ML20212E811
| ML20212E811 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/30/1986 |
| From: | Mcmurray C KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2085 OL-5, NUDOCS 8701050465 | |
| Download: ML20212E811 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 JAN -2 PS :35 Before the Atomic Safety and Licensino Board Y
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In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-5
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(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
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MOTION FOR EXTENSION OF TIME TO RESPOND TO LILCO MOTION At approximately 4:30 p.m. in the afternoon of December 23, 1986 counsel for LILCO telecopied to the County a Motion Regard-ing Pending Discovery Matters and Order of Proceeding Under the December 11 Order (" Motion").1 As LILCO had not previously advised the County of the pending Motion, all of the County's counsel had left their offices by that hour for the Christmas holidays.
Accordingly, counsel did not receive or become aware of LILCO's Motion until they returned to their offices yesterday (Monday, December 29).
LILCO's Motion addresses a number of issues regarding this proceeding and attacks the County for reasons, to the extent they can be understood, which are unsupportable.
Under normal cir-cumst ances, the County's response to the Motion would be due this Friday, January 2.
Ilowever, in light of the fact that the 1
The Motion was accompanied by a letter of the same date addressed to the Board.
The letter raises the same issues as LILCO's Motion.
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County's counsel effectively received the Motion only yesterday, and due further to the New Year holiday which occurs at the end of this week,2 the County hereby requests a 4-day extension of time (i.e. until Tuesday, January 6) in which to file its response.3 Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 KaYTa J.
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Michael S. Miller Christopher M. McMurray KIRKPATRICK & LOCKHART South Lobby - 9th Floor 1800 M Street, N.W.
Washington, D.C. 20036-5891 Attorneys for Suffolk County Dated:
December 30, 1986 2
Counsel for the State of New York has informed the County that the State of New York also intends to seek a time extension due to the Christmas and New Year holidays.
3 The Board should also note that because the Town of Southampton was served by Federal Express, not telecopier, the Town of Southampton's response to LILCO's Motion is not due until Monday, January 5.
Therefore, the County's motion for extension contemplates only one additional day before which the Board would have all of the Governments' responses.
Eil CU, e r !
December 30,'1986 UNITED STATES OF AMERICA eg Jm -2 P5 :36 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board 610Lm g {j* MA
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the MOTION FOR EXTENSION OF TIME TO RESPOND TO LILCO MOTION have been served this 30th day of December 1986 by U.S. mail, first class, except as otherwise noted.
John H. Frye, III, Chairman
- Spence W. Perry, Esq.
Atomic Safety and Licensing Board William R. Cumming, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W.,
Room 840 Washington, D.C.
20472 Dr. Oscar H. Paris
- Mr. Frederick J. Shon*
Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
Bernard M. Bordenick, Esq.
Anthony F. Earley, Jr., Esq.
U.S. Nuclear Regulatory Comm.
General Counsel Washington, D.C.
20555 Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801 Mr. William Rogers W. Taylor Reveley, III, Esq.*
Clerk Hunton & Williams Suffolk County Legislature P.O. 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 Power 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 MHB Technical Associates Hon. Peter Cohalan 1723 Hamilton Avenue Suffolk County Executive Suite K H. Lee Dennison Building San Jose, California 95125 Veterans Memorial Highway Hauppauge, New York 11788 Martin Bradley Ashare, Esq.
Herbert H. Brown, Esq.
Suffolk County Attorney Lawrence Coe Lanpher, Esq.
Bldg, 158 North County Complex South Lobby - 9th Floor Veterans Memorial Highway 1800 M Street, N.W.
Hauppauge, New York 11788 Washington, D.C.
20036-5891 David A. Brownlee Mr. Phillip McIntire Kirkpatrick & Lockhart Federal Emergency Management 1500 Oliver Building Agency Pittsburgh, Pennsylvania 15222 26 Federal Plaza New York, New York 10278 By Telecopy
'rlstopMer M.' McMurray Kirkpatrick & Lockhart South Lobby - 9th Floor 1800 M Street, N.W.
Washington, D.C.
20036-5891