ML20207Q293

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Lilco Motion to File Reply on Need for Commission Review of ALAB-855.* Permission to File Brief Requested Because Important Question of How Other Parties Interpreted Ruling in ALAB-855 Could Not Be Addressed
ML20207Q293
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 01/20/1987
From: Irwin D
LONG ISLAND LIGHTING CO.
To:
NRC COMMISSION (OCM)
Shared Package
ML20207Q294 List:
References
CON-#187-2256 ALAB-855, OL-3, NUDOCS 8701270130
Download: ML20207Q293 (2)


Text

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t 2254 LILCO, January 20,1987 7

4 00CMETED USNP" UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

~87 JAN 21 P 2 :09 Before the Commission

[gh In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station,

)

(

Unit 1)

)

LILCO'S MOTION TO FILE REPLY ON THE NEED FOR COMMISSION REVIEW OF ALAB-855 LILCO files with this motion a very short brief on the need for the Commission to review ALAB-855. This is in response to the NRC Staff's and Intervenors' pleadings opposing'such review.

LILCO asks permission to file the attached brief, and asks that the Commission consider it, for the following reasons:

1.

LILCO could not, in its original petition to review ALAB-855, address the important question of how the other parties interpreted the ruling in ALAB-855, because the other parties had never made known their interpre-tation. Not until their responses to LILCO's petition could LILCO know that the other parties argue that ALAB-855 has very little significance.

For the reasons stated in the attached brief, LILCO believes the other par-ties are incorrect on this point.

2.

LILCO believes that what it has to say below, particularly the setting out of the generic issues that ALAB-855 requires be decided by the Licensing Board, will help to clarify the Commission's thinking on this issue.

For the above reasons, LILCO asks the Commission to consider the enclosed brief.

Respectfully submitted, Bjo12%h b

'o

  • Mh.C6 #m p

onald P. Irwi6 James N. Christman s

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_) Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 20,1987 t

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