ML20091L113

Updated Testimony of Cv Failla on Behalf of State of Ny Re Contention 24.F.2.Certificate of Svc Encl.Related Correspondence

ML20091L113
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/04/1984
From:	Failla C, Zahnleuter R NEW YORK, STATE OF
To:
References
NUDOCS 8406070337
Download: ML20091L113 (6)

Text

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

ATOMIC SAFETY AND LICENSING BOARD h;

l' Before Administrative Judges 4

James A.

Laurenson, Chairman 84 J!]N-7 Af0:51 Dr. Jerry R.

Kline Mr. Frederick J.

Shon

)

.':,l~Q' In the Matter of

)

94A f!O!

)

Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY

)

(Emergency Planning Proceeding)

)

(Shoreham Nuclear Power

)

Station, Unit 1)

)

June 4, 1984

)

UPDATE OF NEW YORK STATE'S TESTIMONY CONCERNING CONTENTION 24.F.2 Pages 2 and 3 of the " DIRECT TESTIMONY OF CHARLES V.

FAILLA ON BEHALF OF NEW YORK STATE REGARDING CONTENTION 24.F.2" have been updated.

Attached hereto are the revised pages 2 and 3.

.cfully submitted, MARIO CUOMO, Governor of the State of New York FABIAN G. PALOMINO, ESQ.

Special Counsel to the Governor of the State of New York

/-F BY:

RICHARD J.

Z NL U E, ESQ.

Assistant to th ial Counsel a l to-the Gov or of the State of New York

.i Albany, New York June 4, 1984 QTQC$b 3 hgq B406070337 840604 PDR ADOCK 05000322 T

OCA

66 -

v radiological accident at Shoreham. However, it is my understandin$ that r*

LILCO's bus company agreements provide that each bus company's obligation to provide buses to LILCO is subject to its obligations to' provide buses to the schools and school districts with which it has contracts.

The State has been able to obtain information with respect to the buses committed to schools and school districts by 7 of the 12.Sua companies with-which LILCO has agreements.

In the following table, the numoer of buses

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committed by each of those companies to schools and school districts is com-q t

pared with the total number of buses that company has in service.1 s

Conmitted Committed Total In Available for Company to Schools to LILCO Service

• LILCO's Use r.,

Educational Bus Trans-98 100 86 '/8. (

0 portation, Inc.

Hermon E. Swezey Co.,

1 29 31 wJ, 30

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Inc.

,69

9, Huntington Coach, Inc.

107 100 0

Seaman Bus Co., Inc.

31 35 35 4

Starlite Bus Co., Inc.

44

.60 633rA 19' N Suburbia Bus Corp.

169 190 l'80'/ ? f

'll' /[

United Bus Corp. '

200 200

'205 A #r

' 5'. G TOTALS 650 714 669'(f7-f 6,9 7y

• 40-adult passenger school buses as of -3/19/84-

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'1The source of information concerning the number of buses committed to schools and school districts by each of the seven bus companies included in the table is LILCO's response to Suffolk County Interrogatory No. 3 of August 19,1983.

LIICO's response only provides such information for the seven bus companies mentioned above.

The total number of buses each of those companies has in service is derived from the bus inspection records of the New York State Department of Transportation, as of dai1E M'a'rbn 1984.- Educational Bus Transportation and Huntington Coach'are able to satisfy their service demand =

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by staggering the number-of buses used at' one time during peak service. As a result of this, the total buses in service less the total buses committed to schools by the 7 bus companies will not equal the total buses available for LIICO's use (i.e. 669-650/69).

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7

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= l7 n

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3-LILCO claims that the seven aforementioned companies togeth'r have 4

e committed 714 buses to LILCO's use in the event of an accident at Shoreham.

(See Testimony of Cordaro et al. on Behalf' of Iong Island ' Lighting Cot.pany on Phase II Emergency Planning Contention 24.F, G, I, K, L, O, P, R, S and T, at 6, 7.)

However, as seen in the above table, if an accident were to occur during school sessions, the seven aforementioned companies could in fact provide LIICO with a total of only 69 buses, or about 10% of the number of buses nominally committed to LILCO.

