ML20215D617
| ML20215D617 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/11/1987 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3742 OL-3, NUDOCS 8706190081 | |
| Download: ML20215D617 (13) | |
Text
.
a
- g ry'"!;y r 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 JUN l6 P3 :19 I
Before the Atomic Safety and Licensing Board CFrn.
c DOCE W..i M u up.
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
LILCO'S MOTION TO SUBSTITUTE WITNESSES AND REQUEST FOR EXPEDITED TREATMENT l
LILCO hereby moves for leave to replace one of its witnesses, Charles A.
Daverio, with witnesses Douglas M. Crocker and Diane P. Dreikorn.I!
Mr. Crocker and/or Ms. Dreikorn would spansor each of the answers presently sponsored by Mr.
Daverio in the " Written Testimony of Charles A. Daverio, Dale E. Donaldson, Edward B.
Lieberman, Roger E. Linnemann, Michael K. Lindell, Dennis S. Mileti, and Richard J.
Watts on the Suitability of Reception Centers," dated March 30,1987. In addition, LILCO asks that Mr. Watts, who is already a LILCO witness, be added as a replacement sponsor for Mr. Daverio on some questions. LILCO does not ask to change the sub-stance of the testimony, only the names of the witnesses sponsoring it.
The reason for this change is that Mr. Daverio broke his leg in a f all on June 3, 1987. He has not yet returned to work and will be confined to a wheelchair for several weeks. Moreover, his doctor does not yet know whether surgery will be necessary. In these circumstances, Mr. Daverlo will not be able to spend the time needed to prepare to testify in this proceeding, and he may be physically unable to testify.
1/
A copy of the professional qualifications of Mr.'Crocker and Ms. Dreikorn are l
l appended hereto as Attachments A and B respectively. Mr. Crocker's professional qual-ifications are current through May 1987. Ms. Dreikorn's are current through January 1
1987. In February, she entered the employ of LILCO. Her responsibilities are the same as they were when she worked for Impell Corporation.
b
.8706190081 870611 PDR ADOCK 05000322 G
PDR v
.e.
4 Accordingly, LILCO asks that Mr. Crocker, Ms. Dreikorn, and Mr. Watts be per-mitted to testify in Mr. Daverio's stead. Three witnesses are necessary because no one person, except Mr. Daverio, has Mr. Daverio's length and depth of experience with the j
LILCO offsite emergency plan.
I The only changes to the March 30 testimony required will be to Answer 1, in j
which the witnesses identify themselves, and to the name "Daverio" wherever it ap-pears at the beginning of an answer. Attachment C to this motion shows the answers sponsored by Mr. Daverio and the witness or witnesses LILCO seeks to substitute for him in each case. For everyone's convenience, LILCO will serve on the Board and par-ties by the end of next week a marked-up copy of the March 30 testimony showing the changes that would result from replacing Mr. Daverio with Mr. Crocker, Ms. Dreikorn, and Mr. Watts.
Because it is only the witnesses and not the testimony that LILCO seeks to change, Intervenors will not be prejudiced by the proposed substitution. On June 9, 1987, LILCO offered to counsel for Suffolk County to make both Mr. Crocker and Ms. Dreikorn available for depositions limited to questions about their background and qualifications to sponsor the testimony. Intervenors turned this offer down, insisting instead on being allowed to ask questions going to the substance of the preflied testimo-ny. Because the substance of LILCO's testimony will not change if Mr. Crocker and Ms. Dreikorn are substituted for Mr. Daverio, there is no justification for such deposi-tions at this time. Intervenors have already explored in great detail the substance and bases for LILCO's positions in the depositions of Mr. Daverio and the other LILCO wit-nesses. Moreover, Intervenors already have before them LILCO's written testimony.
The only purpose served by deposing the new witnesses on the substance of the written testimony would be to give the Intervenors a risk-free rehearsal of their cross-examination shortly before the hearing. This is not an appropriate function of depositions and should not be permitted here.
i
4 ..
