ML20132C654
| ML20132C654 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/23/1985 |
| From: | Kelley E, Palomino F NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#385-615 OL-3, NUDOCS 8509270109 | |
| Download: ML20132C654 (6) | |
Text
1 m CORRFEPUni"M September 23, 1985 '
UNITED STATES OF AMERICA U
U NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND _ LICENSING APPE B AR CFT'CE Or SEUS 4 '
DCCXE imG le S E P'O 8 9N ;H In the Matter of
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)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1)
)
)
JOINT MOTION OF NEW YORK STATE AND SUFFOLK COUNTY FOR AN EXTENSION OF TIME Pursuant to 10 C.F.R. Section 2.730, the State of New York and the County of Suffolk hereby requests an extension of time of one (1) week, until October 7,1985, in which to file their briefs on appeal from the Partial Initial Decision on emergency planning of April 17, 1985.
In support of this request, the State and County state as follows:
The undersigned is the only attorney who is assigned to and is preparing the State's brief in support of the appeal.
As previously explained to this Board, the undersigned did not participate in most of the hearings below.
In addition to the considerable task of familiarizing himself with extensive portions of the record, the proposed finding of fact, the preparation of the brief is complicated by the circumstance that the undersigned must address in excess of 300 pages of that opinion in a 70 pa'ge brief.
It is further complicated by the fact that the undersigned must address t'wo (2) issues -- Contentions 22 and 26.B. -- which 8509270109 850923 PDR ADOCK 05000322 k S.OC,
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. were excluded by the Licensing Board.
In addition, the undersigned has and will experience slippage of time in preparation due to the facts that he has been unable to obtain adequate secretarial assistance during the recent high holy days of the Hebrew faith, and because he has to prepare for and argue another appeal before this Board on Thursday, September 26, 1985.
The undersigned has been diligently progressing the work on this brief in additional to his regularly assigned duties, but will not be able to complete without the addition one (1) week 's time because of the circumstances outlined above.
The attorneys for the County of Suffolk were recently replaced.
The new attorneys assigned to the brief have
- l the same problems of familiarization and complexity as
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explained above.
They als have similar problems with time slippage in their preparation of their brief.
l The counsels for the State and County have
,4 l
contacted the counsel for the Applicant and has been i
authorized to state that the Applicant does not object to the grant of the instant request.
The undersigned has also contacted the counsel for the Staff of the Nuclear Regulatory Commission and has been authorized to state that the Staff a
j does not have objection to this request.
4 i
. WHEREFORE, the State of New York and the County of Suffolk respectfully requests an extension of one (1) week, until October 7, 1985, for the filing of their briefs in support of their appeal from the P.I.D. on emergency planning of April 17, 1985.
Respectfully submitted, STATE OF NEW YORK JZ
/
By:
Fabian G. Palomino Special Counsel.to the Governor Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for the Governor of the State of New York
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SUFFOLK COUNTY
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By:
WPAt f A
l
@ Eugene R. tellef '
f For Martin Bradley Ashare i
County Attorney for the County of Suffolk f
H. Lee Dennison Building l
Veterans Memorial Highway l
Hauppauge, New York 11788 i
s
aY.JATED CORRFEPONDMW SeptemberhNkh[985 CERTIFICATE OF SERVICE
'85 SEP 26 A10:38 0FF ;C t O c g3 3,fjg 00CETING 4 SEg.
In the Matter of HAN :H LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 (Emergency Planning)
I hereby certify that copies of New York State's and Suffolk County's MOTION FOR AN EXTENSION OF TIME were served this date upon the following by first-class mail, postage prepaid or, as indicated by an asterisk, by telecopier.
Hon. Alan S. Rosenthal, Chairman
- Hon. Gary J. Edles*
Hon. Howard A. Wilber*
Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission East-West Tower, North Tower 4350 East-West Highway Bethesda, Maryland 20814 Martin Bradley Ashare, Esq.
Donna Duer, Esq.
Suffolk County Attorney Atomic Safety and Licensing H. Lee Dennison Building Board Panel Veterans Memorial Highway U.S. Nuclear Regulatory Comm.
Hauppauge, New York 11788 East-West Tower, North Tower 4350 East-West Highway Mary Gundrum, Esq.
Bethesda, Maryland 20814 Assistant Attorney General 2 World Trade Center James B. Dougherty, Esq.
Room 4614 3045 Porter Street.
New York, New York 10047 Washington, D.C.
20008 Stewart M. Glass, Esq.
Jay Dunkleberger, Esq.
Regional Counsel New York State Energy Office Federal Emergency Management Agency Building 2 Agency Empire State Building 26 Federal Plaza, Room 1349 Albany, New York 12223 New York, New York 10278 Stephen B. Latham, Esq.
Kirkpatrick & Lockhart, Esgs.
John F. Shea, Esq.
1900 "M" Street, N. W.
Twomey, Latham & Shea Washington, D.C.
20036 33 West Second Street P.O. Box 398 Riverhead, New York 11901
- Telecopied
. Bernard M. Bordenick, Esq.
Mr. Martin Shubert Robert G. Perlis, Esq.
c/o Hon. William Carney Edwin J. Reis, Esq.
1113 Longworth House Office Office of the Executive Legal Building Director Washington, D.C.
20515 U. S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Docketing and Service Branch (3)
Atomic Safety and Licensing Board Office of the Secretary Panel U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Ralph Shapiro, Esq.
Robert E. Smith, Esq.
Cammer and Shapiro, P.C.
Rosenman, Colin, Freund, Lewis 9 East 40th Street
& Cohen New York, New York 10016 575 Madison Avenue New York, New York 10022 Jonathan D. Feinberg, Esq.
New York State Department of Spence M. Perry, Esq.
Public Service, Staff Counsel Associated General Counsel Three Rockefeller Plaza Federal Emergency Management Agency Albany, New York 12223 500 "C" Street, S. W.
/
Room 840 Hunton & Williams, Esgs.
Washington, D.C.
20472 707 East Main Street Richmond, Virginia 23219 Hon. Morton B. Margulies, Chairman Frederick J. Shon Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East-West Tower, Room 402A U.S. Nuclear Regulatory Comm.
4350 East-West Highway East-West Tower, Room 430 Bethesda, Maryland 20814 4350 East-West Highway Bethesday, Maryland 20814 Dr. Jerry R. Kline Atomic Safety & Licensing Board Secretary to the Commission U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory East-West Tower, Room 427 Commission 4350 East-West Highway Washington, D.C.
20555 Ms. Nora Bredes Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street Smithtown, New York 11787 l
F....
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li l 1' l*
- t FABIAN G. PALOMINO Special Counsel to the Governor i
Executive Chamber, Room 229
- l Capitol Building Albany, Mew York 12224 Attorney for the Governor
- j of the State of New York 1
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By:
FABIAN G. PALOMINO l
Special Counsel to the Governor
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i Sworn to before me this 23th day of September, 1985
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