ML20062G147
| ML20062G147 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/08/1978 |
| From: | Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7812270042 | |
| Download: ML20062G147 (5) | |
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NRC PETELIC DCCm;gW ROOM S;4 11 %
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD k f,&, p[4 k4
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DocketNo[.50-322 C N [3 In the Matter of
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LONG ISLAND LIGHTING COMPANY
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(Shoreham Nuclear Power Station,
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Unit 1)
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NRC STAFF MOTION FOR c,
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AN EXTEMSION OF TIME t i The NRC Staff filed its "First Set of NRC Stiaff Interrogatories to the County of Suffolk" on May 15, 1978. S The County partially responded to the Staff's interrogatories by its response of August 23, 1978. With regard to the remaining Staff interrogatories, it was agreed that responses could be delayed until the issuance by MHB Technical Associates of their report supposedly designed to summarize the efforts of MHB as consultants to the County, and to particularize 7
contentions. The MHB report was represented to "... provide infomation requested by both Staff and Applicant in interrogatories submitted to the County" S i
1/ Formal discovery in this proceeding was opened by order of the Atomic
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Safety and Licensing Board on October 11, 1977 at a prehearing conference held at Port Jefferson, New York. See the " Memorandum and Order" of January 27, 1978, specifically page 24, which summarized the action taken at the prehearing conference.
Formal discovery has been practiced by the Applicant, Long Island Lighting Company, by the NRC Staff and by the County of Suffolk. Formal discovery will terminate 30 days after the issuance of the Staff's Safety Evaluation 1
Report.
See the Board's " Order Relative to Recuests for Clariff-cation and Recensideration of the Board Orde-of January 27, 1978,"
dated March 8,1978, specifically page 5.
2/ Letter of October 25, 1978 to this Soard from the County of Suffolk.
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, 4 In a document entitled, " County of Suffolk's Particularized Contentions" 1
dated November 30, 1978, the County served the MH8 report. The County concluded therein that it was of the belief that the need for a particularized response to the Staff's interrogatories has been elimina-ted by the MHB report. S/
The NRC Staff does not share the County's view that the MHB report is an adequate response to the Staff's interrogatories, The Staff intends to file a motion to compel responsive answers, pursuant to 10 CFR 2.740(f), explaining why it concludes that the MHB report is not an adequate response. Under the Commission's Rules of Practice, such a motion must be filed within 10 days of the date of response and thus such a motion would be due on December 11, 1978.
The Staff seeks an extension of the time within which to file its motion.
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The Staff's original interrogatories were extensive. The County's I
response, likewise, is extensive; however, in the Staff's view, that response is misdirected.
In view of the numerous contentions proposed by the County and the extensiveness of the materials which require examination, considerable time will be required by the Staff to prepare its motion to compel.
In addition, both Staff counsel assigned to
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i i a this proceeding will be out of the Washington area for considerable 3
portions of the month of December,1978. For these reasons, the NRC Staff seeks an extension of time until January 12, 1978 within which to file a motion to compel responsive answers to its interrogatories.
I Respectfully submitted, e
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Richard K. Hoeflin Counsel for NRC Staff Dated at Bethesda, Maryland j
this 8th day of December,1978.
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UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket No. 50-322
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(Shoreham Nuclear Power Station,
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Unit 1)
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'l CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MOTION FOR AN EXTENSION
! l 0F TIME" dated Cecember 8,1978, in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 8th day of December,1978.
Elizabeth S. Bowers, Esq.
MHB Technical Associates Atomic Safety and Licensing Board Panel 366 California Avenue U.S. Nuclear Regulatory Commission Sui te 6 Washington, D. C.
20555 Palo Alto, California 94306 Dr. Oscar H. Paris, Member Howard L. Blau Esq.
Atomic Safety and Licensing Board 217NewbridaeEoad U.S. Nuclear Regulatory Commission Hicksville. New York 11801 Washington, D. C.
20555 W. Taylor Reveley, III, Esq.
Mr. Frederick J. Shon, Member Hunton & Williams Atomic Safety and Li. censing Board P. O. Box 1535 U.S. Nuclear Regulatory Commission Richmond, Virginia 23212 Washington, D. C.
20555 Jeffrey Cohen, Esq.
Edward M. Barrett, Esq.
Deputy Commissioner and Counsel General Counsel New York State Energy Office Long Island Lighting Company Agency Building 2 250 Old County Road Empire State Plaza Mineola, New York 11501 Albany, New York 12223 Edward J. Walsh, Esq.
Irving Like, Esq.
l Long Island Lighting Corpany Reilly, like and Schneider 250 Old County Road 200 West Main Street Mineola, New York 11501 Babylon, New York 11702 m...
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Atomic Safety and Licensino Board Mr. J. P. Nevarro, Project Manager l~
U.S. Nuclear Regulatory Ccanission Shoreham Nuclear Power Station
!!ashington, D. C.
20555 P. O. Box 618, North Country Road fj Wading River, New York 11792 Atomic Safety and Licensing Appeal Board
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U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section (3
Office of the Secretary f
U.S. Nuclear Regulatory Commission Nashington, D. C.
20555
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40 Counsel for NRC Staff [/
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Richard K. Hoefling i
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