ML20108D420
| ML20108D420 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/10/1984 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| CON-#484-576 OL-3, NUDOCS 8412130179 | |
| Download: ML20108D420 (9) | |
Text
'b7v LILCO, Dsccmbar 10, 1984
) hr 00CKETED UNITED STATES OF AMERICA '
USNRC NUCLEAR REGULATORY COMMISSION
.N EC 12-Aii:i)6 -
Before the Atomic Safety and Licensina Board
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In the Matter of
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.LONG ISLAND LIGHTING COMPANY
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Docket 1(o. 50-322-OL-3
)
(Emergency Planning (Shoreham Nuclear Power Station, )
Proceiidi'ng)'**~.
Unit.1)
)
LILCO'S~ ANSWER TO SUFFOLK COUNTY AND STATE OF NEW YORK SUBMISSION PURSUANT TO MCGUIRE DECISION The Intervenors have filed a December 5, 1984 motion
(" Submission") requesting that the Board (1) reject certain of LILCO's proposed findings, (2) require LILCO to provide "all pertinent, updated data on the subject of the current actual composition of LERO, the projected future composition of LERO i
and_how LILCO intends to achieve such composition," and (3) re-verse its earlier decision not to entertain an untimely conten-tion-about LERO staffing and morale.
Intervenors' Submission i
at 5.
The motion is based on four newspaper clippings re-porting that substantial numbers of LERO members have resigned.
LILCO opposes the motion in its entirety.
In the first place, the-inference the Intervenors draw from the news clippings -- that LERO presently suffers from a manpower-
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shortage -- is incorrect.
The attached Affidavit of John A.
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&ofof
' Weismantlel/'shows that LERO's present membership is well over its 1750-member goal.
The Affidavit also shows that the Inter-venors have misunderstood the statement by LILCO's Chairman on which they rely.
In the second place, short-term fluctuations in LERO l-membersaip simply do not raise a safety issue.
Volunteers can be expected to both enter and leave LERO as long as it exists.
The daily or monthly variations in LERO's make-up are both-Ldetails with which Licensing Boards should not have to. contend, Louisiana Power & Licht Co. (Waterford Steam Elec. Station, Unit 3), ALAB-732, 17 NRC 1076, 1107 (1983), and facts about the current state of emergency preparedness more appropriately left to FEMA's and the NRC Staff's continuing oversight, id at 1103-04..
Indeed, a serious shortage of manpower would be re-vealed by the FEMA graded exercise.
As the record reflects, LERIO would investigate any apparent staffing problems and take corrective action if LERO's j
viability were threatened.
- See, e.a., Tr. 11,421, 11,427, 11,451 (Daverio).
Moreover, LILCO is fully aware of its duty to report material new information to the Board.
But the i
newapaper clippings cited by the
..tervenors do not rise to that level.
1 1/
The Affidavit is being executed today on Long Island; exe-cuted copies will be served as soon as we receive and copy it.
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i 3-In short, the Intervenors' requests are unwarranted.
Their December 5 Submission should be denied.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY BY mes N. Christman Hunton & Willians P.O. Box 1535 707 East Main Street Richmond, VA 23212 DATED:
December 10, 1984 l
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'i LILCO, Dactmbar 10, 1984 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board LIn-thel Matter of
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)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-327 OL-3
)
(Emergency Planning (Shoreham Nuclear Power Station, )
Proceeding)
Unit 1)
)
AFFIDAVIT OF JOHN A. WEISMANTLE My name is John A. Weismantle.
I am the Manager of LERIO.
My professional qualifications have already been en-tered into the record of this proceeding (Tab 20 following page 4
4068 of the hearing transcript).
This affidavit is made'in re-sponse to the "Suffolk County and State of New York Submission Pursuant to McGuire Decision" of December 5, 1984.
1.
It-is true that some LERO members resigned following the strike of last summer.
It is also true, however, that some of them subsequently rejoined LERO, and that others who'were not formerly members have joined.
(
2.
The result-is that, as of the morning of December 6, 1984, a' total of'2,110 LILCO employees were members of LERO.
.Our goal is to have 1,750 LERO members.
Thus, we have a margin of 360 above our goal.
a
, 3.
