ML20042C534
| ML20042C534 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/25/1982 |
| From: | Latham S TWOMEY, LATHAM & SHEA |
| To: | Brenner L Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20042C535 | List: |
| References | |
| NUDOCS 8203310495 | |
| Download: ML20042C534 (1) | |
Text
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g,.c.::1L'.m:W ;-R A TWOMEY LATHAM & SHEA ATToRNrYS AT LAW THOM AS A. TwoMey, JR.
33 ' Vast sECOND STREET OTEPHEN B. LATHAM P. O.
Box 398 JOHN F. SHEA. H8 RivtpHEAD, NEW Yonn 11901
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joKAy Meg RoosRT D. Ping EAST H AMPTON. N.'Y.'~11937 CHIISTOPHER O MELLiv (516) 727-2180 (516) 324-1200 March 25, 1982 k
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/h Lawrence Brenner, Chairman y
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Atomic Safety
(, Licensing Board Z/
U.S. Nuclear Regulatory Commission b
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- * J, Washington, D.C.
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Re:
Case No. 50-322 c"
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Dear Judge Brenner:
Enclosed please find a Joint Notice of Taking Deposition of certain individuals to be designated by LILCO, which I am submitting today on behalf of SOC and Suffolk County.
Attached to the Notice of Taking Deposition is a list of the subject areas which are of interest to SOC and Suffolk County, each of which relates to Joint Contention 7B.
In my discussions with Mr. Reveley, we have been unable to reach agri ament on item 2 of Attachment A (the LILCO PRA).
It is the position of SOC and Suf folk County that this study, which we believe is in draft form at the present time, is specifically relevant to Contention 7B as redraf ted by the Board.
We have asked LILCO to produce the draf t PRK on the date on which the depositions will be taken, which would avoid the need to depose an individual from SAI (which is performing the study for LILCO).
s In view of the pa.r t ies ' inability to resolve the l
l importance and/or rel'evance of the PRA for next.
Wednesday's deposition, and in. view of the extreme shortness of time in 'which to complete discovery, SOC l
and Suf folk County rbspectfully request that you convene a conference call on. Friday, March 26, 1982, to resolve i
the matter.
i'~
Yours tru,1y,
(,,,
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8203310495 820325 DR ADOCK 05000 Step en B. Latham SBL/ lam Enclosure O
cc:
50-322 Service List hl l