ML20206U725

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Response to Intervenors Pleading Concerning Scheduling.Requests ASLB Deny Intervenors Unsubstantiated & Unsupportable Request for Summary Rejection of Util Proposed Scheduling Order.Certificate of Svc Encl
ML20206U725
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 10/03/1986
From: Irwin D
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
Atomic Safety and Licensing Board Panel
References
CON-#486-0997, CON-#486-997 OL-5, NUDOCS 8610080137
Download: ML20206U725 (2)


Text

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h LILCO, October 3,1986 i

l UNITED STATES OF AMERICA CatKE!LC NUCLEAR REGULATORY COMMISSION UiNPC l

l Before the Atomic Safety and LicensingMagi -6 P 1 :17 0FFiUE 0; D L. - t' f In the Matter of

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00CKET E a

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BRANCH LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-5

) (EP Exercise)

(Shoreham Nuclear Power Station,

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Unit 1)

)

LILCO'S RESPONSE TO INTERVENORS' LETTER PLEADING CONCERNING SCHEDULING LILCO requests that the Board treat Mr. Lanpher's letter of October 2 as a mo-tion by Intervenors, and rule now on its prayers for relief so as to minimize delay. Spe-cifically, LILCO requests, first, that the Board deny Intervenors' unsubstantiated and unsupportable request for summary rejection of LILCO's proposed scheduling order and accompanying pleading. Second, LILCO requests that if the Board decides to permit comments on the October 1 pleadings, it grant that right to all parties, limit such com-ments' length to 5 pages, and require them to be physically submitted by 10:00 a.m.

Monday morning, October 6.

A pecmpt ruling by the Board is essential to avoid delay. Intervenors' proposal to take advantage of the full time period nominally permitted by the Rules of Practice would allow them to respond, by first-class mail, as late as October 14, thus merely adding nearly two more weeks of unavoidable delay to the actual start of this already much-delayed proceeding and frustrating the taking of FEMA depositions during the pe-riod of October 14-17, which is the only time FEMA has promised its witnesses' avail-ability until the end of the year.

Respectfully submitted, P

Don ~ald P. Irwin Counsel for Long Island Lighting Company Hunton & Williams 707 East Main Street P.O. Box 1535 ggg3 Richmond, Virginia 23212 e610080137 e61003 PDR ADOCK 05000322 DATED: October 3,1986 0

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LILCO, October 3 1986 3

00tBElE0 usNhc i

CERTIFICATE OF SERVICE

  1. *"I 0FFICE 05 In the Matter of 00CKEtts A M M BMN" LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-5 l

1 I hereby certify that copies of LILCO'S RESPONSE TO INTERVENORS' LETTER PLEADING CONCERNING SCHEDULING 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.

Morton B. Margulies, Chairman

  • Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board U.S. Nuclear Regulatory Commission l

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 J,

East-West Towers, Rm. 407

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4350 East-West Hwy.

Bernard M. Bordenick, Esq.

  • Bethesda, MD 20814 Oreste Russ Pirfo, Esq.

j Edwin J. Reis, Esq.

j Dr. Jerry R. Kline

  • U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 7735 Old Georgetown Road j

Board (to mailroom)

U.S. Nuclear Regulatory Commission Bethesda, MD 20814 East-West Towers, km. 427

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Herbert H. Brown, Esq.

  • 4350 East-West Hwy.

Bethesda, MD 20814 Lawrence Coe Lanpher, Esq.

Karla J. Latsche, Esq.

Mr. Frederick J. Shon

  • Kirkpatrick & Lockhart

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Atomic Safety and Licensing Eighth Floor Board 1900 M Street, N.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20036 East-West Towers, Rm. 430

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4350 East-West Hwy.

Fabian G. Palomino, Esq.

  • j Bethesda, MD 20814 Richard J. Zahnleuter, Esq.

Special Counsel to the Governor Secretary of the Commission Executive Chamber Attention Docketing and Service Room 229 Section State Capitol -

U.S. Nuclear Regulatory Commission Albany, New York 12224 1717 H Street, N.W.

i Washington, D.C. 20555 Mary Gundrum, Esq'.

Assistant Attorney General l

Atomic Safety and Licensing 2 World Trade Center i

Appeal Board Panel Room 4614 U.S. Nuclear Regulatory Commission New York, New York 10047 Washington, D.C. 20555 i

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Spence W. Perry, Esq.

  • Ms. Nora Bredes i

William E. 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 Gerald C. Crotty, Esq.

Mr. Jay Dunkleberger Counsel to the Governor l

New York State Energy Office Executive Chamber Agency Building 2 State Capitol j

Empire State Plaza Albany, New York 12224 Albany, New York 12223 i

Martin Bradley Ashare, Esq. **

Stephen B. Latham, Esq. **

Eugene R. Kelly, Esq.

j Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway j

Riverhead, New York 11901 Hauppauge, New York 11787 Jonathan D. Feinberg, Esq.

Dr. Monroe Schneider New York State Department of North Shore Committee Public Service, Staff Counsel P.O. Box 231 Three Rockefeller Plaza Wading River, NY 11792 Albany, New York 12223 i

l Donald P. Irwin

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Hunton & Williams j

707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: October 3,1986 4

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