ML20199K752: Difference between revisions

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{{#Wiki_filter:KIRKPATRICK & LOCKHART 1900 M STREET, N.W.
{{#Wiki_filter:KIRKPATRICK & LOCKHART 1900 M STREET, N.W.
WASHINGTON, D.C. 200M ONT BOSTON PLACE BOSTON, MA 02108 TElf. PHONE a02) 4s24000 16th 97M400 1428 BRICKELL A*.TNUE TuzcoPsacon smsz                                 MIAMI. FL HIH DOLMETED USNRC                 om m uz LATRENCE CoE LANPHER am en                                                                               ,R H     s 86 J1. -7 P3 :15           ein ==
WASHINGTON, D.C. 200M ONT BOSTON PLACE BOSTON, MA 02108 TElf. PHONE a02) 4s24000 16th 97M400 1428 BRICKELL A*.TNUE TuzcoPsacon smsz DOLMETED MIAMI. FL HIH USNRC om m uz LATRENCE CoE LANPHER am en
Lando W. Zech, Jr., Chairman Commissioner James K. Asselstine                             OFFICE OF EstIAsY 00CKETittG 5 SERVICI.
,R H s
Commissioner Frederick M. Bernthal                                 BRANCH Commissioner Thomas M. Roberts U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
86 J1. -7 P3 :15 ein==
Washington, D.C.           20555 Re:   Docket 50-322-OL-3; Shoreham Nuclear Power Station
Lando W.
Zech, Jr., Chairman OFFICE OF EstIAsY Commissioner James K.
Asselstine 00CKETittG 5 SERVICI.
Commissioner Frederick M.
Bernthal BRANCH Commissioner Thomas M.
Roberts U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555 Re:
Docket 50-322-OL-3; Shoreham Nuclear Power Station


==Dear Mr. Chairman and Members of the Commission:==
==Dear Mr. Chairman and Members of the Commission:==
 
Suffolk County last week received LILCO's pleadings entitled "LILCO's Motion to Strike Unauthorized Pleading Filed on June 23 by Suffolk County" and "LILCO's Reply to Unauthorized Pleading Filed on June 23 by Suffolk County."
Suffolk County last week received LILCO's pleadings entitled "LILCO's Motion to Strike Unauthorized Pleading Filed on June 23 by Suffolk County" and "LILCO's Reply to Unauthorized Pleading Filed on June 23 by Suffolk County." The County today received the " Response of Long Island Lighting Company to Governor Cuomo's June 30, 1986, ' Statement.'" The County will respond to LILCO's filings in accordance with the time limits set forth in the regulations.
The County today received the " Response of Long Island Lighting Company to Governor Cuomo's June 30, 1986, ' Statement.'"
In advance of the County's substantive response, several comments must be made.           First, LILCO's diatribe is inherently out of order.       Second, LILCO's Reply contains many significant distortions and misstatements, both of the law and facts.                             The i
The County will respond to LILCO's filings in accordance with the time limits set forth in the regulations.
County will address these in its response.                         Third, contrary to                   s LILCO's assertions, the County did not submit a " pleading" on                                           '
In advance of the County's substantive response, several comments must be made.
LILCO's " realism" argument. Rather, the Suffolk County Executive on June 23 issued a public statement and held a press conference to put an end to LILCO's mischaracterizations of the County Executive's views. Some of the matters he addressed also have relevance to issues pending in the Shoreham proceeding. The statement of Mr. Cohalan is thus merely a fact of which the County believes the NRC should be aware, particularly given past reliance by LILCO and the Commission on documents which the County Executive has rescinded.                 LILCO, however, seized this proper filing of the County as a pretext to file a 17 page brief.
First, LILCO's diatribe is inherently out of order.
LILCO has followed with a five page brief regarding the                                                   l Governor's filing.
Second, LILCO's Reply contains many significant distortions and misstatements, both of the law and facts.
l Sincerely yours' 8607090236      860707 ADOCK 05000322 PDR                   PDR Q                                                                                     _                ,
The i
County will address these in its response.
Third, contrary to s
LILCO's assertions, the County did not submit a " pleading" on LILCO's " realism" argument.
Rather, the Suffolk County Executive on June 23 issued a public statement and held a press conference to put an end to LILCO's mischaracterizations of the County Executive's views.
Some of the matters he addressed also have relevance to issues pending in the Shoreham proceeding.
The statement of Mr. Cohalan is thus merely a fact of which the County believes the NRC should be aware, particularly given past reliance by LILCO and the Commission on documents which the County Executive has rescinded.
LILCO, however, seized this proper filing of the County as a pretext to file a 17 page brief.
LILCO has followed with a five page brief regarding the Governor's filing.
8607090236 860707 Sincerely yours' ADOCK 05000322 PDR PDR Q
Lawrence Coe Lanpher}}
Lawrence Coe Lanpher}}

Latest revision as of 04:10, 8 December 2024

Responds to Util 860623 & 30 Filings.Util Diatribe Out of Order,Reply Distorted & County Did Not Submit Pleading on Util Realism Argument.Util Mischaracterization of County Addressed in 860623 Public Statement & Press Conference
ML20199K752
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 07/07/1986
From: Lampher L
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To: Asselstine J, Bernthal F, Zech L
NRC COMMISSION (OCM)
References
CON-#386-861 OL-3, NUDOCS 8607090236
Download: ML20199K752 (1)


Text

KIRKPATRICK & LOCKHART 1900 M STREET, N.W.

WASHINGTON, D.C. 200M ONT BOSTON PLACE BOSTON, MA 02108 TElf. PHONE a02) 4s24000 16th 97M400 1428 BRICKELL A*.TNUE TuzcoPsacon smsz DOLMETED MIAMI. FL HIH USNRC om m uz LATRENCE CoE LANPHER am en

,R H s

86 J1. -7 P3 :15 ein==

Lando W.

Zech, Jr., Chairman OFFICE OF EstIAsY Commissioner James K.

Asselstine 00CKETittG 5 SERVICI.

Commissioner Frederick M.

Bernthal BRANCH Commissioner Thomas M.

Roberts U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C.

20555 Re:

Docket 50-322-OL-3; Shoreham Nuclear Power Station

Dear Mr. Chairman and Members of the Commission:

Suffolk County last week received LILCO's pleadings entitled "LILCO's Motion to Strike Unauthorized Pleading Filed on June 23 by Suffolk County" and "LILCO's Reply to Unauthorized Pleading Filed on June 23 by Suffolk County."

The County today received the " Response of Long Island Lighting Company to Governor Cuomo's June 30, 1986, ' Statement.'"

The County will respond to LILCO's filings in accordance with the time limits set forth in the regulations.

In advance of the County's substantive response, several comments must be made.

First, LILCO's diatribe is inherently out of order.

Second, LILCO's Reply contains many significant distortions and misstatements, both of the law and facts.

The i

County will address these in its response.

Third, contrary to s

LILCO's assertions, the County did not submit a " pleading" on LILCO's " realism" argument.

Rather, the Suffolk County Executive on June 23 issued a public statement and held a press conference to put an end to LILCO's mischaracterizations of the County Executive's views.

Some of the matters he addressed also have relevance to issues pending in the Shoreham proceeding.

The statement of Mr. Cohalan is thus merely a fact of which the County believes the NRC should be aware, particularly given past reliance by LILCO and the Commission on documents which the County Executive has rescinded.

LILCO, however, seized this proper filing of the County as a pretext to file a 17 page brief.

LILCO has followed with a five page brief regarding the Governor's filing.

8607090236 860707 Sincerely yours' ADOCK 05000322 PDR PDR Q

Lawrence Coe Lanpher