ML20024E435

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Response to 830727 & 0802 Sixteen Informal Discovery Requests.Lists Names of Witnesses NRC Expects to Call During Emergency Planning Hearings
ML20024E435
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 08/05/1983
From: Bordenick B
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Birkenheier J
KIRKPATRICK & LOCKHART
Shared Package
ML20024E436 List:
References
NUDOCS 8308150047
Download: ML20024E435 (6)


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August 5,1983 John E. Birkenheier, Esq.

Kirkpatrick, Lockhart, Hill Christophes & Phillips 1900 M Street, N.W.

Washington, D.C.

20036 In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (Emergency Planning)

Dear Mr. Birkenheier:

This is in reply to your letters of July 27, 1983, and August 2, 1983, which enclosed a list of sixteen informal discovery requests to the Staff.* Set out below are-the Staff's responses to your informal requests which have been provided to me. As to the first eight requests, with the exception of items 5 and 6 I gave you these responses over the telephone on July 29, 1983.

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'gave you most of item 5 on' August 3, 1983.

I gave verbal responses to items 9-16 to you by telephone.on August 3, 1983.

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1.

The Staff presently, expects to call the following named persons as witnesses during the Shoreham emergency planning hearings.

Witness Subject matter John R. Sears Onsite emergency preparedness as it interfaces with offsite planners Thomas Urbanik, II Evacuation Time Estimate Analysis In' order to expedite this proceeding and to continue the long standing spirit of cooperation between the Staff and Suffolk County with respect to discovery matters, the Staff agrees to treat the County letters as informal discovery requests. The Staff's voluntary response to the County's-requests should not, however, be construed as a Staff acknowledgement that the County discovery requests. in any way comply with the provisions.of 10 C.F.R. 5 2.720(h)(2)(ii) or 6 2.744 as regards discovery against the Staff.

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2.

Thomas Urbanik, II, is a consultant retained by a Staff consultant (Battelle) to perform an Evacuation Time Estimate Analysis. Mr. Urbanik is from the Texas Transportation Institute of the ~ University of Texas (College Station, Texas). -See also 4 below.

3.

To date.there are no NRC staff evaluations etc. of the LILC0 Transition s.

~ Plan. The criteria which will be used to evaluate the Plan are set out in NUREG-0654, a copy of which I believe the County has in its possession, t

4.

Attached find copy of a letter dated December 2,1982 from Thomas Urbanik, II, identified above, to John Sears, also identified above.

(This was telecopied to you on August 3, 1983).

5.

The Staff presently expects to call the following named FEMA (or contractor) witnesses as a panel to testify to whatever contentions are admitted in the Shoreham proceeding which relate to FEMA.

A.

Roger P Kowieski - FEMA Region 2, Radiological Assistance Committee Chairman B.

Fred Sharrocks - FEMA, Washington, D.C.

Emergency Management Offices C.

Edward Tanzman

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Argonne National Laboratory

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Argonne National Laboratory Personnel who reviewed the LILCO Transition Plan.

Edward Tanzman Chris Saricks Kenneth Lerner Phyllis Becherman James H. Opelka

. FEMA personnel who reviewed the LILC0 Transition Plan.

Headquarters Richard Krimm Jeffrey Bragg-George Jett Gary Johnson Fred Sharrocks Spence Perry-D

. Region II Roger Kowieski Stewart Glass Frank Petrone Phil McIntire 7 and 8.

The Staff is presently defining the scope of work for review of the recently submitted Shoreham PRA and expects to have this task completed by the end of August. This task is being performed by Edward Chow of the Staff. A schedule for completion of the review has not yet been finalized.

It is presently anticipated that the review will require six to twelve months to complete.

It has not yet been decided who the review contractor will be for the Staff. As you are no doubt aware, the Staff does not view the PRA as a prerequisite for the licensing of Shoreham.

(See generally the record compiled with regard to SC-SOC Contention 7EJT 9.

See 4 above.

In addition Battelle is preparing a comparison or the range of evacuation time estimates, including Shoreham, based on input-from Mr. Urbanik.

I will provide further information on this next week.

10.. John R. Sears
11. Mr. Urbanik is a subcontractor for Battelle who works independently.

His contact at Battelle is Art Desrusiers. -

12. See 14 below.
13. Mr. Urbanik is not under contract to the NRC.

(In any event I fail to see the relevance of this request to any potential County contention.)

14. Mr. Urbanik has testified' at hearings in Al. lens Creek, Indian Piont, Byron, Waterford, Diablo Canyon,-Zimmer, Three Mile Island, and Fermi.

9e also prefiled testimony at Comanche Peak. We are checking on the dates of such testimony.

In any event, this information may be obtained at the Commission's Public Document Room.

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15 and 16. See attached Biographical Data for Mr. Urbanik which responds to your requests (Telecopy was sent to you on August 3, 1983).

Sincerely, Bernard M. Bordenick Counsel for NRC Staff

Enclosures:

As Stated 4

cc:

(w/enclosuresand incoming)

Janes N. Chrisman, Esq.

Stewart Glass DISTRIBUTION Bordenick Repka Dewey Mcdonald Rawson Reis Christenbury Murray Lieberman i

Olmstead OELD FF (2)

NRC Docket File: PDR/LPDR Chron(2)

R.Ca ruso 144 A.Schwencer 330 J.Norris AR5008 bXo'7

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tecturer, Civil t regir.eering, T e > e r :< M 'O rrsity 1

Education Ph.D., Civil E ngineering,' fei.as At,M Uni versity,1982.

M.S., Civil Engineering, Purdue University,1971.

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' B.S., Torest Engineering, State University of New York, 1968.

Experience Assistant Research Engineer, T exas T ransportation I nstitute, Texas A&M Uni versity, 1977-Present, tecturer, Civil Engineering, Texas A&M University,1982-Present.

Traf fic Engineer, City of Ann Arbor, Ann Arbor, Michigan, 1972-1976.

5 Transportation P1anning Engineer, City of Ann Arbor, Ann Arbor, Michigan 1971-1972.

Research Assistant, Joint liighway Research Project, Purdue Uni versity.

-1970-1971.

j Professional Licenses Registered Professional Engineer, Texas and Michigan Memberships American Society of Civil Engineers Institute of Transportation Engineers Sigma Xi

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Chi Epsilon Si mI FI CANT IEPORTS MD PUBLI CATI ONS _.

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. 7mffic Engineering Priority Treatment of Buses at T raf fic Signais. T ransportation Engineering, l

. November 1977.

Priority Treatment of liigh-Occupancy Vehicles on Arterial Streets.

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h:'%r Wie.ory -

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and Texas.

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E v a l uati on of Sel ected Human

  • Se'r vi ces T ransportation Providers.

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Total Accessibility Versus Equivalent Mobility of the Handicapped. Institute of Transportation Engineers, Compendium of Technical Papers, 49th Annual Meet-

.i n g, 197 9.

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