ML20062F928
| ML20062F928 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/21/1978 |
| From: | Like I REILLY & LIKE |
| To: | Whittemore C HUNTON & WILLIAMS |
| References | |
| NUDOCS 7812210471 | |
| Download: ML20062F928 (2) | |
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REn.Ix, LIKE AND SCHNEIDER 1
t COUNSEI.I. ORS AT Z.AW 200 WEST MAIN STREET BADYZ.ON, N. Y.11702 tRvino LIxE MoMAww 9 3000 CABI.E ADDRESS SERNARD J. REILLY RELIE WTLSUR N. SCENEIDER GEORGE MOFFMAN EDw ARD A. BROOE S,JR.
WEMNER J. IDMSRITWW Eva 4.COM O
Q PATRICIA A.DEMPSEY November 21, 1978 PIIDL[c t \\&
Case Whittemore, Esq.
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Hunton & Williams, Esqs.
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P.O. Box 1535 Richmond, Virginia 23212
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In the Matter of Long Island Light C7mpany (Shoreham Nuclear Power Stat e
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Docket No. 50-322
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Dear Mr. Whittamore:
In a recent telephone conversation you advised that the "Suffolk County Supplemental Response to Applicants Second Interrogatories" (October 26, 1978) failed to address Applicants' Interrogatory Q. 1, which asked:
Please explain the basis for your conclusion that 10 CFR Part 50, Appendix (B), Criterion III mandates the development of " experimental L-data to verify the suitability of material selection design" at Shoreham.
"Second Set of Applicant's Interrogatories to Suffolk County", p. 14 (12/8/77).
The hearing board, in its April 4, 1978'" Order Relative to Applicant's Request for Clarification and Limited Recon-sideration" required the County to explain its interpretation of 10 CFR 50, App. B, Criterion III, and why it believes this section mandates tests.
The basis for the County's position on this issue is substantially the same as that set forth in
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I November 21, 1978 Page 2 the County's response to Interrogatory J.1 regarding the necessity of a testing program to verify the Shoreham design.
See "Suffolk County Supplemental Responses To Applicant's Second Interrogatories", p. 3 That is, the County contends that due to the complexity of analysis and environmental conditions testing and development of experimental data is the only suitable means to verify the suitability of material selection design at Shoreham.
With regard to Applicant's Interrogatory F.1, the hearing board required the County to disclose the calcula-tions and assumptions which yield higher source terms for those accidents (identified in County Contention 6) than have been previously considered.
" Order Relative To Applicant's Motion To Compel Suffolk County Concerning
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Applicant's Second Set of Interrogatories",
pp. 2-3 (3/2/78).
Responses to this question will be provided in the report being prepared for the County by its present consultants, MHB Technical Associates.
Very truly yours, 1
d%Ij MA88 Irving Like Special Counsel to the County of Suffolk IL/jg 1[)
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To members of the hearing Board and all parties
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