ML20024E440

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Addl Informal Discovery Requests Re Emergency Planning. Written Responses to 830727 Requests Needed
ML20024E440
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 08/02/1983
From: Birkenheier J
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To: Repka D
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20024E436 List:
References
NUDOCS 8308150051
Download: ML20024E440 (2)


Text

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EIFEPATRIG,LDrXEART,JOMWsDS & ETTERISON m== - ->. n Fa ns August 2, 1983 FITitSL BGE, FENESTLTANIA 3S988 WOITE S S Df M RCI DI AL NPNBBB (449) 368*S500 (202) 452-7097 i

Y David A.

Repka, Esq.

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S.

Nuclear Regulatory Commission g

7735 Old Georgetown Road

/ g gf.o Room 10205 g/l y c 00'/) /ke /5 Bethesda, Maryland 20814

Dear Dave:

Please find enclosed a list of additional informal discovery requests.

We would appreciate the responses of the Staff as soon as possible, and we also would ap-preciate the written responses to discovery requests sent to you under cover dated July 27, 1983.

If you have any questions concerning discovery-related matters, please do not hesitate to call.

Sincerely, Joh'n E.

Birkenheier Encl.

cc:

Jessine A..Monaghan, Esq.

Stephen B.

Latham, Esq.

James B.

Dougherty, Esq.

Ralph Shapiro, Esq.

8308150051 030905 PDR ADOCK 05000322 0

PM sm,

....,x

s Additional Discovery Requests to NRC Staff 9.

Provide copics of all documents relating to the preparation, analysis or review of evacuation time estimates or traffic conditions, with respect to an emergency at Shoreham or on Long Island.

s 10.

Identify the members of the NRC Staf f who worked with, or had contact with, Thomas Urbanic, II, in connection with Mr. Urbanic's analyses or views concerning evacuation of Long Island in the event of an emergency at Shoreham, 11.

Identify any other persons who worked with Mr. Urbanic, assisted or supervised him in his work on evacuation time estimates for the Staff, or reviewed or commented on that work.

Provide copies of any such reviews or comments.

P 12.

Identify any other work, performed by Mr. Urbanic on behalf of the NRC Staff, in connection with emergency planning.

13.

Provide a copy of the Staff's contract with-Mr. Urbanic relating to his work with respect to Shoreham.

14.

Identify all ASLB proceedings in which Mr. Urbanic has testified on behalf of the NRC or any other party and the date of such testimony.

15.

Provide a copy of Mr. Urbanic's resume.

16.

Provide a list of papers, articles, books or other such' documents written and/or published by Mr. Urbanic pertain-ing to emergency planning or evacuation time estimates.

4

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