ML20050J764
| ML20050J764 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/08/1982 |
| From: | Shapiro R Cammer & Shapiro, NORTH SHORE COMMITTEE AGAINST NUCLEAR & THERMAL POLLU |
| To: | Brenner L, Carpenter J, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8204140195 | |
| Download: ML20050J764 (2) | |
Text
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g,fg> cDE CAMMER 8 SHAPIRO, P. C.
ATTORNEYS AT l.AW 9 LOT 40m STREET r y,
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N EW YoR K,N.Y.10016 April 8, 1982 mun.e.
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fig E/Pp Lawrence Brenner, Esq.
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,Dr. James L.
Carpenter 6-C 28
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Morris g
Administrative Law Judges
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Nuclear Regulatory Commission 91 x hashington, D.
C.
20555 on Re:
Long Island Lighting Company Shoreham Nuclear Power Station, Unit 1 Docket No. 50-322 Sirs:
At the April 2 conference call, the Board requested, among other things, the parties to submit in writing, no later than the morning of the April 14 pre-hearing conference, a summary of the issues which they deem to arise out of the Emergency Response Plans filed by LILCO and Suffolk County (SC).
Insofar as the Northshore Committee against Nuclear and Thermal Pollution (NSC) is concerned, this request requires a review of the SC Emergency Response Plan, especially as it relates to off-site emergency planning.
On April 1, 1982, we received Mr. Brown's March 30 letter to you (copy enclosed), enclosing a draft of the "Suffolk County Radiological Emergency Response Plan as of March 10, 1982".
However, the document was not enclosed with the copy of the March 30 letter to us.
Because of its apparent bulk, we assumed that it was being mailed under separate cover and would reach us the next day, Friday, April 2.
When it did not do so, I called Mr. Brown's office on the morning of Monday April 5 and, neither he nor Mr. Lanpher being available, was referred to a secretary (Ms. Gordon?).
Ke informed her that we had not received the document and requested her to send us a l
copy by Federal Express.
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B204140195 820408 PDR ADOCK 05000322 zI D G
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.e CAMMER 8 SHAPIRO, P. C.
Lawrence Brenner, Esq.
April 8, 1982 Dr. James L.
Carpenter Page 2 Dr. Peter A.
Morris The following day, Tuesday, April 6 at about 12:00 noon, Ms. Thurman, of Mr. Brown's office, informed me by phone that they did not have any more copies of the document but she had called SC to ask them to send me a copy by Federal Express at once and SC had stated that it would do so.
As of this writing (April 8 at 12:00 noon) we have not received the document.
We have no doubt that the request was transmitted and received and that a good faith effort was made to comply.
Understandably, the near blizzard of April 7 undoubtedly interfered with that effort.
Nevertheless, (and especially since I will be out of my office on Friday April 9) full compliance with the Board's request to identify issues in the Suffolk County Emergency Plan will be difficult because of the obvious time constraints.
%e will, however, make every effort to prepare a meaningful and helpful summary.
We thought that the Board should have this infor-mation prior to April 14.
Yours truly, T
Yi 2Ul$
/
Ralph Shapiro Attorney for NSC RS:rsf Enc.
cc:
Service List
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