|
---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18
[Table view] Category:PLEADINGS
MONTHYEARML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20082G8971991-08-0909 August 1991 Lilco Responses to Petitioner Filings of 910805 & 06.* W/Certificate of Svc ML20082G8441991-08-0707 August 1991 Motion for Offical Notice to Correct Representation.* Moves Board to Take Official Notice of Encl NRC Records to Correct Representation Made at Prehearing Conference. W/Certificate of Svc ML20082G8571991-08-0707 August 1991 Petitioners Response to Lilco Re Physical Security Plan.* Petitioners Suggest That Util post-hearing Filing Does Not Dispose of Any Issue as to Util Compliance W/Settlement Agreement.W/Certificate of Svc ML20076D0721991-07-22022 July 1991 Petitioners First Emergency Motion for Stay.* Movants Urge Commission,In Interest of Justice,To Enjoin Lilco from Taking Any Actions Under possession-only License Which Might Moot Renewed Application for Stay.W/Certificate of Svc ML20076D1541991-07-22022 July 1991 Lilco Response to Petitioner Emergency Motions.* Believes Petitioner Emergency Motions Should Be Denied to End Frivolous Pleadings & Burdens of Time & Resources of Nrc. W/Certificate of Svc ML20076D0841991-07-21021 July 1991 Petitioners Second Emergency Motion for Stay.* Petitioners Urge Commission,Ex Parte,To Enjoin Lilco,From Any & All Acts W/Respect to Shoreham Which Would Be Inconsistent W/Nrc Representation in Court.W/Certificate of Svc ML20076D2071991-07-15015 July 1991 Lilco Opposition to Shoreham-Wading River Central School District (Swrcsd) Appeal from LBP-91-26.* Appeal Should Be Denied Due to Listed Reasons.W/Certificate of Svc ML20082D4051991-07-12012 July 1991 Lilco Opposition to SE-2s Contentions on Possession Only License Amend.* Concludes That Contentions Should Be Rejected & Request for Hearing on Possession Only License Amend Should Be Denied.W/Certificate of Svc ML20082D4001991-07-12012 July 1991 Movant-intervenors Motion for Change of Venue of Prehearing Conference.* Intervenors Request Change of Venue of 910730 Prehearing Conference from Hauppauge,Ny to Washington DC Area.W/Certificate of Svc ML20082D3891991-07-10010 July 1991 Lilco Support of NRC Staff Motion for Reconsideration of LBP-91-26.* for Reasons Listed,Nrc 910625 Motion Should Be Granted & Request for Hearing & Petition to Intervene in Amend Proceeding Should Be Denied.W/Certificate of Svc ML20082B4311991-07-0303 July 1991 Lilco Opposition to Petitioner Contentions on Confirmatory Order,Physical Security Plan & Emergency Preparedeness License Amends.* Petitioner Contentions Should Be Rejected & License Amends Denied.W/Certificate of Svc ML20082B3531991-07-0202 July 1991 Unopposed Motion for Variance in Svc Requirements.* Informs That Filing & Svc Requirements Presents No Obstacle to Filing W/Aslb or Svc Upon Any Parties.W/Certificate of Svc. Served on 910702.Granted for Licensing Board on 910702 ML20082B2461991-06-28028 June 1991 Movant-Intervenor Brief in Support Accompany Notice of Appeal.* School District Urges Commission to Reverse & Remand Dismissal Order W/Appropriate Guidance.W/Ceritifcate of Svc ML20082B2571991-06-28028 June 1991 Unopposed Motion for Variance in Svc Requirements.* Petitioners Urge ASLB to Grant Variance in Svc Procedures Requested to Allow Svc of Judge Ferguson.W/Certificate of Svc 1993-10-08
[Table view] |
Text
~4 d
LILCO, EgitchTE16, 1984 UWC
'84 mR 19 N0n47 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI_ON. SEuita.
00CnEimG a SEFW '
ERANCH Before tne Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)
Unit 1) )
LILCO'S ANSWER TO SUFFOLK .
COUNTY MOTION TO STRIKE TESTIMONY OF JOHN R. SEARS Suffolk County has moved to strike the entire Testimony of John R. Sears on Behalf of the NRC Staff Regarding Emergency Preparedness Contentions 26.A, 26.C, and 26.D. The County's motion is based on Mr. Sears' statement that his testimony con-sists of his " personal professional opinions." The County's theory, which it puts forth without citing any authority, is that "[t]he Staff is a party to licensing proceedings for one purpose: to provide licensing boards with the views of the NRC Staff as to matters at issue" (Motion at 2). Apparently, in the County's view, an NRC Staff witness must represent an offi-cial, final position of the Staff, or.he may not testify.
l It appears to LILCO, on the other hand, that the purpose of expert testimony is to help the Board decide issues of fact, and that if a witness is qualified, then his professional 8403200037 840316 PDR ADOCM 05000322 9 PDR
_2-J l
opinior. may help resolve issues of fact regardless of whether I he represents some sort of " official" position of one party or another.
