ML19352A013
| ML19352A013 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/20/1981 |
| From: | Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Trifunac M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8102250414 | |
| Download: ML19352A013 (3) | |
Text
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UtHTED STATES
,,f h.,.
[ 'g NUCLEAR REGULATORY COMMISSION 3p:
E C Vi ASH WGT ON, D. C. 2035 kM.O.,
February 20, 1981 Dr. Mihailo Trifunac 1488 Old House Road Pasadena, CA 91107 In the Matter of Public Service Company of New Hampshire, et al.
(Seabrook Station, Units 1 and 2)
Docket Nos. 50-443, 50-444
Dear Dr. Trifunac:
You may recall that the presiding Atomic Safety and Licensing Appeal Board granted the request of the-New England Coalition on fluclear Pollution that you be called as a Board witness in this proceeding.
In the words of the Appeal Board:
The request of the New England Coalition on Nuclear Pollution ("NECNP") that Dr. Mihailo Trifunac be called to testify as a Board witness is granted.
In such capacity, Dr. Trifunac will be under the pro-tection of the Board. Any party to the proceeding may cross-examine him.
Inasmuch as he previously had testiHed in this proceeding on behalf of the Coalition (and will be now called as a Board' witness only because of his consultant relationship with the Advisory Committee on Reactor Safeguards), the Coalition will not be permitted to pose leading questions to him. _1/
The Appeal Board's~" Memorandum-and Order" also provided that your prepared l
written testimony "on the second issue identified at p. 4 of the Commission's September 25 [1980] remand order" 2/ was to be filed on or before liarch 16, 1981.
That issue was identified by the Commission as follows:
(
The Appeal Board shall also reopen the record to take more evidence on the consistency of Appendix A and staff's methodology for correlating vibratory motion
_lj Unpublished " Memorandum and Order," pp. 1-2 (November 6, 1980).
J Id., p. 3 (November 6,1980).
810!? 25n ~
l
a,.... with the SSE.
In particular, the parties should provide a discussion of the relation between the mean of the maximum ground acceleration and the maximum effective ground acceleration. The Appeal Board should also reconsider its opinion on this matter. _3]
I.have enclosed a copy of the Staff testimony (of Dr. Leon Reiter, Dr. Robert E.
Jackson and Mr. James P. Knight) that was filed this week (February 17,1981)
-in this proceeding. As you will note, portions of that testimony address "the second issue" as above delineated.
As to the mechanics of filing your testimony as a Board witness, permit me to suggest the following procedure.
Inasmuch as the evidentiary hearing is scheduled to commence in Nashua, New Hampshire, on April 6,1981, I suggest that you send two copies of your testimony to me.
I will then send one copy by hand-delivery directly to the presiding Appeal Board. The
'other copy will be xeroxed and hand-delivered to counsel for NECNP, express-mailed to counsel for the Pennittee, and mailed first class to all other parties on the service list.
Because of the relatively short time between the filing of your testimony and the commencement of the evidentiary hearing, I suggest that your testimony be sent so as to arrive in Washington, D.
C.,
as close as possible to the filing date of March 16, 1981.
As.to your deposition,- a.co'py of the transcript was sent to you for review and signature during your recent trip to India.
Inasmuch as there may have been a problem-in transmittal, another copy (together with my previous transmittal letter) is also enclosed.
Sincerely, 9
V m
g I
Roy P. Lessy
. Deputy Assistant Chief L
Hearing Counsel Enclosures As Stated cc: See Page Three-p J " Order,"-CLI-80-33, 12;NRC'295, 298 (1980).
. +- =
cc w/o enc 1:
Alan S. Rosenthal, Esq.
Dr. John H. Buck Dr. W. Reed Johnson Ivan W. Smith, Esq.
Joseph F. Tubridy, Esq.
Dr. Ernest 0. Salo Dr. Kenneth A. McCollom Robert A. Backus, Esq.
Thomas G. Dignan, Jr., Esq.
John A. Ritsher, Esq.
Norman Ross, Esq.
E. Tupper Kinder, Esq.
Francis S. Wright, Esq.
f Laurie Burt, Esq.
William C. Tallman
-Ellyn R. Weiss, Esq.
Ms. Elizabeth H. Weinhold D. Pierre G. Cameron, Jr., Esq.
- - Atom c Safety and Licensing Appeal Board Panel i
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Atomic Safety and Licensing Board Panel Docketing and Service Section L