ML20136J433
| ML20136J433 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/06/1986 |
| From: | Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#186-701, CON-186-701 OL-3, NUDOCS 8601130371 | |
| Download: ML20136J433 (4) | |
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UNITED STATES OF AMERICA 24,
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARIfgg A9:56 LF:
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SDUC In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station, )
' Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that, on this 9th day of January, 1986, I mailed a copy (first page only) of the Appeal Board's grant by stamp endorsement of "Suffolk County, State of New York,
-and Town of Southampton Motion for Leave to File Reply Briefs,"
dated January 6, 1986, to each of the following:
Stephen B.
Latham, Esq.
Fabian G. Palomino, Esq.
Twomey, Latham & Shea Special Counsel to the Governor P.O. Box'398 Executive Chamber 33 West Second Street State Capitol,'Rm. 229 Riverhead, New York 11901 Albany, NY 12224 Sherwin E.
Turk, Esq.
Martin Bradley Ashare, Esq.
Deputy Assistant Chief Suffolk County Attorney Hearing Counsel H. Lee Dennison Building Office of Ehe Executive Veterans Memorial Highway Legal Director Hauppauge, NY 11788 U.S.
Nuclear Regulatory Commission Donald P.
Irwin, Esq.
Washington, D.C.
20555 Hunton & Williams 707 East Main Street Herbert H.
Brown, Esq.
P.O. Box 1535 Kirkpatrick & Lockhart Richmond, VA 23212 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Docketing & Service Branch U.S.
Nuclear Regulatory Commission Wash ing ton, D.C.
20555
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J pn Sb6emaker Board B601130371Oggjh22-DR ADOCK O 0V DR
m-o f ~En UNITED STATES OF AMERICA
'gg JNI to 4 NUCLEAR REGULATORY COMMISSION 9236 Before the Atomic Safety and Licensing Appeal Board v.
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
....,.i r am Nuclear Power Station, g
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,1 SUFFOLK COUNTY, STATE OF NEW vnne b. Q g 6 _ - A M AND TOWN OF SOUTHAMPTON MOTJgN;retary% th'e Appeal Bo FOR LEAVE TO FILE REPLY BRTEFS Pursuant to this Board's Order of May 15, 1985, Suffolk County, the State of New York and the Town of Southampton hereby seek leave to file reply briefs to respond to certain matters raised in (1) LILCO's Brief in Opposition to the Intervenors' Appeal of the ASLB's Partial Initial Decision on Emergency Planning, December 13, 1985, and the NRC Staff Brief in Opposition to "Suffolk County, State of New York, and Town of Southampton Brief on Appeal of Licensing Board April 17, 1985 Partial Initial Decision on Emergency Planning," December 23, 1985; and, (2) LILCO's Brief in Opposition to Intervenors' Appeal of the Nassau Coliseum and Guard Issues, December 11, 1985, and the NRC Staff Brief in Response to Intervenors' Appeal of Licensing Board's August 26, 1985 Concluding Partial Initial Decision on Emergency Planning, December 23, 1985.I That Order set forth various dates for filings, which were extended by subsequent orders. Consistent with the schedule in the May 15 Order, (footnote continued)
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The briefs of LILCO and the NRC Staff contain mischaracterizations and misstatements which require correction, and some arguments as to which Appellants believe a written response, prior to oral argument, would assist the Appeal Board. Accordingly, Appellants seek leave to file the two reply briefs attached hereto. Since the Appeal Board asked for submittal of the reply briefs at the same time any motion is filed, Appellants do not set forth in this Motion the precise matters as to which Appellants need.to respond. Those matters are, of course, set forth in the reply briefs.
Appellants address in their reply briefs only a limited number of the arguments made by LILCO and the Staff. Many of the LILCO and Staff arguments were already addressed in Appellants' initial briefs filed on October 23 and November 6, 1985; those rot already covered or discussed in the reply briefs submitted herewith will be addressed at oral argument. The fact that only selected issues are covered in the attached reply briefs does not indicate that Appellants agree with the characterizations, arguments, or responses made by LILCO or the Staff with respect to matters not addressed therein.
(footnote continued from previous page) this Motion is being served two weeks after the filing of the NRC Staff's briefs. See May 15 Order at 2, n.3.
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,3, Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge New York 11788 Herbert H. Br
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~j Lawrence Coe 2npher Karla J. Letsche Michael S. Miller KIRKPATRICK & LOCKHART 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Attorneys for Suffolk Co gty
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Fablan G. Palodino Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Robert Abrams Attorney General of the State of New York Two World Trade Center New York, New York 10047 Attorneys for Governor Mario M.
Cuomo, and the State of New York 1/
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/Stepne B. Latham
- Twon, Latham & Shea P.O. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton January 6, 1986 w.