ML20215L026

Lilco Notice of Intent to File Rebuttal Testimony.* Rebuttal Testimony Will Focus on Traffic Analyses.Certificate of Svc Encl.Related Correspondence

ML20215L026
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/04/1987
From:	Miller S HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
CON-#287-3380 OL-3, NUDOCS 8705120076
Download: ML20215L026 (4)

Text

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LILCO, May 4,1987 maowmme UNITED STATES OF AMERICA 00(KETED USNaC NUCLEAR REGULATORY COMMISSION

'87 MAY -5 P4 :32 Before the Atomic Safety and Licensing Board 0FFICE Gi :i ,t ,e y 00CKETiHii a SEPvttf.

BRANCH In the Matter.of )

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

LILCO'S NOTICE OF INTENT TO FILE REBUTTAL TESTIMONY In two pleadings filed by LILCO on April 27,1987 responding to motions by Inter-venors for leave to file rebuttal testimony, LILCO indicated that it too intended to file rebuttal testimony and stated that it would inform this Board by May 4,1987 when it would be able to file such testimony. Since that time, LILCO has been in contact with Mr. Lieberman, who, as previously indicated, will be presenting LILCO's rebuttal testi-mony. This rebuttal testimony will focus on the traffic analyses sponsored by New York State witnesses Hartgen and Millspaugh.M Mr. Lieberman has indicated that he can complete his rebuttal testimony by Tuesday, May 26,1987. Accordingly, LILCO pro-poses to send out the rebuttal testimony by overnight delivery service on that date, for delivery May 27. This should leave ample time before June 15, the interim date set for the commencement of the hearing, for motions to strike and responses to such motions.

/

i 1/ LILCO is telecopying a letter to the State of New York requesting certain infor-mation which Mr. Lieberman needs to complete his review of the State's traffic analy-sis. It is primarily this analysis that will be the subject of Mr. Lieberman's rebuttal tes-timony. The anticipated May 26 date for the filing of that testimony is premised on the assumption that the State provides Mr. Lieberman with the requested information by May 11,1987. Should that not occur, LILCO might not be able to file its rebuttal testi-mony by May 26.

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Along with the rebuttal testimony, LILCO will also provide a motion for leave to file the testimony. It is LILCO's belief that such a motion can best be dealt with when the Board has the proposed testimony before it.

Respectfully submitted, James N. Christman Stephen W. Miller Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 4,'1987 s

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LILCO, May 4,l[Udh

'87 MY -5 P4 :32 0FFtk y n,.. ar CERTIFICATE OF SERVICE 00CXEi3ri*.3:pvia enANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S NOTICE OF INTENT TO FILE REBUTTAL TESTIMONY were served this date upon the following by telecopier or by hand delivery 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 Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Erat-West Towers, Rm. 407 Washington, D.C. 20555 4350 East-West Hwy.

B thesda, MD 20814 Atomic Safety and Licensing Board Panel Dr. Jerry R. Kline

• U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board U.S. Nuclear Regulatory Commission Richard G. Bachmann, Esq.

• East-West Towers, Rm. 427 George E. Johnson, Esq.

4350 East-West Hwy. U.S. Nuclear Regulatory Commission B thesda, MD 20814 7735 Old Georgetown Road (to mailroom)

Mr. Frederick J. Shon

• Bethesda, MD 20814 Atomic Safety and Licensing Board Herbert H. Brown, Esq.

• U.S. Nuclear Regulatory Commission Lawrence Coe Lanpher, Esq.

East-West Towers, Rm. 430 Karla J. Letsche, Esq.

4350 East-West Hwy. Kirkpatrick & Lockhart B:thesda, MD 20814 South Lobby - 9th Floor 1800 M Street, N.W.

S:cretary of the Commission Washington, D.C. 20036-5891 Attention Docketing and Service Section U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C. 20555

I Frbian G. Palomino, Esq.

• Mr. Philip McIntire Richard J. Zahnleuter, Esq. Federal Emergency Management Sp cial Counsel to the Governor Agency Ex;cutive Chamber 26 Federal Plaza Room 229 New York, New York 10278 State Capitol Albany, New York 12224 Jonathan D. Feinberg, Esq.

New York State Department of Mary Gundrum, Esq. Public Service, Staff Counsel Assistant Attorney General Three Rockefeller Plaza 120 Broadway Albany, New York 12223 Third Floor, Room 3-116 N;w York, New York 10271 Ms. Nora Bredes Executive Coordinator Sp;nce W. Perry, Esq. ** Shoreham Opponents' Coalition William R. Cumming, Esq. 195 East Main Street Fcderal Emergency Management Smithtown, New York 11787 Agency 500 C Street, S.W., Room 840 Gerald C. Crotty, Esq.

W::shington, D.C. 20472 Counsel to the Governor Executive Chamber Mr. Jay Dunkleberger State Capitol N;w York State Energy Office Albany, New York 12224 Ag;ncy Building 2 Empire State Plaza Martin Bradley Ashare, Esq. **

Albany, New York 12223 Eugene R. Kelly, Esq.

Suffolk County Attorney Stephen B. Latham, Esq. ** H. Lee Dennison Building Twomey, Latham & Shea Veterans Memorial Highway 33 West Second Street Hauppauge, New York 11787 P.O. Box 298 Riverhead, New York 11901 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Wading River, NY 11792 James N. Christman Stephen W. Miller Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212

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