ML19352A577

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Requests That Applicant 770208-16 Testimony Re Coal & U Fuel Cycle Health Effects,Given Before Ny Siting Board,Be Incorporated Into Record
ML19352A577
Person / Time
Site: 05000516, 05000517
Issue date: 05/24/1977
From: Whittemore F
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML18025B195 List:
References
FOIA-80-587 NUDOCS 8104170233
Download: ML19352A577 (2)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket Nos. 50-516 i

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50-517 (Jamesport Nuclear Power Station,

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Units 1 and 2)

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APPLICANT'S MOTION THAT ITS TESTIMONY ON COAL AND URANIUM FUEL CYCLE HEALTH EFFECTS GIVEN IN THE NEW YORK SITING BOARD'S JAMESPORT PROCEEDING BE INCORPORATED INTO THIS RECORD The comparative health effects of the coal and uranium fuel cycles have already been the subject of extensive written and oral testimony by LILCO in the New York Siting Board hearings on Jamesport.

LILCO submitted 229 pages of pre-filed testimony, consisting of an 8-page su= mary comparing the health effects of the uranium and coal fuel cycles; followed by Appendix A, a 151-page detailed analysis of the uranium fuel cycle; Appendix B, a 63-page analogue for the coal fuel cycle;

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and Appendix C, a 7-page list of references cited in short form a

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.in the text.

The cross-examination of the 7 witnesses who spon-7g sored this testimony lasted 7 days, February 8-16, 1977, and Y

spans 1453 transcript pages.

Mr. Like and Mrs. Tiedke were among the cross-examiners.

Because LILCO has already presented this written testimony on comparative health effects and has been cross-examined con-

-.cern ng it by representatives of all the active participants i

- 810.4170033

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  • in this proceeding except the NRC Staff, we request that the

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l testimony be admitted into this record as an exhibit.

The 1

incorporation would be akin to the -earlier introduction of parts of the Siting Board record into evidence here via exhibits, e.g.,

Tr. 2011-13, 6216-17.

If the Board grants the present motion,- LILCO's health effects exhibit will consist of (a) all aspects of the written testi=ony described above except for 27 pages dealing with security arrangements and repair / outage costs, and (b) all cross-examination on the pertinent written testimony.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY Q9 irff,*...-

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F. Case Whitte= ore l

W. Taylor Reveley, III, Esq.

Hunton & Williams 707 East Main Street Rich =ond, Virginia 23212 DATED:

May 24,1977 I

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