ML20092P722

Motion to Admit Supplemental Testimony on Contention 85 Re Recovery & Reentry.Testimony Discusses New Procedure for Calculating Total Population Dose

ML20092P722
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/03/1984
From:	Horoschak M HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20092P723	List: ML20092P722 ML20092P724 ML20092P726 ML20092P727
References
OL-3, NUDOCS 8407090309
Download: ML20092P722 (3)

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L:LCO, July 3, 1994 UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION L'. C_ -5 P 2 :07 Sefore the Atomic Safety and Licensinc Board r J. . .J{iU In the Matter of )

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

) (Emergency Planning (Shoreham Nuclear Power ) Proceeding)

Station, Unit 1 )

LILCO's MOTION TO ADMIT SUPPLEMENTAL TESTIMONY ON CONTENTION 85 (RECOVERY AND REENTRY)

LILCO hereby moves to admit the attached "LILCO's Supple-

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mental Testimony on Contention 85 (Recovery and Reentry)" for.

the reasons stated below.

LILCO's Supplemental Testimony on Contention 85 is' limit'ed to a discussion of the methodology for calculating total popu-lation dose, as set forth in OPIP 3.10.2, Rev. 4. This newly developed procedure is responsive to a specific comment made by the Regional Assistance Committee of the Federal Emergency Man-agement Agency in its Report dated February 10, 1984. In that Report, FEMA /RAC asserted that LILCO's Emergency Plan did not include a method for calculating total population, dose, and thus did not comply with NUREG 0654, II.M.4. See FEMA /RAC Re-port to the Nuclear Regulatory Commission at 50. This observa-

. tion was also made in the Testimony of Gregory C. Minor on Be-

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half of Suffolk County on Contentions B5 and SS, which was filed on March 21, 1984.

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6 The attached Supplemental Testimony addresses this alleged deficiency in LILCO's general , plan for. recovery and reentry.

Specifically, this testimony delineates the steps to be taken under OPIP 3.10.2 in order to calculate teral population expo-sure. As such, this testimony is directly relevant and materi-al to the central issue of Contention 85, that is, whether LILCO has a general plan for recovery and reentry in accordance with NUREG.0654, II.M.

The Supplemental Testimony which LILCO seeks to file is quite brief. The parties will not be prejudice'd if this testi-mony is admitted because they will have an opportunity to cross-examine LILCO witnesses concerning CPIP 3.10.2, and be-cause the'SupplementIl' Testimony i~s limited to.h discussion 'of an issue previously raised in the,FEMh/RAC Report and Mr.

Minor's testimony. Efficiency also commends filing this Sup- ,

plemental Testimony now rather than as rebuttal after ques-tioning Mr. Minor on his_ direct testimony; questioning thus can be better focused now than it could have been otherwise.

For the foregoing reasons, LILCO moves th'at the Board admit LILCO's Supplemental Testimony on Contention 85 (Recovery and Reentry).

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c, -1 ei Respectfully submitted, t -

LCNG ISLAND LIGHTING COMPANY f~

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! Donald P. Irwin I Mark J. Horoschak i

Hunton & Williams 707 East Main Street Post Office Box 1535 '

Richmond, Virginia 23212 i i

', DATE: July 3, 1984.

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