ML20053D196
| ML20053D196 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/25/1982 |
| 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 | |
| ISSUANCES-OL, NUDOCS 8206040174 | |
| Download: ML20053D196 (4) | |
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.CAMMER 8 SHAPIRo, P. C.
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ATTORNEY 5 AT LAW 9 EAST 40" STREET NEW YORK,N.Y.10016 g,;;.,
(2121683-s7eo May 25, 1982 Lawrence Brenner, Esq.
Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James L. Carpenter Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Re:
Long Island Lighting Company (Shore Nuclear Power Station, Unit 1)
Docket No. 50-322(OL)
P_ art 70 License Application Sirs:
We write to assure the members of the Board and the parties to this proceeding of our continued interest in both the Part 70 License Application and the above referenced licensing pro-ceeding.
The limited resources, both legal and financial, of the North Shore Committee (NSC) and professional commitments on May 25th did not permit my appearance at the hearing this morning.
The Board will recall that it was only at a conference call on the afterne - of May 20th that the possible need for an appearance 1
in connection with the Part 70 Licensing Application became apparent.
Until that time, the contentions being litigated did not involve NSC.
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8206040174 820525 PDR ADOCK 05000322 O
We understand from Mr. Latham, rho was kind enough to call us this afternoon, that it is not clear that the requirements of Paragraph 2(b) of the September 18, 1979 Stipulation have been fulfilled.
It appears that the Staff has not completed its review and approval of the adequacy of the training of LILCO personnel involved in the procedures and activities described in Paragraph 1 of the Stipulation.
Therefore, by copy of this letter to Mr. - Bordenick, we re-quest that we be kept currently and fully informed about the steps taken by the Staff tp assure compliance with Paragraph 2 of the Stipulation.
As an important aside, we note for the record that, after a thorough search of our files, we are unable to find SNRC-683 (3-18-82),
SNRC-686(4-5-82), and SNRC-688(4-12-82) referenced on page 1 of LILCO's May 22, 1982 Part 70 License Application submission.
We are not impugning the assertions in the submission that the three documents were served upon all parties and the Board and have no desire to engage in controversy about them.
We merely state the facts and, by a copy of this letter to Mr. Reveley, we request copies.
Aware that none of the parties are or will be in their offices this week, we have requested Mr. Latham, and he has kindly con-sented to this request, to deliver this submission to the Board members and parties at the hearing.
We have, in addition, served copies by mail on all parties to this proceeding.
Yours truly, M
1ph Shapiro $
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l RP:dr cc:
The Service List
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIONi L:I 25 EJ:22 N
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' L;;.:..
.u In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322(OL)
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(Shoreham Nuclear Power Station,)
Unit 1)
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CERTIFICATE OF SERVICE I, Deborah Ruiz, an employee of Cammer & Shapiro, P.C., the attorneys for NSC, certify that copies of the foregoing letter have been served to the following on May 25, 1982 by U.S. mail,
~
l first class.
t Lawrence Brenner, Esq.
Howard L. Blau, Esq.
Administrative Judge 217 Newbridge Road Atomic Safety and Licensing Board Hicksville, New York 11801 U.S. Nuclear Regulatory Commission i
Washington, D.C. 20555 W. Taylor Reveley, III, Esq.
Hunton & Williams i
Dr. James L. Carpenter 707 East Main Street j
Administrative Judge P.O. Box 1535 4
Atomic Safety and Licensing Board Richmond, Virginia 23212 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Matthew J. Kelly, Esq.
Staff Counsel Dr. Peter A. Morris New York State Public Administrative Judge Service Commission Atomic Safety and Licensing Board 3 Rockefeller Plaza U.S. Nuclear Regulatory Commission Albany, New York 12223 Washington, D.C. 20555 Stephen B. Latham, Esq.
Edward M. Barrett, Esq.
Twomey, Latham & Shea General Counsel 33 West Second Street Long Lahnd Lighting Company P.O. Box 398 250 016 Court Road Riverhead, New York 11901-Mineola, New York 11501 Marc W. Goldsmith Mr. Brian McCaffrey Energy Research Group, Inc.
Long Island Lighting Company 400-I Totten Pond Road 175 East Old Country Road Waltham, Massachusetts 02154 Hicksville, New York 11801 4
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David H. Gilmartin, Esq.
Mr. Jeff Smith Suffolk County Attorney Shoreham Nuclear Power Station County Executive / Legislative P.O. Box 618 Building Wading River, New York 11792 Veterans Memorial Highway Hauppauge, New York 11788 MHB Technical Associates 1723 Hamilton Avenue, Suite K Hon. Peter Cohalan San Jose, California 95125 Suffolk County Executive County Executive / Legislative Bldg.
Bernard M. Bordenick, Esq.
Veterans Memorial Highway David A. Repka, Esq.
Hauppauge, New York 11788 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Jay Kunkleberger, Esq.
New York State Energy Office Docketing and Service Section
~
Agency Building 2 Office of the Secretary Empire State Plaza U.S. Nuclear Regulatory Comm.
Albany, New York 12223 Washington, D.C. 20555 Ezra 1. Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Proteccion Bureau U.S. Nuclear Regulatory Comm.
New York State Department of Law Washington, D.C. 20555 2 World Trade Center New York, New York 10047 Atomic Safety and Licensing Appeal Board Lawrence Coe Lanpher, Esq.
U. S. Nuclear Regulatory Comm.
Kirkpatrick, Lockhart, Hill, Washington, D.C. 20555 Christopher & Phillips.
1900 M. Street, N.W.,
8th Fl.
Washington, D.C. 20036 DEBORAH RUIZ l
DATED:
May 25, 1982 i
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