ML20027C312

Forwards Written Testimony on Phase I Emergency Planning Contentions EP 1(B),2(A),2(B),4,5(A),5(B),7(B),10(B),10(C), 11(A),11(B),11(C),13 & 14.Stipulations Will Be Sent as Soon as Received.W/O Testimony

ML20027C312
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/12/1982
From:	Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Brenner L, Carpenter J, Morris P Atomic Safety and Licensing Board Panel
Shared Package
ML20027C313	List: ML20027C312 ML20027C326
References
ISSUANCES-OL, NUDOCS 8210150279
Download: ML20027C312 (4)

Text

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Docket No. 50-322 (OL)

LILCO's Phase I Emergency Planning Testimony

Dear Administrative Law Judges:

Enclosed is LILCO's written testimony on the Phase I l

l emergency planning contentions EP 1(B), 2(A), 2(B), 4, 5(A),

5(B), 7(B), 10(B), 10(C), ll(A), ll(B), ll(C), 13, and 14.

Happily, agreements to settle contentions EP 1(A), 3, 5(C),

7(A), 8, 9, 10(A), ll(D), ll(E), ll(F), and 12 have been reached by the parties. The agreements have been going the rounds of the parties for signature and will be submitted to the Board as soon as we receive them back from the NRC l

Staff -- today possibly, and almost certainly by tomorrow.

I O

h0kD R

i HUNTox & WILLIAxs Lawrence Brenner, Esq.

Dr. James H. Carpenter Dr. Peter A. Morris Page 2 October 12, 1982 Agreement has also been reached on EP 1(C); a final settlement agreement is now being circulated among the parties for signa-ture, and we hope to file it tomorrow as well. We regret to say that the settlement agreement on EP 6, which we hoped as recently as Frt3ay afternoon would be concluded in time to accompany the testimony today, is still being negotiated. The only remaining unsettled item is a footnote reserving certain rights, and so we believe that settlement of EP 6 is imminent.

We ask that we be permitted to have until October 13 to file a settlement agreement on EP 6; failing settlement, we ask to be allowed to file testimony on EP 6 by October 15. (This sugges-ted schedule is LILCO's proposal alone; we do not mean to sug-gest that the other parties have agreed to it.)

We believe that some of the contentions on which we are filing testimony today are also susceptible to settlement, and we will be exploring settlement with suffolk County end the North Shore Coalition.

The Board should be aware that LILCO, in response to one of the findings from the NRC's onsite appraisal, is review-ing and revising its emergency plan implementing procedures.

Many of the present procedures are referenced in and attached to the LILCO testimony. If any of these procedures change as a result of the onacing review, we shall substitute the revised versions for the present attachments.

We are not today serving copies of LILCO's emergency plan with the testimony, since everyone already has received a

o Huwrow & WILLIAMS Lawrence Brenner, Esq.

Dr. James H. Carpenter Dr. Peter A. Morris Page 3 October 12. 1982 copy, including the page revisions that were served September 1, 1982. We do expect to offer the plan into evidence at the hearing, however.

In light of the Phase I contentions on traffic conges-tion, EP 2(B) and EP 5(B), we should like to call the Board's attention to the fact that KLD Associates has done a detailed evacuation plan and evacuation time estimate, which was served on the Board and parties September 1. We believe the KLD eva-cuation study is a matter for Phase II, and so LILCO does not propose to offer it as an exhibit in Phase I.

Regarding contention EP 14, the Board indicated at the prehearing conference (Tr. 7398) that it might want a better explanation of what LILCO plans to do with the probabilistic risk analysis in the context of emergency planning. I have inquired of people at LILCO and at Pickard, Lowe and Garrick, which is doing the consequence part of the PRA, to learn their views of the role of the PRA in emergency planning.

The purpose of the PRA, in the context of emergency planning, is simply to increase understanding of potential accidents; this deeper understanding, it is felt, might suggest ways in which the emergency plan can be fine-tuned. The PRA might provide such information as the characteristics of a po-tential release or its timing, and that information, along with KLD's modeling of the traffic network, might enable LILCO to see, for example, whether certain routes for evacuating vehi-cles would be better than others. At present I understand the

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l Huwrow & WILLIAus 1

Lawrence Brenner, Esq. i Dr. James H. Carpenter Dr. Peter A. Morris Page 4 October 12, 1982 PRA work has been delayed pending a reassessment of the source terms, because the ones that have been used are apparently quite conservative.

The use of the PRA for emergency planning is not an NRC requirement, and LILCO did not in fact use the PRA to develop its emergency plan. LILCO's idea has alwcys been to use the

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PRA to fine-tune an already adequate emergency plan developed by more conventional methods in accordance with NRC guidance such as NUREG-0396 and NUREG-0654.

Yours very truly, James N. Christman 126/765 Enclosures cc: Service List

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