ML20084A757
| ML20084A757 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/23/1984 |
| From: | Zahnleuter R NEW YORK, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8404250265 | |
| Download: ML20084A757 (5) | |
Text
Tslo UNITED STATES OF AMERICA s
e NUCLEAR REGULATORY COMMISSION I
ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges 00Cyhfp James A.
Laurenson, Chairman USN Dr. Jerry R.
Kline L
Mr. Frederick J.
Shon g4 APR25 go;4g In the Matter of
)
0 Fro r Docket No. 5004Yi2[
W-(EmergencyPlannid@Q(f(dd' ding)
)
AR '
e LONG ISLAND LIGHTING COMPANY
)
)
(Shoreham Nuclear Poral
)
April 23, 1984 Station, Unit 1)
)
)
STATEMENT OF GOVERNOR MARIO M. CUOMO, REPRESENTING THE STATE OF NEW YORK, IN SUPPORT OF THE COUNTY OF SUFFOLK'S RESPONSE TO "LILCO'S MOTION TO SET DEADLINE FOR SUBMISSION OF NEW CONTENTIONS RELATING TO RAC REVIEW" This is in response to "LILCO'S MOTION TO SET DEADLINE FOR SUBMISSION OF NEW CONTENTIONS RELATING TO RAC REVIEW,'" dated April 13, 1984 (hereinafter, "LILCO'S motion").
LILCO is seeking a declaration by the Board that April 20, 1984 be set as the' deadline for any party to submit new conten-tions based on the RAC Review.
LILCO's motion is premature.
It appears that the basis for LILCO's motion is some suspicion that the County of Suffolk or another party may wish to file new, proposed contentions after discovery of FEMA's witnesses is conducted. - There is no apparent basis for LILCO's suspicion.
First, the letter of April 9, 1984Lfrom the County of Suffolk's counsel-to-FEMA's' counsel'(attached _to LILCO's motion) provides no indication that the County of Suffolk intends to seek-discovery, or otherwise-pursue, matters outside the scope of~
contentions _already admitted in this proceeding.
.If, at some time-in the' future, the Countyfof Suffolk or any other. party actually 8404250265 840423 PDR ADOCK 05000322 i
g PDR M()/.
b e
a does seek such discovery, FEMA's counsel or LILCO's counsel will have an ample opportunity to raise an objection at that i
time.
In addition, the County of Suffolk's letter of April 9, 1984 is silent with respect to new, proposed contentions.
At this time, the State of New York has no intention to seek to file new, proposed contentions, and the State of New York is not aware that any other party intends to seek to file new, proposed contentions.
Accordingly, LILCO's motion requests that the Board issue an unnecessary, irrelevant ruling.
The State of New York concurs with the position of the County of Suffolk on this matter and respectfully requests that the Board deny LILCO's motion.
Respectfully submitted, MARIO CUOMO, Gevernor of the State of New York FABIAN G.
PALOMINO, ESQ.
Special Counsel to the Governor of the State of New York BY._ _ f?
L RICHARD J.
HI' R,
ESQ.
Assistant e Special Counsel to the Go rnor of the State of New York Albany, New York April 23, 1984
UNITED STATES OF AMERICA NUCLEAR REGJLATORY COMMISSION
~
ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges James A. Laurenson, Chairman Dr. Jerry R.
Kline Mr. Frederick J.
Shon
)
In the Matter of
)
)
Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY
)
(Emergency Planning Proceeding)
)
(Shoreham Nuclear Power Station, )
April 23, 1984 Unit 1)
)
)
)
CERTIFICATE OF SERVICE I hereby certify that one copy of the STATEMENT OF GOVERNOR MARIO M.
CUOMO, REPRESENTING THE STATE OF NEW YORK, IN SUPPORT OF THE COUNTY OF 2
SUFFOLK'S RESPONSE TO "LILCO'S MOTION TO SET DEADLINE FOR SUBMISSION OF NEW CONTENTIONS RELATING TO RAC REVIEW" has been served to each of the following this 23rd day of April 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. Nuclear Regulatory Commission Washington, D.
C.
20555 W. Taylor Reveley III, Esq.
Hunton & Williams Mr. Frederick J.
Shon P.
O. Box 1535 Administrative Judge 707 East Main Street Atomic Safety and Licensing Board Richmond, Virginia 23212 U.S. Nuclear Regulatory Commission Washington, D.
C.
20555
mmmmmm umm um mim m mi
~.
Mr. Jay Dunkleberger Marc W.
Goldsmith New York State Energy Office Energy Research Group, Inc.
Agency Building 2 400-1 Totten Pond Road Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates James B.
Dougherty, Esq.
1723 Hamilton Avenue, Suite K 3045 Porter Street, N. W.
San Jose, California 95125 Washington, D. C.
20008 Honorable Peter F. Cohalan Mr. Brian McCaffrey Suffolk County Executive Long Island Lighting Company H. Lee Dennison Building Shoreham Nuclear Power Station Veterans Memorial Highway P. O. Box 618 Hauppauge, New York 11788 North Country Road Wading River, New York 11792 Ezra I. Bialik, Esq.
Assistant Attorney General Martin Bradley Ashare, Esq.
Envirommental Protection Bureau Suffolk County Attorney New York State Department of Law
~ D H.
Lee Dennison Building 2 World Trade Center Veterans Memorial Highway New York, New York 10047 Hauppauge, New York 11788 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Par.al U.S. Nuclear Regulatory Commission Ls U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555
~
Stewart M. Glass, Esq.
Docketing and Service Section Regional Counsel Office of the Secretary Federal Emergency Management U.S. Nuclear Regulatory Commission Agency 1717 H Street, N.W.
26 Federal Plaza, Room 1349 Washington, D. C.
20555 New York, New York 10278 s
Bernard M.
Bordenick, Esq.
Nora Bredes David A.
Repka, Esq.
Executive Director U.S. Nuclear Regulatory Commission Shoreham Opponents Coalition Wasnington, D.
P.
20555 195 East East Main Street
~'
Smithtown, New York 11787 Stuart Diamond Environment / Energy Writer Eleanor L. Frucci, Esq.
NEWSDAY Atomic Safety and Licensing Long Island, New York 11747 Board Panel U.S. Nuclear Regulatory Commission Stephen B.
Latham, Esq.
Washington, D. C.
20555 Twomey, Latham & Shea P. O. Box 398 33 West Second Street g
Riverhead, New York 11901
=
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Herbert U. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Karla 3. Letsche, Esq.
,1900 M Street, N. W.,
Suite 800 Washington, D. C.
20036 Spence Perry, Esq.
s Associate General Counsel Federal Emergency Management Agency Washington, D.
C.
20472 l
L RICHARD J.
N ST Assistant t tb ecial Counsel to the Governor of the State of New York Executive Chamber State Capitol Albany, New York 12224
- By Hand 4,
- By Federal Express
- By Telecopier
- By U.S. Express Mai.
Albany, New York April 23, 1984
-_