ML20073A769
| ML20073A769 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/05/1991 |
| From: | Mcgranery J DOW, LOHNES & ALBERTSON, SCIENTISTS & ENGINEERS FOR SECURE ENERGY, SHOREHAM, NY |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20073A773 | List: |
| References | |
| CON-#291-11642, CON-#291-11643, CON-#291-11644 LBP-87-26, OLA, OLA-2, NUDOCS 9104230357 | |
| Download: ML20073A769 (2) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE SECRETARY OT THE COMMISSIO!v a.,.
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- /!L' In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket Hos. 50-322
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50-322-OLA, and
-(Shoreham Nuclear Power Station,
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50-322-OLA-2 Unit 1)
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PETITIONER $' JOINT MOTION FOR LEAVE TO FILE JOINT REPLY Pursuant to 10 C.F.R.
I 2.730(c), Petitioners move the Secretary of the Commission to grant them leave to file a Reply (attached hereto and lodged herewith) to the four oppositions to their Joint Motion to Stay License Issuance and Other Matters in the above-captioned proceedings for good cause shown as detailed r
below.
Petitioners' Joint Motion was opposed by a blizzard (69 pages) of oppositions from two parties and two amici.
Not only would the filing of a reply be helpful to the Commission in sorting out the similarities and contradictions among these various oppositions, it would also be useful to the Commission in identifying the concessions by silence contained within these-oppositions and correcting various errors of fact and law within the"oppositions.
In addition, the reply.would. allow Petitioners to address certain new legal arguments which could not have been anticipated in their original motion (for example, the Long Island Power Authority's res iudicata argument relying on Restatement (Second) of Judgments (LIEA at 8)).
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n 9 e I Petitioners also note that this is not a case where i
there have been "already exhaustive filings and arguments on the i
issue," but rather the first notion addressing stays of j
Commission action on comerehensive bases in a case of admittedly national significance.
fag Lono Island Liahtina Co. (Shoreham Nuclear Power Station, Unit 1), LBP-87-26, 26 NRC 201, 205 (1987).
WHEREFORE, Petitioners urge the Secretary to grant leave to file the Joint' Reply for good cause shown.
Respectfully submitted, 8'c < w a+
April'5, 1991
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J $ s P. McGranary, Jf/
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- @ite 500-, Lohnes &-Albert (on Su 1
1255 Twenty-Third Street, N.W.
Washington, D.C.
20037 202-857-2929-i Counsel for Petitioners l
Shoreham-Wading River Central l
School District and Scientists and i
Engineers for Secure Energy, Inc.
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