LILCO believes there is no basis in NRC regulations or case law for the County's motion to strike Mr. Sears' testimony and the County cites none. Accordingly, LILCO opposes the County's motion.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY Ab Jadesp.Christma6 4
Hunton & Williams Post Office Box 1535 707 East Main Street Richmond, Virginia 23219 DATED: March 16, 1984
(
I e
. - . - ,w - =,~r, e , .r+ -
O rILCO, March 16, 1984 CERTIFICATE OF SERVICE l
l
- 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 LILCO'S RESPONSE TO SUFFOLK COUNTY AND NEW YORK STATE MOTIONS TO STRIKE PORTIONS OF LILCO'S GROUP II-A TESTIMONY and LILCO'S ANSWER TO SUFFOLK COUNTY MOTION TO STRIKE TESTIMONY OF JOHN R. SEARS were served this date upon the following by first-class mail, postage pre-
! paid, or by hand (as indicated by one asterisk), or by Federal Express (as indicated by two asterisks).
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 Appcal Poard Panel 4350 East-West Hwy. U.S. Nuclcar Regulatory Bethesda, MD 20814 Commission Washington, D.C. 20555 Dr. Jerry R. Kline*
Atomic Gafety and Licer. sing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory j 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, Esg.* Federal Emergency Management i Attorney _ Agency Atomic Safety and Licensing 26 Federal Plaza, Room 1349
, Board Panel New York, New York '10278 l U. S. Nuclear Regulatory Commission Stephen B. Latham, Esq.**
Eest-West Tower, North Tower Twomey, Latham & Shea
- 4350 East-West Highway 33 West Second Street Bethesda, MD 20834 Post Office Box 398 Riverhead, NY 11901 l
O
_p_ t Fabian 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 30016 Room 229 State Capitol James B. Dougherty, Esq.**
Albany, New York 12224 3045 Porter Street Washington, D.C. 20008 Herbert H. Brown, Esq.* i Lawrence Coe Lanpher, Esq. Howard L. Blau Christopher M. McMurrey, Esq. 217 Newbridge Road Kirkpatrick, Lockhart, Hill Hicksville, NY 11801 Christopiler & Phillips 6th 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, Messachusetts 02154 Associate General Counsel Federal Emergency Management MHB Technical Associates Agency 1723 Hamilton Avenue 500 C Street, S.W.
Suite F Washington, D.C. 20472 San Jose, California 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 Plaza 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 Capitol Hauppaugg, New York 11788 Albany, New York 12224 In addition, copiec of (1) LILCO'S CROSS PLAN FOR THE CROSS-EXAMINATION OF DEPUTY INSPECTOR KENNETH J. REGENSBURG, DEPUTY INSPECTOR ROBERT A. SNOW AND POLTCE OFFICER VINCENT R.
STYLE ON EMERGENCY PLANNING CONTENTIONS 20 AND 50-58 (NOTIFICA-TION TO THE PUBLIC); (2) LILCO'S PLAN FOR THE CROSS-EXAMINATION OF DEPUTY INSPECTCR KENNETH J. REGENSBURG, DEPUTY INSPECTOR i l
ROBERT A. SHOW AND POLICE OFFICER VINCENT R. STYLE ON EMERGENCY I PLANNING CONTENTION 26 (NOTIFICATION OF EMERGENCY PERSONNEL);
O AND (3) LILCO'S PLAN FOR THE CROSS-EXAMINATION OF DEPUTY IN-SPECTOR RICHARD C. POBERTS, SERGEANT DONALD A. HOFFMAN AND PO-1 LICE OFFICER JAMES J. READ ON EMEFGENCY PLANNING CONTENTIONS 24.T AND 59 (NOTIFICATION TO THE PUBLIC BY THE U.S. COAST GUARD) are being served by hand on Judges, Laurenson, Fline and Shon, and Ms. Frucci.
% & & 4.11M
'\ Fe th+ E.
di
!. McCle sRe7 '
\
Hunton & Williams 707 East Main Street Post Office Box 1535 )
Richmond, Virginia 23212 LATED: March 14, 1984 t ,c- r tm - -