ML20214N497
| ML20214N497 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/22/1987 |
| From: | Bachmann R NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20214N501 | List: |
| References | |
| CON-#287-3611 OL-3, NUDOCS 8706020193 | |
| Download: ML20214N497 (2) | |
Text
05/22/87 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 my 28 P2 :10
' BEFORE THE ATOMIC SAFETY AND LICENSING BODE.55kghd,
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Eh MM In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
NRC STAFF MOTION FOR LEAVE TO FILE REBUTTAL TESTIMON_Y The Staff hereby moves the Licensing Board for leave to file the attached
" Rebuttal Testimony of Dr. Thomas Urbanik II on Behalf of the NRC Staff on Capacity Analysis in the Vicinity of Reception Centers".
As indicated in Dr. Urbanik's testimony, he addresses new issues raised by Messrs.
Hartgen and Millspaugh in their written testimony filed April 13, 1987 1 The Hartgen/Millspaugh testimony discusses a " computerized version of the assignment package" (p.33, n.12), known as the Comprehensive Assignment and Routing System (CARS).
Since the use of the CARS computer model was not disclosed prior to the submission of New York State's testimony, 2_/
Dr. Urbanik was unable to include his views regarding that model in his original testimony.
Dr. Urbanik's rebuttal testimony will provide the Board additional information to compile a more
-1/
Direct Testimony of David T. Hartgen and Robert C. Millspaugh on Behalf of the State of New York Regarding LILCO's Reception Centers (April 13, 1987)..
-2/
See Deposition of Robert C. Millspaugh, Charles E. Kilduff, David EHartgen, Ph.D., and William J. Acquario (March 3,1987).
8706020193 870522 PDR ADOCK 05000322 hSo1 eon
L a e complete record and arrive at a reasoned decision.
The Board should apply the same rationale advocated by Suffolk County when it moved to 3,/
file rebuttal testimony to Ftaff witness Lewis G.
Hulman
, i.e., that technical analyses not disclosed prior to the filing of testimony should be grounds for allowing rebuttal testimony. M Therefore, for good cause shown 'the Board should admit the attached rebuttal testimony of Dr.
Thomas Urbanik II.
Respectfully submitted, i
Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this day of May,1987 l
l l
3/
Suffolk County Motion for Leave to File Rebuttal Testimony (April 17, 1987).
-4/
The Staff did not oppose Suffolk County's motion. See NRC Staff Response to Suffolk County's Motion for Leave tolle Rebuttal Testimony (April 23, 1987).