ML20092K934

Requests That NRC Summarily Dismiss 22 Untimely,Unauthorized Pages of Rehashed Argument Filed in Petitioner Opposition to NRC Recommendation for Approval of License Transfer

ML20092K934
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/21/1992
From:	Irwin D, Schenker C HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO., LONG ISLAND POWER AUTHORITY, O'MELVENY & MYERS
To:	Curtiss J, Remick F, Rogers K, Selin I, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20092K940	List: ML20092K934 ML20092K951
References
CON-#192-12601 OLA-3, NUDOCS 9202260076
Download: ML20092K934 (2)

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l February 21, 1992 l BY FAI j The Hon. Ivan Solin, Chairman Commissioner Kent.oth C. Rogers  % '

commissioner Forrest W. Romick

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Commissioner James W. Curtiss pg0 3 Commissioner E. Gail de Planque United States Nuclear Regulatory Commission di FEB 21592 'n '

11555 Rockville Pike *~

ly Rockvillo, Maryland 20852 gyMg"cn DLWARO  %

Long Island Lighting Company # 1 g

(Shoreham Nuclear Power Statioq)

NRC Docket 50-322 ~O C D Recuest for Transfer of Onoratina Licenga

Dear Chairman Selin and Members of the Commission:

Long Island Lighting Company (LILCo) and the Long Island Power Authority (LIPA) request that the commission summarily dismiss the 22 untimely, unauthorized pages of rehnshed argument filed last evening in " Petitioners' (Shoreham-Wading River Central School District and Scientists and Engineers for Secure Energy) Opposition to Nuclear Regulatory Commission Staff Recommendation for Approval of License Transfer." Virtually nothing in that " opposition" is anything other than reworking of earlier arguments fully natured in papers already on file with the commission, or untimely amplification, without good cause, of material that could and should havo been argued earlier.

LILCO and LIPA, as the Commission knows, are vitally concerned lest the commission's fair-minded interest in full exploration of kegitimate issues be subverted for purposes of delay pure and simple, to their great and unnecessary expense and to the demeaning of the Commission's process. Neither safety issues nor environmental concerns have been colorably raised by Petitionerst no issues, indeed, independent of the utterly moot ,

nolicy issue of oporation of Shoreham.

LILCO and LIPA do not wish to add materially to the pile of paper before the Commission, and thereby play into the hands of potential further delay. We therefore urge the Commission to disregard the " Opposition," to approve the license amendment-authorizing transfer of Shoreham's license from LILCO to LIPA at its next meeting, and to make that approval immediately effective, without a housekeeping stay.

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1l In the event the Commission desires to inspect the arguinents of Petitioners in more detail, we submit the enclosed ,

Memorandum in Response for the Commission's c..>nvenience.

Sincorely yours, Donald P. Irwin N$ta %tfR. Schenker,4I .

Carl Hunton & Wil.1.iams O'Melveny & Myers 951 East Byrd Street 555 13th Street Richmond, Va. 23219 Washington, D.C. 20004 Counsel for Long Island Counsel for Long Island Lighting Company Power Authority cci James P. McGranery, Jr., Esq. (by fax)

Edwin J. Reis, Esq. (by fax)

Charles E. Mullins, Esq. (by fax)

Samuel J. Chilk (by fax)

Nicholas S. Reynolds, Esq.

Stanley B. Klimberg, Esq.

Samuel A. Cherniak, Esq.

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