ML20214G446
| ML20214G446 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/18/1987 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3520 OL-3, NUDOCS 8705270069 | |
| Download: ML20214G446 (6) | |
Text
'L2LCO,~Moy 18, 1987 gggg[)l "I'
00CKETED USinc UNITED STATES OF AMERICA 17 MAY 21 P6:11 NUCLEAR REGULATORY COMMISSION GFFICE Cr R.w its t.
Before The Atomic Safety and Licensing Board 00CKti1Na e.. c.wici, SH A NC't In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
.'(Shoreham Nuclear Power-Station,
)
Unit 1)
)
MOTION TO MODIFY TESTIMONY In written testimony on the suitability of reception cen-
^
ters, LILCO submitted testimony on the monitoring capacities of other relocation centers in New York State based upon contacts made~with utility and county personnel.
The Intervenors-sought-to' compel disclosure ~ of the names of the individuals who provided this informa tion.
LILCO objected, fearing that disclosure would subject these individuals to intimidation and harassment and in-terfere with LILCO's business relationships with these counties and utilities.
While acknowledging the need to protect these individuals from potential intimidation or harassment, the Board granted the Intervenors' motion to compel, contingent upon an appropriate protective order being submitted by LILCO that would safeguard these individuals from such intimidation or harassment.
LILCO submitted a protective order which it believed protected the in-terests of all parties and individuals concerned.
The protective 8705270069 870518 PDR ADOCK 05000322'
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PDR a
I order would have required LILCO to. provide the Intervenors with a general description of the individuals who provided LILCO with the informa tion.
In addition, LILCO provided the Board, under seal, a list of the individuals and their positions with the utility or county they worked for.
On May 15, 1987 the Board rejected LILCO's protective order and denied LILCO's request to refer the issue to the Appeal Board.
Having no other way to avoid the dangers it saw in dis-closure of the names, LILCO asked to modify its testimony so as to withdraw that portion of its testimony containing the informa-tion supplied by the county and utility personnel.
The testimony in question can be found at page 12 of LILCO's prefiled written testimony of Charles A.
Daverio et al. on the suitability of reception centers dated March 30, 1987.
It reads as follows:
16.
O.
What are the monitoring capacities (in terms of percent of EPZ population) of relocation centers for some nuclear plants other than Shoreham?
A.
[Daverio]
Based on contacts made by my staff with county and utility personnel at several sites, the following table was developed:
4 Percent of Population EPZ Monitored County Utility Population in 12 Hours 1.
Westchester NYPA/ Con Ed 125,000 58%
2.
Rockland NYPA/ Con Ed 80,000 4%
3.
Orange NYPA/ Con Ed 20,000 100%
4.
Monroe RG&E 30,000 100%
5.
Wayne RG&E 23,000 50%
6.
Oswego NYPA/Niagra 43,000 8%
Mohawk Af ter this informa tion was gathered, my staff reviewed State and county plans and FEMA assessment reports to see if additional data were available.
This review indicated that these publicly available documents do not provide enough information to determine moni-toring capabilities.
LILCO now asks to modify the above testimony by submitting the following testimony in its place:
16.
Q.
What are the monitoring capabilities of relocation centers for some nuclear plants other than Shoreham?
A.
(Daverio]
My staff reviewed State and county plans and FEMA assessment reports to assess the monitoring capabilities of relocation centers at other nuclear plants.
This review i.dicated that these publicly available documents do not provide enough information to deter-mine monitoring capabilities.
It is difficult or impossible to learn the monitoring capabilities of various coun-ty response organiza tions without di-rectly contacting their personnel.
LILCO requests that the Board permit LILCO to file the above modified testimony in substitution for its original testimony on the monitoring capabilities of other relocation centers, since the modified testimony eliminates reliance on the data that were the subject of the Intervenors' motion to compel.
O i
Respectfully submitted, en.OJ James N. Christman Mary Jo Leugers
!!unton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:
May 18, 1987
_4
i LILCO,'May 18, 1987
- g.
00LKETED UNC CERTIFICATT OF SERVICE OFFILf. M n dr i An '
00CMLimG & SERWCL BRANCH In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of MOTION TO MODIFY TESTIMONY were served this date upon the following by telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.
Morton B. Margulies, Chairman **
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board. Panel U.S. Nuclear Regulatory Commission Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 East-West Towers,'Rm. 407 4350 East-West Hwy.
Atomic Safety and Licensing Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R.
Kline **
Washington, D.C.
20555
. Atomic Safety and Licensing Board Richard G. Bachmann, Esq. **
U.S. Nuclear Regulatory Commission' George E. Johnson, Esq.
East-West Towers, Rm. 427 U.S. Nuclear Regulatory Commission 4350 East-West Hwy.
7735 Old Georgetown Road Bethesda, MD 20814 (to mailroom)
Bethesda, MD 20814 Mr. Frederick J. Shon **
Atomic Safety and Licensing-Herbert H. Brown, Esq. **
Board Lawrence Coe Lanpher, Esq.
U.S. Nuclear Regulatory Commission Karla J. Letsche, Esq.
East-West Towers, Rm. 430 Kirkpatrick & Lockhart 4350 East-West Hwy.
South Lobby - 9th Floor Bethesda, MD 20814 1800 M Street, N.W.
Washington, D.C.
20036-5891 Secretary of the Commission Attention Docketing and Service Fabian G. Palomino, Esq.
Section Richard J.
Zahnleuter, Esq.
U.S. Nuclear Regulatory Commission Special Counsel to the Governor 1717 H Street, N.W.
Executive Chamber Washington, D.C.
20555 Room 229 State Capitol Albany, New York 12224
s: -
t:
~
Mary-Gundrum, Esq.
Jona than D.
Feinberg, Esq -
Assistant Attorney General New York State. Department of~
120 Broadway-Public Service, Staff. Counsel Third Floor,' Room 3-116.
Three Rockefeller. Plaza-New York, New York 10271 Albany, New York 12223 Spence W.' Perry, Esq.
Ms. Nora.Bredes William ~R.
Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W.,
Room 840 Smithtown, New York 11787 Washington, D.C.
20472 Gerald C. Crotty, Esq.
Mr. Jay Dunkleberger-Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq.
Stephen B. La tham, Esq.
Eugene-R. Kelly, Esq.
Twomey, Latham & Shea suf folk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298-Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 ames N. Chfistman Hunton & Williams 707 East Main Street P.O. Box 1535 R chmond, Virginia 23212 DATED:
May 18, 1987