ML20207C606

Intervenor Exhibit I-State-41,consisting of 870904 Memo Discussing Witnesses for 870928 Hearing in Concord,Nh

ML20207C606
Person / Time
Site:	Seabrook
Issue date:	05/27/1988
From:	Flynn H Federal Emergency Management Agency
To:	Federal Emergency Management Agency
References
OL-I-STATE-041, OL-I-STATE-41, NUDOCS 8808100020
Download: ML20207C606 (2)

Text

l

@ ~*

f4 NUCLEAR REGULATORY COMMiss;cu 7_ g 4/

j/, f m tno.5 N /3d & d o m m ,n3, t nau a &drms ~

3 IDENiiFIED

/ DOCKE T EE-unec (d

. . _ _ _ U"EiVD _ V

- - - - - - U------- September 4, 1987 '88 AL 19 P6 :05

.~:- - - - . 5 $(r"

(- ~

f DOCYY?rY 3RN Edward A. Thomas, Chief Natural and Technological Hazards Division Federal Emergency Management Agency, Region I J. W. McCormack post Office and Courthouse Building Boston, Massachusetts 02109 Re: Witnesses for Seabrook Hearing

Dear Ed:

This will confirm our recent conversations about the identification and preperation of witnesses for the licensing hearing on Seabrook Station to be helci in Concord, New Hampshire, beginning September 28, 1987, It has been decided, with the concurrence of Spence Perry and Dave

(,)

r-McLoughlin, that the witnesses for the Federal Emergency Management Ageacy (FEMA) will be you, 3ruce Swiren, and Ed Tanzman of Argonne National Laboratories. You are expected to testify on the beach population issue; you and Ed Tanzman to testify on Letter-of-Agreement issues; and the three of' you to testify on the remaining issues. Prefiled testimony must be filed and mailed to the service list by Thursday, September 10, and I will provide your office all possible help in the preparation of that testimony. Yesterday I sent by telefax a suggested outline the principal elements of which were introduction of the witnesses, identification of the focus and purpose of their testimony and the incorporation by reference of the Statement of Position of June 4, 1987, and my letter to Thomas Dignan of August 7, 1987.

I plan to meet with the three of you here in Washington throughout the week of September 21 to prepare for cross-examination by the applicant, intervenors and interested governments, and the Nuclear Regulatory Comis sion. I will need you to be present at the beginning of the hearing for as much as the first two weeks to provide me with guidance on the program implications of the matters brought up during the hearing. I expect that the direction of the hearing will be clear by the end of the second week, if not sooner. If I am satisfied at an earlier time that I do not require your continual presence, we will make arrangements for you to be on call.

For the sake of prudence, I have also roserved the week of October 13 through 19 for additional witness preparation, in Washington. I will make a O

gymn 8%

G I

9 4

s l l

l s

decision on whether that will be necessary after I have had a chance to observe the other parties at the hearing and get a sense of their lines of attack. My intention is to use the additional time for preparation only to the extent that it is necessary to address lines of inquiry which we did not anticipate or develop an adequate response to before the hearing began.

I thank you in advance for the professional care that I know you will take in preparing and presenting FEMA's testimony. The rigorous attention to detail which is the hallmark of your work makes me confident that you will do an excellent job.

Sincerely, H. Joseph Flynn,.

Assistant General Counsel cc: William Tidball Henry Vickers Dave McLoughlin

(~)

\/

Richard Krimm Craig Wingo Ed Tanzman Bruce Swiren

!cc: CF 2, GC/ Perry, FLYNN, Watsen

! GC: FLYNN:hjf: 9/4/87

! Document # 0166R O