ML20206T185

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Forwards Transcripts of Direct Testimonies Re Lilco Reception Ctrs & Motion Requesting Board to Reschedule Commencement of Hearing of Reception Ctr Issues Until Ongoing Litigation Completed.Related Correspondence
ML20206T185
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 04/13/1987
From: Mcmurray C
KIRKPATRICK & LOCKHART
To: Kline J, Margulies M, Shon F
Atomic Safety and Licensing Board Panel
Shared Package
ML20206T188 List:
References
CON-#287-3205 OL-3, NUDOCS 8704230131
Download: ML20206T185 (2)


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  • C02) 7759054 April 13, 1987 VIA HAND DELIVERY 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 4350 East-West Highway Bethesda, Maryland 20814 Gentlemen:

Enclosed herewith are copies of Suffolk County's Direct Testimony regarding LILCO's reception centers. These include:

1. Direct Testimony *of Stephen Cole, g al., on Behalf of Suffolk County Regarding LILCO's Reception Centers (Planning Basis);
2. Direct Testimony of Edward P. Radford, et al., on Behalf of Suffolk County Regarding LILCO's Reception Centers (Monitoring and Decontamination Procedures);
3. Direct Testimony of James H. Johnson, Jr. and Susan C. Saegert on Behalf of Suffolk County Regarding LILCO's Reception Centers (Evacuation Shadow Phenomenon and Traffic Issues);

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KIRKPATRICK & LOCKHART Morton B. Margulies, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon April 13,1987 Page 2 Scheduling Also enclosed is a motion requesting this Board to reschedule the commencement of the hearing of the reception cen-ter issues until the ongoing Shoreham Exercise (OL-5) litigation is completed. As Judge Shon is aware, the facts giving rise to this motion were discussed last Tuesday before the OL-5 Board.

In essence, it is now plain to the OL-5 Board and to all the parties that the OL-5 proceeding will not be completed by May 4.

Holding the OL-5 and OL-3 proceedings concurrently raises the prospect of overwhelming scheduling problems and fragmented proceedings, not to mention the problem of Judge Shon's inability to participate in proceedings at once.

We ask that the Board consider this motion on an expedited basis for obvious reasons.

Motion To Compel Also enclosed is a Motion To Compel LILCO to reveal the source of certain data.which it is attempting to submit in its direct case through hearsay testimony. Specifically, LILCO has made certain statements about the capacities of reception centers at other facilities, which are based on " contacts" with unspeci-fled " utility and county" sources. LILCO has objected to reveal-ing the sources of their information on grounds that " disclosure might subject individuals to harassment and intimidation." That groundless assertion may serve to prejudice the Governments in cross-examining LILCO's witnesses on the validity of LILCO's hearsay evidence (assuming that the hearsay is not stricken).

Accordingly, we ask that the Board direct its attention to the enclosed Motion To Compel.

Yours truly, Christopher M. McMurray CMM/ mas Enclosures cc: Service List 1