ML20072J566

Answer Supporting Citizens for Orderly Energy Policy,Inc 830614 Petition to Intervene in Proceeding on Emergency Planning Issues.Criteria for Untimely Intervention Met. Certificate of Svc Encl

ML20072J566
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/27/1983
From:	Reveley W HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, ISSUANCES-OL-3, NUDOCS 8306300147
Download: ML20072J566 (5)

Text

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LlLCO, June _277 53

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UNITED STATES OF AMERICA '

FIN, -g NUCLEAR REGULATORY COMMISSION fo -

iC C h3i 3b gg $ 'l!j Before the Atomic Safety and Licensing Boardj

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In the Matter of ) g gf

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

~ rem i . C. .. . . . . . ,_,'8d-32c9 -0 b 3 APPLICANT'S ANSWEP TO THE JUNE 14 ' ' ' ' ' ' ' ' ' ' * * *

• INTERVENTION DP'IT'sd OF CITIZENS FOR ORDERLY to_.. POLICY, INC.

On June 14, 1983, the Citizens for an Orderly Energy Poli-cy, Inc. (Citizens) filed a petition to intervene in the Shoreham operating-license proceeding on emergency-planning is-sues. LILCO supports Citizens' petition. Although the peti-tion is out of time,1/ a combination of four factors t

l nonetheless justifies Citizens' intervention.

l First, the members of Citizens live in the community sur-rounding the Shoreham Nuclear Power Station. Most of the mem-bers live within 20 miles of the plant (Petition at 4); several live within five miles of the plant (see the affidavics at-l tached to Citizens' petition.)

l l

Second, the members of Citizens have expertise in i

radiological emergency planning. They are engineers,

! 1/ We note, however, that in many respects (including the re-cent creation of this Board and the recent deadline for filing contentions), the offsite-emergency-planning phase of the Shoreham case is essentially a new proceeding.

r3063OO147 830627 l PDR ADOCK 05000322 l 0 PDR }g]

o physicians, and scientists who are " recognized authorities in the field of nuclear power." Petition at 8. Some members spe-cialize in_ radiological emergency planning, participate in emergency planning drills in the northeastern United States, and are members of federal radiological emergency response teams. Id . - As a result, the members of Citizens are highly qualified to address emergency-planning issues as those issues bear specifically upon Shoreham.

Third, Citizens' purpose is to establish, coordinate, and implement programs to promote the development of an energy pol-icy for Long Island that includes nuclear power as a source of energy. Petition at 4, 6. The members of Citizens want to

! protect their interests in having an adequate emergency plan c for their families, a reliable emergency plan for their commu-nity, and revenues from Shoreham. Id. at 9-10. The organiza-tion supports the issuance of an operating license for i Shoreham. Id. at 4. Thus, the perspective that Citizens brings to this proceeding is unlike that of the other interve-nors.

Fourth, Citizens is not affiliated with the Long Island

. Lighting Company or any of the other parties to the proceeding.

LILCO is seriously concerned about any actions that might delay the resolution of offsite-emergency planning issues. But Citizens notes in its petition that it does not intend to delay (Petition at 10), and has illustrated its intent by timely fil-ing draft emergency-planning contentions.

. Because Citizens brings singular expertise and a unique perspective to this proceeding and has indicated it will take the proceeding as it finds it, see Pacific Gas and Electric Co.

(Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-600, 12 NRC 3, 8 (1980), LILCO supports Citizen's petition for in-tervention.

Respectfully submitted, y db$

W. Tyyl h

Refeley, III Jamep Christman Kathy E. B. McCleskey Hunton & Williams 707 E. Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 27, 1983 I

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, LILCO, June 27, 1983 l

CERTIFICATE OF SERVICE In the Matter of I LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I hereby certify that copies of Applicant's Answer to ,

l the June 14 Intervention Petition of Citizens for Orderly Ener-gy Policy, Inc. , were served this date upon the following by first-class mail, postage prepaid, or (as indicated by one as-terisk) by hand,. or (as indicated by two asterisks) by Federal Express.

James A. Laurenson,* Secretary of the Commission

' Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing East-West Tower, Rm. 402A Appeal Board Panel 4350 East-West Hwy. U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, D.C. 20555 Dr. Jerry R. Kline*

l Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel i U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 427 Washing ton, D.C. 20555

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4350 East-West Hwy.

Bethesda, MD 20814 Bernard M. Bordenick, Esq.**

David A. Repka, Esq.

Dr. M. Stanley Living ston** Edwin J. Reis, Esq.

1005 Calle Largo U. S. Nuclear Regulatory Sante Fe, New Mexico 87501 Commission 7735 Old Georgetown Road Ronald A. Zumbrun (to mailroom)

Sam Kazman Bethesda, MD 20814 Lucinda Low Swartz Pacific Legal Foundation 1990 M Street, N.W., Suite 550 Washing ton, D.C. 20036 i-4

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e Eleanor L. Frucci, Esq.** Stewart M. Glass, Esq.**

Attorney Regional Counsel Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U. S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Highway Stephen B. Latham, Esq.**

Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street David J. Gilmartin, Esq. P.O. Box 398 Attn: Patricia A. Dempsey,-Esq. Riverhead, New York 11901 County Attorney Suffolk County Department Ralph Shapiro, Esq.**

of Law Cammer & Shapiro, P.C.

Veterans Memorial Highway 9 East 40th Street Hauppauge, New York 11787 New York, New York 10016 Herbert H. Brown, Esq.** James Dougherty, Esq.**

Lawrence Coe Lanpher, Esq. 3045 Porter Street Christopher McMurray, Esq. Washington, D.C. 20008 Kirkpatrick, Lockhart, Hill Christopher & Phillips Howard L. Blau 8th Floor 217 Newbridge Road 1900 M Street, N.W. Hicksville, New York 11801 Washington, D.C. 20036 Matthew J. Kelly, Esq.**

Mr. Marc W. Goldsmith State of New York Energy Research Group Department of Public Service 4001 Totten Pond Road Three Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates Spence W. Perry, Esq.**

l 1723 Hamilton Avenue Associate General Counsel Suite K Federal Emergency Management San Jose, California 95125 Agency 500 C Street, S.W.

Mr. Jay Dunkleberger Room 840 New York State Energy Office Washington, D.C. 20472 Agency Building 2 1 Empire State Plaza '

Albany, New York 12223 ) *

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h. Taylor pbveley, III Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 27, 1983

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