ML20083N384
| ML20083N384 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/13/1984 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8404190172 | |
| Download: ML20083N384 (6) | |
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LILCO, April 13, 1984 000 METED USNRC N4 APR 18 A10:30 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- l5.5F SECRG,w e RimG 4 SERvir:;
BRA t,'cn Before the Atomic Safety and Licensing Board In the Matter of
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3 LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning (Shoreham Nuclear Power Station, )
Proceeding)
Unit 1)
)
LILCO MOTION TO SET SCHEDULE FOR PARTIAL INITIAL DECISION ON " GROUP I" EMERGENCY PLANNING ISSUES With the testimony on March 20, 1984, all the evidence has been submitted on the " Group I" emergency planning issues:
Contention 23 (" Shadow Phenomenon"), Contention 25 (" Role Con-flict"), and Contention 65 (Evacuation Time Estimates).
The Board and parties now face the task of making their way through over 40 more witness panels on the Group II-A and II-B issues.
LILCO believes it is important to begin resolving the issues as soon as possible.
To that end, we propose that the Board set a schedule for the parties to submit proposed find--
ings, with an eye toward a Partial Initial Decision on the
" Group I" issues.
Our-proposed schedule is the following:
eMay 18, 1984 All parties to file-proposed findings on the Group I issues June 1,~1984 All-parties file reply findings to the'other parties' findings a
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This schedule would permit, we would hope, a Partial Initial Decision by July.
The need for beginning the process of submitting pro-
-posed findings and for a Partial Initial Decision are, we be-lieve, compelling.
First, the sooner proposed findings are prepared, the fresher is the record in the parties' minds and the easier and more reliable the task of writing the findings.
Second, the size and complexity of this litigation virtually compel the conclusion that the process, including the process of submitting findings, must be broken into parts.
To put it another way, if we are to wait until the end of the hearings to begin the proposed finding process, we will'be faced with a mountain of transcripts and, no doubt, requests by some parties for a great deal of time to deal with that mountain.
By con-trast, the pile of transcripts from the Group I hearings alone is_not mountainous and ought to be manageable onethe schedule outlined above, particularly since the parties have already filed _ preliminary findings.
Third, there is precedent in this proceeding for;the filing of proposed findings in phases.
The practice was adopted during the health-and-safety. phase, where proposed findings.were filed in~three phases.1/
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Proposed findings and opinions, and proposed' reply find-ings,-on all' issues;within the' initial scope of"the conten-tions,iexcept Quality Assurance-and Environmental Qualifica-tion, were; filed in the first group; those on=QA and EQ in the' second group; and those on'a. late-developed issue were filed in-
'thecthird group.
' ' ' Accordingly, LILCO hereby moves the Board (1) to adopt the schedule set out above for the filing of proposed findings of fact and conclusions of law on the Group I issues and (2) to issue a Partial Initial Decision on those issues as soon after the proposed findings have been submitted as is practicable.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
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BY p4mesN.
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Christman Hunton & Williams P.O.
Box 1535 707 East Main Street Richmond, VA 23219 DATED:
April 13, 1984
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4 LILCO, April 13, 1984
,y 00LKETED U' IMP.C gEg ATE OF SERVICE Jr;;;E OF SEcatI.nk,the Matter of (Shored $M'h,5 $d ND LIGHTING COMPANY
"%dLLONQ ) lear Power Station, uc Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S MOTION TO SET SCHEDULE FOR PARTIAL INITIAL DECISION ON " GROUP I" EMERGENCY PLANNING ISSUES were served this date upon the following by first-class mail, postage prepaid or, as indicated by an aster-isk, by Federal Express, or, as indicated by two asterisks, by hand:
James A.
Laurenson,**
Secretary.of the Commission Chairman 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 14350 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.
. East-West Tower,.
(to mailroom).
Rm. 430 Bethesda, MD
.20814
~ 4350 East-West Hwy.
Bethesda, MD'
. 20814 9
I
e a
v Eleanor L.
- Frucci, Esq.**
Stewart M. Glass, Esq.*
~ Attorney Regional Counsel Atomic Safety and. Licensing Federal Emergency Management Board Panel Agency U.
S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Highway Stephen B.
Latham, Esq.*
Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street Fabian G.
Palomino, Esq.*
P.O.
Box 398 Special Counsel to the Riverhead, New York 11901
-Governor Executive Chamber Ralph Shapiro, Esq.*
Room 229 Cammer & Shapiro, P.C.
State Capitol 9 East 40th Street Albany, New York-12224 New York, New York 10016 Herbert H.
- Brown, Esq.**
James Dougherty, Esq.*
Lawrence Coe Lanpher, Esq.
3045 Porter Street Christopher McMurray, Esq.
Washington, D.C.
20008 Kirkpatrick, Lockhart, Hill Christopher & Phillips Jonathan D.
Feinberg, Esq.
8th Floor New York State Department of 1900 M Street, _N.W.
Public Service, Staff Counsel Washington, D.C.
20036 Three Empire State Plaza Albany, New York 12223' Mr. Marc W.
. Energy Research Group Spence W.
Perry, Esq.
4001 Totten Pond Road Associate General Counsel Waltham, Massachusetts 02154 Federal Emergency Management Agency MHB Technical Associates 500 C Street, S.W.
1723 Hamilton Avenue Room 840-Suite K Washington, D.C.
20472 San Jose, California 95125 Ms. Nora Bre' des Mr.-Jay Dunkleberger Executive Coordinator New York State Energy Office Shoreham Opponents' Coalition
. Agency Building 2 195 East Main Street Empire State Plaza
.Smithtown, New York 11787 Albany,;New York-12223 s-
3:
- 4; - ;
Gerald C.
Crotty, Esq.
Martin Bradley Ashare, Esq.
' Counsel'to the Governor Suffolk County Attorney Executive Chamber H.
Lee Dennison Building
~
State, Capitol Veterans Memorial Highway Albany, New York 12224 Hauppauge, New York 11788 H
v7 ? ^J mes N.
Christman Hunton & Williams 707-East Main Street P.O.
Box 1535
- Richmond, Virginia 23212 DATED
April ~13, 1984 4
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