&RIE I hereby certify that on Jan. 31, 1979 , a copy of

' County of Suffolk'~s. Motion for Time Extensio2 to Respond to Staff's Motion to Compel, were sent to 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 Mineola, 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 -W. Taylor Reveley, III, Esq.

Atomic Safety & Licensing Board Hunton & Williams U.S. Nuclear Regulatory Comm. P.O. Box 1535 Washington, D.C. 20555 Richmond, Virginia 23212 Docketing and Service Section Jeffrey C. Cohen, Esq.

Office of the Secretary 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.

Hashington, D.C. 20555i 217 Newbridge Road Hicksville, New York 11801 Richard Hoefling Esq.

Atomic Safety & Licensing Board T. J. Burke U.S. Nuclear Regulatory Comm. Project Manager Washington, D.C. 20555 Shoreham Nuclear Power Statio P.O. Box 618 Energy Research Group, Inc. North Country Road '

400-1 Totten Pond Road- Wading River, New York 11742 Waltham, Mass. 02154

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