ML20106E553
| ML20106E553 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/12/1985 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Asselstine J, Bernthal F, Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20106E555 | List: |
| References | |
| CON-#185-542 OL-4, NUDOCS 8502130347 | |
| Download: ML20106E553 (2) | |
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KIRKPATRICK & LOCKHART 1900 M STREET, N.W.
WASHINGTON, D.C. 20036 ONE BOSTON PLACE BOSTON, MA 02106 TEl.EPHONE C0D 452-7000 (617) 97ks4Jo TELEX WM HIPH Ut b[
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February 12, 1985 PrTTsatsca. rA is2:2 TRITER S DIRECT DIAL NUMBER 44:a 194500 (202) 452-7011 (BY HAND)
Nunzio J. Palladino, Chairman Commissioner James K. Asselstine Commissioner Frederick M.
Bernthal Commissioner Thomas M. Roberts Commissioner Lando W.
Zech, Jr.
U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555 Re:
Motion for Stay of Low Power Testing: Docket No. 50-322-OL-4
Dear Members of the Commission:
On February 12, 1984, the NRC authorized an exemption from the regulations to permit issuance of a Phase III/IV testing license for the Shoreham Nuclear Power Plant, which will permit operation of Shoreham at up to 5 percent of rated power.
Enclosed herewith is a "Suffolk County and State of New York Motion for Stay of Phase III and IV License."
The grounds for the stay are the NRC's NEPA violation and the failure of Chairman Palladino to disqualify himself.
Simultaneous herewith, we are filing with the Appeal Board a motion for a stay which alleges as its basis the Miller Board's errors.
The State and County intend to file an Emergency Stay motion with the United States Court of Appeals by 5:00 p.m.
tomorrow if neither the instant motion nor the Appeal Board motion is grant-ed.
However, we of course want to avoid filing unnecessary papers in court.
Thus, to avoid the potential for such unneces-sary filings, we require a decision by the NRC on the instant B502130347 850212
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D PDR COMMS NRCC CORRESPONDENCE PDR
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KmKPATRICK & LOCKHART NRC Commissioners February 12, 1985 Page 2 mention no later than 11:00 a.m.
tomorrow.
We are making a similar request to the Appeal Board.
Sincerely yours, 4lM.A</
Lawrence Coe Lanpher Attorney for Suffolk County LCL/dk Enclosure cc:
Herzel Plaine, Esq. (by hand)
LILCO Counsel (by hand)
Staff Counsel (by hand)
Service List (by first-class mail)
,