ML20084S386
| ML20084S386 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/22/1984 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20084S387 | List: |
| References | |
| OL-4, NUDOCS 8405240434 | |
| Download: ML20084S386 (1) | |
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LILCO, May 22, 1984 e.
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
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'd".?t i s Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-4
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(Low Power)
(Shoreham Nuclear Power Station,
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Unit 1)
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MOTION FOR PROMPT RESPONSES TO LILCO'S
SUMMARY
DISPOSITION MOTIONS Today, LILCO renews its request for summary disposition on Phases I and II of its low power testing proposal.
As to these phases, there has yet been no dispute by the County or State to LILCO's evidence that no AC power -- and hence no onsite power source -- is necessary to-protect the public even in a LOCA.
No dissent has arisen despite numerous objections by the County and State to other portions of LILCO's Supplemen-tal Motion and despite the following opportunitites for raising contrary facts:
(1) two filings by the County between the March 20 filing of LILCO's Supplemental Motion and the April 6 Memorandum Order of this Board; (2) extensive oral argument on April 4 on the issues in the Supplemental Motion; (3)~ Joint Ob-jections to the April 6 Order; (4) affidavits filed by the County with the Board and with the federal court; (5)
B405240434 840522-6 PDR ADOCK 05000322 O
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4 opportunity for opening statement and cross-examination of LILCO's witnesses on April 24 and 25; (6) opportunity to file direct testimony on April 20; (7) comments filed on May 4 in response to the Commission's April 30 Order; (8) oral argument before the Commission on May 7 at which time LILCO's motions for summary disposition on Phases I and II were pending; and (9) May 10 comments by the County to the Commission in which the County reargued its substantive opposition to LILCO's Sup-plemental Motion.
LILCO's Supplemental Motion was filed more than 2 months ago accompanied by extensive affidavits.
On April 13, LILCO produced thousands of documents in response to the Coun-ty's extensive document requests.
Thus, the County and State have had ample opportunity to review the facts.
If they dis-pute the material facts set forth in LILCO's motions for summa-ry disposition, they should be in a position to enumerate the disputed facts promptly.
Accordingly, this Board should exer-cise its discretion pursuant to 10 CFR S 2.711 and order that responses, if any, to LILCO's motions for summary dispositions be filed by May 30, 1984.
By the 30th, the County.will have had LILCO's May 4 motions 26 days, more than the usual time
_ permitted for response.
10 CFR $ 2.749(a).
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t g Respectfully submitted, LONG ISLAND LIGHTING COMPANY Robert M. foT W ~Earley,-Jr./
Anthony F.
Jessine A. Monaghan Hunton & Williams P. O.
Box 3535 Richmond, Virginia 23212 DATED:
May 22, 1984
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