ML20080K996
| ML20080K996 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/14/1984 |
| From: | Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL-3, NUDOCS 8402160214 | |
| Download: ML20080K996 (5) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 E115 A10 54 Before the Atomic Safety and Licensing Board..
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)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3 (Emergency Planning)
)
(Shoreham Nuclear Power Plant,
)
Unit 1)
)
)
SUFFOLK COUNTY'S RESPONSE TO LILCO'S MOTION FOR LEAVE TO REPLY AND REPLY TO NEW YORK STATE'S RESPONSE IN SUPPORT OF SUFFOLK COUNTY'S MOTION TO CHANGE SCHEDULE On February 13, 1984, LILCO filed a Motion For Leave To Reply And Reply To New York State's Response In Support Of Suffolk County's Motion To Change Schedule (hereinafter Reply).
In its Reply, LILCO cites a recent decision by the State of New York to reduce the number of contentions on which it will be presenting direct testimony.b!
Based on the State's position, LILCO stated in its Reply:
To the extent that any consideration of the desirability of extending the date for filing Group II testimony from March 2 to March 12
[ sic] may have hinged on the complexity of coordinated presentation of issues and a resulting need to provide the parties addi-tional time to prepare their direct cases,
'1! While LILCO's Reply notes that the State of New York will be submitting direct testimony on Contentions 67 and 97, it is the County's understanding from discussions with counsel for the State that the State will also be submitting direct testimony on Contentions 66 and 73.
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that consideration has now been mooted by New York State's truncation of the scope of its direction participation. (Footnote omitted).
Reply at 2.
LILCO's Reply totally misses the point of the County's Motion to Change Schedule (hereinafter Motion).
Both the County's Motion and the State's Responses! in support of that motion were based upon a delay in the issuance of FEMA's RAC review and the consequent need to revise the schedule for filing Group II testimony by twelve days so that the parties could address the FEMA review in their direct testimony.
Neither the County nor the State have premised their arguments in support of
' the County's Motion on the " complexity of coordinated presenta-tion of issues and a resulting need to provide the parties addi-tional time to prepare their direct cases.
." Therefore, LILCO's Reply is not relevant to the issue placed before the Board by the. County's motion.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney H.
Lee Dennison Building Veterans Memorial Highway Hauppauge, New York 11788 e
Herbeft H. Bf6wn
' ~
Christophe: M. McMurray KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, NW Washington, DC 20036 Attorneys for Suffolk County Dated:
February 14, 1984
$! New York State's Response To Suffolk County Motion To Change Schedule.(February 10, 1984).
l
-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In.the-Matter of
)
)
LONG. ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S RESPONSE TO LILCO'S MOTION FOR LEAVE TO REPLY AND REPLY TO NEW YORK STATE'S RESPONSE.IN SUPPORT OF SUFFOLK COUNTY'S MOTION TO CHANGE SCHEDULE dated February 14, 1984,- have been served to the following this 14th day of February 1984 by U.S. mail, first class, except as otherwise noted.-
James A. Laurenson, Chairman
- Ralph Shapiro, Esq.
Atomic Safety and Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D.C.
20555 New York, New York 10016 Dr. Jerry.R. Kline
- Howard.L. Blau, Esq.
. Administrative Judge 217 Newbridge Road
' Atomic Safety and Licensing Board Hicksville, New York 11801 U.S.
Nucleat Regulatory Commission Washington, D.C.
20555 W. Taylor Reveley. III, Esq.##
Hunton & Williams P.O.
Box 1535 707 East Main Street Mr'.' Frederick J. Shon
- Richmond, Virginia 23212 LAdministrative Judge Atomic Safety and Licensing Board Mr. Jay Dunkleberger U.S. Nuclear Regulatory Commission New York State Energy Office Washington, D.C.
20555 Agency Building 2 Empire State Plaza Edward M..Barrett, Esq.
Albany, New York 12223
-General Counsel Long. Island Lighting Company James B. Dougherty, Esq.
250 Old Country Road 3045. Porter Street, N.W.
Mineola,-New York 11501 Washington, D.C.
20008
r: -
1tE. Brian McCaffrey -
Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea 175 East Old Country Road P.O.
Box 398 Hicksville, New York 11801 33 West Second Street Riverhead, New York 11901 Jeff Smith Marc W. Goldsmith
'Shoreham Nuclear Power Station Energy Research Group, Inc.
P.O.
Box 618 400-1 Totten Pond Road North Country Road Waltham, Massachusetts 02154 Wading River, New York 11792 Joel-Blau, Esq..
MHB Technical Associates New York'Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter F. Cohalan Suffolk County Executive Martin Bradley Ashare, Esq.
H. Lee Dennison Building Suffolk County Attorney.
Veterans Memorial Highway
'H.
Lee Dennison Building Hauppauge, New York 11788 Veterans Memoricl Highway Hauppauge, New York 11788 Atomic Safety and Licensing Board Ezra I. Bialik, Esq.
Panel.
Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Washington, D.C.
20555 Bureau New York State Department Docketing and Service Section of Law
- Office.of the Secretary 2 World Trade Center U.S. Nuclear Regulatory Commission New York, New York 10047 1717 H Street, N.W.
Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Bernard M.
Bordenick, Esq.*
U.S. Nuclear Regulatory
_ David A. Repka, Esq.
Commission U.S.; Nuclear Regulatory Commission Washington, D.C.
20555
. Washington, D.C.
20555 Jonathan D. Feinberg, Esq.#'
Stuart Diamond Staff Counsel Environment / Energy Writer New York State Public NEWSDAY
-Service Commission
'Long Island, New York 11747 3 Rockefeller Plaza Albany, New York 12223
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Stewart M. Glass, Esq.
Gerald C. Crotty, Esq.
Regional Counsel Counsel to the Governor Federal Emergency Management Executive Chamber Agency State Capitol 26 Federal Plaza, Room 1349 Albany, New York 12224 New York, New York 10278 Fabian Palomino, Esq.#
Special Counsel to Nora Bredes the Governor
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Executive Director Executive Chamber, Room 229 Shoreham Opponents Coalition State Capitol 195 East Main Street Albany, New York 12224 Smithtown, New York 11787
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Eleanor L.
Frucci, Esq.*
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Spence Perry, Esq.
Associate General Counsel Federal Emergency Management Agency Washington, D.C.
20472 Y
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As ChristopKer M.
McMQrray
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KIRKPATRICK, LOCKHART, HILL, '/
CHRISTOPHER & PHILLIPS 1900 M Street, NW, Suite 800 Washington, DC 20036 DATE:
February 14, 1984 ByJHand
'## By Telecopy By Federal Express l
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