ML20235W190
| ML20235W190 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/09/1987 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4599 OL-3, NUDOCS 8710160043 | |
| Download: ML20235W190 (4) | |
Text
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LILCO, October 9,1987
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UNITED STATES OF AMERICA 37 si 14 P4 41 l
NUCLEAR REGULATORY COMMISSION h$k I
Before the Atomic Safety and Licensing Board In the Matter of
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LONQ ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S ANSWER TO INTERVENERS' MOTION FOR MODIFICATION OF RULING By motion of October 5,1987, the Interveno's have asked the Board to modify its September 17 Memorandum and Order ruling on LILCO's motion for summary disposi -
tion of the " legal authority" issues. The Interveners ask the Board to find that they have in fact contested facts 8,9, and 10 in the Statement of Material Facts attached to LILCO's motion. These three statements of fact address (in part) the Radiological Emergency Communications System (RECS) lines connecting Shoreham to various State offices.
In its May 22 Reply to the Interveners' answer LILCO pointed out, on page three, that the Interveners had not fully admitted statements of fact 8,9, and 10. The inter-venors are correct that they have taken issue with these statements, but only to the extent that specific facts are included in the Papile affidavit. Thus, LILCO agrees that the Interveners have raised issues about whether four RECS lines are " operational" (which apparently means " plugged in") and about how far two of the RECS drops are from particular State offices. (On the other hand, as LILCO pointed out on page 2 of pu21888SNE!S!R O
ps0
.o n4 its Reply, it is now admitted that a RECS line connects LILCO with the Suffolk County
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police.) Whether the issues raised by the Papile affidavit are materialis another mat-ter; as LILCO said on pages 4-5 of its Reply, the facts set out in the Papile affidavit make no difference at all when it comes to deciding the ultimate issue.
Respectfully submitted, l
l l
James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: October 9,1987
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y LII CO, October 9,1987 g
30CKETEC-USNttC CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY j
(Shoreham Nuclear Power Station, Unit 1),
Docket No. 50-322-OL-3 I hereby certify that copies of LILCO'S ANSWER TO INTERVENERS' MOTION -
FOR MODIFICATION OF RULING were served this date upon the following by 1
telecopier as indicated by one asterisk, by Federal Express as indicated by two aster-isks, or by first-class mail, postage prepaid.
i Morton B. Margulies, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers, Rm. 407 4350 East-West Hwy.
Atomic Safety and Licensing.
Bethesda, MD '. 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, D.C. 20555
-- Atomic Safety and Licensing Board..
Richard G. Bachmann, Esq.
U.S. Nuclear Regulatory Commission George E. Johnson, Esq.
East-West Towers, Rm. 427 U.S. Nuclear Regulatory Commission 4350 East-West Hwy.
7735 Old Georgetown Road Bethesda, MD 20814 (to mallroom) i Bethesda, MD 20814 Mr. Frederick J. Shon Atomic Safety and Licensing Herbert H. Brown, Esq.
j Board Lawrence Coe Lanpher, Esq.
j U.S. Nuclear Regulatory Commission Karla J. Letsche, Esq.
j East-West Towers, Rm. 430 Kirkpatrick & Lockhart 1
4350 East-West Hwy.
South Lobby - 9th Floor f
Bethesda, MD 20814 1800 M Street, N.W.
i Washington, D.C. 20036-5891
)
Secretary of the Commission l
Attention Docketing and Service Fabian G. Palomino, Esq.
Section Richard J. Zahnleuter, Esq.
U.S. Nuclear Regulatory Commission Special Counsel to the Governor 1717 H Street, N.W.
Executive Chamber Washington, D.C. 20555 Room 229 State Capitol Albany, New York 12224 D
j Mary Gundrum, Esq..
Jonathan D. Feinberg, Esq.
Assistant Attorney General New York State Department of 120 Broadway.
Public Service, Staff Counsel Third Floor, Room 3-116 Three Rockefeller Plaza New York, New York 10271
' Albany, New York 12223 Spence W. Perry, Esq.
Ms. Nora Bredes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Gerald C. Crotty, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq.
Stephen B. Latham, Esq.
Eugene R. Kelly, Esq.
Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building
' P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee
' Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York.10278
- h. Mas James N. Chrfstman Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: October 9,1987