ML20052H045

Comments on Whether Suffolk County Contention 32 & Shoreham Opponents Coalition Contention 19(i) Are Ripe for Filing on 820525.Util Lacks Facts to Answer Problem.Certificate of Svc Encl

ML20052H045
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/13/1982
From:	Reveley W HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20052H025	List: ML20052H024 ML20052H027 ML20052H033 ML20052H037 ML20052H038 ML20052H045
References
ISSUANCES-OL, NUDOCS 8205190299
Download: ML20052H045 (4)

Text

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LILCO, May 13, 1982

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. UNITED STATES OF AMERICA ' II '1'- 80 NUCLEAR REGULATORY COMMISSION L.

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Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

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(Shoreham Nuclear Power Station, )

Unit 1) )

WHETHER SC 32 AND SOC 19(i)

ARE RIPE FOR FILING ON MAY 25

1. Until yesterday, counsel for LILCO were unaware that the Staff, County and SOC believe that they lack suffi-cient information to file testimony by May 25 on SC 32 and SOC 19(i).

2. Discussions since then have not wholly resolved (a) what exactly it is these parties want, the Staff in partic-ular, (b) whatever it is they want, whether that information would materially affect resolution of the contentions, and (c) when the Company first became aware (if before yesterday) that something material (if anything) might be missing.

3. Given this confusion, we lack the facts to know whether good cause exists to find SC 32 and SOC 19(i) unripe for filing on May 25. Accordingly, as Mr. Lanpher recited in his Motion to Defer of May 12, "LILCO takes no position regard-ing this motion." As a practical matter, if the Staff, County 8205190299 820513 i PER ADOCK 05000322 O POR i 1

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• and SOC have all concluded that they lack sufficient information to go forward on May 25, that would seem to resolve the issue,.given the imminence of the 25th. In light of the present scope and pace of this proceeding, there will inevita-bly be some belated discoveries of the sort in question. We i

hope there will not be many.

Respectfully submitted, LONG-ISLAND L,IGHTING. COMPANY

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W. Tayl6r'Reveley, III i

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Hun *.on & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: May 13, 1982

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LILCO, May 13,a1982

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LONG ISLAND LIGHTING COMPANY ~

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(ShorehamNuclearPowerStation,Unitjl)t'. 4 '? " '

Docket Nc. 50-322 (OL) ' " ~ W h'h CERTIFICATE OF SERVICE I hereby certify that copies of LILCO'S (1) MOTION TO STRIKE THE MINOR TESTIMONY ON SC 28(a)(iii)/ SOC 7A(3),

(2) CROSS-EXAMINATION PLAN ON MR. MINOR'S TESTIMONY, (3) CORRECTIONS AND ADDITIONS TO THE HILL TESTIMONY ON SC 10, (4) COUNTY ACCESS TO SECURITY PLAN, and (5) COMMENTS ON THE i

RIPENESS OF SC 32 and SOC 19(i), were served upon the following people by first-class mail, postage prepaid, on May 13, 1982, except for those people indicated by an asterisk who were served by hand on that date, and except that for Item (2) above which went only to the Board:

Lawrence Brenner, Esq.* Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Ssfety 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 Dr. Peter A. Morris

• 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.

Washingtoit, 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 Department of Law W'ashington, D.C. 20555 Veterans Memorial Highway Hauppauge, New York 11787

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Secretary of the Commission Ralph Shapiro, Esq.

U.S. Nuclear Regulatory Cammer and Shapiro, P.C.

Commission 9 East 40th Street Washington, D.C. 20555 New York, New York 10016 Herbert H. Brown, Esq.* Howard L. Blau, Esq.

Lawrence Coe Lanpher, Esq. 217 Newbridge Road Karla J. Letache, Esq. Hicksville, New York 11801 Kirkpatrick, Lockhart, Hill, Christopher & Phillips Matthew J. Kelly, Esq.

8th Floor New York State Energy Office 1900 M Street, N.W. Agency Building 2 Washington, D.C. 20036 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

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W. fay'or Reveley, III Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212  ;

DATED: May 13, 1982 l

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