ML20087P950

Joint Motion for Deferral of Motions to Strike Testimony on Contentions 11 & 15 Until 7 Days from Date of Svc by Util of Amended Testimony on Contention 11.Certificate of Svc Encl.Related Correspondence

ML20087P950
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/05/1984
From:	Irwin D, Letsche K LONG ISLAND LIGHTING CO., SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
References
OL-3, NUDOCS 8404100143
Download: ML20087P950 (4)

Text

k gycaue"# April 5, 1984

. i r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS$$)NAPR -9 A11 :41 LFFRE OF 3!,Li.t ~.;

CCCdEilWiA SI%i Before the Atomic Safety and Licensinq4Bo.ard:

In the Matter of )

)

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

) (Emergency Planning Proceeding)

(Shoreham Nuclear Power Station, )

Unit 1) )

JOINT LILCO/SUFFOLK COUNTY MOTION FOR DEFERRAL OF MOTIONS TO STRIKE TESTIMONY ON CONTENTIONS 11 AND 15 One of the witnesses sponsoring LILCO's testimony on Con-tention 11 (conflict of interest), filed on March 30, 1984, was Andrew Wofford. On the same day the testimony was filed, Mr.

Wofford took early retirement from LILCO, effective immedis.tc=

ly. Mr. Wofford served as a Director of Local Response in the LILCO Local Emergency Response Organization. LILCO is in the process of determining whether, and if so how, to replace Mr.

Wofford's testimony, or whether to delete that portion attrib-utable to him. LILCO expects to arrive at this decision in the near future. In the meantime, LILCO believes that it would be reasonable that motions to strike any portion of LILCO's testi-mony on Contention 11 be deferred until seven days after the date of service of LILCO's amended testimony to account for Mr.

Wofford's retirement.

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. T Suffolk County does not oppose an equal deferral of LILCO's motion to strike any portion of its testimony on Con-tention 11, so as to preserve symmetry of filings. Since Suffolk County's testimony on Contention 11 is merged in one document with its testimony on Contention 15, this would mean

-deferral of all motions to strike testimony on Contentions 11 and 15 until seven days after LILCO's amendment to its current testimony on Contention 11.

For the above reasons, LILCO and Suffolk County jointly move for a deferral of the filing date of motions to strike testimony on Contentions 11 and 15 until seven days from the date of service by LILCO of its amended testimony on Contention 11.

Respectfully submitted, Donald P. Irwin Counsel for Long Island Lighting Company L L.

Karla g. Letsche ' / Y V' Counsd for Suffolk]Co{anty DATED: April 5,_1984 e

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April 5, 1984 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

(Emergency Planning Proceeding) Docket No. 50-322-OL-3 I'hereby certify that copies of JOINT LILCO/SUFFOLK COUNTY MOTION FOR DEFERRAL OF MOTIONS TO STRIKE TESTIMONY ON CONTEN-TIONS 11 AND 15 were served this date upon the following by first-class mail, postage prepaid, and in addition by hand if present at the hearings in Hauppauge (as indicated by an aster-isk).

James A. Laurenson,* Secretary of the Commission Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing East-West Tower, Rm. 402A Appeal Board Panel 4350 East-West Hwy. U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, D.C. 20555 Dr. Jerry R. Kline*

Atomic Safety and Licensing , Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower,-Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.

Bethesda, MD 20814 Bernard M. Bordenick, Esq.*

David'A. Repka, Esq.

Mr. Frederick J. Shon* Edwin J. Reis, Esq. -

Atomic Safety and Licensing' U. S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom)

East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.

Bethesda, MD 20814 Stewart M. Glass, Esq.*

Regional Counsel Eleanor L. Frucci, Esq.* Federal Emergency Management Attorney Agency Atomic Safety and Licensing 26 Federal Plaza,' Room.1349 Board Panel New York, New York 10278 U. S. Nuclear Regulatory Commission .

Stephen B. Latham, Esq.*

' East-West ~ Tower, North Tower Twomey, Latham & Shea 4350 East-West Highway 33 West Second Street Bethesda, MD 20814 Post Office Box 398 Riverhead, NY 11901

~-- -

+ - ... -~- . . . - . . --

.*_ \

Febian G. Palomino, Esq.*: Ralph Shapiro, Esq.*

~' ~

Special Counsel to the Cammer & Shapiro, P.C.

Governor ~. 9 East 40th Street Executive Chamber' New York, New York 10016 Room 229 State' Capitol- . James B. Dougherty, Esq.*

LAlbany, New York. _ 12224 3045 Porter Street Washington, D.C. 20008 Herbart H. Brown, Esq.*

Lawrence Coe Lanpher,-Esq. Howard L. Blau 1

Christopher ~M..McMurray, Esq. 217 Newbridge Road

.Kirkpatrick,z Lockhart,' Hill- Hicksville, NY 11801 Christopher & Phillips

.8th Floor. Jonathan.D. Feinberg, Esq.

1900'M-Street, N.W. New York' State Public Service Washington, D.C. 20036 Commission, Staff Counsel 3 Rockefeller Plaza Mr. Marc W.' Goldsmith Albany, New-York 12223 Energy Research Group 4001 Totten' Pond' Road Spence W. Perry, Esq.

Waltham,-Massachusetts '02154 Associate General Counsel Federal Emergency Management

.MHB-Technical Associates Agency 1723 Hamilton Avenue 500 C Street, S.W.

. Suite K' Washingtoit, D.C. .-20472

' San; Jose,TCalifornia 95125.

Ms.-Nora Bredes Mr. Jay Dunkleberger Executive Coordinator

'New York / State Energy Office-Shoreham Opponents'~ Coalition Agency Building 2 195 East Main Street ,

Empire State.P1aza Smithtown, New York 11787~

-Albany,;New York. 12223 Martin Bradley'Ashare, Esq.

Gerald C. Crotty,.Esq. Suffolk-County Attorney

Counsel to the' Governor H., Lee Dennison Building

-Executive Chamber- Veterans Memorial. Highway-

' State l Capitol. .

Hauppauge, New York 11788 l Albany, New York.:12224 l

e l DATED: April 5, 1984-4 6

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