ML20042A356

Motion for Extension of Time Until 820326 to Answer Suffolk County 820308 & 09 First & Second Set of Interrogatories, Respectively.Suffolk County Does Not Object.Certificate of Svc Encl

ML20042A356
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/18/1982
From:	Flanagan D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8203230357
Download: ML20042A356 (4)

Text

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, March 18, 1982 a

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'82 KM 22 N0:08 UNITED STATES OF AMERICA 7; NUCLEAR REGULATORY COMMISSION '

Before the Atomic Safety and Licensing Board In the Matter of ) -ij,N

) s3 [ ~ //S, LONG ISLAND LIGHTING COMPANY ) Docket No. 50- d5xOL 4, (Shoreham Nuclear Power Station, li h Unit 1) ) .

IMP E ] J^gp3 MOTION FOR EXTENSION OF TIME 3' ""l I , (( >

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. J;c ls TO ANSWER SUFFOLK COUNTY INTERROGATORIES 6

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On March 8 and 9, 1982, LILCO received "SUFFOLK COUNTY INTERROGATORIES TO LONG ISLAND LIGHTING COMPANY," and "SUFFOLK COUNTY SECOND SET OF INTERROGATORIES TO LONG ISLAND LIGHTING COMPANY." Pursuant to 10 CFR $ 2.740b LILCO's answers to these interrogatories are due by March 22 and 23, respectively. By this motion, LILCO requests an extension of time until March 26, 1982 to answer these interrogatories.

The interrogatories reached LILCO on the day preceding and the first day of the pre-hearing conference. The late ar-rival of these interrogatories precluded any work on answering l

them until after the conference. Moreover, in the spirit of i

cooperation, LILCO met with representatives of Suffolk County on April 11 to discuss Suffolk County's discovery requests. As D503 s

B203230357 820318 PDR ADOCK 05000322 G PDR

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a result of that meeting, 1) the parties were able to significantly reduce the number of interrogatories to be an-swered (although an exhaustive number remains); 2) an agreement was reached on the scope of discovery for many issues, which obviated the need for the Board to rule on several discovery objections. Unfortunately, the date on which preparations to answer the interrogatories could begin was pushed back yet an-other day by this meeting.

LILCO has vigorously pursued the preparation of answers to the discovery requests; however, it is a time consuming task that simply cannot be completed by March 22 and 23. Therefore, LILCO requests that the deadline for complying with Suffolk County interrogatories be extended to March 26, 1982. Counsel for Suffolk County has indicated the County has no objection to such an extension.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY RRo. h W. Taylor Reveley, III Anthony F. Earley, Jr.

Daniel O. Flanagan Hunton & Williams P.O. Box 1535 Richmond, Virginia 23212 DATED: March 18, 1982

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In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

CERTIFICATE OF SERVICE l

I hereby certify that copies of MOTION FOR EXTENSION OF TIME TO ANSWER SUFFOLK COUNTY INTERROGATORIES were served upon a

the following people by first-class mail, postage prepaid, on March 18, 1982, except for the asterisked people, who were j served by hand on March 18, 1982.

Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Mr. Frederick J. Shon* U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Bernard M. Bordenick, Esq.

Commission David A. Repka, Esq.

Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. James H. Carpenter

• Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.

Board Panel Attn: Patricia A. Dempsey, Esq.

U.S. Nuclear Regulatory County Attorney Commission Suffolk County Departmer.t of Law Washington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

Herbert H. Brown, Esq.

• Lawrence Coe Lanpher, Esq. Howard L. Blau, Esq.

Karla J. Letsche, Esq. 217 Newbridge Road Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Jeffery C. Cohen, Esq.

8th Floor 1900 M Street, N.W. New York State Energy Office Washington, D.C. 20036 Swan Street Building, Core 1 Empire State Plaza Albany, New York 12223 Mr. Mark W. Goldsmith Energy Research Group Mr. Jay Dunkleberger 400-1 Totten Pond Road New York State Energy Office Waltham, Massachusetts 02154 Agency Building 2 Empire State Plaza MHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue Suite K San Jose, California 95125 Stephen B. Latham, Esq.

Twomey, Latham & Shea 33 West Second Street P. O. Box 398 Riverhead, New York 11901 Ralph Shapiro, Esq.

Cammer and Shapiro, P.C.

9 East 40th Street New York, New York 10016 e OTw sm W. Taylor Reveley, III)

Daniel O. Flanagan Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 DATED: March 18, 1982

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