ML20027E519

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Forwards Motion to Strike Testimony on Suffolk County Contention EP 5(A),motion to Strike Portions of Direct Testimony & Motion for Summary Disposition on Traffic Congestion Issues.Related Correspondence
ML20027E519
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/09/1982
From: Christman J
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To: Brenner L, Carpenter J, Morris P
Atomic Safety and Licensing Board Panel
Shared Package
ML20027E520 List:
References
ISSUANCES-OL, NUDOCS 8211150456
Download: ML20027E519 (2)


Text

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Lawrence Brenner, Esq.

Dr. James H. Carpenter Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Long Island Lighting Company Shoreham Nuclear Power Station, Unit 1 Docket No. 50-322 OL

Dear Administrative Law Judges:

Enclosed are (1) LILCO's Motion to Strike the Testimony of Kai T. Erikson and Stephen Cole on Suffolk County Contention EP 5(A) -- Role Conflict, (2) LILCO's Motion to Strike Portions of the Direct Testimony of Fred C. Finlayson, and (3) LILCO's Motion for Summary Disposition on the Traffic Congestion Issues, EP 2(B) and 5(B), and the Augmentation of Onsite Staff Issues, EP 5(B) and 7(B).

A word of explanation is in order about the summary disposition motion.

On November 2 we advised the Board that 8211150456 021109 PDR ADOCK 05000 G

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HUNTON 8e WILLI AMS our guess at that time was that we would file no motions for summary disposition (Tr. 12,581).

In fact we have decided to file one, simply because the issues involved there seem particularly appropriate for summary disposition.

We hope this change in plans will not inconvenience anyone.

We have encountered two logistical problems.

First, we were simply unable to get the affidavits supporting the motion for summary disposition executed in time for filing today.

The best we can do is file the unsigned affidavits and pledge to serve executed copies as soon as possible.

Second, four of the other attachments to the summary disposition motion will not reach you until tomorrow.

Fortunately they are documents that you already have, because they were served along with LILCO's written testimony: to pages 6-7 of LILCO's written the motion for testimony on EP 5(B) summary disposition (B)-6 (B)-9 (B)-7 Again, I apologize for any inconvenience this may cause.

l Yours very truly, t bh. Me ca jfEfamesN.Christman 126/586 cc:

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