ML20092K810

From kanterella
Jump to navigation Jump to search
Rev to Direct Testimony of D Harris & M Mayer Re Contention 75 Per ASLB 840608 Ruling.Certificate of Svc Encl.Related Correspondence
ML20092K810
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/26/1984
From: Mark Miller
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:
Shared Package
ML20092K806 List:
References
OL-3, NUDOCS 8406290118
Download: ML20092K810 (8)
v • d • e


Text

-

e

[YEfr  ? I" . ; . ., . C U d i

00LKETED UNITED STATES OF AMENECA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet n b e si Board w r:cE C; m .-

ta p;Lil;G A St M '

=?MCH In the Matter of )

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

)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

REVISIONS TO THE DIRECT TESTIMONY OF DAVID HARRIS AND MARTIN MAYER ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION 75 On May 31, 1984, the Board admitted into evidence the Direct Testimony of David Harris and Martin Mayer on Behalf of Suffolk County Regarding Contentions 24.G, 24.K, 24.P, 73 and 75. Tr.

9574. However, as a result of LILCO's stated intention to abandon its reliance on two relocation centers designated in Revision 3 of the LILCO Plan (Suffolk County Community College and SUNY Stonybrook) and to substitute another facility (Dowling College) in their place and stead, cross-examination on Contention 75, which concerns relocation centers, was held in abeyance pending a decision by the Board on how to proceed. See Tr. 9573-74. On June 8, 1984, the Board ruled that revisions to the County's testimony on Contention 75 (as well as on the other relocation center related issues, Contentions 24.0 and 74) must be filed on June 26, 1984. Tr. 10973. Pursuant to the Board's-ruling, the County hereby submits the following revisions to the testimony of Drs. Harris and Mayer on Contentioa 75, which is DR O DR ,

Q

k contained in the document entitled " Direct Testimony of David Harris and Martin Mayer on Behalf of Suffolk County Regarding Contentions 24.G, 24.K, 24.P, 73 and 75":

1. Pages 24-25. Delete footnote 2.
2. Page 26, line 7. Change "five" to "four."
3. Page 28, lines 12 and 14. Change " Stony Brook" to "Farmingdale."
4. .Page 30. Insert the following paragraph following line 7:

" Finally, LILCO cannot assure that it can provide adequate capacity and services for evacuees at its designated relocation centers because at least two of the relocation centers upon which LILCO states it now intends to rely, BOCES II and SUNY Farmingdale (see LILCO Supplemental Testimony at 3), have informed the American Red Cross that those facilities will not be made available to implement the LILCO Plan in the event of a radiological emergency at Shoreham. See Attachments 2 and 3 to this testimony. And, as we stated in our testimony concerning Contention 24.N,-the LILCO Plan contains no agreements from facility owner, indicating the availability of the other two facilities now apparently relied upon -- that is, St. Joseph's I

College and Dowling College. Thus, two of the facilities have flatly stated that they,are not available for use in implementing the LILCO Plan, and LILCO has failed to provide any assurance or

[

evidence that the other two facilities have agreed to LILCO's proposals for their use. Accordingly, in our opinion, LILCO has

}

failed to provide assurance that the relocation centers it has l

s

'A designated will be sufficient in capacity to provide the neces-sary services for the number of evacuees that will require them in the event of a radiological energency at Shoreham."

5. Add Attachments 2 and 3 (attacted to this pleading).

Respectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS l

Lawrence Coe Lanpher Karla J. Letsche Michael S. Miller Christopher M. McMurray 1900 M Street, N.W.

Washington, D.C. 20036 Date: June 24, 1984 ATTACHMENT 2 g 8@ARD OF COOPERATIVE EDUCATIONAL SERVICES  ;

SECoNO $UPERVISORY Di$fRICT SUMOLK COUNTY. NEW YORK g + (516) 289 2200 201 Sunrise Highway, Patchogue, New York 11772 ,

JAMES HINES, EXECUTIVE OFFICER f

1 June 21, 1984 Mrs. Patricia Nocher Executive Director American Red Cross l 475 East Main Street l Patchogue, NY 11772 l

Dear Mrs. Nocher:

I have recently become aware that the American Red Cross and the Long Island Lighting Company have designated the campus of the BOCES II Occupa-tional Center in Islip .s a relocation center in the event of a radiological emergency at the Shoreham Nuclear Power Station. .

Please be advised that BOCES II has not entered into any agreement with ,

the American Red Cross or LILC0 to serve as a relocation center, or as a  ;

decontamination and monitoring facility, for a Shoreham emergency. Any such agreement would have to have been approved by BOCES II, and no such approval has been granted. BOCES II has entered into an agreement with the American Red Cross concerning the use of the B0CES II Occupational Center in Islip as a mass care shelter, but that agreement does not grant the American Red Cross or  !

LILC0 permission to use our campus as a relocation center, or as a decon-  !

tamination and monitoring facility, pursuant to LILC0's proposed plan to deal  !

with a radiological emergency at Shoreham.

c In addition, the Governor of the State of New York has determined that  ;

the State of New York will not participate in the implementation of the off-  ;

site radiological emergency response plan for Shoreham proposed by LILCO. In accordance with the Governor's position, the campus of the BOCES II Occupa- .

. tional Center in Islip will not be available to the American Red Cross or l LILC0 for use in implementing the LILCO Plan.

Consequently, as District Superintendent and Executive Officer of the ,

Board of Cooperative Educational Services of the Second Supervisory District of Suffolk County, I am advising you that we have not entered into any agree- i merit to serve as a relocation center, or as a decontamination and monitoring f acility, in the event of a radiological emergency at Shoreham.

