ML20071P809

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Forwards Util Response to Suffolk County Submission Re Diesel Generators.Suffolk County Unwarranted Attack on Util, Util Counsel & NRC W/O Basis.Leave to Submit Response to Demonstrate No Issues of Fact Exist Requested
ML20071P809
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/03/1983
From: Twana Ellis
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To: Brenner L, Carpenter J, Morris P
Atomic Safety and Licensing Board Panel
Shared Package
ML20071P815 List:
References
ISSUANCES-OL, NUDOCS 8306080171
Download: ML20071P809 (2)


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Huwrow 6e WILLIAMS USNRC j 7o7 East MAIN sTR,,7 P. o. Box 1535 )

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f 1 k June 3, 1983 i b

. Lawrence Brenner, Esq. Dr. James H. Carpenter Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel

.. U.S. Nuclear Regulatory U.S. Nuclear Regulatory

' Commission Commission

. Washington, D.C. 20555 Washington, D.C. 20555 2 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Long Island Lighting Company Shoreham Nuclear Power Station, Unit 1 Docket _No. 50-322(OL)

Dear Administrative Judges:

Enclosed is "LILCO's Response to Suffolk County submission of Data Regarding Shoreham Diesel Generators."

Attached to LILCO's Response is an Affidavit of Edward J.

Youngling, Startup Manager for the Shoreham Nuclear Power Station. Iteis LILCO's understanding that the NRC Staff also will be filing a response to the County's pleading.

In addition, LILCO received on June 1 "Suffolk County's Response to the LILCO and Staff Oppositions to Motion for Leave to File a New Contention Concerning the Shoreham Emergency Diesel Generators." The County's " Response" has four notewor-thy aspects: (1) it is an unwarranted and scurrilous attack on LILCO, LILCO's counsel and the NRC Staff that falsely accuses r:306080171 830606 PDR ADOCK 05000322 O

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HUNTON 8C WILLI AM S Lawrence Brenner, Esq.

Dr. James H. Carpenter Dr. Peter A. Morris June 3, 1983 Page 2.

those part'ies of a " coverup" of information concerning the diesel generators; (2) it. improperly uses the authorities cited; (3) it alleges as fact, in both the " Response" and Mr.

Goldsmith's affidavit, natters which are either untrue or which, at best, may be subject to differing opinions; and (4) it should in any event, h* ave been filed in support of the County's original motion for leave'to file a contention.

The County's unwarranted ~ attack on LILCO, LILCO's counsel and the NRC Staff is totally without basis and does not deserve extended response. Response to the second and third aspects will' demonstrate that there are no issues of fact to litigate and that the County's reliance on the authorities.

cited is misplaced. LILCO hereby requests the Board's leave to submit such a response.

LILCO is aware of the Board's desire for consolidated responses; however, in this instance, LILCO believes that the facts in Mr. Youngling's affida'vit.should come to the immediate attention of the.. Board, given the' gravity of the County's alle-gations.

Sincerely, c ,

,4 75/869 T. S. Ellis, III

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