ML20133F385
| ML20133F385 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/04/1985 |
| From: | Kelley E SUFFOLK COUNTY, NY |
| To: | Edles G, Rosenthal A, Wilber H NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#485-734 OL-3, NUDOCS 8510110004 | |
| Download: ML20133F385 (4) | |
Text
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COUNTY OF SUFFOLK o
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m PETER F. COHALAN SUFFOLK COUNTY EXECUTIVE
'] Q -3 M '.}h MARTIN BRADLEY ASHARE DEPARTMENT OF LAW l
COUNTY ATTORNEY R CS.G L COMMUNICATIONS
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October 4, 1985 VIA TELECOPIER
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Alan S. Rosenthal, Esq., Chairman Gary J.
Edles, Esq.
Dr. Howard A. Wilber Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission
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Fifth Floor (North Tower)
East-West Highway.
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Bethesda, MD 20814" Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1)
(Docket No. 50-322-OL-3)
Gentlemen:
On our last appearance before the Appeals Board on Thursday, September 26, 1985, an extension to file the brief on the emergency planning issue was extended until October 15, 1985 Since then, as everyone knows, Hurricane Gloria has struck Long Island causing extensive damage to the electric power systems as well as real property.
As relates to the operation of the County Attorney's office, the following problems have been encountered:
1)
The County Government's operation was forced to shut down for two days.
2)
Since most of the employees did not have electic power at home, the absentee rate was higher than usual.
8510110004 851004 PDR ADOCK 05000322 G
PDR VCTER ANS MEMORI AL H8GHW AY a
H AUPPAUGE. NEW YORK 19788 s
1516) 360-4049
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~ Atomic Safety and Licensing f
Appeals Board October 4, 1985 Page 2 i
3)
Because of loss of electric power, the data processing department had to establish priorities which resulted in the County Attorney's office receiving a low priority (Police Agencies, Department of Social Services, were given preference).
4)
The electric supply power is consistently being interrupted thereby interfering with our data processing availability.
As a result of the foregoing, additional time will be needed to complete and file our brief in this matter, however, as of this moment I am/not certain how much additional time is required.
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This letter is to respectfully advise all parties that sometime during the week of October 7, 1985, when I am better informed as to the reliability of the electrical power supply in the County, I will be making a written motion. to extend the time to file the brief due on emergency planning.
In addition, the brief due on the Coliseum issue (Contentions 24.0, 24.P, 74, 75, 77) is also due on either Monday, October 7, 1985 or Wednesday, October 9, 1985 depending on whose calculation is being followed.
I am requesting that the filing date of that brief also be extended indefinitely because of the reaons set out above and in addition because of the pending lawsuit in Nassau County challenging the legal authority of the Nassau County Executive to permit the use of the Coliseum by LILCO.
Counsel to the State and Southampton have been advised '
of this letter and wish to join in the application.
Counsel for the applicant, as well as NRC Staff Counsel, have indicated that they are not opposed to this application but wish to be advised as to how many additional days are being requested before they express an opinion.
Thanking the Board in advance for its consideration, I remain Very truly yours, MARTIN BRADLEY ASHARE Suffolk County Attorney S
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By: EUGEtJE. R.
KELLEY
(
jeputy County Attorge/
Chief y
ERK/dag cc:
Service List L
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. r October 4, 1985 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (1
/*fik (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 (Emergency Planning)
I hereby certify that a letter to the Appeals Board requesting an extension of time on behalf of Suffolk County, dated October 4, 1985, has been served on the following by first class mail, postage prepaid, or as indicated by two asterisks, by telecopier:
Alan S. Rosenthal, Esq., Chairman **
Gary J.
Edles, Esq.**/
Mr. Howard A. Wilber*
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission East-West Tower, North Tower 4350 East-West Highway Bethesda, MD 20814 Fabian G. Palomino, Esq.
Donna Duer, Esq.
Special Counsel to the Governor Atomic Safety and Licensing Executive Chamber, Rm. 229 Board Panel State Capitol U.S. Nuclear Regulatory gomm.
Albany, New York 12224 East-West Tower, North Tower 4350 East-West Highway Mary Gundrum, Esq.
Bethesda, MD 20814 Assistant Attorney General 2 World Trade Cer.Ler Room'4614 James B.
Dougherty, Esq.
New York, New York 10047 3045 Porter Street Washington, D.C.
20008 Stewart M. Glass, Esq.
Regional Counsel Jay Dunkleberger, Esq.
Federal Emergency New York State Energy Office Management Agency Agency Building 2 26 Federal Plaza, Rm. 1349 Empire State Building New York,_New York 10278 Albany, New York 12223 Kirkpatrick & Lockhart, Esgs.
Morton B. Marguiles, Chairman 1900 M Street, N.W.
Dr. Jerry R.
Kline Washington, D.C.
20036 Mr. Frederick J. Shon Administrative Judges Atomic Safety and Licensing Bd.
U.S.
Nuclear Regulatory Comm.
4350 E/W Highway Bethesda, Maryland 20814 L
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d Stephen B.
Latham,..Esq.
Mr.. Martin Shubert John F.
Shea, Esq.
c/o Congressman William Carney Twomey, Latham & Shea 1113 Longworth House Office 33 West Second Street Building P.O. Box 398 Washington, D.C.
20515 Riverhead, New York 11901 Docketing and Service Bernard M. Bordenick, Esq.*
Branch (3)
Robert G. Perlis, Esq.
Ofice of the Secretary Edwin J. Reis, Esq.
U.S.
Nuclear Regulatory Comm.
Office of the Executive Legal Washington, D.C.
20555 Director U.S. Nuclear Regulatory Commission Ralph Shapiro, Esq.
Washington, D.C.
20555 Cammer and Shapiro, P.C.
9 East 40th Street Atomic Safety and Licensing Board New York, New York 10016 Panel
-U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Robert E.
Smith, Esq.
Rosenman Colin Freund Lewis Jonathan D. Feinberg, Esq.
& Cohen New York State Department of 575 Madison Avenue Public Service, Staff Counsel New York, New York 10022 Three Rockefeller Plaza Albany, New York 12223 Spence W. Perry, Esq.
Hunton & Williams, Esgs.
Associated General Counsel 707 East Main Street Federal Emergency Richm6nd, Virginia 23219
. Management Agency 500 C Street, S.W.
- If being sent by Federal Room 840 Express, send to:
Washington, D.C.
20472 U.S.
Nuclear Regulatory Comm.
7735 Old Georgetown Road (to mailroom)
Atomic Safety and Licensing
. Appeal Board Panel Bethesda, MD 20814 U.S. Nuclear Regulatory Comm.
Wshington, D.C.
20555 MARTIN BRADLEY ASHARE Suffolk County Attorney H.
Lee Dennison Building Veterans Memorial Highway Hauppauge, New York 11788 (51 360-4066 By:
EUGENE R KELLEY Chief De Aty County Attorne,U,
-Sworn to before me this N' a iccc J 0 hli Q,85.u-o:[.
4th day of October 19
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