ML20207P720

Responds to ASLB Requirement for Filing Statement Re Summary Disposition of Issues & Hearing Schedule by 870116.Proposed Testimony Will Be Filed Simultaneously.No Motions for Summary Disposition Will Be Filed.Certificate of Svc Encl

ML20207P720
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/13/1987
From:	Cumming W Federal Emergency Management Agency
To:	Frye J, Paris O, Shon F Atomic Safety and Licensing Board Panel
References
CON-#187-2202 OL-5, NUDOCS 8701200126
Download: ML20207P720 (4)

Text

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Federal Emergency Management Agenego.

Washington, D.C. 20472 January 13, 1986 '87 JAN 14 P4 :02 1

1 CFF:e CCCN 7 t a,g

John H. Frye, III, Chairman Dr. Oscar Paris

_ Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Long Island Lighting Company Shoreham Nuclear Power Station (Docket No. 5-322-OL-5)

Summary Disposition and Hearing Schedule Gentlemen:

This letter fufills the Board's requirement that by January 16, 1987, all parties and other interested persons file by January 16, 1987, a statement as to the summary disposition of issues and hearing schedule. FEMA has been copied with LICO Counsel's letter of January 9, 1987, and agrees with its statement of the schedule. Also, FEMA does not intend to file Motions for Summary Disposition. FEMA believes that it is less resource intensive in the long run to file all proposed testimony at once, and intends to do so. Also, the Board is requested to structure the proceeding so that with respect to FEMA witnesses only, testimony is only required once, and frequent return to testify isssue by issue is not required. Certainly, if the Board has a special or unique problem that requires some FEMA witness testimony, FEMA is willing to work out some accommodation to satisfy the Board.

There is a second issue that concerns FEMA. FEMA believes that Contentions EX 22, 38 Q, 39 D, 40 8, 40 E, 41 E, 47, 49 C, and 50 I, involve potential overlap with the OL-3 proceeding. FEMA is willing to testify once, but due to resource constraints will have difficulty supporting both proceedings. Accordingly, FEMA requests that the OL-5 and OL-3 Boards work out some protocol concerning these contentions. Perhaps, both Boards could sit together on these issues.

i I

RespectfullysubmJ1ted, h & f L b :::::

I William R. Cumming Counsel for FEMA CC: Service List 8701200126 870113 h PDR ADOCK 03000322 U D' dJ2 O PDR

COLMETEF UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION T7 JM114 P4114 I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ECCEf i. [ "$m In the Matter of )

) Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5

) (EP Exercise)

(Shoreham Nuclear Power Station, )

Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " FEMA JANUARY 13, 1987 LETTER TO THE BOARD" in the above-captioned proceedings have been served on the following by deposit in the United States mall, first class, this 13th day of January, 1987:

- John H. Frye, III, Fabian G. Palomino, Esq.

Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, D.C. 20555 Albany, NY 12224 Oscar H. Paris W. Taylor Reveley III, Esq.

Administrative Judge Hunton & Williams Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission P.O. Box 1535 Washington, D.C. 20555 Richmond, VA 23212 Frederick J. Shon Jonathan D. Feinberg, Esq.

Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington 0.C. 20555 Albany, NY 12223

Morton B. Margulies Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatcry Commission

. East-West Towers, Rm. 430 East-West Towers , Rm. 430 4350 East-West Hwy. 4350 East-West Hwy Bethesda, Maryland 20814 Bethesda, MD 20814 b

Stephen B. Latham, Esq.

John F. Shea, III, Esq. Herbert H.. Brown, Esq.**

Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.

Attorneys at Law Karla J. Letsche, Esq.

P.O. Box 398 Kirkpatrick & Lockhart 33 West Second Street 1800 M Street, N.W.

Riverhead, NY 11901 9th Floor Washington, D.C. 20036 Atomic Safety and Licensing Board Panel Joel Blun, Esq.

U.S. Nuclear Regulatory Commission Director, Utility Intervention Washington, D.C. 20555 . NY State Consumer Protection Board Suite 1020 Atomic Safety and Licensing 99 Washington Avenue Appeal Board Panel Albany, NY 12210 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Docketing and Service Section Wading River, NY 11792 Office of the Secretary U.S. Nuclear Regulatory Commission Philip H. McIntire Washington, D.C. 20555 Federal Emergency Management Agency 26 Federal Plaza Spence Perry, Esq.** New York, New York 10278 i General Counsel, Rm. 840 Federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C. 20472 Robert Abrams, Esq.

l Attorney General of the State .

Gerald C. Crotty, Esq. of New York Ben Wiles, Esq. Attn: Peter Blenstock, Esq.

l Counsel to the Governor Department of Law Executive Chamber State of New York State Capitol Two World Trade Center Albany, NY 12224 Room 46-14 New York, NY 10047 I Anthony F. Earley, Jr., Esq. MHB Technical Associates i General Counsel 1723 Hamilton Avenue Long Island Lighting Company Suite K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501 i

I i

O 3-Hon. Peter Cohalan Martin Bradley Ashare, Esq.

Suffolk County Executive Suffolk County Attorney County Executive / Legislative Bldg. H. Lee Dennison Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, NY 11788 Hauppauge, NY 11788 Mr. Jay Dunkleberger Ms. Nora Bredes

. New York State Energy Office Shoreham Opponents Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown,llY 11787 Albany, New York 12223 Ellen Blackler Mr. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Ms. Sharlene Sherwin Energy Committee 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Bernard M. Bordenick, Esq.

475 E. Main Street U.S Nuclear Regulatory Agency Patchogue, NY 11772 7735 Old Georgetown Road Bethesda, MD 20814

/ hs:

William R. Cumming ./

Federal Emergency Management Agency J