ML20092G472

Supplemental Testimony of Mc Cordaro & Wf Renz on Contention 24.R Re Ltr of Agreement W/State of Ct. Certificate of Svc Encl

ML20092G472
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/20/1984
From:	Cordaro M, Renz W LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20092G443	List: ML20092G437 ML20092G472
References
OL-3, NUDOCS 8406250131
Download: ML20092G472 (8)

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LILCO, June 20, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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

) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

LILCO'S SUPPLEMENTAL TESTIMONY ON CONTENTION 24.R (LETTER OF AGREEMENT WITH CONNECTICUT)

1. Q. Please identify yourselves.

My name is Matthew C. Cordaro. My address is Long Is-land Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.

My name is William F. Renz. My address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New, York, 11801.

[Both witnesses] Our professional qualifications have previously been admitted into the record. Each of us sponsors the remaining testimony below.

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2. Q. What is Contention 24.R?

A. Contention 24.R states, in essence, that the State of Connecticut has not agreed to implement protective ac-tions for that portion of the Shoreham 50-mile inges-tion exposure pathway EPZ that is within Connecticut.

LILCO's previously filed testimony on Contention 24.R sets out the complete text of the contention (Tr. Apr.

6, 1984, Vol. II, p. 27).

3. Q. Since LILCO witnesses filed testimony on Contention 24.R on March 2, 1984 and were cross-examined on that testimony on April 6 and 24, have you received addi-tional information that bears upon the issues raised in Contention 24.R?

A. Yes. LILCO witnesses have testified, based upon a December 15, 1983 letter from the State of Connecticut to the-State of New York (Tr. Apr. 6, 1984, Vol. II, .

Attachment 28),.that the State of' Connecticut has agreed to assume responsibility for implementing pr'o-tective actions for the ingestion exposure pathway in-3 the event of a radiological emergency.at Shoreham (see Tr. Apr. 6, 1984, Vol. II, pp. 27-28). As a result-of the letter introduced by the' State.of New York on cross-examination of LILCO's witnesses /on Contention-

- 24.R-(N.Y. Ex. 3, ff. Tr. 6598), we contacted the I

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. State of Connecticut to confirm our understanding of 1 the meaning of the December 15, 1983 letter (see At- l tachment 1 to this testimony). The State of Con-necticut responded on June 14, 1984, with a letter to LILCO that states (1) Connecticut officials will pro-tect citizens of Connecticut should there be an acci-dent at Shoreham, (2) they will do so by instituting existing State emergency plans, (3) they will do so whether they are notified by LILCO "or any other com-petent source," and (4) they will do so regardless of a response, or lack of it, from New York State or LILCO. That letter is Attachment 2 to this testimony.

It was received by LILCO on June 18, 1984.

L Taken together, the December 15 and June 14 letters from Connecticut indicate beyond any doubt that, con-trary to the allegations of Contention 24.R, the State of Connecticut has. agreed to implement protective ac-tions for that portion of,the 50-mile-ingestion' expo-sure pkthway EPZ within its boundaries.

4. Q. Does that conclude your supplemental testimony?

A. Yes.

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anaf4BdetL4VM LONG ISLAND LIGHTING COM PANY 175 EAST OLD COU NTRY ROAD

• H IC K SVI LLE. NEW YORK 11801 Direct Dial Number ATTACHMENT 1 TO O'S SUPPLEMENTAL (516) 733-4945STIMONYON ta CONTENTION 24.R l

I May 22, 1984 Mr. Frank Mancuso Director Connecticut Office of Civil Preparedness State Armory 360 Broad Street Hartford, CT 06105

Dear Mr. Mancuso:

A few weeks ago, I had the opportunity to talk to Mr. Grandone of your office to discuss the present state of emergency planning in support of the Shoreham Nuclear Power Station. As you know, the Long Island Lighting Company is in the process of developing and implementing a Local Offsite Radiological Emergency Response plan to respond to an emergency at Shoreham. LILCO has undertaken this endeavor as a result of Suffolk County's refusal to participate in the planning for such a reponse. As I believe you are also aware, the State of New York has taken the position that they will not " impose" a plan on Suffolk County. LILCO's Plan is currently being considered before the Atomic Safety and Licensing Board. During the development and institution of this Plan, LILCO has reached agreement, or understanding, with many of the external organizations that would be needed to support such a response, such as the U.S. Department of Energy, the U.S. Coast Guard, the American Red Cross, and various ambulance and bus companies. During my conversation with Mr. Grandone, he indicated that if the LILCO Plan is approved by the NRC, and LILCO receives an operating license for Shoreham, the State of Connecticut would institute its emergency plans to protect the health and safety of the residents of Connecticut were LILCO to notify Connecticut of an accident at Shoreham, even in the unlike,1y event that New York State and Suffolk County were not

ATTACIIMENT 1 TO LILCO'S SUPPLEMENTAL

                  -                                              TESTIMONY ON Mr. Frank Mancuso May 22, 1984 Page 2 participating in a response to that accident. I know that you have no wish to get involved in the political situation surrounding emergency planning for Shoreham.             Although I believe your letter of December 15, 1984 states this position clearly, I would be grateful if you would send us a letter reconfirming this informatior.

