ML20205F297
| ML20205F297 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/24/1987 |
| From: | Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2929 OL-3, NUDOCS 8703310135 | |
| Download: ML20205F297 (6) | |
Text
-$2 $ o 00LKETED USNRCMarch 24, 1987 Il7 MNt 26 P3 51 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMI g g ]}.?]'g, y } BRAliCH Before the Atomic Safety and Licensina Board ) In the Matter of ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 ) (Emergency Planning) (Shoreham Nuclear Power Station, ) Unit 1) ) ) ) SUFFOLK COUNTY'S
SUMMARY
OPPOSITION TO LILCO'S MOTION TO COMPEL STATE OF NEW YORK TO RESPOND TO LILCO'S FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING RECEPTION CENTERS On March 18, 1987, LILCO filed a pleading entitled Motion To Compel State of New York To Respond To LILCO's First Set of Requests for Admissions Regarding Reception Centers (" Motion"). While the title of the Motion and the thrust of its arguments suggest that the Motion is aimed at the State of New York, the broad language used by LILCO appears at times to sweep the County within the scope of the Motion. Accordingly, the County will not respond in detail to LILCO's Motion, but nevertheless submits this summary opposition. 0703310130 870324 PDR ADOCK 05000322 O PDR
4 i 1. Suffolk County stated in the Government's Responsel to LILCO's Requests 2 that the County did not have sufficient information to admit or deny those Requests. That is a truthful response and is the best answer that the County can provide. LILCO's Motion does not state that the County has responded evasively or that it is withholding relevant information. Indeed,- from reading the Motion, it appears that LILCO's complaints are j actually directed against the State of New York. Thus, to the j extent that LILCO seeks an order to compel against the County, I that request is meritless and must be denied. 4 2. With respect to LILCO's argument that this Board should issue an order compelling the State to answer LILCO's Requests yet again, the County supports the State's opposition to LILCO's Motion, filed today. For the reasons stated in that Opposition, i LILCO's Motion should be denied in its entirety. l Respectfully submitted, i Martin Bradley Ashare Suffolk County Attorney l Building 158 North County Complex j Veterans Memorial Highway Hauppauge, New York 11788 i 1 Suffolk County and State of New York Response and Objections to LILCO's First Set of Requests For Admissions Regarding l Reception Centers, (March 17, 1987). 2 LILCO's First Set of Requests For Admissions Regarding Reception Centers Directed To Suffolk County and State of New York, (March 3, 1987) (" Requests"). 2-F P" 'e--+----wr--ma-en-+pe-p W9vgmeymg... m Wy-g e Sp r ,wgw,,
c s Christopher M. McMurray David T. Case KIRKPATRICK AND LOCKART 1800 "M" Street, N. W. South Lobby - Ninth Floor Washington, D. C. 20036-5891 Attorneys for Suffolk County March 24, 1987 4 i.
00LKETED March 24 $h87 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE 0F ?ECRElARY BeforetheAtomicSafetyandLicensin@0fj6fa'((j,jcf ) In the Matter of ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 ) (Emergency Planning) (Shoreham Nuclear Power Station, ) Unit 1) ) ) CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S
SUMMARY
OPPOSITION TO LILCO'S MOTION TO COMPEL STATE OF NEW YORK TO RESPOND TO LILCO'S FIRST SET OF REQUESTS FOR ADMISSIONS REGARDING RECEPTION CENTERS have been served on the following this 24th day of March, 1987 by United States mail, first class, except as otherwise noted. Morton B. Margulies, Esq., Chairman * -Joel Blau, Esq. Atomic Safety and Licensing Board Director, Utility Intervention l U.S. Nuclear Regulatory Commission N.Y. Consumer Protection Board Washington, D.C. 20555 Suite 1020 Albany, New York 12210 Dr. Jerry R. Kline* William R. Cumming, Esq. Atomic Safety and Licensing Board Spence W. Perry, Esq. U.S. Nuclear Regulatory Commission Office of General Counsel j Washington, D.C. 20555 Federal Emergency Management Agency: 500 C Street, S.W., Room 840 l Washington, D.C. 20472 f u .~.
Mr. Frederick J. Shon* Anthony F. Earley, Jr., Esq. Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C. 20555 175 East Old Country Road Hicksville, New York 11801 Ms. Elisabeth Talbbi W. Taylor Reveley, III, Esq.* Clerk Hunton and Williams Suffolk County Legislature Post Office Box 1535 Suffolk County Legislature 707 East Main Street Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq. Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear.?ower Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm. 195 East Main Street 1717 "H" Street, N. W. Smithtown, New York 11787 Washington, D.C. 20555 Mary M. Gundrum, Esq. Hon. Michael A. LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, Third Floor H. Lee Dennison Building Room Number 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite "K" Post Office Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, EFq. Fabian G. Palomino, Esq.* Suffolk County Attorney Richard J. Zahnleuter, Esq. Bldg. 158, North County Complex Special Counsel to the Veterans Memorial Highway Governor of the State Hauppauge, New York 11788 of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Mr. Jay Dunkleburger Richard G. Bachmann, Esq.* New York State Energy Office U.S. Nuclear Regulatory Comm. Agency Building 2 Washington, D. C. 20555 Empire State Plaza Albany, New York 12223 - -
David A. Brownlee, Esq. Mr. Stuart Diamond Kirkpatrick and Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 West 43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 ifM Christophet M. KcMurray David T. Case KIRKPATRICK & LOCKART 1800 "M"
- Street, N. W.
South Lobby - Ninth Floor Washington, D. C. 20036-5891
- Via Telecopy March 24, 1987
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