ML20093N237
| ML20093N237 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/30/1984 |
| From: | Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-4, NUDOCS 8408010239 | |
| Download: ML20093N237 (4) | |
Text
.
.C74 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
21 Before the Atomic Safety and Licensing BoardL
)j Y1 J!l 3;
=
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
)
Docket No. 50-322-OL-4 (Shoreham Nuclear Power Station,
)
(Low Power)
Unit 1)
)
4
)
)
4 RESPONSE OF SUFFOLK COUNTY AND NEW YORK STATE TO "LILCO'S MOTION FOR PARTIAL RECONSIDERATION OF JULY 18 SECURITY PROCEEDINGS ORDER" E
Suffolk County and the State of New York hereby oppose LILCO's Motion for Partial Reconsideration of the July 18 Security Proceedings Order.
LILCO has not shown any justifica-d tion for altering the Board's schedule.
The County and State w
need the time provided by the Board to confer with consultants and to prepare and submit security contentions, particularly e
given the July 30 commencement of hearing on other low power issues and the overlap of several personnel involved in both
]
matters.
In addition, because the County and State have been 2
prevented from conducting discovery on security issues during the other low power discovery period, the time provided in the Board's order for such discovery is necessary.
Finally, the statements and inferences concerning the I
County's and State's ability to file contentions and such i
which are drawn by LILCO in its Motion are without any foundation s
d u
8408010239 840730 m
PDR ADOCK 05000322 A
- } Q}
O PDR
-95aR,n IN 5
b 4
[ c r
or factual basis.
The plain fact is that LILCO has made a new proposal for operation of Shoreham, and the County and State h-require the time provided by the Board in order to be able to k-deal with the security implications of that proposal.
Accordingly,
[.
there is no need for reconsideration of the Board's July 18
[
ta -
order, and LILCO has failed to demonstrate any basis for its T
3F Motion.
The Motion should be denied.
52 Respectfully submitted, e-A' Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 T-L
/
Brown I
Letsche f Herberu H.
E Karla J.
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 jF Attorneys for Suffolk County i
6 i-.
e Fabian G.
Palomino
- "T' Special Counsel to the Governor cf New York State Executive Chamber, Room 229
+-
Capitol Building Albany, New York 12224 4-Attorney for MARIO M. CUOMO July 30, 1984 Governor of the State of New York h'
l^
=
w
?._
=
G
}
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION p
~
Before The Atomic Safety And Licensing Board i:
)
In the Matter of
)
)
L LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-4
)
(Low Power)
~
(Shoreham Nuclear Power Station,
)
Unit 1)
)
g
)
l l
CERTIFICATE OF SERVICE l
I hereby certify that copies of RESPONSE OF SUFFOLK COUNTY AND NEW YORK STATE TO "LILCO'S MOTION FOR PARTIAL RECONSIDERATION OF g
i JULY 18 SECURITY PROCEEDINGS ORDER," Lated July 30, 1984 have been sent to the following this 30th day of July, 1984 by U.S. mail, first class and by hand when indicated by one asterisk.
Judge M'arshall E. Miller, Chairman
- Edwin Reis, Esq.
- Atomic Safety and Licensing Board Counsel for NRC Staff U.S. Nuclear Regulatory Commission Office of the Executive Legal Washing ton, D.C.
20555 Director U.S. Nuclear Regulatory Commission r
Washing ton, D.C.
20555 Judge Glenn O. Bright m
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Edward M. Barrett, Esq.
Washington, D.C.
20555 Long Island Lighting Company 250 Old Country Road p-Judge Elizabeth B. Johnson
- Mineola, New York 11501 h_
Oak Ridge National Laboratory P.O. Box X, Building 3500 Honorable Peter F. Cohalan Oak Ridge, Tennessee 37830 Suffolk County Executive H. Lee Dennison Building i
g Eleanor L. Frucci, Esq'
- Veterans Memorial Highway Atomic Safety and Licensing Board Hauppauge, New York 11788 e
~5 U.S. Nuc. ear Regulatory Commission Washington, D.C.
20555
i Fabian Palomino, Esq.
- James B. Dougherty, Esq.
Special Counsel to the Governor '
3045 Porter Street, N.W.
Executive Chamber Washington, D.C.
20008 Room 229 State Capitol Mr. Brian McCaffrey Albany, New York 12224 Long Island Lighting Company Shoreham Nuclear Power Station W. Taylor Reveley, III, Esq.
- P.O. Box 618 Anthony F. Earley, Jr., Esq.
North Country Road Robert M. Rolfe, Esq.
Wading River, New York 11792 Hunton & Williams P.O. Box 1535 Jay Dunkleberger, Esq.
707 East Main Street New York State Energy Office Richmond, Virginia 23212 Agency Building 2 Empire State Plaza Mr. Martin Suubert Albany, New York 12223 c/o Congressman William Carney 1113 Longworth House Office Bldg.
Stephen B.
Latham, Esq.
Washing ton, D.C.
20515 John F. Shea, Esq.
Twomey, Latham and Shea Martin Bradley Ashare, Esq.
33 West Second Street Suffolk County Attorney Riverhead, New York 11901 H. Lee Dennison Building Veterans Memorial Highway Docketing and Service Branch Hauppauge, New York 11788 Office of the Secretary U.S. Nuclear Regulatory Commission Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Washington, D.C.
205'55 Commission 1717 H Street, N.W.,
Room 1114 Commissioner Lando Zech, Jr.
- Washing ton, D.C.
20555 U.S. Nuclear Regulatory Commission Commissioner Thomas M. Roberts
- 1717 H Street, N.W.,
Room 1113 U.S. Nuclear Regulatory Washington, D.C.
20555 Commission 1717 H Street, N.W.,
Room 1103 Commissioner James K. Asselstine
- Washing ton, D.C.
20555 U.S. Nuclear Regulatory Commission Commissioner Frederick M.
Bernthal
- 1717 H Street, N.W.,
Room 1149 U.S. Nuclear Regulatory Washington, D.C.
20555 Commission 1717 H Street, N.W.,
Room 1156 Washing ton, 20555
[
KarIa'J. Letsche
KIRKPATRICK, LOCKHART, iILL, CHRISTOPHER &'PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 DATE:
July 30, 1984 4