ML20148K856

Forwards Standard Size Copies of Display Charts Presented by County at 781019 Oral Argument W/Explanatory Notes.Believes Hearing Bd Has Deprived Itself of Chance to Consider Alternatives,Thus Invalidating Basis for Approval of Appl

ML20148K856
Person / Time
Site:	05000516, 05000517
Issue date:	10/27/1978
From:	Like I REILLY & LIKE
To:	Sharfman J NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 7811200020
Download: ML20148K856 (2)

Text

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REILLY, LIxE Axo SCHNEIDEIt

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o7R"" E "#r'd*E"" NRC PUBLIC DOCUMENT ROOM D g EDWARD A. BROOMS, JR.

WERN ER J. 2tJNBRUNN IIICMAND C. MAND EN R ICO J. CONSTANTINO FATRJCfA A. DEMPSEY October 27, 1978 Jerome E. Sharfman, Esq., Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Re: In the Matter of Long Island Lighting Company (Jamesport Nuclear Power Station, Units 1 & 2)

Docket Nos. 50-516 and 50-517

Dear Chairman Scharfman:

Pursuant to the Appeal Board's request made at the October 19, 1978 oral argument in the above-captioned proceeding, please find enclosed redrawn copies of the display charts pre-sented by the County at said argument. The charts have been re-drawn to fit on utandard size papersand maintain insofar as possible approximately the same relative scale and color schemes used in the originals. I have also enclosed notes explaining the charts and documenting the basis in the record for the data used in their preparation.

If detailed explanation of.the small scale xeroxed figures distributed during oral argument is required, please so notify us. The only additional data reflected in those figures beyond what has been documented herein are the summer and winter peak forecasts presented by the Applicants in the 1978 149-b Report which the League of Women Voter's has re-quested the Board to take official notice of. Portions of this l

material are already in evidence in the form of LILCO 1978 summer peak forecasts and NYSEG 1978 winter peak forecasts as preaented in Amendment 7 to the Environmental Report, pp. Q.3.3 and Q.3.4 (3/15/78). All of these data represent an updating i of the portions of the 149-b Reports now in the record as I documented in the enclosed attachments, l

l 781120002;O 1

Rz1LCY, LIxz AND SCHNEIDER Jeroms E. Scharfman, Esq.

October 27, 1978 Page 2 ,

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Although exceptions might be taken to some details of l f

the County's argument as' presented in its Brief in Support of Exceptions, and graphically displayed in the enclosed charts, the implications of any such arguments cannot properly be evaluated in view of the Hearing Board's utter failure to con-sider and weigh such alternatives. Thus, it is the County's fundamental position.that the' Hearing Board, by its failure to consider the County's arguments, deprived itself of the opportunity to weigh the costs and benefits of relevant alter-natives thus invalidating the entire decisional basis for its approval of the subject application.

Very truly yours, Y f lh(Rb Irving Like -

Special Counsel for the County of Suffolk IL/j g CC: Copy of letter with attachments:

Richard S. Salzman, Esq. Dr. W. Reed Johnson Member, Atomic Safety & Licensing Member, Atomic Safety & Licensing Board Board W. Taylor Reveley, III, Esq. Bernard M. Bordenick, Esq.

Counsel for Applicant Counsel for NRC Staff Long Island Lighting Company Ms. Jean Tiedke, Ms. Shirley Bachrach - League of Women Voters Copy of letter without attachments:

Sheldon J. Wolfe, Esq. Ira Lee Zebrak, Esq.

Mr. Ralph S. Decker Joseph C. Gramer, Esq.

Dr. Leonard E. Cheatum Frederick H. Lawrence, Esq.

Edward J. Walsh, Jr., Esq. NRC Docketing & Service Se.ction Dr. Harris Fischer NRC Office of the Secretary Mrs. Laetitia deK. Bradley Jeffrey C. Cohen, Esq.

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