ML20215L074
| ML20215L074 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/06/1987 |
| From: | Lanpher L, Latham S, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | |
| Shared Package | |
| ML20215L077 | List: |
| References | |
| CON-#287-3373 OL, OL-3, NUDOCS 8705120093 | |
| Download: ML20215L074 (3) | |
Text
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M I Dor:KET NUMBER
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PR00. f. UTIL FAC.)
00LHETED z
USNRC 6, 19 g g 4.-p4 y May UNITED STATES OF AMERICA 0FFICE U hud femY NUCLEAR REGULATORY Ci.MMISSION 00CKE11f.3 A SERVICf.
BRANCH Before the Commission In the Matter of.
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LONG ISLAND LIGHTING COMPANY
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Docket Nos. 50-322-OL
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50-322-OL-3
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(Emergency Planning)
-_(Shoreham' Nuclear Power Station,
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Unit 1)
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l
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SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN'OF SOUTHAMPTON SUBMISSION OF ADDITIONAL AFFIDAVIT IN OPPOSITION TO LILCO MOTION FOR EXPEDITED CONSIDERATION OF 25% POWER REOUEST On April' 27, 1987, Suffolk County, the State of New York, and:the Town of Southampton submitted a response to LILCO's motion for expedited consideration of its " Request" to operate Shoreham at 25% power this summer.
Sag Suffolk County, State of New York, and Town of Southampton Response in Opposition to LILCO's Motion for Expedited Consideration, April 27, 1987.
Attached to that Response was an Affidavit of William E. Davis, Executive Deputy Commissioner, New York State Energy Office, which demonstrated that contrary to the LILCO allegations, there is no need for Shoreham's power this summer or in the future.
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Due to the brief time available to respond to LILCO's filings, the Governments were unable by April 27 to obtain an additional affidavit in opposition to the LILCO " Request."
That affidavit has now'been completed and is submitted herewith.
It is presented by Dr. Steven S. Bernow, Vice President of Energy l
Systems Research Group.
Dr. Bernow discusses additional' reasons g
why there is no need for Shoreham's power this summer or in the
-future.
Dr.-Bernow's affidavit constitutes an additional reason why there-is no basis for the NRC to grant LILCO's motion for expedited consideration and, indeed, why there is no basis for the Commission even.to consider LILCO's unprecedented request to operate Shoreham at 25% power in the absence of all safety and emergency planning findings.
Respectfully submitted, 1
Martin Bradley Ashare.
Suffolk County Attorney Building 158 North County Complex 4.
Veterans Memorial Highway j
Hauppauge, New York 11788 1
h Herbert H. Brown 7
Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK & LOCKHART 1800 M Street, N.W.
Eouth Lobby - 9th Floor Washington, D.C. 20036-5891 j -
Attorneys for Suffolk County 1
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F x d A/~ a C N 7)
Fabian G..alomino Special Counsel to the Governor of the State of New York Executive Chamber, Room 229' Capitol Building Albany, New York 12224 Attorney for Mario M..Cuomo, Governor of the State of New York k,
e Stephen B. Latham Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton.
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