ML20080H067

Request to Make Change to Attachment a to Util Response to Suffolk County Motion to Admit Supplemental Diesel Contentions.Certificate of Svc Encl

ML20080H067
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/10/1984
From:	Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8402140075
Download: ML20080H067 (5)

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LILCO, February 10pog984 l'3Q{lO O

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NUCLEARREGULATORYCOMMISS$p 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) )

Errata to LILCO's Diesel Generator Response Please make the following change to Attachment A to LILCO's Response to Suffolk County's Motion to Admit Supplemen-tal Diesel Contentions.

Page 4, change the sentence beginning on line 8 to read:

Moreover, reliance on the " Seaworthy Re-port" as a basis for this and other con-tentions related to occurrences on the M. V. Columbia may be inappropriate.

Counsel for Suffolk County. claims that the original wording implied impropriety on the part of the County. That was not LILCO's intent.

Counsel for LILCO became aware of the " Sharp Report" on Friday, February 3. LILCO knew that this report was not in-cluded with material sent to LILCO by the County in early December. The County had represented that this was all of the DR O

o material received as a result of a subpoena to the State of Alaska. LILCO was unaware, however, that the County did not know of the report (which pre-dated the production of documente under the subpoena) or had not received the report through other means until Mr. Dynner brought the matter to our atten-tion on February 8. Although LILCO believes the County had an l obligation to confirm the allegations and assertions made in l its pleading, LILCO did not intend to give the impression that the County deliberately failed to disclose the " Sharp Report."

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

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Anthony F. ~

arlbyf Jr. /.

Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: February 10, 1984 i

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LILCO, February 10, 1984 9

CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I hereby certify that copies of Errata to LILCO's Die-sel Generator Response were served this date upon the following by first-class mail, postage prepaid, or by Federal Express, as indicated by an asterisk.

Lawrence Frenner, Esq.* Secretary of the Commission Adminirirative Judge U.S. Nuclear Regulatory Atonic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris

• Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. George A. Ferguson*

Administrative Judge Martin Bradley Ashare, Esq.

Atomic Safety and Licensing Attn: Patricia A. Dempsey, Esq.

Board Panel County Attorney School of Engineering Suffolk County Department of~ Law Howard University Veterans Memorial Highway 2300 6th Street, N.W. Hauppauge, New York Washington, D.C. 20059 11787 I

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4 Bernard M. Bordenick, Esq.* Stephen B. Latham, Esq.

David A. Repka, Esq. . Twomey, Latham & Shea U.S. Nuclear Regulatory 33 West Second Street Commission P. O. Box 398 Washington, D.C. 20555 Riverhead, New York 11901 Herbert H. Brown, Esq.* Ralph Shapiro, Esq.

Lawrence Coe Lanpher, Esq. Cammer and Shapiro, P.C.

Karla J. Letsche, Esq. 9 East 40th Street Kirkpatrick, Lockhart, Hill, New York, New York 10016 Christopher & Phillips 8th Floor James Dougherty, Esq.

1900 M Street, N.W. 3045 Porter Street Washington, D.C. 20036 Washington, D.C. 20008 Mr. Marc W. Goldsmith Howard L. Blau Energy Research Group 217 Newbridge Road 4001 Totten Pond Road Hicksville, New York 11801 Waltham, Massachusetts 02154 Jonathan D. Feinberg, Esq.

MHB Technical Associates New York State 1723 Hamilton Avenue Department of Public Service Suite K Three Empire State Plaza San Jose, California 95125 Albany, New York- 12223 Mr. Jay Dunkleberger New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223

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' Anthony F. p rte g Jr.

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Hunton & Williams 707 East Main Street P.O. Box 1535-Richmond, Virginia 23212' I

DATED: February.10, 1984 ,

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