In light of the short time before hearing, and the possibility that two short depo-sitions on the new witnesses' qualifications may be required in that time, LILCO re-quests expedited treatment of this motion.
Respectfully submitted, l
-W James N. Christman Stephen W. Miller Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212
- DATED: June 11,1987 I
i j
1
1 Attachment A I
hy 1987 C10CKER, b0t'GLAg He MANACER, NUCLEAR EMERCENCY PREPAREDFEg8 N7CLgAR CPERATIONg 3CFFot? Dr.FARIMENT
{
j
_ EDUCATION i
Stevens Institute of Technology - 5.I. with Honor in Hochanical Engineering 1972 -
8 tate t)niversity of itew York at Itony Irook. h.8. in Marine Invironmental science 1978 Stone 6 Webster Radiologieel Safety Course Medical Aspects of Radiological Emergencies Course, New York Academy of Medicine, 1983 stone 6 Webster interaction Xanagement Course Earvard School of Public Health " Planning for Nuclear Emergencies," 1983 Harvard 8thool of Public health, " Advanced Flanning for Nuclear Emergencima, 1986 JIPttIENCE Sm00$Y Mr. Crocker to presently Nuclear Emergency Freparedness Hanager responsible for the SNPS Oneite and Offeite (lit 0) Emergency Preparedness Program.
This consiste of developing and maintaining facilitise. plans, procedures, training, and drill programs to satisfy NRC and TEMA requiremente in support of the gNPS licensing effort.
He presently directo a staff of 25 LILCO and consultant personnel.
During the period March 1983 to January 1986, Mr. Crocker was Onsite amargency Preparednase Supervisor responsible for all onsite planning activities including the onsite portion of the 1986 NRC observed axercise.
Until February,1985 Mr. Crocker was Project Engineer responsible for all Stone & Wabeter Engineering Corp. - N.Y. amargency planning prefects.
In this capacity, he has directed a staff of forty-five engineers and'plannere in the execution of up to five simultaneous projects for utility clients.
These projects represent annual man-hour budgets of 90.000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> with individual total project budgere of 115.C00 man-hours.
Hr. Crocker has been responsible for propering emergency plans, procedures, training programs, exercies scenarios, and other emergency planning activities.
He has been actively involved in ASL5 li:ensing hearings en acergency planning and has percicipated'in many practice and cbeerved enargency plan exercises, l
Mr. Crocker joined Stone & Webster Engineering Corporation (S'aC in May 1976 as an Engineer in the Environmental Engineerir. 01 vision. *erking in ths Environmental Impact Analysis Group, his activittee have included the mathematical modeling of cooling tower visible plumes. coastel e*orm surge, and vava effects on shoreline intake structures. He has sleo had experience
-M with the podeling of thermal discharges from power plants 4.nd with the collection and analysis of hydrothermal data. His past assignments include circulating water system performance tests at Shoreham Nuclear Power Station and the preparation of industrial energy survey reports for the petroleum refining and elefins industry. At shoreham, Mr. Crocker was roepensibis for the collootton and'analyets of hydraulie transient data. The petroleum refiting and elefine industry survey reports were prepared se part of a feasibility study of the conversion of process heaters from high form value fuele to coal.
Prior to joinns 5WgC Mr. Crocker worked as a Easearch Assistant at the Marine Science Bassarch Center at the 8 tate University of New York at Stony Brook, collecting and analysing oceanographic data during h'.s graduate study fres 1974 to 1976.
From 1972 to 1973, he worked as an Estimator for L.K. Coastuck and Co.. Inc.,
preparing' bids for electrical construction projects.
