ML20031B362
| ML20031B362 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/25/1981 |
| From: | Latham S TWOMEY, LATHAM & SHEA |
| To: | Carter L, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20031B363 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8110010278 | |
| Download: ML20031B362 (2) | |
Text
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September 25, 1931
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SEP3 0 1981=,.
. 6 giu. game ma Louis J. Carter, Chairman
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Administrative Judge 23 Wiltshire Road e
Philadelphia, Pa.
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84 Hee Mr. Frederick J. Shon, Member R; 982 8 $ Da k Atomic Safety.& Licensing Board Ofra d h%
O.S. Nuclear Regulatory Comm.
g, Dodeting & 3enke
, Washington, D.C.
20555 Dr. Oscar H. Paris, Member Adil' Atomic Jafety & Licensing Boo.rd U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555-Re:
50-322-CP
Dear Board Members:
Enclosed is SOC's " Statement of Contentions f.
Pursuant To 10 CFR Section 2.714, With Respect To The g; ?
Application For A Construction Permit Extension" and
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- Motion Pursuant To 10 CFR Section 2.714 To Supplement
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ting License.
Copies have been served on all parties in Cont'entions With Respect To The Application For An Opera Fi
Docket'50-322.
SOC deferred the submission of this document in view of the resumption of informal discussions among SOC, LILCO and Staff in mid-August.
A number of the issues raised by SOC in its original " Petition To
@3 Institute Proceedings" (January 23, 1981), particularly V 7 those issues now listed in part II of the enclosed document, are the subject of ongoinq discussions end j
particularization by SOC, LILCO and Staff.
However, in view of the possibility that those discussions will not lead to ultimate (or timely) stipulation on the issues O
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e to be litigated in the OL proceedino, and in view of SOC's belief that the enclosed document provides independent grounds for the admisnion in the CP or OL proceedings of the contentions contained therein, SOC is submitting them for the Board's considera'. ion at this time.
SOC, Staff and LILCO have previously reached an oral agreement on the time for responding to the enclosed contentions.
Staff and LILCO will respond to this filing in 20 days (October 15): SOC will. submit any reply by October 25; and the parties hope that the Board j
will decide the issues as soon thereafter as is 6
practicable.
9 As the Board is aware, informal discussions, discovery, particularization and resolution of contentions by the parties is continuing.
It is conceivable that those discussions may affect the contentions which have been submitted in the enclosed i'
document.
Should that occur, the parties will gg:
immediately potify the Board of that fact.
Sincerely,
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I-Steve Latham SL jo enc.
cet All parties
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