ML20092P796
| ML20092P796 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/28/1984 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Kline J, Laurenson J, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8407090383 | |
| Download: ML20092P796 (3) | |
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James A.
Laurenson, Mr. Frederick J.
Shon Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 430 East-West Tower, Rm. 402A 4350 East-West Highway 4350 East-West Hwy.
Bethesda, MD 20814 Bethesda, MD 20814 Dr. Jerry R.
Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
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5C g..C L-East-West Tower, Rm. 427 4350 East-West Hwy.
Bethesda, MD 20814 Ground Rules for FEMA Witnesses
Dear Administrative Law Judges:
l The parties have discussed how the cross-examination of t
the FEMA witnesses should proceed, and we have agreed on the following matters:
1.
During the week of July 10-13, the FEMA witnesses l
will be subject to cross-examination on their written testimony for the following contentions only:
20, 21, 22, 24, 26, 27, 28, 29. 30, 31, 32, 34, 55, 56, 57, 58, 59, 60, 63, 64, 66, 67, 68, 69, 70, 71, 72, 73, 93, 94, 95, 96, and 97.
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H L7NTON & WILLI AMS i
i 2.
The order of cross-examination will be as follows:
Suffolk County will cross-examine the FEMA witnesses first, i
followed by the State of New York, followed by LILCO.
(This is consistent with the order of cross-examination that was fol-i lowed when NRC witness Sears and FEMA witness McIntire appeared earlier in this proceeding.)
I i
3.
The parties are unable to give time estimates for cross-examining the FEMA panel as yet but will provide them along with the cross-examination planh that are due July 3.
If l
we finish with the FEMA witnesses before the end of the week of July 10-13, the LILCO panel on Contention 92 will be cross-5 examined.
If there is still time lef t that week even af ter the Contention 92 panel is finished, the parties have not agreed how to proceed.
4.
Counsel for FEMA has advised the other parties that FEMA will file its testimony on the training issues (Conten-l tions 39, 40, 41, 44, 98, 99, and 100) on August 8, and that
{
the FEMA witnesses will be available for cross-examination on August 13-15.
Neither Suf folk County nor New York State be-l lieves that this proposed schedule permits sufficient time j
af ter the receipt of the FEMA testimony to prepare adequately j
for cross-examination of the FEMA witnesses on the dates pro-
- posed, i.e.,
August 13-15.
Further, it may be necessary to f
conduct discovery of the FEMA witnesses and Suffolk County and l
New York State reserve their rights in this regard, pending re-ceipt of the FEMA testimony on August 8.
In addition, although j
counsel for FEMA has advised the other parties that the FEMA witnesses will be available for cross-examination on all re-l maining pre-filed testimony (Contentions 61, 74, 75, 77, 81, l
l 3
- _ _ _ _ - - -.. - -. ~ _ _ -.., -.
HuxTox & WILLI AMS 85, 88, 92, 33 and 49) on August 13-15, counsel for Suffolk County and New York State do not believe that it can be deter-mined at this time whether the dates proposed by FEMA's counsel provide sufficient time to conduct cross-examination on all such testimony, in addition to the FEMA testimony not yet filed on training issues.
5.
When and if FEMA will file testimony on Contentions 16 (public information brochure) and 18 (zone and route infor-mation) are as yet undetermined.
The Board's resolution of LILCO's motion for summary disposition of Contention 16 may af-feet the schedile.
6.
FEMA will file no testimony on Contentions 11 and 15.
Counsel for the other parties named below have reviewed this lettet and find it an accurate summary of our discussions and agreements to date.
l Yours very truly, h.0/ad ~
James N. Christman 126/586 cc:
Stewart M. Glass, Esq.
Bernard M.
Bordenick, Esq.
Richard J.
Zahnlauter, Esq.
Michael S. Miller, Esq.
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