ML20024E439
| ML20024E439 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/27/1983 |
| From: | Birkenheier J KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Repka A NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20024E436 | List: |
| References | |
| NUDOCS 8308150049 | |
| Download: ML20024E439 (4) | |
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BY MESSENGER J
David A.
Repka, Esq.
U.
S.
Nuclear Regulatory Commission 7735 Old Georgetown Road Room 10205 Bethesda, Maryland 20814
Dear Dave:
I am enclosing a short list of informal discovery requests.
We would appreciate receiving the responses of the NRC Staff as soon as practicable.
In particular, the County needs to have answers to questions 1, 2,
5 and
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6 by Friday of this week if it is to develop its scheduling proposals with regard to the Emergency Planning hearing.
In addition, copies of Suffolk County's responses to J
certain of LILCO's discovery requests inadvertently were not sent to you.
They are enclosed with this letter.
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If you have any questions related to. discovery, please do not hesitate to call.
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Sincerely, John E.
Birkenheier Enclc.
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Identafy each I'ert :
call as an expert o r n or.- e :-: t e r t :i t :,e s s d u r i r.g
.h e Ehcreham energency planning hearings and state the subject matter on i
which each is expected to testify.
2.
Identify all con' tractors retained by the Staf f, or which the Staff currently intends to retain, to review, analyze or comment upon the LILCO Transition Plan or any offsite emer-2.
gency plana,for the Shoreham plant.
What is the schedule for f.
such review and analysis?
3.
Provide copies of any evaluations, reviews and/or
/LOfqp analyses of the adequacy, implementability and effectiveness of the LILCO Transition Plan and/or the OPIPs performed by or on behalf of the Staff or its contractors.
Identify the criteria used to evaluate the LILCO Transition Plan and the l
OPIPs, if any.
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Provide copies of the floal report, supporting docu-ments and analyses, supporting data,'and any other documentation relating to Wilbur Smith and Associates, An Evacuation Time Assessment of Nine Nuclear Power Plants Emergency Planning Zones, Program Report, Contract No. EMW-C-0758, June, 1980, Vol. IX Shoreham Nuclear Power Plant Evacuation Time Assessment.
If not
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described in the requested materials, please describe the methodology by which the evaluation was conducted.
5.
Identify each FEMA representative whom the Staff ex-pects to call as a witness during the Shoreham emergency planning hearings and state the subject matter on which each is expected to testify.
i j
6.
Provide the names of the Argonne National Laboratory personnel who; performed, participated in, or reviewed the re-sults of the ' Argonne - review of the Transition Plan ' at the re -
quest',of FEMA.
Also, provide the names of the FEMA represen-tatives who requested, directed, participated in, reviewed, critiqued, or commented upon, the Argonne review or-the report documenting the results.
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7.
What is the schedule for the Staff's review of the Shoreham PRA dated-July 1983?
Identify the Staff personnel who l
I are, or will be, involved in such review.
Provide. copies of i
all documents which relate to such ~ review.
I 8.
Identify all contractors retained by the Staff, or which the Staff. intends to reta'in, to review, analyze or com-ment upon the Shoreham PRA dated July 1983.
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BY MESSENGER 4
- David A.
Repka, Esq.
U.
S. Nuclear Regulatory _ Commission 7735 Old Georgetown Road 3
Room 10205 Bethesda, Maryland 20814
Dear Dave:
I am~ enclosing a short list of informal discovery requests.
We would appreciate receiving the responses
~
of the NRC Staff as soon as'. practicable.
In particular, the County needs to have answers to questions 1, 2, ' 5 and
- 6 by Friday of this week if it is to. develop its scheduling proposals with regard to the Emergency Planning hearing.
In addition, copies of Suffolk County's responses to certain of LILCO's discovery requests inadvertently were not sent to you.
They are enclosed with this letter.
If you have any questions related to discovery, please do not hesitate to call.
Sincerely, i-
-John E.
Birkenheier I
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1.
Identi fy each.-n a
%.m the ::RC Staff expects to call as an expert or non-expert witness during the Shoreham emergency planning hearings and state the subject matter on which each is expected to testify.
2.
Identify all con' tractors retained by the Staff, or which the Staff currently intends to retain, to review, analyze or comment upon the LILCO Transition Plan or any offsite emer-gency plan for the Shoreham plant.
What is the schedule for s
such review and analysis?
, 3.
Provide copies of any evaluations, reviews and/or analyses of the adequacy, implementability and effectiveness i
of the LILCO Transition Plan and/or the OPIPs performed by or on behalf of the Staff or its contractors.
Identify the criteria used to evaluate the LILCO Transition Plan and the OPIPs, if any.
4.
Provide copies of the final report, supporting docu-ments and analyses, supporting data, and any other documentation relating to Wilbur Smith and Associates, An Evacuation Time Assessment of Nine Nuclear Power Plants Emergency Planning Zones, Program Report, Contract No. EMW-C-0258, June, 1980, Vol. IX Shoreham Nuclear Power Plant Evacuation Time Assessment.
If not described in the requested materials, please describe the methodology by which the evaluation was conducted.
5.
Identify each FEMA representative whom the Staff ex-pects to call as a witness during the Shoreham emergency planning hearings and state the subject matter on which each is expected to testify.
6.
Provide the names of the Argonne National. Laboratory personnel who performed, participated in, or reviewed the re-sults of the Argonne review of the Transition Plan at the re-quest of FEMA.
Also, provide the names of the FEMA represen-j tatives who requested, directed, participated in, reviewed,
/
critiqued, or commented upon, the Argonne review or the report documenting the results.
7.
What is the schedule for the Staff's review of the Shoreham PRA dated July 1983?
Identify the Staff personnel who are, or will be, involved in such review.
Provide copies of all documents which relate to such review.
8.
Identify all contractors retained by the Staff, or which the Staff intends to retain, to review, analyze or com-
~
ment upon the Shoreham PRA dated July 1983.
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