ML20214W607

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NRC Staff Response to State of Ny & Suffolk County Motion to Strike Portions of Lilco Rebuttal Testimony.* Motion Opposing State of Ny & Suffolk County 870605 Motion to Strike Lilco 870516 Request of Leave for Substitution
ML20214W607
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/10/1987
From: Bachmann R
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20214W610 List:
References
CON-#287-3728 OL-3, NUDOCS 8706160099
Download: ML20214W607 (2)


Text

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/2I 06/10/87 i

DXFETE:

UWf UNITED STATES OF AMERICA i'

NUCLEAR REGULATORY COMMISSION

'87 JUN 11 P3 :10 BEFORE THE ATOMIC SAFETY AND LICENSING BOAlk In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station,

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Unit 1)

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NRC STAFF RESPONSE TO NEW YORK STATE AND SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO'S REBUTTAL TESTIMONY The Staff hereby responds to that part of the June 5,1987 filing 1 of New York State and Suffolk County which moves the Licensing Board to strike portions of LILCO's rebuttal testimony sponsored by Edward B.

Lieberman.

The sole basis for the State and County's motion to strike is that Mr. Lieberman relies on, and makes reference to, a relatively new traffic analysis, KLD TR-201A.

On May 16,1987, LILCO requested leave of the Board to substitute KLD TR-201A for KLD TR-201 as an attachment 2,/

LILCO's request was opposed by the State to its direct testimony 1/

New York State and Suffolk County Response to LILCO's Motion for Leave to File Rebuttal Testimony, and Motion to Strike Portions of

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Rebuttal Testimony, flied June 5,1987.

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Motion for Leave to Substitute KLD TR-201A for KLD TR-201 as Attachment S to LILCO's Written Testimony of March 30,1987, filed May 16,1987.

8706160099 870610 PDR ADOCK 05000322

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Q PDR and County S, and supported by the Staff II The instant motion to strike seeks the same relief as the State and County's opposition to i

LILCO's substitution request and the proferred bases are the same.

Therefore, for the reasons given in its May 21, 1987 filing, the Staff urges the Board to grant LILCO's request to substitute KLD TR-201A, and to deny the motion to strike.

Respectfully submitted, Richard G. Bachmann Counsel for NRC Staff Dated at Dethesda, Maryland this 10th day of June,1987

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Suffolk County and State of New York Opposition to LILCO Motion for Leave to Substitute KLD TR-201A for KLD TR-201, filed May 26, 1987.

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NRC Staff Response to LILCO's Motion to Substitute KLD TR-201A for KLD TR-201, filed May 21, 1987.

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