ML20154E070
| ML20154E070 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/11/1988 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6277 OL-3, NUDOCS 8805200080 | |
| Download: ML20154E070 (4) | |
Text
( 4A77 uLCO, May 11,1988 i
00(KETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 16 MY 13 P4 :28 Before the Atomic Safety and Licensing Board f0 b
r, e BRMe in the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S ANSWER TO INTERVENORS' MOTION TO DEFER MOTIONS TO STRIKE REALISM TESTIMONY On May 10,1988, the Intervenors filed their Governments' Motion to Defer Filing Date for Motions to Strike on Realism Testimony ("Motion"). They ask that the motions to strike realism testimony, now due May 20, be "deferred until 7 days af ter receipt of the Board's ruling on realism issues." Motion at 2.
LILCO does not oppose the Intervenors' Motion,II if the filing date is extended for al_1 motions to strike - that is, those filed by LILCO as well as the Intervenors. At the appropriate time, LILCO expects to move to strike the Halpin and Axelrod testimo-ny in its entirety, primarily because it is a challenge to NRC regulations, and portions of the Sholly and Minor testimony on the ground that they attempt to reopen already-litigated issues and stray beyond the expertise of the witnesses. LILCO believes that these motions should be filed on the same date that the Intervonors file theirs.
LILCO does ask that, if the Board grants the Intervenors' Motion, it give notice by phone when it issues its decision on the pending realism issues.
Since the 1/
LILCO does not agree with footnote 1 of the Intervenors' Motion, which suggests that if the Halpin and Axelrod testimony is stricken, then the Intervenors may be enti-tied to strike part of LILCO's testimony. But resolution of this issue must of course await the filing of the motions to strike.
88052000B0 080511 PDR ADOCK 05000322 A
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Intervenors propose a Uting date seven days beyond "receipt" of the Board's decision, the parties need a chance to pid up tne decision prompt!y.
LILCO agrees with the Intervenors that a prompt decision on their Motion is needed, since otherwise we will need to file our motions to strike this Friday.
Respectiully submitted,
? :)
ames N. Christman Counsel for Long Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 11,1988 l
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t LILCO, May 11,1988
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00tnfiEC UWC CERTIFICATE OF SERVICE OFHCE Of Hua W 7 0006EMG & MkVKf.
BR t.NCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 i
I hereby certify that copies of LILCO'S ANSWER TO INTERVENORS' MOTION TO DEFER MOTIONS TO STRIKE REALIS'<t TESTIMONY were served this date upon the following by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid, i
James P. Gleason, Chairman
- Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 2055S Dr. Jerry R. Kline
- Atomic Safety and Licensing Richard G. Bachmann, Esq.
- Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of the General Counsel East-West Towers, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 Herbert H. Brown, Esq.
- Lawrence Coe Lanpher, Esq.
Mr. Frederick J. Shon
- Karla J. Letsche, Esq.
i Atomic Safety and Licensing Kirkpatrick & Lockhart l
Board South Lobby - 9th Floor i
U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
East-West Towers, Rm. 430 Washington, D.C. 20036-5891 4350 East-West Hwy.
Bethesda, MD 20814 Fabian G. Palomino, Esq.
- Richard J. Zahnleuter, Esq.
Secretary of the Commission Special Counsel to the Governor Attention Docketing and Service Executive Chamber Section Room 229 U.S. Nuclear Regulatory ummission State Capitol 1717 H Street, N.W.
Albany, New York 12224 Washington, D.C. 20555 Alfred L. Nardelli, Esq.
Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel 120 Broadway U.S. Nuclear Regulatory Commission Room 3-118 Washington, D.C. 20555 New York, New York 10271 l
[
4 -t George W. Watson, Esq.
- Ms. NOL Dredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.
l Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Of fice Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223
(
E. Thomas Boyle, Esq.
Stephen B. Latham, Esq. **
Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 f
Dr. Monroe Schneider I
Mr. Philip McIntire North Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Pt'blic Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 11,1988
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