ML20082N950

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Advises That Suffolk County Policy Dept Will Not Prepare Supplemental or Amended Testimony Until Release & Review of Rev 3 to Util Transition Plan
ML20082N950
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 12/05/1983
From: Mark Miller
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To: Kline J, Laurenson J, Shon F
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL-3, NUDOCS 8312080034
Download: ML20082N950 (2)


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WEIIRE S DIEECT DIAL NUMBER FITTEBU FENNETLTANIA ISSSS (202) 452-7022 James A. Laurenson, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 4350 East-West Highway -

Bethesda, Maryland 20814 Re: Docket No. 50-322-OL-3

Dear Administr~ative Judges:

During last Thursday's Conference of Counsel in Bethesda,

' counsel for Suffolk County noted that the County's expert wit-nesses have been reviewing Revision 2 of the LILCO Transition Plan to determine whether that revision affects testimony filed on behalf of the County on November 18, 1983. This review has made clear that, at least with respect to the Suffolk County Police Department ("SCPD") testimony, supplemental or amended testimony should be prepared and file -1 in order to take into account substantive changes made by LILCO in Revision 2.

The Board and parties have now been informed that a

" Revision 3" to the LILCO Plan will be forthcoming in the next few weeks. LILCO has informed the County that Revision 3 will involve changes to Appendix A in order to correct inconsistencies between the underlying traffic modeling relied on by LILCO and the traffic control plan and strategies identified by LILCO in Appendix A. As a practical matter, this means that, insofar as the SCPD witnesses are concerned, Revision 3 will directly per-tain to and, indeed, in some instances respond to matters raised in the SCPD testimony of November 18.

The County concludes that it likely will waste time and

' resources for the~SCPD personnel to prepare supplemental or amended testimony ~on Revision 2, since some of the very matters which are of concern will apparently be changed in Revision 3.

The Board specifically noted at last Thursday's conference that it is concerned about such a waste of time and resources. Under these circumstances,.and since the SCPD testimony will likel'y not.

be heard until sometime in January, the SCPD will not prepare O&

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KrREPATRICE, IACEHART, H11.L, CHRISTOPHER & P1HLLIPS December 5, 1983 Page Two ~

. supplemental or amended testimony until release and review of Revision 3. Thereafter, if it is still determined that the November 18 written testimony should be supplemented or amended, the SCPD will prepare and file such supplemental or amended test-imony.as promptly as possible.

Sincerely, Michael S. Miller MSM:ph cc: Service List 4

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