ML17207A676
| ML17207A676 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/27/1979 |
| From: | Hodder M HODDER, M.H. |
| To: | Mike Farrar, Johnson W, Salzman R Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17207A677 | List: |
| References | |
| NUDOCS 7912270147 | |
| Download: ML17207A676 (4) | |
Text
1131 N.E.
86 Street Miami, Fla.
33138 November 27, 1979 Atomic Safety Licensing and Appeal Board Michael C. Farrar, Esq.,
Chairman Richard S.
- Salzman, Esq.
Dr.
W. Reed Johnson In the Matter of Florida Power and Light Company
( St. Lucie Nuclear Power Plant, Unit 2)
Docket No. 50-389
Dear Members of the Board,
Intervenors wish to advise the parties and members of the Board that for good and sufficient reason they presently will not be able to present the direct testimony of Robert Pollard of the Union of Concerned Scientists at the hearing scheduled for Dec. 11, 1979.
Intervenors will participate and will present their case through crossexamination and interrogatories.
Intervenors had advised counsel for the Staff and the applicant informally by telephone prior to the Nov. 16, 1979 deadline for filing written testimony, that this would be the likely outcome of any effort by the Intervenors to present Mr. Pollard's testimony in a direct case.
The Intervenor+ further advised the parties counsel that their decision not to present direct testimony was subject to review upon examination of testimony of Patrick W. Baranowsky to be filed by the Staff on Nov. 9, 1979 and which was received by the Intervenors for the first time Friday, Nov. 16, 1979.
That testimony is now under review by Intervenors.
The subject testimony involved probabilistic analysis.
In addition, Intervenors propound the attached interrogatories to the utility in an effort to develop a complete record on FPL's history of on-site and off-site power availability so as to aid, the Appeal Board in their deliberations on these issues.
Finally, INtervenors are attempting to obtain the testimony of Dale Bridenbaugh of MBH Associates of San Jose, California since he has performed an analysis of the safety implications of the problems associated with the on-site power failures at the St. Lucie plant and Mr. Baranowsky's probabilistic analysis testimony.
If Intervenors obtain Mr. Bridenbaugh's services it will be too late to prefile his testimony.
Therefore, in lieu of that testimony, and for the information of the Board and the parties, the Intervenors file herewith an in-depth newspaper article treating Mr. Bridenbagh',s views from the Palm Beach Post Times of October 28
, 1979..
Page 2
- Farrar, Sazman, Johnson November 27, 1979 It had been Intervenors intention to file this letter and accompanying Interrogatories by Monday, Nov. 19, 1979 but some delay was occasioned when Intervenors typwriter broke.
o rs truly, rtin H. Hodder Counsel for Intervenors CC Norman A. Coll Harold F. Reis Milliam D. Paton
N