ML20206P755
| ML20206P755 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/30/1986 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#386-802 CLI-86-11, OL-3, NUDOCS 8607020234 | |
| Download: ML20206P755 (5) | |
Text
LILCO, June 30,1986 Og#rrgp UNITED STATES OF AMERICA NRC NUCLEAR REGULATORY COMMISSION N N ~f N1:3g hf7f"Sqn@
Before the Commission Ag In.the Matter of
)
)
LONG ISLAND LIGIITING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S MOTION TO STRIKE UNAUTHORIZED PLEADING FILED ON JUNE 23 BY SUFFOLK COUNTY Outside counsel for Suffolk County has filed with the Commission, without leave, a document labeled " Statement of Suffolk County Executive Peter F. Cohalan, June 23, 1986," under cover of a letter from Deputy County Executive Frank Jones. This docu-ment, which disputes LILCO's " realism" argument at length, comes scarcely two weeks af ter the Commission made clear to all parties that it had already received " extensive, papers" on the realism and immateriality issues and saw no need for further written briefs before rendering a decision on them in the "near future". CLI-86-11 (June 6, 1986), at 7,2.
The " Statement" attributed to Mr. Cohalan, while merely the latest in Interve-nors' long line of unsolicited eleventh-hour filings, differs from its predecessors in that its very submission is contrary to the plainly expressed views of the Commission in kogh0500aggy 86063o 0
PDR 63
CLI-86-11. The Commission should reject it and its covering letter summarily.II Respectf ully submitted, l 0Yb s
%YTaylor Reveley, III Donald P. Irwin James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23:12 DATED: June 30,1986 t
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In that event, the Commission need also not consider LILCO's Reply to Mr.
Cohalan's " Statement," filed herewith.
LILCO, June 30,1986 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S REPLY TO UNAUTHORIZED PLEADING FILED ON JUNE 23 BY SUFFOLK COUNTY and LILCO'S MOTION TO STRIKE UNAUTHORIZED PLEADING FILED ON JUNE 23 BY SUFFOLK COUNTY were served this date upon the following by Federal Express as indicated by an asterisk, or by first-class mail, postage prepaid.
Nunzio J. Palladino, Chairman
- Gary J. Edles, Esq.
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 1717 H Street, N.W.
Appeal Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Commissioner Thomas M. Roberts
- Fif th Floor (North Tower)
U.S. Nuclear Regulatory Commission East-West Towers 1717 H Street, N.W.
4350 East-West Highway Washington, DC 20555 Bethesda, MD 20814 Commissioner James K. Asselstine
- Dr. Howard A. Wilber U.S. Nuclear Regulatory Commisison Atomic Safety and Licensing 1717 H Street, N.W.
Appeal Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Commissioner Frederick M. Bernthal
- Fif th Floor (North Tower)
U.S. Nuclear Regulatory Commission East-West Towers 1717 H Street, N.W.
4350 East-West Highway Washington, DC 20555 Bethesda, MD 20814 Commissioner Lando W. Zech, Jr.
- Morton B. Margulies, U.S. Nuclear Regulatory Commission Chairman 1717 H Street, N.W.
Atomic Safety and Licensing Washington, DC 20555 Board U.S. Nuclear Regulatory Alan S. Rosenthal, Esq.,
Commission Chairman East-West Towers, Rm. 407 Atomic Safety and Licensing 4350 East-West Hwy.
Appeal Board Bethesda, MD 20814 U.S. Nuclear Regulatory Commission Fif th Floor (North Tower)
East-West Towers 4350 East-West Highway Bethesda, MD 20814
. Dr. Jerry R. Kline Fabian G. Palomino, Esq.
- Atomic Safety and Licensing Special Counsel to the Board Governor U.S. Nuclear Regulatory Executive Chamber Commission Room 229 East-West Towers, Rm. 427 State Capitol 4350 East-West Hwy.
Albany, New York 12224 Bethesda, MD 20814 Mary Gundrum, Esq.
Mr. Frederick J. Shon Assistant Attorney General Atomic Safety and Licensing 2 World Trade Center Board Room 4614 U.S. Nuclear Regulatory New York, New York 10047 Commission East-West Towers, Rm. 430 Spence W. Perry, Esq.
- 4350 East-West Hwy.
General Counsel Bethesda, MD 20814 Federal Emergency Management Agency Secretary of the Commission 501 C Street, S.W., Room 840 U.S. Nuclear Regulatory Washington, D.C. 20472 Commission Washington, D.C. 20555 Mr. Jay Dunkleberger New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel Empire State Plaza U.S. Nuclear Regulatory Albany, New York 12223 Commission Washington, D.C. 20555 Stewart M. Glass, Esq.
- Regional Counsel Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U.S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 Washington, D.C. 20555 Stephen B. Latham, Esq.
- Bernard M. Bordenick, Esq.
- Twomey, Latham & Shea Oreste Russ Pirfo, Esq.
33 West Second Street Edwin J. Reis, Esq.
P.O. Box 298 U.S. Nuclear Regulatory Riverhead, New York 11901 Commission 7735 Old Georgetown Road Jonathan D. Feinberg, Esq.
(to mallroom)
New York State Department of Bethesda, MD 20814 Public Service, Staff Counsel Three Rockefeller Plaza Lawrence Coe Lanpher, Esq.
- Albany, New York 12223 Karla J. Letsche, Esq.
Kirkpatrick & Lockhart Eighth Floor 1900 M Street, N.W.
Washington. D.C. 20036
William E. Cumming, Esq.
Gerald C. Crotty, Esq.
Associate General Counsel Counsel to the Governor Federal Emergency Management Executive Chamber Agency State Capitol 500 C Street, S.W.
Albany, New Yotk 12224 Room 840 Washington, D.C. 20472 Martin Bradley Ashare, Esq.
- Eugene R. Kelly, Esq.
Ms. Nora Bredes Suffolk County Attorney Executive Coordinator H. Lee Dennison Building Shoreham Opponents' Coalition Veterans Memorial Highway 195 East Main Street Hauppauge, New York 11787 Smithtown, New York 11787 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Wading River, NY 11792
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Donald P. Irwin Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 30,1986
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