ML20090K407

Affidavit of P Mcintire in Support of FEMA Response to Suffolk County Discovery Request.Regional Assistance Committee Activity Will Be Further Delayed If Ruling Act Reversed

ML20090K407
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/21/1984
From:	Mcintire P Federal Emergency Management Agency
To:
Shared Package
ML20090K363	List: ML20090K362 ML20090K373 ML20090K407 ML20090K443
References
NUDOCS 8405240196
Download: ML20090K407 (3)

Text

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P.82 f%Y.21 '84 24:21 FEr% REGTON II tEW YORK 2 UNITED STATES OF AMERICA NUCLgAR REGULAIORY C00 MISSION Before the Atomic gafety and IJzensing Appeal Board

)

In the Matter of )

) AFFIDAVIT OF

) FHILIF MC INTIRE LONG ISLAND LIGHTING CGG'ANY

) Chief. Natural and Technological Bazards Division (Shoreham Nuclear Fower Station Unit 1 ))

Philip McIntire hereby declares I am the Chief of the Natural and Technological Bazards Division of the Federal Emergency Management Agency. Eagion II, an agency of the executive branch of the Federal government. I make this declaration in support of the Agency's Response tn Suffolk County's Discovery RagtIest.

The purpose of this affidavit is to inform the NRC Appeals Board for Shoreham about the impact upon tbs off-site amergency planning process that will occur if the Atomic gefety and Licensing Board's (ASLB) ruling that

' written reports of the individual Regional Assistancia Committee (RAC) members are allowed to be exanined under discovery by parties to this proceeding. The RAC in Region II has always aparated under the management principle that the views of the individual members would be kapt' confidential. The collegial judsnent of the group is the only f actor that impacts the off-site issues for a site. This principle was upheld by the Indian Point AELB.

If the ASLB's ruling is not reversed, the following will occur. All RAC activity for the five operating sites .in New Jersey and New York will be further delayed. It should be pointed out that not one of these sites has a final ap-

, proval for off-site safety primarily because of the heavy involvesant by the RAC for Indian Point and now Shorehen. New procedures to ensure that indivi-dual RAC member views will never.be discoverable again will have to be devised.

Basically, these procedures will have to do away with individual reports from the members and stress conference calls and meetings as the basis for the RAC process.

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- MAY.21 '84 14:22 FEMA FEGICN H tEW YOR< 2 It is my judgment that, at a minimas, this will double tha time for the This might be a conservative estimate in view of the MC review process.

tight travel budgets of most Federal agencies.

The impact on the RAC review of Revision 4 for Shorehsa cannot be p Because of the extrasely short deadlina Bovever, delays will be substantial.

for FDLA to file this appeal we have not been able to discuss the ASLB's r in detail with the individual RAC moabers.

From the program aansgenent perspective of the Shoreham off-site safety question, for which'I sa responsible, the ruling is a disaster for the reso-The RAC process is by its nature an lution of the off-site safety gsestions.

Initial percaptions change when the EAC meets interactive and evolving ares. discuss.

and all information and evaluations are available to the entire group to The individual written connants are only the catalyst for the final collegial judgnant. In my best professional judgment, the taleasing of individual f RAC cossents, submitted early in the evaluation process, does nothing to clari y the off-site issues at Shorehen.

From the FDIA Region II perspective, the sustaining of this ruling lise the will significantly delay and neediossly complicate the EAC's ability to fina I In addition, it will delay the issuing of final off-site issues at Shorehen. At CFR 350 reports for the five operating sites in Nw Jersey and i New counter-York.

this time, without the opportunity to discuss this ruling with my n ne l j

parts, there is no way I can estimate at this time the impact on the nuc ea industry in the rest of the country.

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• P.04 f%Y.21 '84 14:24 fem REGION ZI NEW YORK 2 9

I hereby certify tiet the abwe is tzus and cortect to the best of my knowisege and h=14=f. .

Philip *Tr*4 *e, fhiaT Natural & TodmoL74 =1 Besartie Division 21 dqy of May, 1984.

SUBEKRIBI!D AtO 9Citi to befiore me this  !

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