ML20197E013

Lilco Motion for Leave to File Corrections to Rebuttal Testimony.* Requests Leave to File Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Util Hosp Evacuation Time Estimates

ML20197E013
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/31/1988
From:	Sheffey R HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20197D973	List: ML20197D969 ML20197E013 ML20197E040
References
OL-3, NUDOCS 8806080053
Download: ML20197E013 (2)

Text

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.. . .9 LILCO, May 31,1988 -

UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION a.

Before the Atomic Safety and Licensing Board In the Matter of )

i

)

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, ) (Hospital Evacuation Time Unit 1) ) (Estimates)

LILCO'S MOTION FOR LEAVE TO FILE CORRECTIONS TO REBUTTAL TESTIMONY LILCO hereby moves for leave to file Corrections to Rebuttal Testimony of Edward B. Lieberman and Diane P. Dreikorn on the Remanded Issue of the Bases and Accuracy of LILCO's Hospital Evacuation Time Estimates. These Corrections address issues raised by New York State witness David T. Hartgen in his surre%ttal testimony 1

i and accompanying exhibits filed May 26,1988 ("Hartgen Surrebuttal Testimony"), and

! make certain other minor corrections in LILCO's Rebuttal Testimony.

j Specifically, Dr. Hartgen identified a "discrepancy" in the Output Tables at-tached to LILCO's Rebuttal Testimony. Hartgen's Surrebuttal Testimony at 6-9. Mr.

I Lieberman has confirmed that this "discrepancy" resulted from a minor error, or "bug",

j in KLD's recently developed computer model for calculating hospital evacuation time i

estimates (ETEs). The "bug" occurred between the second and third waves of evacuating vehicles, and has now been corrected. During the process of correcting this l "discrepancy," KLD identified certain additional minor errors and corrected them as i

well. Following this debugging, KLD re-ran the base case and the sensitivity analyses which were attached to LILCO's Rebuttal Testimony. Those corrected computer runs j are attached to the Corrections to Rebuttal Testimony as Tables IA,2A, 3A, 4A,6A, l and 11A.

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SBP188E T

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These corrections have not altered the methodology employed in the computer model, and have not significantly altered the results obtained.

LILCO's Corrections to its Rebuttal Testimony are timely, being filed on the sec-ond business day af ter Dr. Hartgen's Surrebuttal Testimony identifying the error was filed. These corrections are necessary to correct minor errors to the Rebuttal Testimo-ny filed on May 18, 1988, and would be necessary prior to placing the testimony in the record in any event. No additional analyses or new information is presented. The Cor-rections should be allowed in order to provide the Board with accurate and complete in-formation for consideration of the hospital ETE remand issue.

CONCLUSION For the foregoing reasons, LILCO respectfully requests that this Board grant leave to file Corrections to Rebuttal Testimony of Edward B. Lieberman and Diane P.

Dreikorn on the Romanded Issue of the Bases and Accuracy of LILCO's Hospital Evacua-tion Time Estimates.

Respectfully submitted, dwA.Mvu g K. Dennis Sisk Rita A. Sheffey Counsel for Long Island Lighting Company Hunton & Williams l 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 31,1988

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