ML20084D162

Supplemental Testimony of Jr Kessler on Behalf of Util on Contention 11 Re Conflict of Interest.Certificate of Svc Encl

ML20084D162
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/26/1984
From:	Kessler J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20084D147	List: ML20084D143 ML20084D162
References
NUDOCS 8405010205
Download: ML20084D162 (7)

Text

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l LILCO, April 26, 1984 WP UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION hI Before the Atomic Safety and Licensing Board In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning (Shoreham Nuclear Power Station, )

Proceeding)

Unit 1)

)

SUPPLEMENTAL TESTIMONY OF JAY R.

KESSLER ON BEHALF OF THE LONG ISLAND LIGHTING COMPANY ON CONTENTION 11 (CONFLICT OF INTEREST)

PURPOSE This testimony in given by Mr. Kessler, one of the LILCO officers who is designatad to fill the command-and-control po-sition, Director of Local Response.

He replaces the former LILCO witness, Mr. Wofford, who has retired.

The testimony i

gives Mr. Kessler's opinion, based on his experience, that the LILCO employees'in the command-and-control position would not let LILCO's corporate interests interfere with protecting the public.

Attachment Biographical Information on Jay Richard Kessler 8405010205 840426 PDR ADOCK 05000322 g

PDR

LILCO, April 26, 1984 VNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

Before the Atomic Safety and Licensing Board In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322-OL-3

)

(Emergency Planning (Shoreham Nuclear Power Station, )

Proceeding)

Unit 1)

)

SUPPLEMENTAL TESTIMONY OF JAY R.

KESSLER ON BEHALF OF THE LONG ISLAND LIGHTING COMPANY ON CONTENTION 11 (CONFLICT OF INTEREST) 1.

Q.

Please state your name and business address.

A.

My name is Jay R.

Kessler; my business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.

2.

Q.

Please give your professional qualifications.

A.

My resume is attached to this testimony.

3.

Q.

Have you read the "LILCO Testimony on Contention 11 (Conflict of Interest)"?

A.

Yes.

4.

Q.

Do you adopt Answer 25 (on pages 19-20 of that tes-timony) as your own?

N

, A.

Yes.

5.

Q.

Are you one of the people designated to fill the LERO command-and-control position?

A.

Yes.

I am designated to be Director of Local Re-sponse in an emergency.

I am one of the people who are alleged to be subject to a " conflict of inter-est."

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6.

Q.

Do you think you, or other LILCO employees in the command-and-control position, would let LILCO's corporate interests interfere with protecting the public?

A.

No.

I have been an employee at LILCO for more than 32 years.

In that time, I have had numerous as-signments which entailed as part of their responsi-bility the requirement to respond to or participate in emergency activities involving LILCO's electric or gas system.

During these assignments, I have had the opportunity to view first-hand the tradi-tion of public service which is a part of the work-ing philosophy of LILCO employees.

My experience involves actual hands-on participation in emergency situations where I had to expose myself to danger-ous and explosive gaseous atmospheres in order to i

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v evaluate the emergency situation and to prepare to take steps to provide for the public safety.

I have also partici. pated for many years in a supervi-sory role, directing LILCO personnel in these pro-tective actions, and I have never seen a case where a LILCO employee did not do what was required to protect the public.

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LILCO, April 26, 1984 DOLKETED USHFC CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMBhy (Shoreham Nuclear Power Statior50C Nh; Docket No. 50-322-OL-3 BRANcy I hereby certify that copies of LILCO'S MOTION TO WITH-DRAW CERTAIN PORTIONS OF ITS TESTIMONY ON CONTENTION 11 (CON-FLICT OF INTEREST) AND TO FILE SUPPLEMENTAL TESTIMONY ON THAT l

CONTENTION and SUPPLEMENTAL TESTIMONY OF JAY R. KESSLER ON BE-HALF OF LONG ISLAND LIGHTING COMPANY ON CONTENTION 11 (CONFLICT OF INTEREST) were served this date upon the following by first-class mail, postage prepaid or, as indicated by an asterisk, by Federal Express:

James A.

Laurenson,*

Secretary of the Commission Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission l

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 l

Bethesda, MD 20814 Commission Washington, D.C.

20555 Dr. Jerry R.

Kline*

Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Towcr, Rm. 427 Washington, D.C.

20555 4350 East-West Hwy.

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

David A. Repka, Esq.

Mr. Frederick J. Shon*

Edwin J.

Reis, Esq.

Atomic Safety and Licensing U.

S. Nuclear Regulatory.

Board Commission U.S. Nuclear Regulatory

-7735 Old Georgetown Road Commission

~

(to mailroom)

East-West. Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.

Bethesda, MD 20814 O-

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l Eleanor L.

Frucci, Esq.*

Stewart M. Glass, Esq.*

Attorney Regional Counsel 3

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.*

i Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street I

Fabian G.

Palomino, Esq.*

2 O.

Box 398 Special Counsel to the Riverhead, New York 11901 Governor Executive Chamber Ralph Shapiro, Esq.*

Roem 229 Cammer & Shapiro, P.C.

State Capitol 9 East 40th Street Albany, New York 12224 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 Kirkpatric?c, Lockhart, Hill Christopher & Phillips Jonathan D.

Feinberg, Esq.

8th Floor New York State Department of 1,

.1900 M Street, N.W.

Public Service, Staff Counsel Washington, D.C.

20036 Three Empire State Plaza Albany, New York 12223 i

Mr. Marc W.

Goldsmith Energy Research Group Spence W.

Perry, Esq.

4001 Totten Pond Road Associate General Counsel Waltham,' Massachusetts 02154 Federal Emergency Management Agency MHB Technical Associates 500 C Street, S.W.

1723 Hamilton Avenue Room 840 Suite K Washington, D.C.

20472

' San Jose, California 95125 Ms. Nora Bredes Mr. Jay Dunkleberger Executive Coordinator New York' State Energy Office Shoreham Opponents' Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, New York 11787 Albany, New York 12223 e

a

' Gerald C.

Crotty, Esq.

Martin Bradley Ashare, Esq.

Counsel to the Governor Suffolk County Attorney Executive Chamber H.

Lee Dennison Building State Capitol Veterans Memorial Highway Albany, New York 12224 Hauppauge, New York 11788 James N.

Christman Hunton & Williams 707 East Main Street P.O.

Box 1535 Richmond, Virginia 23212 DATED:

April 26, 1984

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