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(_

Ww UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges James A.

Laurenson, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon

)

In the Matter of

)

)

Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY

)

(Emergency Planning Proceeding)

)

(Shoreham Nuclear Power Station, )

Unit 1)

)

)

June 4, 1984

)

CERTIFICATE OF SERVICE I hereby certify that one copy of the " UPDATE OF NEW YORK STATE'S TESTIMONY CONCERNING CONTENTION 24.F.2" has been served to each of the following this 4th day of June 1984 by U. S. Mail, first class, except as otherwise noted:

• James A. Laurenson, Chairman Ralph Shapiro, Esq.

Atomic Safety and Licensing Board Cammer and Shapiro 6

U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D.

C.-

20555 New York, New York 10016

• Dr. Jerry R.

Kline Howard L.

Blau, Esq.

Administrative Tudge 217 Newbridge Road Atomic Safety and Licensing Board Hicksville, New York 11801 U.S. Nuclear Regulatory Commission Washington, D. C.

20555

• W. Taylor Reveley III, Esq.

Hunton & Williams

• Mr. Frederick J. Shon P. O. Box 1535 Administrative Judge 707 East Main Street Atomic Safety and Licensing Board.

Richmond, Virginia 23212 U.S. Nuclear Regulatory Commission Washington, D. C.

20555 a

o

l l

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Mr. Jay Dunkleberger Marc W. Goldsmith g

New York State Energy Office Energy Research Group, Inc.

Agency Building 2 400-1 Totten Pond Road Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates James B.

Dougherty, Esq.

1723 Hamilton Avenue, Suite K 3045 Porter Street, N. W.

San Jose, California 95125 Washington, D. C.

20008 Honorable Peter F. Cohalan Mr. Brian McCaffrey Suffolk County Executive Long Island Lighting Company H. Lee Dennison Building Shoreham Nuclear Power Station Veterans Memorial Highway P. O.

Box 618 Hauppauge, New York 11788 North Country Road Wading River, New York 11792 Ezra I. Bialik, Esq.

Assistant Attorney General Martin Bradley Ashare, Esq.

Envirommental Protection Bureau Suffolk County Attcency New York State Department of Law H. Lee Dennison Building 2 World Trade Center Veterans Memorial Highway New York, New York 10047 Hauppauge, New York 11788 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D. C.

20555 Stewart M. Glass, Esq.

Docketing and Service Section Regional Counsel Office of the Secretary Federal Emergency Management U.S. Nuclear Regulatory Commission Agency 1717 H Street, N.W.

26 Federal Plaza, Room 1349 Washington, D. C.

20555 New York, New York 10278

• Bernard M. Borden,ick, Esq.

Nora Bredes David A.

Repka, Esq.

Executive Director U.S. Nuclear Regulatory Commission Shoreham Opponents Coalition

~

Washington, D. C.

20555 195 East East Main Street Smithtown, New York 11787 Stuart Diamond Environment / Energy Writer Eleanor L. Frucci, Esq.

NEWSDAY Atomic Safety and Licensing Long Island, New York 11747 Board Panel U.S. Nuclear Regulatory Commission Stephen B.

Latham, Esq.

Washington, D. C.

20555 Twomey, Latham & Shea P. O. Box 398 33 West Second Street Riverhead, New York 11901

d6 O

=

4 4

• Herbert H.

Brown, Esq.

Lawrence Coe Lanpher, Esq.

Karla J. Letsche, Esq.

1900 M Street, N. W.,

Suite 800 Washington, D. C.

20036 Spence Perry, Esq.

Associate General Counsel Federal Emergency Management Agency Washington, D. C.

20472

/

RICHARD J.

Z NL U R

Assistant to th S

ial Counsel to the Gov or of the State of New York Executive Chamber State Capitol Albany, New York 12224

• By Hand - In addition to service by mail, revisions were served by hand on June 1, 1984.

• • By Federal Express

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• • • By Telecopier

• • • • By U.S. Express Mail Albany, New York i

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