ML20062L506

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Advises That Suffolk County Objects to Procedure Whereby County Must Conduct cross-examination W/O Benefit of Technical Assistance
ML20062L506
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 08/16/1982
From: Letsche K
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To: Brenner L, Carpenter J, Morris P
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8208190132
Download: ML20062L506 (2)


Text

KIRKPATRICK, LOCKIIART, HILL, Cmusro@'%E8e PrIrLLIrs A PARTNERSHIF INCLUDINo A PaormesioMAL CoBFORATmW 1900 31 Srnnzr, N. MB2 ASO 18 R0 :29 DSHINGTON, D. C. 20036 0FFICE OF SELAtI" niernoxa (ac ) .1000 00CKETlhG & SERC~~ = rrrr==vman CArLE: MIPM: B R ANCH rimanraxx,iocmam,,onn on . acxxison r;", LEX 440909EllPR UI 100 OLIVER BcILDING wurzo . m ecx mix. c . August 16, 1982 ,,m ,c,, ,,,,, m ,,, ,,,,,,

(202) 452-7064 <> ...oo Lawrence Brenner, Esq.

Dr. James L. Carpenter Dr. Peter A. Morris Administrative Judges Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Long Island Lighting Company; Shoreham Nuclear Power Station, Unit l'; Docket'No. 50-3~22 0.L.

Gentlemen:

This is in response to the Board's request for the parties' views on the possibility of having the witnesses for all parties on the stand simultaneously for testimony on SC Contention 27.

As Judge Carpenter noted on August 5, 1982, (Tr. 9143-44) such a procedure would deprive the County's counsel of the opportunity to consult with its technical-experts during cross-examination of the LILCO and Staff witnesses. The County does object to a proce-dure whereby it is forced to conduct its own cross-examination without the benefit of technical assistance. Such a procedure would infrinci upon the County's ability to pursue its right to cross-examine the technical experts proffered as witnesses by the other parties, and accordingly, the County opposes the suggestion that cross-examination of all witnesses take place with all witnesses on the stand.

The County would not object, however, to the procedure suggested by Judge Carpenter for SC Cont 4ntion 27 at page 9144 of the August 5 transcript -- that is for " nome eyeball-to-eyeball interplay" with respect to "the Board,'s turn" at question-ing the witnesses. Af ter all three witness p'anels have been presented and questioned by the opposing parties, the County would have no objection to the Board's questioning all the parties' 8208190132 820816 PDR ADOCK 05000322 G PDR lMO

KruxrArnicx, LocxHART, IIILL, CHRISTOPHER & Pn LLres witnesses simultaneously. Such a procedure would, in the County's opinion, protect the cross-examination rights of all parties while at the same time provide the Board its desired access to all witnesses simultaneously.

Sincerely, J

Karla J. Letsc e cc: Service List