ML20100F297

From kanterella
Jump to navigation Jump to search
Forwards Security Contentions,Jointly Proffered by State of Ny & Suffolk County & Request for Clarification Re Alab 850322 Memorandum & Order.Revised Contentions Supersede 840828 Submission.W/O Contentions
ML20100F297
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 04/01/1985
From: Lanpher L
KIRKPATRICK & LOCKHART
To: Bright G, Johnson E, Joseph Kelly
Atomic Safety and Licensing Board Panel
Shared Package
ML20100F302 List:
References
CON-#285-365 ALAB-800, OL-4, NUDOCS 8504040284
Download: ML20100F297 (2)


Text

o b 4

KIRKPATRICK & LOCKHART 1900 M STREET, N.W.

WASHINGTON, D.C. 20036 3(p p gg' ONE BOSTON PLACE

' ! % '7 -' BOSTON. MA 02108 TELEPHONE 002) 452-7000 (617) 975 5400 O U 1428 BluC AVENUE m1COPnc=45="'oS /H -2 ,111 :54 " " " " '

0 05) 3744112

. 1500 OUNTR BUILDtNG LAWRENCE CoE LANPHER PITTS8URCH, PA 15222 aca 4u 7en April 1, 198'5, , '~ '" ,,,3 ,3%

2 ; . >.

By Hand James L. Kelley, Esquire, Chairman Ms. Elizabeth B. Johnson Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Long Island Lighting Co. (Shoreham Nuclear Power Plant); Docket No.

50-322-OL-4 (Security Remand)

Dear Members of the Board:

Enclosed you will find security contentions jointly proferred by the State of New York and Suffolk County and a Request for Clarification of matters in the Board's March 22 Memorandum and Order. The contentions contain safeguards information and thus are being restricted in their distribution.

The Request for Clarification is being sent to the entire service list.

A word of explanation is in order concerning the enclosed contentions. So much has happened since the prior contentions were submitted on August 28, 1984 -- chiefly, amendments to LILCO's security plan, LILCO's March 15 submittal pertaining to additional security measures, ALAB-800, and the Board's March 22 Memorandum and Order -- that the State and County decided that instead of resubmitting the prior contentions, plus adding new ones, it was best to submit revised contentions that supercede the August 28 submission.

The four contentions submitted today necessarily overlap in some respects and we have cross-referenced in instances to avoid repetition. Generally, however, the four contentions cover the following points:

8504040284 850401 PDR ADOCK 05000322 G PDR  %

d

-,e

', KIRKPATRICK & LOCKHART Members of the Board April 1,-1985 Page. 2 Contention 1. Whether LILCO complies with 10 CFR S 73.55 Contention 2. Safeguards risks of Shoreham low power operation using the alternate AC power system. (Under the March 22 Order, the safeguards risks bear on Section 73.55 compliance, as well as on exemption matters. See Order at page 10).

Contention 3. Exemption matters.

Contention 4. Offsite power matters.

Sincerely yours, Lawrence Coe Lanpher LCL:me Enclosures cc: Service List