ML20086R792
| ML20086R792 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/27/1984 |
| From: | Mccleskey K HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL-3, NUDOCS 8403010183 | |
| Download: ML20086R792 (5) | |
Text
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,3 LILCO, February 27, 1984
!,u gjJED COiprONDk'b COCKETE0 L
~
ugnac UNITED STATES OF AMERIC4 NUCLEAR REGULATORY COMMISS0bN9 29 NO M2 cFFrE OF SEC?d" GCCKEilus & SERV N.
Before the Atomic Safety and Licensing 3S^ hrd o
-In.the Matter of-
)
)
LONG ISLAND LIGHTING COMPANY-
)
Docket No. 50-322-OL-3
)
(Emergency Planning (Shoreham Nuclear Power Station, )
Proceeding)
Unit.1)
)
LILCO'S OPPOSITION TO SUFFOLK COUNTY'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DOE
SUMMARY
DISPOSITION MOTIONS LILCO opposes Suffolk County's' request for additional
' time in.which to respond to LILCO's motions for-summary dispo-sition on DOE-related' contentions.1/
Suffolk County states it cannot meet the schedule it agreed to because (1) its lawyers have been busy with other work and (2) LILCO's motions are more
" extensive" than the County had expected.
These reasons do not constitute good cause for an extension of time.
In addition, the County has had LILCO's' motions since February 14, and has waited until. the day before its response is due to request an extension.
' Presumably, the " extensive" nature of LILCO's motions 'as discernible on February 14.
w v s 1/
Counsel for Suffolk-County has informed us about the Coun-ty's Motion for Extension of-Time by phone today and has
,telecopied us a draft of it.
This response is to the draft mo-tion, since we have not yet seen the final version.
bh B403010183 840227 PDR ADOCK 05000322 9-PDR
W 7 '
Because the County's request is not timely and it not supported by. good cause, LILCO asks that the Board deny it.
?The~ Board and parties have spent a great deal of time in this proceeding negotiating schedules (including as recently as last I+
Friday, and at that time-the County made no mention of any de-sire for an extension).
The County should be required to meet those schedules.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY BY k
A/l Jf James p. Chris'tmin ~
~;
Kathy E.
B. McCleskey Hunton'& Williams P. O '. Box 1535 4
707 East Main Street Richmond,'VA 23219 DATOD:- February 27, 1984 N
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,m, e n v
+-
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7 LILCO, February 27, 1984 p
CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY t -
.(Shoreham Nuclear Power Station, Unit 1)
C Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S OPPOSITION TO
-SUFFOLK COUNTY'S MOTION FOR EXTENSION -OF TIME TO RESPGND TO DOE
SUMMARY
LDISPOSITION MOTIONS were served this date upon the fol-
-lowing by'first-class mail, postage prepaid or, as indicated by an asterisk, by hand or, as indicated by two asterisks, by Fed-eral Express:
James A.
Laurenson,*
~ Secretary of_the Commission Chairman U.S.
Nuclear Regulatory Atomic' Safety and Licensing Commission
- Board' Washington,_D.C.
20555 U.S. NuclearMRegulatory
. Commission Atomic Safety and Licensing East-West Tower, Rm.- 402A Appeal Board. Panel 43501 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 4350~ East-West Hwy.
L
- Bethesda, MD:
20814-Bernard M._Bcrdenick, Esq.*
David A. Repka,1Esq.
'Mr. Frederick J. Shon*
Edwin J. Reis, Esq.
Atomi'c Safety and Licensing U.
S. Nuclear Regulatory
' Board Commission LU.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom)
East-West' Tower, Rm. 430 Bethesda, MD 20814
.4350. East-West Hwy.
i:
Bethesda, MD 20814 a
2
.,. t 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 Howard L.
Blau 8th Floor 217 Newbridge Road 1900 M Street, N.W.
Hicksville, New York 11801 Washington, D.C.
20036 Jonathan D.
Feinberg, Esq.
Mr. Marc W.
Goldsmith New York State Energy Research Group DeDartment of Public Service 4001 Totten. Pond Road.
Three EK.pire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates Spence W.
Perry, Esq.*
1723 Hamilton Avenue Associate General Counsel
_ Suite K Federal Emergency Management LSan Jose, California 95125 Agency
'500 C' Street, S.W.
Mr. Jay Dunkleb'erger Room 840 New York State Energy Office Washington, D.C.
20472
-Agency' Building 2
- Empire State Plaza Ms. Nora Bredes
' Albany,'New York 12223 Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street Smithtown, New York 11787 y
. - t.
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
&&fA.
KakhyE/B. ~KcCleskey"'
'~
- Hunton & Williams 707. East Main Street
-P.O. Box 1535 Richmond, Virginia 23212 DATED:
February 27, 1984 w