ML20207R809

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Informs That Suffolk County Intends to Offer Two Witnesses, Sholley & Gc Minor to Address Anticipated NRC Testimony Re Pras,Consequence Analyses & Similar Technical Analyses
ML20207R809
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 03/10/1987
From: Mcmurray C
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To: Bachmann R, Christman J, Cumming W
Federal Emergency Management Agency, HUNTON & WILLIAMS, NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20207R794 List:
References
OL-3, NUDOCS 8703180159
Download: ML20207R809 (2)


Text

6 Ig-KIRKPATRICK & LOCKHART SOUTH Lo88Y FDi floor m ytaca 1900 M STREET. N.W.

53 sTAtt smsr WASHINGTON, D.C. 20045891 22 1428 BRIQ2LL AVENUE MIAnd, FL 33131 TtuPHONE 00D 774400 (305) 374 4 112 Trux 440 zoo 10. DC UI TEMCOPER CCD 77&#100 FITT58URCH, PA15222-5379 CHRISTOPHER M. McMURRAY "8D 3*580 aca 778L9054 March 10, 1987 James N. Christman, Esquire Hunton and Williams 707 East Main Street Post Of fice Box 1535 Richmond, Virginia 20212 William R.

Cumming, Esquire Office of General Counsel Federal Emergency Management Agency 500 "C" Street, S. W.

Room Number 840 Washington, D.

C.

20472 Richard G.

Bachmann, Esquire United States Nuclear Regulatory Commission 7735 Old Georgetown Road Bethesda, Maryland 20814 Gentlemen:

Upon finally receiving the NRC Staff's written l

designations of its witnesses only last Friday, March 6, the l

Governments were informed for the first time that the Staff's witnesses intend to rely on probabilistic risk assessments, consequence analyses, and similar technical analyses for the purpose of addressing.the issue of how many people will arrive at LILCO's reception cer.ters.

Indeed, this was not made explicit in the Staff's March 6 response, but was indicated by the technical documents which the Staff stated its witnesses intended to rely upon.

Today's deposition has confirmed the Staff witnesses' l

reliance on PRA's, consequence analyses, and the like.

l This is to inform you that the County intends to offer l

two witnesses, Steven Sholley and Gregory C. Minor, to address I

the Staff's anticipated testimony.

Mr. Sholley will be available l

for deposition in Washington, D.

C.,

next Tuesday or Wednesday, March 17 or 18.

Mr. Minor has already been deposed but, if the parties deem it necessary, he will be made available for a l

0703180159 870312 PDR ADOCK 05000322 l

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KIRKPATRICK & LOCKHART James N. Christman, Esquire William R. Cumming, Esquire Richard G. Bachmann, Esquire March 10, 1987 Page 2 deposition on the issues raised by the Staff as his schedule allows.

Please contact me if you wish to make arrangements for depositions of either Mr. Sholley or Mr. Minor.

Sincerely, Christopher M. McMurray CMM/ mas cc:

Richard J.

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