ML20129J796
| ML20129J796 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/19/1985 |
| From: | Irwin D LONG ISLAND LIGHTING CO. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#385-913 OL-3, NUDOCS 8507230350 | |
| Download: ML20129J796 (5) | |
Text
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o LILCgd;MtEDy 19, 1985 ussr UNITED STATES OF AMERICA s5 JUL 22 A11 :33 NUCLEAR REGULATORY COMMISSION OFFICE 0: SECRtI Wl 00CKETtNG i'. SER'MJ BRANCH Before the Atomic Safety and Licensing Appeal Board In the Matter of
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)
i LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3 l
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(Emergency Planning Proceeding)
(Shoreham Nuclear Power Station,)
Unit 1)
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LILCO'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE BRIEF ON LEGAL AUTHORITY-RELATED ISSUES On July 11, the Staff requested, with LILCO's consent, a four-day extension of time, from Monday July 15 to Friday July 19, to file its brief on legal authority-related issues, based on per-i solfal hardship to Staff counsel.
Staff counsel accurately repre-i sen.ted that LILCO did not at that time request a corresponding ex-ter) ion of its filing deadline of Tuesday, July 23, but would evalsate the need for it upon review of the Staff's brief.
In agreeing to the Staff's requested extension on the terms recited, LILCO counse?
purely by inadvertence, overlooked the l
fact that a weekend followed immediately upon the Staff's revised briefi~ng deadline, and that only one business day would remain be-tween the Staff's revised deadline and LILCO's current one.
The vagaries of weekend document service are such as to commend an an-ticipatory request for a brief extension of LILCO's deadline.
Ac-cordingly, LILCO requests a two-day extension of time, from 8507230350 850719 ADOCK0500g2
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DR
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, Tuesday July 23 to Thursday July 25, to file its responsive brief.
If'the requested' extension is granted, LILCO will ensure service by hand that day on all parties in the Washington area and service by Federal Express on all other active parties.
LILCO believes that the shortness of time to review and re-spond to the Staff's brief, the brevity of the requested exten-sion, and the amount of time remaining before the oral argument on this issue establish good cause for and the absence of prejudice from the requested extension.
LILCO has requested the consent of counsel for the Regulatory Staff, the Suffolk County Attorney's Office, the firm of Kirkpatrick & Lockhart, and the State of New York, and is autho-rized to state that they do not oppose the requested extension.
Respectully submi ed,
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Irwin James N.
Christman Counsel for Long Island Lighting Company Hunton & Williaims 707 East Main Street P.O.
Box 1535 Richmond, VA 23212 DATED:
July 19, 1985
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LILCO, July 19, 1985 00ty?",
us.Q CERTIFICATE OF SERVICE
& 22 All34 In the Matter of c7p_
(ShorehamNuclearPowerStation, Unit 1)g.0#'g'jjg,gj((
LONG ISLAND LIGHTING COMPANY Og-52 g
EMy Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S Motion For Ex-tension of Time To File Responsive Brief on Legal Authority-Related Issues were served this date upon the following by first-class mail, postage prepaid or, as indicated by an aster-isk, by Federal Express, or, as indicated by two asterisks, by telecopier:
Morton B. Margulies, 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 Licensi.g 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.**
Sherwin Turk, 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 j
4350 East-West Hwy.
j Bethesda, MD 20814 1
f
1 Donna Duer,-Esq.
Stewart M. Glass, Esq.*
Attorney Regional Counsel Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U.
S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Highway Stephen B.
Latham, Esq.*
Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street Fabian G. Palomino, Esq.**
P.O. Box 398 Special Counsel to the Riverhead, New York 11901 Governor Executive Chamber Ralph Shapiro, Esq.
Room 229 Cammer & Shapiro, P.C.
State Capitol 9 East 40th Street Albany, New York 12224 New York, New York 10016 Mary Gundrum, Esq.*
James Dougherty, Esq.
Assistant Attorney General 3045 Porter Street 2 World Trade Center Washington, D.C.
20008 Room 4614 New York, New York 10047 Jonathan D.
Feinberg, Esq.
New York State Department of Herbert H.
- Brown, Esq.**
Public Service, Staff Counsel Lawrence Coe Lanpher, Esq.
Three Rockefeller Plaza Christopher McMurray, Esq.
Albany, New York 12223 Kirkpatrick & Lockhart 8th Floor Spence W.
Perry, Esq.
1900 M Street, N.W.
Associate General Counsel Washington, D.C.
20036 Federal Emergency Management Agency MHB Technical Associates 500 C Street, S.W.
1723 Hamilton Avenue Room 840 Suite K Washington, D.C.
20472 San Jose, California 95125 Ms. Nora Bredes Mr. Jay Dunkleberger Executive Coordinator New York State Energy Office Shoreham Opponents' Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, New York 11787 Albany, New York 12223
. Gerald C. Crotty, Esq.
Martin Bradley Ashare, Esq.**
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 Alan S.
Rosenthal, Chairman **
Mr. Howard A. Wilber**
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Gary J.
Edles**
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory i
Commission
[
Washington, D.C.
20555 i
Dodald P.
Irwin Hunton & Williams 707 East Main Street P.O.
Box.1535 Richmond, Virginia 23212 i-DATED:
July 19, 1985 b