ML20086T723

Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc

ML20086T723
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/03/1992
From:	Reynolds N, Schenker C LONG ISLAND POWER AUTHORITY, O'MELVENY & MYERS, WINSTON & STRAWN
To:	NRC COMMISSION (OCM)
Shared Package
ML20086T726	List: ML20086T723 ML20086T754
References
CON-#192-12474 OLA-3, NUDOCS 9201070039
Download: ML20086T723 (2)

Text

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I LIPAJanuarfgi)092 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION W M -3 P3 m Eqfore the Commission

)

In the Matter of ) Docket No. 50-322-OLA-3

)

LONG ISLAND LIGHTING COMPANY ) (License Transfer

) Application)

(Shoreham Nuclear Power Station, )

Unit 1) )

- - _ _ _ )

s MOTION OF THE LONG ISLAND POWER AUTHORITY fpR LEAVE TO FILE Ep2EkEliEHTAk_liATERIALS__

The Long Island Power Authority ("LIPA") respectfully requests leave to file the attached memorandum and supplemental legislative history materials in support of LIPA's opposition to Motion for Stay of License Transfer and to Suggestion of Mootness, which was filed with the Commission on December 30, 1991. LIPA requests leave to file the attached materials after the Commission's December 30 deadline because LIPA was unable to obtain them in time to incorporate them into LIPA's December 30 Oppccition. These materials were not readily available to LIPA's counsel, and delays were encountered in obtaining them during the holiday season after receipt of petitioners' December 19, 1991 Suggestion of Mootness Due to LIPA's Imminent Demise.

Or bk ADO l2 }h

The attached legislative materials strongly support LIPA's previous summary of the legislative history of section 2828 of the New York Public Authorities Law, the focal point of petitioners' December 19 Suggestion of Mootness. LIPA respectfully suggests that this legislative history will further clarify the meaning of section 2828 and assist the Commission in resolving petitioners' Suggestion of Mootness. No one will 0e prejudiced by receipt of these legistive history materials.

For the reasons shown herein, LIPA respectfully requnsts that the attached memorandum and supplemental legislative history materials be filed with the Commission.

Respectfully submitttJ, ik 0,_ l~

Of Counsel: William T. Coleman, 3f5 Carl R. Schenker, Jr.

Stanley B. Klimberg John D. Holum President of Shoreham Project Jchn A. Rogovin and General Counsel O'MELVENY & MYERS Richard P. Bonnifield 555 13th Street, N.W.

Deputy General Cnunsel Washington, D.C. 20004 LONG ISLAND POWER AUTHORITY (202) 383-5360 200 Garden City Plaza Garden City, N.Y. 11530 Nicholas S. Reynolds (516) 742-2200 David A. Repka WINSTON & STRAWN 1400 L Street, N.W.

Washington, D.C. 20005 (202) 371-5726 Counsel for the Long Island Power Authority-l Dated: January 3, 1992 l

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