ML20041G190
| ML20041G190 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/15/1982 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20041G191 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8203190374 | |
| Download: ML20041G190 (3) | |
Text
u, 4
e P'
q RECElv60 UNITED STATES OF AMERICA Cor;KETE 2;
g1 g 1982> {g NUCLEAR REGULATORY COMMISSION F '-
a newimust esas gaun usEfA01 M
\\
MC ORE THE ATOMIC SAFETY AND LICENSING BOAR 5ll7 Ol:29 s
b
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 0.L.
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUF10LK COUNTY REQUEST FOR BOARD APPROVAL OF REVISION OF SECURITY PROTECTIVE ORDER On January 14, 1981, this Licensing Board issued an Order granting a " Joint Motion to Accept a Stipulation on the Security Plan," dated December 31, 1980.
Pursuant to the January 14, 1981 i
Order and a " Protective Order on Security Plan Information," which was attached to the January 14 Order, Mr. Marc Goldsmith, Suffolk County technical consultant, and Ms. Pat Dempsey, Deputy Suffolk County Attorney, were provided access to the Shoreham security plan under specified safeguards, including execution of an "Affi-davit of Non-Disclosure."
Suffolk County now requests that the Board amend its previous orders to permit Lawrence Coe Lanpher-also to have access to the LILCO plan under the safeguards l
previously enunciated by this Licensing Board.
l Mr. Goldsmith is scheduled to review the LILCO security plan l
on March 18, 1982.-1/
The purpose of this review is to determine l
l
\\
-1/
See Tr. 298, et, seg, of Prehearing Conference where this visit was mentioned.
i 0h l
W So l l
8203190374 820315 l
PDR ADOCK 05000322 l
0 PDR
, whether suffolk County has concerns which merit the filing of a security contention.
Mr. Lanpher's law firm has been retained 2/
to be the County's lead attorneys on this licensing proceeding.-
In order to confer with Mr. Goldsmith and evaluate whether to propose a security contention, it is essential that Mr. Lanpher be present with Mr. Goldsmith when he reviews the security plan and that Mr. Lanpher likewise be familiar with the plan.
The County's intention is to make the necessary review of the security plan on March 18, 1982, and to report to the Board promptly thereaf ter concerning whether to propose a contention.
Such prompt review and reporting to the Board can best be accom-Lan? er and Mr. Goldsmith are present together plished if Mr.
h 3/
for the March 18 review.-
The undersigned has spoken with Mr. Early, LlLCO attorney, concerning the addition of Mr. T anpher to the list of persons permitted to review the plan.
Mr. Early stated that LILCO has no objection so long as Board approval is obtained.
Mr. Bordenick of the NRC Staff likewise had no objection.
-2/
Ms. Dempsey, while remaining on the service list in this proceeding, will no longer serve as lead counsel for the County and it is not proposed that she be present on March 18 when the plan is reviewed.
3/
The Board specifically instructed counsel to attempt to file a security contention in March, 1982, if one is to be filed at all.
Tr. 300.
Counsel believes that the Board action requested herein will ensure that the County will comply with the Board's request.
An original Affidavit of Non-Disclosure executed by Mr.
Lanpher is attached hereto.
The undersigned respectfully requests expedited Board consideration of this Request so that Mr. Lanpher may attend the March 18 review with Mr. Goldsmith if Board approval is granted.
Respectfully submitted, DAVID J.
GILMARTIN PATRICIA A. DEMPSEY Suffolk County Attorneys Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
'/*
v
/
L: -'
/
rG trL/1< n W
~s f's !
Herbert H.
Brown Lawrence Coe Lanpher Karla J.
Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036 (202) 452-7000 Attorneys for Suffolk County March 15, 198't 4
i 1
, -