ML20087G588
| ML20087G588 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/15/1984 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8403200069 | |
| Download: ML20087G588 (4) | |
Text
LILCO, MatcbETIS, 1984
- uret 84 gg 19 N0 27 UNITED STATES OF AMERICA NUCLEARREGULATCRYCOMMIqSIONr.
mia -
6'fc7yisG'5 SW 3RtWCH Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Decket No. 50-322-OL-3
)
(Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
LILCO'S OPPOSITION TO SUFFOLK COUNTY'S LETTER REQUEST FOR DELAY IN BOARD RULING ON CONTENTION 65 " REBUTTAL" LILCO opposes Suffolk County's letter request of March 14 that this Board delay ruling on pending motions until after Friday, March 16, to the extent that it relates to New York State's motion to file " rebuttal" testimony on Contention 65.
Suffolk County claims (Letter at 3) that it wishes to file what it terms a response to the New York State motion on that date.
The County's request is either feckless or disingenuous.
The only papers authorized to be filed on March 16 on Group I contentions, under the Board's March 2 Scheduling Order, are motions to strike; and the transcript of February 24 (Tr. 3876) makes crystal-clear that the only party as having E. right to reply to State-proffered testimony was LILCO.
Suffolk County took no exception to this ruling.
Thus Cuffolk County has no right to file any papers at all on March 16.
In any event, LILCO needs and expects no help from Suffolk County with its 8403200069 840315 DR ADOCK 05000322 PDR "DSC)5
, March 12 motion to strike the State's proffered testimony on l
Contention 65.
If Suffolk County is intending, on the other hand, to reply as New York State's surrogate to LILCO's March 12 motion to strike, that would be merely an attempt to end-run this Board's repeated injunctions against multiple pleadings, as well as being an unauthorized pleading under the March 2 Scheduling Order.
There is no need to await useless paper from Suffolk County on this issue before ruling.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY By_
i Monald P.
Irwin HUNTON & WILLIAMS 707 East Main Street P.O.
Box 1535 Richmond, Virginia 23212 DATED:
March 15, 1984
d LILCO, March 15, 1984 CFRTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY i
('Shoreham Nuclear Power Station, Unit 1) 1 Emergency Planning Proceeding) Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S OPPOSITION TO SUFFOLK COUNTY'S LETTER REQUEST FOR DELAY IN BOARD RULING ON CONTENTION 65 " REBUTTAL" were served this date upon the follow-ing by first-class mail, postage prepaid, or by hand (as indi-cated by one asterisk), or by Federal Express (as indicated by two asterisks).
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 4350 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 (to mailroom)
East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Ewy.
Bethesda, MD 20814 Stewart M. Glass, Esq.**
Regional Counsel Eleanor L, Frucci, Esq.*
Federal Emergency Management Attorney Agency Atomic Safety and Licensing 26 Federal Plaza, Room 1349 Board Panel New York, New York 10278 U.
S. Nuclear Regulatory Commission Stephen B. Latham, Esq.**
East-West Tower, North Tower Twomey, Latham & Shea 4350 East-West Highway 33 West Second Street Bethesda, MD
'20814 Post Office Box 398 Riverhead, NY 11901 1
e
, Fabian G.
Palomino, Esq.**
Ralph Shapiro, Esq.**
Special Counsel to the Cammer & Shapiro, P.C.
Governor 9 East 40th Street Executive Chamber New York, New York 10016 Room 229 State Capitol James B. Dougherty, Esq.**
Albany, New York 12224 3045 Porter Street Washington, D.C.
20008 Herbert H. Eruwn, Esq.*
Lawrence Coe Lanpher, Esq.
Howard L. Blau Christopher M. McMurray, Esq.
217 Newbridge Road Kirkpatrick, Lockhart, Hill Hicksville, NY 11801 Christopher & Phillips 8th Floor Jonathan D. Feinberg, Esq.
1900 M Street, N.W.
New York State Public Service Washington, D.C.
20036 Commission, Staff Counsel 3 Rockefeller Plaza Mr. Marc W. Goldsmith Albany, New York 12223 Energy Research Group 4001 Totten Pond Road Spence W. Perry, Esq.**
Waltham, Massachusetts 02154 Associate General Counsel Federal Emergency Management MHB Technical Associates Agency 1723 Hamilton Avenue 500 C Street, S.W.
Suite K Washington, D.C.
20472 San Jose, California 95125 Ms. Nora Bredes 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 Martin Bradley Ashare, Esq.
Gerald C.
Crotty, Esq.**
Suffolk County Attorney Counsel to the Governor H. Lee Dennison Building Executive Chamber Veterans Memorial Highway State Capitol Hauppsuge, New York 11788 Albany, New York 12224 VDonald P.
Irwin Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED:
March 15, 1984 1
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