ML20028A736
| ML20028A736 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/22/1982 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | |
| References | |
| NUDOCS 8211240337 | |
| Download: ML20028A736 (6) | |
Text
11/22/82 UNITED STATES OF AMERICA q[
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing BoI2d hDV 23 A11 :27
' ivy fFSLCniinny f* e ti?.G & service
)
5 RANCH In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 0.L.
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY SCHEDULE FOR CONSIDERATION OF TORREY PINES REPORT On November, 19, 1982, the Licensing Board requested Suffolk County to reconsider what dates in the County's view would be appropriate for submission of testimony concerning the Torrey Pines Report.
The' County previously provided a proposed schedule for consideration of the Torrey Pines Report.
See Suffolk County Filing Concerning the Torrey Pines Technology Report, November 16, 1982.
The County continues to believe that that schedule is appropriate, since it provides a reasonable opportunity for review of the Torrey Pines data by all parties and for further submissions, as appropriate.
At the Board's request, however, the County has reevaluated its proposal, considering the following new developments:
1.
The Board's tentative decision to defer OQA examination of Mr. Hubbard and the Staff until the Staf f OQA evaluation has been completed and made available to the parties.
The County understands that the Staff's evaluation will probably not be 8211240337 821122 PDR ADOCK 05000322
available until early January 1983, and that the evaluation may require some supplemental testimony from the Staff and perhaps, other parties.
2.
The Board's suggestion that Torrey Pines testimony be staggered, with LILCO (including Torrey Pines sponsors) filing on December 7 and other parties filing later.
Tr.
14,695-96.
This staggered filing may facilitate the Staff and County review of the Torrey Pines data, since it will provide the views of those entities (LILCO and Torrey Pines) most familiar with the data and should highlight particularly important points.
3.
Based on prior time estimates by LILCO and the Staff, the examination of Mr. Hubbard on design and construction QA/QC 1/
should be completed by December 3, 1982,~ permitting Mr. Hubbard thereafter to devote time to Torrey Pines review.
If Mr. Hubbard's examination is not completed by December 3, the schedule pro-posed below will need to be adjusted.
4.
Mr. Hubbard likely will be unavailable for Torrey Pines review during a portion of the week of December 6 due to the need for him to be present at a significant technical meeting of all parties in the Diablo Canyon proceeding on December 9, 1982 in San Francisco, California.
1/
In its October 29, 1982 " Schedule" filing, LILCO predicted "two days for all aspects of the examination of the County's witnesses."
(p. 12, fn. 7).
The County assumes that the scheduled discussion of outstanding contentions and the completion of the examination of the LILCO OQA panel will take place on November 30 and that Mr. Hubbard will be examined during the remainder of that week.
. i Based on the foregoing, the County suggests the following schedule:
December 7 Board and parties receive LILCO testimony on Torrey Pines Report.
December 15 County and Staff indicate whether either seeks depositions of LILCO and/or Torrey Pines personnel and, if so, designate the subjects and portions of Torrey Pines Report and/or prefiled testimony to be covered.
December 23 Last day for completion of deposi-tions.
Precise date(s) and locations for depositions to be arranged among parties.
December 31 Board and parties receive Staff and/or County testimony on Torrey Pines Report.
January 6 Designation whether depositions will be held of Staff and/or County witnesses and, if so, designate the subjects and portions of Torrey Pines Report and/or pre-filed testimony to be covered.
January 11-14 Depositions to be held of Staff and/or County witnesses.
Precise date (s) and locations for deposi-tions to be arranged among parties.
January 11 Motions to Strike, if any, to be i
received.
(The County believes that motions to strike are unlikely since testimony is to focus solely on Torrey Pines Report and its relationship to QA/QC issues.)
January 17 Responses to Motions to Strike and submission of cross plans, t
January 18 Rulings on Motions to Strike;t hearing commences on Torrey Pines testimony.
Due to shortness of time, a coordinated filing with LILCO and the Staff was not possible.
Respectfully submitted, David J. Gilmartin Patricia A.
Dempsey
^
Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788-
. A=Ao x
Herbert H.
Brown 7
Lawrence Coe Lanpher
..blan Roy Dynner
.KIRKPATRICK, LOCKHART, HILL, CHRISTCPHER & PHILLIPS 4
! 1900 M Street, N.W.
Washington, D.C.
20036 November 22, 1982 Nttorneys for Suffolk County I
k.
's 4 k
4
+
/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the' Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
)
Docket No. 50-322 (0.L.)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
i CERTIFICATE OF SERVICE I-hereby certify that copies of "SUFFOLK COUNTY SCHEDULE
.FOR ' CONSIDERATION OF TORREY PINES REPORT," dated November 22,
'1982, hus been served to the following this 22nd day of November, 1932 by U.S.~ Mail, first' class, except as otherwise noted.
\\.
sLawrendeBrenner, Esq.
i(*)
Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S.
Nuclear Regulatory.' Commission New York, New York 10016 Wa shing ton,
D.C.
20555 Howard L.
Blau, Esq.
Dr. James L.
Carpenter
(*)
217 Newbridge Road Administrative Judge 1
Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W.
Taylor Reveley III, Esq. (J)
Washington, D.C.
20555 Hunton & Williams
(
P.O.
Box 1535 707 East Main St.
g Dr. PG er A.
Morris
( *)
Richmond, Virginia 23212 s
Administrative Judge Atomic p3fety and Licensing Board 1
U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C.
20555 New York State Energy Office Agency Building 2 e
Edward M.
Barrett, Esq.
Empire State Plaza k.
General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Mineola, New York 11501 Stephen B.
Latham, Esq.
Twomey, Latham & Shea Mr. Brian McCaffrey Attorneys at Law Long Island Lighting Company P.O.
Box 398 175 East Old Country Road
i t
~~%%
Marc W.
Goldsmith Mr. Jeff Smith Energy Research Group, Inc.
Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road
' Wading River, New York 11792 Joel Plau, Esq.
MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A.
Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David J. Gilmartin, Esq.
County Executive / Legislative Suffolk County Attorney Building County Executive / Legislative Bldg.
Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I.
Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S.
Nuclear Regulatory Commission New York State Department of Washington, D.C.
20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board U.S.
Nuclear Regulatory Bernard M.
Bordenick, Esq.
(*)
Commission David A.
Repka, Esq.
Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Matthew J.
Kelly, Esq.
Staff Counsel, New York 1
Stuart Diamond State Public Service Comm.
Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223 Long Island, New York 11747 Daniel F.
Brown, Esq. (*)
Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 R&tavu ~
u
' Lawrence Coe Lancher KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: November 22, 1982 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036
(*) By Hand
(#) By Telecopier
_ - _