'The 1,750-member goal includes the overstaffing
=
that LILCO witnesses testified about during the hearings, for example, at'pages 28-30 of LILCO's prefiled written testimony on the training issues, located after page 11,140 of the hear-ing transcript.
As that testimony shows, when we spoke of maintaining LERO staffing at 150%, we were talking about jobs that are needed only during evacuations, such as bus drivers and traffic guides.
For these jobs, 100% staffing is the total number of bus drivers (for example) needed to provide a full i
tan-mile response; the extra 50% gives us assurance that the needed 100% will be available at any given time.
(Administrative support at the staging areas is staffed at 140%, as our testimony stated.)
For LERO jobs that might have to be performed for a longer period than an evacuation would take, such as personnel at the EOC, staffing has been planned 4
to support two 12-hour shifts plus a third, reserve shift.
4.
Chairman Catacosinos's statement about LILCO's ob-i-
jective of building up the LERO roster 30%, as Attachment B to the Intervenors' December 5 Submission indicatos, refers to 30%
in' excess of the goal of 1,750 referred to above.
For jobs needed only during an evacuation, this means 30% over and above the 150%, for a to*al of 195% (1.3 x 1.5 = 1.95).
5.
Two other categories of people, not included in the t
2,110, have volunteered for LERO and are considered "back-up" LERO workers.
They are the following:
. (a) about 175 retired LILCO employees and (b) over 100 outside bus company bus drivers.
6.
As of December 6, 1984, only 104 of the 2,110 LERO members livsd inside the ten-mile plume exposure pathway EPZ.
7.
'; raining for all LERO volunteers, including the "back-ups," is underway.
LILCO expects that classroom training for everyone will be completed by January 31, 1984.
John A. Weismantle Subscribed and sworn to before me this day of 1984.
My commission expires:
Notary Public e
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LILCO, D c1mb2r 10, 1984 CERTIFICATE OF SERVICE f
In--the Matter of LONG ISLAND LIGHTING COMPANY (Shorehan Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 c
I.hereby certify that copies of LILCO'S ANSWER TO SUFFOLK COUNTY AND STATE OF NEW YORK SUBMISSION PURSUANT TO MCGUIRE DECISION were served this date upon the following by first-class mail, postage prepaid or, as indicated by an aster-isk, 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 Sofety and Licensing i
Board Board Panel i.
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 naad Commission (to mailroom)
East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.
Bethesda, MD 20814 w-
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Donna Duer, Esq.*
Stewart M. Glass, Esq.*
Attorney Regional Counsel 1
Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U. S. Nuclear Regulatory 26 Federal Plaza, Room 1349 1
Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Highway Stephen B. Latham, Esq.*
Bethesda, MD 20814 Twomey, Latham & Shea 33 West Second Street Fabian G. Palomino, Esq.*
P.O. Box 398 Special Counsel to the Riverhead, New York 11901 4
Governor Executive Chamber Ralph Shapiro, Esq.*
Room 229 Cammer & Shapiro, P.C.
State Capitol 9 East 40th Street Albany, New York 12224 New York, New Ycrk 10016 Herbert H. Brown, Esq.*
James Dougherty, Esq.
Lawrence Coe Lanpher, Esq.
3045 Porter Street Christopher McMurray, Esq.
Washington, D.C.
20008 Kirkpatrick & Lockhart 8th Floor Jonathan D.
Feinberg, Esq.
i 1900 M Street, N.W.
New York State Department of Washington, D.C.
20036 Public. Service, Staff Counsel Three Rockefeller Plaza MHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue l
Suite K Spence W. Perry, Esq.
San Jose, California 95125 Associate General Counsel Federal Emergency Management Mr. Jay Dunkleberger Agency i
New York State Energy 500 C Street, S.W.
Office Room 840 Agency Building 2 Washington, D.C.
20472 Empire State Plaza Albany, New York 12223 Ms. Nora Bredes Executive Coordinator Shoreham Opponents' Coalition 4
195 East Main Street i
Smithtown, New York 11787 I
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. Gerald C. Crotty,'Esq.
Martin Bradley Ashare, Esq.
Counsel to the Governor Suffolk County Attorney Executive Chamber H. Lee Dennison Building State Capitol Veterans Memorial Highway Albany, New York 12224 Hauppauge, New York 11788 FA b Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:
December 10, 1984
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