ML20097C497
| ML20097C497 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/12/1984 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8409170113 | |
| Download: ML20097C497 (4) | |
Text
LILCO, September 12, 1984 rXyJJP u:3 mm UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g4 SEf 14 A11:36 Before the Atomic Safety and Licensing Board kN' In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
LILCO'S RESPONSE TO NRC STAFF MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO LILCO'S
SUMMARY
DISPOSITION MOTIONS On August 6, Long Island Lighting Company filed a Motion for Summary Disposition on the so-called " legal authority contentions" (Suffolk County Contentions 1-10 in this proceeding).
At a con-ference of counsel on August 8, the Board set a schedule for re-sponse, permitting other parties to respond on September 17, forty days from the date of LILCO's Motion.
The Staff's pending motion requests a two-week extension of the Staff's time to respond, advancing as one reason the fact that counsel previously unfamiliar with this case has been recently as-signed responsibility for drafting its papers.
LILCO does not ob-ject to the Staff's request.
LILCO accepts at face value the Staff's representation that the amount of additional time re-quested is needed to prepare its papers adequately, and believes that adequate preparation serves the process well.
In addition, the requested extension would not prejudice the schedule since the findings-drafting process will still be underway during this 3 50?)
8409170113 840912 PDR ADOCK 05000322 0
pon
entire period.
Further, there is a positive virtue to the Staf f's filing last:
traditionally, the Staff has performed an assimila-tive and distilling function on issues in controversy in the hear-ing, reflecting and evaluating the other parties' views.
Particu-larly given the relatively unconventional nature of the pending issues, LILCO believes that the Staf f's performing this traditi-onal role, which presupposes its filing last, would be of benefit to the Board.
LILCO opposes, however, further extension of time for Suffolk County or New York State, as was implicitly requested in their re-sponses to Staff counsel.
Suffolk County's and New York State's present response times are exactly what they asked for on August 8
-- 40 days, or twice the period normally allowed under the Rules of Practice.
The Board granted this extended time over LILCO's obj ec tion.
Tr. 14,034-035.
Neither Suffolk County nor New York State han shown any good cause why this already extended period should be further protracted.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY l?
Donald P.
Irwin Kathy E.
B. McCleskey Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:
September 12, 1984
.6 LILCO, S2ptember 12, 1984 4
CERTIFICATE OF SERVICE
~ XENP In the Matter of eShAC LONG ISLAND LIGHTING COMPANY
-(Shoreham Nuclear Power Station, Unit,N32Y2dd-3AM :36 1)
(Emergency Planning Proceeding) Docket No. S
-I hereby certify that copies of LILCO'S RESPONSE TO NRC STAFF MOTION FOR EXTENSION OF TIME TO FILE RESPONSELTO;LILCO'S
SUMMARY
DISPOSITION MOTIONS were served this.date up6n:th'e fol-t lowing by first-class mail, postage prepaid, or by hand (one asterisk), or by Federal Express (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 Licenuing 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.*
Oreste Russ Pirfo, 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 Hwy.
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 John F.
Shea, Esq.
4350 East-West Highway Twomey, Latham & Shea Bethesda, MD 20814 33 West Second Street P.O. Box 398 Riverhead, NY 11901 I
i
- : \\
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. Brown, Esq.*
1 Lawrence Coe Lanpher, Esq.
Jonathan D.
Feinberg, Esq.
Christopher M.
McMurray, Esq.
New York State Public Service Kirkpatrick, Lockhart, Hill Commission, Staff Counsel Christopher & Phillips 3 Rockefeller Plaza 8th Floor Albany, New York 12223 1900 M Street, N.W.
Washington, D.C.
20036 Spence W. Perry, Esq.
Associate General Counsel MHB Technical Associates Federal Emergency Management 1723 Hamilton Avenue Agency Suite K 500 C Street /
S.W., Ra. 840 San Jose, California 95125 Washington, D.C.
20472 Mr. Jay Dunkelberger Ms. Nora Bredes New York State Energy Office Executive Coordinator Agency Building 2 Shoreham Opponents' Coalition Empire State Plaza 195 East Main Street Albany, New York 12223 Smithtown, New York 11787 a
Gerald C.
Crotty, Esq.
Martin Bradley Ashare, Esq.
i-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
.d v
Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED:
September 12, 1984 5
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