ML20042B262
| ML20042B262 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/22/1982 |
| From: | Letsche K KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8203250155 | |
| Download: ML20042B262 (7) | |
Text
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UNITED STATES OF A'4 ERICA NUCLEAR REGULATORY CO?i!!ISSION 9TD BEFORE THE ATO!!IC SAFETY AND LICENSINd3230ARfhy P137 r.
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LONG ISLAND LIGHTING COfiPANY
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Docket No. 50-322 0.L.
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(Shoreham Nuclear Power Station, i
Unit 1)
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JOINT FILING REGARDING SUB!!ISSION
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OF PREFILED TESTIMONY In accordance with this Board's tiarch 15, 1982 Memorandum and Order, as revised by the Board during the Conference Call on !! arch 19, 1982, the parties have conferred concerning sub-mission of prefiled testimony.
A proposed schedule is attached hereto.
The Staff, S.O.C.
and Suffolk County believe that a schedule calling for approximately one-hearing day-per-contention should ensure productive work during the four-week (16-day) period specified by the Board.
There are likely to be three panels of witnesses on most contentions and such a number of witnesses makes it unlikely that the hearing will proceed more rapidly than one contention every hearing day.
Further, the attached schedule counts suffolk County and related S.O.C. contentions as only a single contention.
In fact, the related contentions differ in certain instances, which may require some additional N
hearing time.
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LILCO would prefer that additional issues be included in the April' 13 and/or May 4 filings.
LILCO may suggest such additional issues in a separate filing.
The Staff does not oppose inclusion of additional issues, but believes they are not necessary and should be lef t for the May 25 filing.
S.O.C.
and Suffolk County strongly oppose the addition of more issues to the April 13 or May 4 filings and, if LILCO suggests any such additions, S.O.C. and Suffolk County request the opportunity to address the Board on the matter.-1/
There is one basic scheduling disagreement which the Board must resolve.
Suffolk County and S.O.C. suggest that the Revised 7B testimony be submitted May 4, 1982; LILCO and the Staf f dis-agree and urge that it be submitted April 13.
Revised 7B is a complex, many-faceted issue which (the County and S.O.C. believe) will be much more sharply focused if the County and S.O.C. have a short o.dditional period for submission of testimony.
This also l
will allow the County and S.O.C.
to retain additional expert consultants and thus to address comprehensively the issue the Board has posed.
The County and S.O.C. are willing to provide in the near future a detailed systems interaction report prepared by MHB Technical Associates for the Swedish Government.-2/ This
-1/
One reason that S.O.C. and Suffolk County object to the in-clusion of additional issues is that these parties, unlike the Staff and LILCO, must submit testimony on revised Contention 7B on April 13 or May 4.
This will require a considerable l
effort by Suffolk County /S.O.C. experts; any additional issues included in the April 13 or May 4 filings would impose an unfair burden on S.O.C. and Suffolk County who already must address more issues than the Staff and LILCO.
2/
The report is scheduled to be published laba this month.
1
report will be relied upon in the proposed testimony.
The County and S.O.C. also are willing to submit a detailed outline of the 7B testimony at the April Prehearing Conference, putting the Staff and LILCO on notice regarding the County /S.O.C. approach to the Board's revised issue and thus allow them to commence prepara-tion of their positions on the contention.
The County and S.O.C. submit that a short deferral of the 7B testimony will not prejudice any party.
The Staff /LILCO 7B testimony could still be submitted May 25 or, if the Board so ordered, a specified time after cross-examination of the County /
S.O.C.
7B testimony.
In either event, this should not delay ultimate completion of the hearing.
For convenience, Suffolk County counsel is making this filing on behalf of all the parties.
There have been telephone consul-tations since the March 19 Conference Call, but time did not permit the County to transmit this filing for advance review by
- LILCO, S.O.C. or the Staff.
The County believes, however, that it is correct in asserting that the only fundamental disagreement 3/
concerns the timing of the 7B testimony.-
-3/
S.O.C. and the County, as the Board is aware, believe that the entire schedule.should be revised further.
This schedule submission by the parties does not constitute agreement by S.O.C. and the County that the schedule, as now specified by the Board, is correct, but rather is their submission in compliance with the Board's directive.
-4_
It is respectfully requested that the Board rule as expeditiously as possible on these matters so that consultants' priorities may be properly arranged.
Respectfully submitted, DAVID J. GILMARTIN PATRICIA A. DEMPSEY Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 NW
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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 March 22, 1982 Attorneys for Suffolk County
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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 (OL)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the " JOINT FILING REGARDING SUBMISSION OF PREFILED TESTIMONY" in the above-referenced matter have been served to the following on March 22, 1982 by U.S. Mail, first class, except as otherwise noted.
Lawrence Brenner, Esq. (*)
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 Washington, D.C.
20555 Howard L.
Blau, Esq.
Dr. James L. Carpenter ( *)
217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W.
Taylor Reveley III, Esq. (*)
Washington, D.C.
20555 Hunton & Williams P.O.
Box 1535 Mr. Frederick J.
Shon
(*)
Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board Jeffrey Cohen, Esc.
U.S. Nuclear Regulatory Commission Deputy Commissioner & Counsel Washington, D.C.
20555 New York State Enurgy Office Agency Building 2 Edward M.
Barrett, Esq.
Ea$ ire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road 5tephen 3.
Latham, Esq. (#)
Mineola, New York 11501 Taomey, Latham & Shea Attorneys at Law Mr. Brian McCaffrey (#)
P.O.
Box 398 Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, N.Iw York 11901 Hicksville, New York 11801
.o Marc W. Gcidsmith 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 Blau, Esq.
New York Public Service Commission MHB Technical Associates The Governor Nelson A.
Rockefeller 1723 Hamilton Avenue Building Suite K Empire State Plaza San Jose, California 95125 Albany, New York 12223 Hon. Peter Cohalan David H. Gilmartin, Esq.
Suffolk County Executive Suffolk County Attorney County Executive / Legislative County Executive / Legislative Bldg.
Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Atomic Safety and Licensing Ezra I.
Bialik, Esq.
Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Bureau Washington, D.C.
20555 New York State Department of Law Docketing and Service Section 2 World Trade Center Office of the Secretary New York, New York 10047 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Bernard M. Bordenick, Esq. (*)
U.S. Nuclear Regulatory David A.
Repka, Esq.
Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
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Ka'rla J.
Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
8th Floor Washington, D.C.
20555 flarch 22, 1982
(*)
By hand on 3/22/82
(#)
By Federal Express