ML20080L007
| ML20080L007 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/14/1984 |
| From: | Dynner A KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080L010 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8402160219 | |
| Download: ML20080L007 (2) | |
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- o 00CKETED U;' C 2/14/84
'8.i E 15 T10 :14 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL
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(Shoreham Nuclear Power Station,
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Unit 1)
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SUFFOLK COUNTY'S MOTION FOR LEAVE TO REPLY TO LILCO'S RESPONSE TO SUFFOLK COUNTY'S MOTION TO ADMIT SUPPLEMENTAL DIESEL GENERATOR CONTENTIONS Suffolk County hereby moves for leave to file with this Board the attached Reply to LILCO's February 7, 1984 Response (the "LILCO Response") to the County's Motion to Admit Supplemental Diesel Generator-Contentions.
This motion is prompted by the novel, if not unique, nature of the LILCO Response, which proposes lower standards of diesel reliability'for a low power license than for a full power license and urges this Board to " rewrite" the
. County's supplemental EDG contentions in a manner which either vitiates or fundamentally changes them.
The LILCO Response urges that litigation of only five components should be necessary prior to low power licensing, and overlooks significant evidence of diesel-inadequacies, including cracks in a cylinder block dis-8402160219 840214 PDR ADOCK 05000322 0
covered last week.
Finally, the LILCO Response clearly shows that
.LILCO;has almost completely misunderstood the supplemental EDG contentions, both in substance and in detail.
Respectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
, ;1 -s ~
Herbert H. Brownf f
Lawrence Coe La%her Alan Roy Dynner Douglas J. Scheidt KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Attorneys for Suffolk County February 14, 1984
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