Sincerely, James Hines District Superintendent  ;

JH/tw

' ATTACHMENT 3 4 w

f. ,,.:

.}, k y .ll FAIMIINGDALE SITil: L'%fVEl451D OF NI.W)OHk e AGillGI't.Il Itti, & 18481%fCu.f All t.LGl. e FAHill%Cll tl.L. \Lu )olth itr.s i s sib 400 214 offin e of the .%ident June 21, 1984 Mrs. Patricia Nocher Executive Director American Red Cross 475 East Main Street Patchogue, NY 11772

Dear Mrs. Nocher:

I recently have become aware that the American Red Cross and the Long Island Lighting Company have designated the cacpus of the State University of New York at Farmingdale as a relocation -

. center in the event of a radiological emergency at the Shoreham Nuclear Power Station.

Please be advised that SUNY-Farmingdale has not entered into any agreement with the American Red Cross or LILCO to serve as a relocation center, or as a decontamination and monitoring facility, for a Shoreham emergency. Any such agreement would have to have been approved by me, and no such approval has been granted.

In addition, the Governor of the State of New York has determined that the State of New York will not participate in the icplementa-tion of any radiological emergency response plan for Shoreham pro-posed by LILCO. The Governor has stated that the LILCO Plan is not adequate and is not implementable. In accordance with the Governor's position, SUNY-Farmingdale will not be available to the American Red Cross or LILCO for use in icplementing the LILCO Plan.

Consequently, as President of the State L'niversity of New York at Farmingdale, I am advising you that we have not entered into any agreement to serve as a relocation center, or as a decontamina-tion and monitoring facility, in the event of a radiological emer-gency at Shoreham.

Sincerely,

,s' .

, c. . . /

/

Frank A.f Ciprliani PresideiltM FAC:hs ,

?: ,

RELATED CC.,,,_4UNDENCE i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before The Atomic Safety And Licensing Board

(

) [

In the Matter of ) .  ;

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

' Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of REVISIONS TO THE DIRECT TESTIMONY OF DAVID HARRIS AND MARTIN MAYER ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION 75, dated June 26,.1984, have been served to the following this jLs day o f June , 1984 by U. S.  ;

mail, first class; by hand when indicated by one asterisk; and by Federal Express when indicated by two asterisks. ,

t t

James A. Laurenson, Chairman

  • Edward M. Barrett, Esq.

Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washing ton, D.C. 20555 250 Old Country Road Mineloa, New York 11501 Dr. Jerry R. Kline

  • W. Taylor Reveley III, Esq.#

Atomic Safety and Licensing Board Hunton & Willaims i U.S. Nuclear Regulatory Commission P.O. Box 1535 j

s Washing ton, D.C. 20555 707 East Main Street Richmond, Virginia 23212 .

Mr. Frederick J. Shon

  • Atomic Safety and Licensing Board Mr. Jay Dunkleberger U.S. Nuclear Regulatory Commission New York State Energy Office  !

Washing ton, D.C. 20555 Agency Building 2 ,

Empire State Plaza  ;

Albany, New York 12223 i

n l

t

- . _ . . _ _ _ _ . . - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . - . _ _ _ _ _ _ . - ~ . - .- .

Mr. Brian McCaffrey Stephen B. Latham, Esq.

Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station P.O. Box 398 P.O. Box 618 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 hora Bredes Docketing'and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition 1717 H Street, N.W.

195 East Main Street U.S. Nuclear Regulatory Comm.

Smithtown, New York 11787 Washing ton, D.C. 20555 Marc W. Goldsmith Hon. Peter Cohalan Energy Research Group, Inc. Suffolk County Executive 400-1 Totten Pond Road H. Lee Dennison Building Waltham, Massachusetts 02154 Veterans Memorial Highway Hauppauge, New York 11788 MHB Technical Associates Eleanor L. Frucci, Esq.

  • 1723 Hamilton Avenue Atomic Safety and Licensing Suite K Board Panel San Jose, California 95125 U.S. Nuclear Regulatory Comm.

Washing ton , D.C. 20555 Joel Blau, Esq. Martin Bradley Ashare, Esq.

New York Public Service Commission Suffolk County Attorney The Governor Nelson A. Rockefeller H. Lee Dennison Building Building Veterans Memorial Highway Empire State Plaza Hauppauge, New York 11788 Albany, New York 12223 Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.

Washing ton , D.C. 20555 Washing ton, D.C. 20555 Edwin J. Reis , Esq.

  • Jonathan D. Feinberg, Esq.

Bernard M. Bordenick, Esq. Staff Counsel, New York State U.S. Nuclear Regulatory Commission Public Service Commission Washing ton, D.C. 20555 3 Rockefeller Plaza Albany, New York 12223 Stuart Diamond Stewart M. Glass, Esq.

Business / Financial Regional Counsel NEW YORK TIMES Federal Emergency Management 229 W. 43rd Street Agency New York, New York 10036 26 Federal Plaza New York, New York 10278 s ,

Spence Perry, Esq. James B. Dougherty, Esq.

Associate General Counsel 3045 Porter Street, N.W.

Federal Emergency Management Agency Washington, D.C. 20008 Washington, D.C. 20471 Fabian Palomino, Esq.

  • Special Counsel to the Governor Executive Chamber Room 229 State Ct.pitol Albany, New York 12224

%Q 1. m Michael S. Miller KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 DATE: June 26, 1984

  • By. Hand
  1. By Federal Express s

a G

s t

.w **%

f w

dw. g v

3-9 m

g.

  1. y

%

Retrieved from "https://kanterella.com/w/index.php?title=ML20092K810&oldid=2791238"