ML20080S362
| ML20080S362 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/14/1983 |
| From: | Axelrad M LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Buck J, Johnson W, Moore T NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20080S365 | List: |
| References | |
| NUDOCS 8310180354 | |
| Download: ML20080S362 (2) | |
Text
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LAW OFFICE 5 lhWENSTEIN, NEWMAN, REIs 6c AXELE sD, P. COOLKETED USNRC
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Octvber 14, 1983 Judge Thomas S. Moore, Chairman Judge John H. Buck Judge W.
Reed Johnson Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555
(
Re:
Docket No. 50-275 Docket No. 50-323
Dear Judges Moore,
Buck and Johnson:
In accordance with the Appeal Board's Order of October 7,
1983, enclosed is the prefiled direct testi:aony of wit-nesses from the Independent Design Verification 'rogrcn (IDVP), the qualifications of such witnesses and the exhibit list of the 1DVP.
The prefiled direct testimony consists of:
(1)
Testimony on Behalf of the Independent Design Verification Program of Dr. Wil2_am E. Cooper, Dr.
Robert L. Cloud, Mr. John E. Krechting and Mr.
Roger F. Reedy hegarding Contentions 1, 2 and 5-8; (2)
Testimony on Behalf of the Independent Design Verification Program of Dr. Robert L. Cloud, Professor J. M.
Biggs, Professor M.
J.
Holley, Jr.
and Mr. Ronald Wray Regarding Contentions 3, 4.m.
and 4.n.; and (3)
Testimony on Behalf of the Independent Design Verification Program of Mr. Jchn E. Krechting and Dr. William E. Cooper Regarding Contentions 4.a.-l.
and o.-u.
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DR v
LOWENUTEIN, NzsnN, Rrw & Axzt.::s.D, P. C.
Judges Moore, Buck and Johnaon Page Two October 14, 1983 The IDVP will present three panels, each of which will consist of the witnesses named in the titles of the fore-going testimony.
As requested by ^ he Board, we have identi-fled clearly the witness or witnesses aponsoring each part of the testimony.
However, in light of the collegial manner in which the work of the IDVP was conducted, it can be expected that, depending upon the questions that may be raised on cross-examination, members of panels will be able to contribute responses even with respect to portions of the testimony which they did not sponsor:
As required by the Board's Order, enclosed are affi-davits as to qualifications of each of the foregoing wit-nesses, except Mr. Reedy.
Mr. Reedy's unswort qualifica-tions are enclosed, and his affidavit will be supplied during the week of October 23, when he returns to his office.
The attached exhibit list identifies a Uponsoring wit-neas for each exhibit.
Again in light of the collegial nature of the IDVP's efforts, other members of the panels will also be able to respond to questions concerning such exhibits or their participation therein.
Very truly yours, fu q
Maurice Axelrad David B. Raskin Attorneys for the Independent Design Verification Program MA/aps Enclosures cc:
Service List
_.