ML20151G605
| ML20151G605 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/18/1988 |
| From: | Weismantle J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20151G594 | List: |
| References | |
| OL, NUDOCS 8807290035 | |
| Download: ML20151G605 (4) | |
Text
.
LILCO, July 18,1988 s
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
1 Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
U' nit 1)
)
AFFIDAVIT OF JOHN A. WEISMANTLE John A. Weismantle, being duly sworn, deposes and says as follows:
1.
My name is John A. Weismantle. My business address is 175 East Old Coun-try Road, Hicksville, New York. My position is Vice President - Research and Devel-opment and Corporate Studies for Long Island Lighting Company. I have been involved with offsite emergency planning for the Shoreham Nucl(
Jower Station since 1982 and with the functioning of LILCO's Local Emergency Response Implementing Organi-zation, or LERIO, since its inception in 1983, and was the original Manager of LERIO.
LERIO is the organization responsible for developing and implementing the Offsite Ra-diological Emergency Response Plan for Shoreham.
2.
I make this affidavit in order to summarize the results of an inquiry under-taken by LILCO, at the direction and with the assistance of counsel, beginning almost immediately upon receipt of Intervenors' June 28 pleading asserting that LILCO had ob-tained a complete copy of the Suffolk County Emergency Operations Plan (SCEOP) via a LILCO employee, Norman Kelly, outside of formal discovery processes in this pro-ceeding, in either late 1985 or early 1986.
l 8807290035 880721 PDR ADOCK 05000322 O
t 3.
Mr. Kelly was first shown a copy of the SCEOP and of Intervenors' June 28 pleading on June 29, and was asked to identify the document if he could and to cast light on the remaining allegations in the June 28 pleading. He testified last Thursday, July 14, as to matters within his knowledge. He was not in a position, because of the limited nature of his :*esponsibilities at LILCO, to describe either the entire range of LILCO's emergency preparedness knowledge or of LILCO's inquiry concerning the SCEOP.
Mr. Kelly administers basic LERO training, and also updates an annual farmstand survey for the 50-mile ingestion pathway EPZ and oversees the EPZ stren maintenance program. However, he is not involved in planning or decision-making in LERIO c'id has never been a witness in this proceeding.
4.
When the limitations on Mr. Kelly's knowledge became apparent, LILCO's inquiry was broadened to include the following questions:
A.
Was the composite Suffolk County Emergency Operations Plan as re-ceived in May 1988 among the documents held anywhere within LERIO prior to late May 19887 B.
Did anyone in LERIO now or in the 1985-86 period, who now occupies or then occupied a position with actual or apparent author-ity to instruct Norman Kelly to attempt to obtain the SCEOP, ever ask him to do so?
C.
If there is no copy of the composite Suffolk County Emergency Op-erations Plan in LERIO files, is there one anywhere else among LILCO files?
D.
Could there have been reasons other than the Shoreham case, involving parts of LILCO independent of LERIO, for inquiry into the j
existence and nature of Suffolk County emergency plans?
l E.
If so, does anyone in such other parts of LILCO recall having re-quested Norman Kelly to obtain Suffolk County emergency planning documents?
l S.
These inquiries produced the following answers:
1 A.
No. A complete search of LERIO records predating late May 1988 failed to disclose any trace of the composite SCEOP. The composite document was not in LERIO files before late May 1988. The frag-ments of it which LERIO possessed before May 1988 did not include the entire SCEOP, and did not go in fact beyond the fragments pro-vided voluntarily by LILCO counsel in a letter from Mr. Sisk to Mr.
Lanpher dated July 9.
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' s B.
No. No one now in authority in LERIO, or in LERIO in 1985-86, recalls having asked Mr. Kelly in the 1985-86 period to attempt to obtain a copy of. the Suffolk County Emergency Operations Plan by name or description. The persons inquired of included the following present LILCO employees:
John Weismantle, Charles Daverio, Douglas Crocker. It included the following former LILCO employees and consultants, who came to Long Island on July 7 for a face-to-face meeting on the matter: Elaine Robinson, William Renz. It in-cluded the,following LILCO consultants:
Brant Aidikoff, Dennis Behr. No one now or then in a position to '. lave initiated the request to Mr. Kelly was omitted. None of the persons interrogated can recall having requested Mr. Kelly to make the cequest for the SCEOP in 1985-86, or at any other time. Questions were specifically asked as to whether there had been an inquiry in connection with the February 1986 offsite emergency preparedness exercise. The an-swer was in the nega'.lve.
Mr. Aldikoff recalls having asked Mr. Kelly in 1987 to try to obtain a County organization chart and (as indicated in Mr. Kelly's testimony on July 14) Mr. Kelly obtained the County's Emergency Directory.
C.
No. No copies of the Suffolk County Emergency Operations Plan have been located anywhere else in LILCO's files.
D.
Yes. There were two other projects independent of Shoreham which involved attention to emergency preparedness in the 1985-86 time frame. The first was a task force on hurricane preparedness assem-bled af ter Hurricane Gloria in October 1985. The second was emer-gency preparedness for a liquefied natural gas (LNG) facility owned by LILCO in Holtsville. These projects were ongoing in late 1985 and early 1986.
They were directed by personnel elsewhere in LILCO, though some present and former LERIO personnel, primarily Ms. Robinson, were consu"ed on them. Records of them were and are kept separately from LERIO records.
E.
No. Inquiries of key personnel involved in the Hurricane Glcria and Holtsville projects and searches of the projects' records have been made since June 28. No one recalls making the request at issue; no copy of the SCEOP or any of its fragments has been located in the records of either of these projects. Ms. Robinson recalls having re-quested copies of the emergency plans for the towns of Islip and Brookhaven in connection with the Holtsville project; she has no I
recollection of having ever asked for or received the SCEOP er other documents from Suffolk County.
6.
I had never seen the composite SCEOP before late May 1988. Though I was aware of the existence of documents which have turned out to be fragments of it, I had no knowledge before May 1988 that they fit together into a composite whole. The identity of whoever (if anyone) requested Mr. Kelly to attempt to obtain the SCEOP in l
t
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['OL K! ii.7 ats C 1985-86 or at any other time has not been disclosed by a review of all knowledgeable persons who could be interviewed. Nor could the recipient of the EOkibt bb tained. It does not exist in any LILCO files in any area where it might. logically be 10-00CXLi m A i 4ViCI.
cated.
BRANLW
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. bvcM fin A. Weismantle Subscribed and sworn before me this M day of July,1988.
My commission expires:
Eol-dD 1990 CLLLECc $. O k [ C OLY L
No'tary Public LAURA M. Omocco 30seNy lleuritsk apes 90 l
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