Should you or your staff have any questions regarding this request, or have need of further information,_please do not hesitate to contact me at the above listed phone number or address. Very truly yours,

                                                       //     T.'

vm,P - William u. ' . Offsite Emehgency Preparedness Coordinator cc: Mr. Frank Grandone bec: Messrs. J. A. Weismantle E. J'. Youngling C. A. Daveri o J. N. Christman M. Horoschak Ms. K. E. B. McCleskey E. D. Robinson-t

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  . W                    STATE OF CONNECTICUT A'                      DEPARTMENT OF PUBLIC SAFETY
                         -      OFFICE OF CIVIL PREPAREDNESS                       ATTACHMENT 2 TO
                     -                                                             LILCO 'S SUPPLE!1 ENTAL TESTIMONY ON CONTENTION 24.2 June 14,1984 l

Mr. William F. Renz Offsite Emergency Preparedness Coord. Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801

Dear Mr. Renz:

Your letter of May 22, 1984 requests a reconfirmation that the State of Connecticut Office of Civil Preparedness would react to an emergency or pre-emergency at Shoreham by instituting emergency plans to protect the health and safety of the residents of Connecticut. It is incredible that you assume we might not. Nevertheless I will provide reassurance. Regardless of what New York or LILCO does. Connecticut will look after its own public safety. This office will react to an accident at Shoreham or any other nearby facility by instituting existing emergency plans and resources to protect the health and safety of the residents of Connecticut. This is true whether we are notified by LILCO or any other competent source such as the Federal Emergency Management Agency. I don't believe it is the intent of NUREG-0654/ FEMA-REP-1 to make utilities primarily responsible for municipal level preparedness. This is a danger-ous trend. It may lead to a situation with many utilities responsible for off-site standards of preparedness, a development that would make a sham of NUREG-0654/ FEMA-REP-1. I hope this letter satisfies your concern. Sincerely, M?i'd Frank Mancuso State Director FM/lal cc: F. Grandone CF Phoa'i 566-3180 360 Broad Street - Hartford. Connecticut 06105 An Equal Opportunity Employer

LILCO, June 20, 1984 CERTIFICATE OF SERVICE In tho Mattor of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) (Emergency Planning Proceeding) Docket No. 50-322-OL-3 I certify that copies of (1) LILCO's MOTION TO ADMIT LILCO'S SUPPLEMENTAL TESTIMONY ON CONTENTION 24.R (LETTER OF AGREEMENT WITH CONNECTICUT), and (2) LILCO'S SUPPLEMENTAL TES-TIMONY ON CONTENTION 24.R (LETTER OF AGREEMENT WITH CON-NECTICUT) were served this date upon the following by first-class mail, postage prepaid, or (as indicated by one asterisk) 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*

Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy. Bethesda, MD 20814 Bernard M. Bordenick, Esq.* Oreste Russ Pirfo, 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 Stewart M. Glass, Esq.** Regional Counsel Eleanor L. Frucci, Esq.* Federal Emergency Management Attorney Agency Atomic Safety and Licensing 26 Federal Plaza, Room 1349 Board Panel New York, New York 10278 U. S. Nuclear Regulatory Commission Stephen B. Latham, Esq. East-West Tower, North Tower Twomey, Latham & Shea 4350 East-West Highway 33 West Second Street Bethesda, MD 20814 Post Office Box 398 Riverhead, NY 11901

1 Fabian G. Palomino, Esq.** Ralph Shapiro, Esq.  ! Special Counsel to the Cammer & Shapiro, P.C. Governor 9 East 40th Street Executive Chamber New York, New York 10016 Room 229 State Capitol James B. Dougherty, Ecq. Albany, New York 12224 3045 Porter Street Washington, D.C. 20008 Herbert H. Brown, Esq.* Lawrence Coe Lanpher, Esq. Jonathan D. Feinberg, Esq. Christopher M. McMurray, Esq. New York State Public Service Kirkpatrick, Lockhart, Hill Commission, Staff Counsel Christopher & Phillips 3 Rockefeller Plaza 8th Floor Albany, New York 12223 1900 M Street, N.W. Washington, D.C. 20036 Spence W. Perry, Esq.** Associate General Counsel Mr. Marc W. Goldsmith Federal Emergency Management Energy Research Group Agency 4001 Totten Pond Road 500 C Street, S.W., Rm. 840 Waliham, Massachusetts 02154 Washington, D.C. 20472 MHB Technical Associates Ms. Nora Bredes 1723 Hamilton Avenue Executive Coordinator Suite K Shoreham Opponents' Coalition San Joce, California 95125 195 East Main Street Smithtown, New York 11787 Mr. Jay Dunkleberger New York State Energy Office Martin Bradley Ashare, Esq. Agency Building 2 Suffolk County Attorney Empire State Plaza H. Lee Dennison Building Albany, New York 12223 Veterans Memorial Highway Hauppauge, New York 11788 Gerald C. Crotty, Esq.** Counsel to the Governor Executive Chamber State Capitol Albany, New York- 12224

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B. McCle(ke'y K a t"h~y E Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED: June 20, 1984}}