ML20070E622
| ML20070E622 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/11/1991 |
| From: | Mcgranery J DOW, LOHNES & ALBERTSON, LONG ISLAND LIGHTING CO., SCIENTISTS & ENGINEERS FOR SECURE ENERGY |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20070E549 | List: |
| References | |
| NUDOCS 9103060095 | |
| Download: ML20070E622 (4) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
)
In the Matter of
)
Docket No. 50-322
)
Consideration of Issuance of Amendment )
License No. NPF-82 To Facility Operating License and
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Proposed No Significant Hazards
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Consideration Determination and
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Opportunity for Hearing; Long Island
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Lighting Co. (Defueled operating
)
License) (55 Fed. Reg, 34098,
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August 21, 1990)
)
)
PETITIONERS' JOINT NOTICE OF INTENT TO PETITION FOR REVIEW AND RE00EST FOR STAY The Shoreham-Wading River Central School District and Scientists and Engineers for Secure Energy, Inc. (jointly
" Petitioners"), by counsel, give notice of their intent to file a petition for review of any final determination by the Commission that the Long Island Lighting Company's ("LILCO") application for a possession only license for the Shoreham Nuclear Power Station involves no significant hazards consideration and that the amendment shall be issued before hearing in the above-captioned matter.
Ems U.S. App.D.C. General Rule 7(h) (1) (B).
If the Commission does make such a final determination, petitioners respectfully request that the amendment not issue until fifteen (15) working days after publication of that final determination in the Zaden1 Resister, in order to allow Petitioners to seek and obtain a stay of the determination and the order issuing the license in the U.S. Court of Appeals for 9103060093 910211 PDR ADOCK 050003P2 i
O PDR l
the District of Columbia Circuit.
Eta U.S. App.D.C. General Rule l
7 (h) (1) ( A).
Petitioners submit that good cause for such a stay of the issuance of the proposed possession only license amendment is shown by the facts that such a stay will preserve the status gun pending expedited consideration of Petitioners' Emergency Motion by the Court, will not seriously inconvenience LILCO due to the short period of time in question, and the public interest favors a swift, independent judicial consideration of the need for a stay pending review.
WHEREFORE, Petitioners respectfully urge the Commission, in the event of the issuance of a final no significant hazards consideration determination with respect to the LILCO application f or a possession only license for Shoreham, to stay the issuance of that license for fifteen working days after publication of the determination and decision to issue the license in the Federal Reaister.
Respectfully submitted, February 11, 1991 m
2.
J4 dees P. McGranary' Mw, Lohnes & Al on Suite 500 1255 Twenty-Third Street, N.W.
Washington, D.C. 20037 (202) 857-2929
' Counsel for the Petitioners shoreham-Wading River Central School District and Scientists and Engineers for Secure Energy, Inc.
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
{
)
In the Matter of
)
Docket No. 50 322
)
l Consideration of Issuance of Amendment
)
Ucense No. NPF-82 To Facility Operating Ucense and
)
Proposed No Significant llazards
)
l Consideration Determination and
)
Opportunity for llearing; long Island
)
l Ughting Co. (Defueled Operating
)
Ucense) (55 Fed. Reg. 34098, August 21,1990))
i
)
CERTIFICATE OF SERVICE I hereby certify that one copy of the Petitioners' Joint Notice of Intent to Petition for Review and Request for Stay is being served upon the following by first-class mail, postage prepaid on this lith day of February,1991:
Atomic Safety and Ucensing Appeal Board Administrative Judge U.S. Nuclear Regulatory Commission Morton H. Margulies, Chairman Washington, D.C 20555 Atomic Safety and Ucensing Board U.S. Nuclear Regulatory Commission l
Administrative Judge Washington, D.C 20555 l
Jerry R. Kline Atomic Safety and Ucensing Board Administrative Judge U.S. Nuclear Regulatory Commission George A. Ferguson Washirsgton, D.C. 20555 ASLBP l
5307 Al Jones Drive l
Edwin J. Reis, Esq.
Columbia Ecach, Maryland 20764 l
Deputy Assistant General Counsel for Reactor Ucensing Michael R. Deland, Chairman i
Mitzi A. Young. Esq.
Council on Environmental Quality l
Senior Supervisory Trial Attorney Executive Office of the President l
Office of the General Counsel Washington, D.C 20500 U.S. Nuclear Regulatory Commission Washington, D.C 20555 Stanley B. Klimberg, Esq.
Executive Director and General Counsel Carl R. Schenker, Jr., Esq.
Long Island Power Authority Counsel, Long Island Power Authority Suite 201 l
O'Melveny & Myers 200 Garden City Plaza 55513th Street, N.W.
Garden, City, New York 11530 Washington, D.C 20004
.o 0,
2 Stephen A. Wake 6 eld, Esq.
Donald P. Irwin, Esq.
General Counsel Hunton & Williams U.S. Department of Energy P.O. Box 1535 Washington, D.C 20585 RIAW Virginia 23212 Gerald C Goldstein, Esq.
Samuel A. Cherniak, Esq.
Office of General Couanel NYS Department of Law New York Power Authority Bureau of Consumer 1633 Broadway Frauds and Protection
- New York, New York 10019 120 Broadway New York: New York 10271 Nicholas S. Reynolds, Esq.
Regulatory Publications Branch David A. Repka, Esq.
Division of Freedom of Winston & Strawn Information A Publications Services 1400 L Street N.W.
Office of Administration Washington, D.C 20005 U.S. Nuclear Regulatory Commission -
Washington, D.C 20555 February 11,1991
,,t M,rhes P. McGranery, Jr Counsel for Petitioners Shoreham Wading River Central School District and Scientists and Engineers l
for Secure Energy,Itx.
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