ML20205M080
| ML20205M080 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/30/1987 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Kline J, Margulies M, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20205M082 | List: |
| References | |
| CON-#287-2980 OL-3, NUDOCS 8704020265 | |
| Download: ML20205M080 (3) | |
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.=..v,,.....,.3,,.o, pasaraa. vemoss.ia aso 3o ta6an=onstosseaaaoo Pitt =o oimeet o a6 no so vee-BY HAND Morton B.
Margulies, Chairman Dr. Jerry R.
Kline Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission East-West Towers l
4350 East-West Highway Bethesda, MD 20814 LILCO Reception Centers Docket 50-322-OL-3 (Emergency Planning)
Gentlemen:
Enclosed you will find LILCO's written tastimony on the suitability of the reception conters.
With this letter I wish also to alert you to several issues that in all probability you will have to deal with soon.
Since I am not now asking for any i
Board order or other action, I am putting these matters in a let-ter instead of a pleading.
l Scheduling The hearing on reception centers is scheduled to begin May 4.
I suppose it has occurred to everyono that the -05 exer-cise proceeding may still be going on at that date.
Assuming it is, LILCO is nevertheless prepared to go forward with the recep-tion center hearing simultaneously.
The only difficulty from LILCO's viewpoint is that some of the witnessos (Messes. Daverio, Lindell, Watts, Lieberman, and Mileti) must testify in both pro-coedings, and so careful scheduling will be necessary to avoid having them scheduled to be two places at the same time.
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H uw rON & WII.I.IAM S Morton 8. Margulies, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon March 30, 1987 Page 2 Identity of issues in -03 and -05 The Board has directed the parties to inform it when we per-ceive that there will be a duplication of issues in the -03 and
-05 proceedings.
It now appears, based on the depositions of the past faw weeks, that the potential for duplication is great.
I suggest, however, that we cannot know the precise extent of the duplication until we have in hand the Intervenors' written testi-many.
Issues Outsido the Scope of the Admitted Issues The issues in this proceeding are now defined by the Board's Memorandum and Order of December 11, 1986, which in turn depends in part on the Appeal Board's decision in ALAB-832, 23 NRC at 162 n.105.
Based on the depositions of the past few weeks, it ap-pears that the Intervonors will be raising issues that are out-side the scope of the admitted issues we will not know for sure untti wo see their written testimony.
In trying to anticipato what issues the Intervenors may raiso, LILCO in its written tes-timony has addressed matters that wo believe are not properly at issues an example is the " panic" issue addressed in section VI of the LILCO testimony.
If the Intervenors do not raise these is-sues (contrary to our oxpectations) or if LILCO prevails on its motions to strike, then LILCO may well be in a position to with-draw psets of its own testimony.
Thus, the fact that LILCO has addressed a particular issue in its written testimony does not mean that LILCO concedes the admissibility of the issue.
Simi-larly, although LILCO has included as attachments the entire text of two procedures, LILCO does not concede that every subject ad-dressed in the procedures is litigable in this proceeding.
Need for a Rebuttal Phase Since as of this writing LILCO has not yet received New York State's traffic analyses, and since we received only this week cortain traffic signal data from the State and certain documents that wo had toquested from Suffolk County, LILCO foresees the nood for robuttal testimony.
Once again, we will not know for suro untti after we soo the Intervenors' testimony.
1 Huwrox & WILLIAMS l
Morton B. Margulies, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon 1
March 30, 1987 Page 3 The Missing Attachment J LILCO has prepared six maps of the reception centers, with colored lines indicating the flows of people and vehicles.
Thess l
are called Attachment J to the testimony.
We learned on Saturday that, because of an error by the express service, we will not re-ceive the colored maps until today, probably too late to have them in the hands of the other parties today.
I am sorry about this, but the express service has told us that nothing could be done to correct the problem during the week-end.
LILCO has the originals in Hauppauge, but since they are in color they cannot be satisfactorily duplicated on an ordinary copying machine, as you will see from the copies I have enclosed as a substitute for the real thing.
Assuming the documents arrive today, we can have them delivered to you and the Intervonors tomorrow.
Yours very truly, James N. Christman cc Service List i