ML20080L204
| ML20080L204 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/13/1984 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL-3, NUDOCS 8402160278 | |
| Download: ML20080L204 (5) | |
Text
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LILCO, February 13,guNbED l
U..' iC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t 7.::* E y
q-CCC EIiiJi * : E r';
' M, s Before t.he Atomic Safety and Licensing Board
-In the Matter of
)
-)
-LONG. ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
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 Today LILCO received New York State's February 10, 1984 response supporting Suffolk County's Motion to Change Schedule, which would extend the Group II issues testimony filing date from March 2 to March 12.
LILCO requests the Board's leave, pursuant.to 10 CFR $ 2.230(c), to reply to New York's paper
.because related correspondence from New York received by LILCO u
over the weekend further illustrates the lack of need to extend
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the testimony filing date.
Over the weekend LILCO counsel received the attached let-ter from counsel for the State of New York, indicating that New a
York will restrict its direct testimony on Group II issues to hT two contentions (67 and 97), sponsored by four witnesses, rather than the approximately two dozen contentions sponsored
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[hs 8402160 D G40213 POR A C.4000322 G-
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.. by approximately 20 witnesses which had been indicated earli-er.1_/
To the extent that any consideration of the desirability of extending the date for filing Group II testimony from March 2-to March 12 may have hinged on the complexity of coordinated presentation of issues and a resulting need to provide the par-ties additional time to prepare their direct cases, that con-sideration has now been mooted by New York State's truncation of the scope of its direct participation.2/
Respectfully submitted, LONG ISLAND LIGHTING COMPANY l
By 2
Donald P.
Irwin 1
HUNTON & WILLIAMS
,=
707^ East Main Street-P. O. Box 1535
=
Richmond, Virginia 23212
~c DATED:
February 13, 1984 5
f 1/'
On the basis of this position, New York State has asked to a
cancel most~of the remaining depositions of its potential wit-El nesses; in reliance on it, LILCO has today indicated by letter its agreement to.such cancellation.
2/
As this paper was going out, Mr. Zahnleuter, Mr. Palomi-ano's co-counsel, telephoned to state that New York State also intended to file. testimony on Contention 73.
2 The effect of Mr.
Ej Palomino's letter of February 10 is not changed by this infer-mation, however, since the sponsors of New York's testimony on 5h 5h Contention 73 would be the-same as those sponsoring its testi-Ej mony on Contention 67.
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xEROe TELECOPIER 495:10- 2-84; 7:05Pt1 8047888218:to 1 t>>.LU I IVL t>14'stt_- K ths : YUx4 L1IY F* E Smir or Nsw Yonn Extcutive CHAMeta PAeIAN PALOY.IND MAW 38224 s..:..:e w...........,,
February 10, 1984 Donald P. Irwin, Esquire Eunton & Williams P.O.Bos 1535 707 East Main Street Richmond, Virginia 23212
Dear Don:
[
In light of the current direction of this case, f
as well as scheduling conflicts, limitation on resources, and the scope of the NRC proceeding, the l
State of New York has determined that it will not i
submit testimony on Group II contentions other than 5
by Messrs. Acquario, Knighton, Gibbon and Albertin on Contentions 67 and 97.
Accordingly, the depositions i
scheduled for rebruary 13, 15 and 17 are cancelled.
e Let me reiterate, however, that New York State 5
fully supports the position of Suffolk County and each of Intervencrs' contentions in this proceeding 5
and that the State will of the Group II issues. participate in the litigation
~
Sincerely,
~
h 5
Fabian C. Palomino
=
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=.. -
i LILCO, February 13, 1984 CERTIFICATE OF SERVICE IntheMatte$of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
(Emergency Planning Proceeding) Docket No. 50-322-OL-3 I ~ hereby certify that copies of 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 were served this date upon the-following by first-class mail 7 postage prepaid, or (as indicated by one asterisk) by hand, or las indicated by two asterisks) by Federal Express, or (as indicated by three asterisks) by Telecopier.
James-A. Laurenson,*
Chairman Secretary of the Commission U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing
. East-West Tower, Rm. 402A Appeal Board Panel 4350 East-West Hwy.
U.S. Nuclear Regulatory Bethesda,-MD 20814 Commission Washington, D.C.
20555 Dr. Jerry R. Kline*
Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel
'U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 427 Washington, D.C.
20555 5
i 4350 East-West Hwy.
Bethesda, MD
'20814 Bernard M. Bordenick, Esq.*
David A. Repka, Esq.
Mr. Frederick J.
Shon*
Edwin J. Reis, Esq.
Atomic Safety and Licensing U. S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom) g East-West Tower, Rm. 430 Bethesda, MD 20814 G
4350 East-West Hwy.
5 Bethesda, MD 20814 Stewart M. Glass, Esq.**
5
.3 Regional Counsel Elea~nor L.
Frucci, Esq.*
E Attorney Federal Emergency Management 5
Agency Atomic Safety and Licensing 26 Federal Plaza, Room 1349 5
Board Panel is New York, New York 10278 U. S. Nuclear Regulatory y
2 Commission M
Stephen B. Latham, Esq.**
East-West Tower, North Tower Twomey, Latham & Shea te 4350 East-West Highway 33 West Second Street y
Bethesda, MD 20814 Post Office Box 398 Riverhead, NY 11901 a
==
E
w '* Fabian G. Palomino, Esq.***
Ralph Shapiro, Esq.**
Special Counsel to the Governor Cammer & Shapiro, P.C.
Executive Chamber 9 East 40th Street Room 229 New York,.New York 10016 State Capitol James B.
Albany, New York 12224 Dougherty, Esq.**
3045 Porter Street Wr;hington, D.C.
20008 Herbert H. Brown, Esq.*
' Lawrence Coe Lanpher, Esq.
Howard L. Blau Christopher M. McMurray, Esq.
217 Newbridge Road Kirkpatrick, Lockhart, Hill Hicksville, NY 11801 Christopher & Phillips 8th-Floor Jonathan D. Feinberg, Esq.
1900 M Street, N.W.
New York State Public Service Washington, D.C.
20036 Commission, Staff Counsel 3 Rockefeller Plaza Mr. Marc W. Goldrmith Energy Research Group Albany, New York 12223 4001 Totten Pond Road Spence W. Perry, Esq.**
Waltham,' Massachusetts 02154 Associate General Counsel MHB Technical Associates Federal Emergency Management
~1723 Hamilton Avenue Agency Suite K 500 C Street, S.W.
s Washington, D.C.
20472 San Jose, California 95125 E
Mr. Jay Dunkleberger Ms. Nora Bredes 5
2 New York State Energy Office Executive Coordinator Agency Building 2 Shoreham Opponents' Coalition p
Empire State Plaza 195 East Main Street h
5 Smithtown, New York 11787 Albany, New York 12223
=
Gerald C. Crotty, Esq.**
Martin Bradley Ashare, Esq.
=..
Counsel to the Governor Suffolk County Attorney 1
Executive Chamber Lee Dennison Building H.
State Capitol Veterans Memorial Highway 5
Hauppauge, New York 11788 s:
Albany, New York. 12224-5
~~n
)
ew Donald P.
Irwin
'E HUNTON & WILLIAMS
[=l 707 East Main Street EH Post Office Box 1535 Richmond, Virginia 23212 l$
am WE1
. DATED:
February 13, 1984
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