PtitLICATION5 4
8-
" Development and Verification of a synthetic Northeaster Model in Application to Coastal Flooding." Y.J. Tsai, D.M. Crocker T.J. Burda, and F.K. Chou, P.roceedings of Naticaal Systposius on Urban Stors Vater Management in Coastal Areas, 1980
" Intake Icreenws11 Surging Caused by Wave Dynamics," Y.J. Tsai, Y.C. Chang, and D. H. Crscher, Hydraulics in the Coastal Zone. 1977 "g35-129:
Cooling Tower Visible Plume Medal - User's Manual ' Y.J. Tsai and D.M. Crocker, stena & Webster Engineering Corp.. April 1977 "gNa128 - Intaka Burge Model = 1 ser's Manual," D.M. Crocker emd Y.C. Chang, Stena & Webster Engineering Corp.. August 1977 M
Stone & Webster Engineering Corporation's " Ten Best Papers As ard." 1980
{
\\
8
Attachment B 4
DIANE FAT.fl2 DEEIKORN 70 Eaton's Neck Road Northport, New York 11768 Telephone: 516/754-4162 EDUCATIONt Rochester Institute of Technology, Rochester, New York Major: Physics (Nuclear Medicine)
Degree Bachelor of Science Cum Laude. June 1976 State University of New York, Agricultural and Technical College Alfred, New York Major: Medical Lab Technology Degree App 1_ied Associate of Science, June 1974 ADDITIONAL TRAINING:
Health Physics & Radiation Protection - 5 weeks - (February-March 1985) - Oak Ridge Associated Universities, Oak Ridga TN
' Advanced Health Physics Topics (November 1984)
Oak Ridge Associated Universities, Oak Ridge, TN Biological Effects of lonizing Radiation (October 1985) - Harvard School of Public Health, Boston, MA Teletherapy Calibration (June 1984)
M.D.
Anderson Hospital.
Houston, TX Inspection Procedures (July 1982)
U.S.
Nuclear Regulatory Commission Medical Accelerator Course (April 1982) - New York State Health Department Radiation Accident Assessment (November 1981) - Federal Emergency Management Agency Licensing of Radioactive Material (September 1981) - U.S.
Nuclear Regulatory Commission
]
Medical Use of Radioisotopes (May 1981), U.S. Nuclear Regulatory Commission j
t WORK EXPERIENCE:
10/85-present Impe11 Corporation / Radiological Services 225 Broad Hollow Road Melville, New York 11747 Senior Engineer Duties:
Provide consulting services to the nuclear power industry, conduct training sessions in radiological emergency preparedness for on-site and off-site organizations, perform audits of nuclear power electric generating plant
.e radioactive material package and transport procedures and radioactiva waste handling to determine compliance with IOCFR and 49CFR, and perform audits of on-site and off-site emergency preparedness procedures to determine compliance with NUREG-0654.
In addition, currently developing a medical radiological physics consulting service for hospital and private practice nuclear medicine and diagnostic radiology programs.
2/81-10/85 New York State Health Department Bureau of Environmental Radiation Protection Albany, New York 12237 Principal Radiological Health Specialist (10/84-10/85) - Duties:
Responsible for the administration of the U.S. Nuclear Regulatory Commission (NRC)/New York State Department of Health (NYSDOH)
Agreement Program for licensing and compliance of radioactive materials use in medical and academic facilities, maintain compatibility between NRC regulations and NYSDOH Sanitary Code, coordinata response to radiological emergencies and incident investigations through five regional
- offices, and provide technical support for amargency exercises involving nucitar power reactors.
Associate Radiological Health Specialist (4/83-9/84)
Dutiest Reviewed and approved radioactive material license applications and amendment requests for limited and broad-scope programs, reviewed Investigational New Drug research protocols for completeness and coordinated review by Department's Radiological Health Advisory Committee members, reviewed proposed changes to NRC regulations and recommended Depar tment reaction, proposed changes to NYSJOB Sanitary Code to maintain compatibility with NRC regulations, provided assistance to regional personnel for inspection of complex licenses.
Senior Radiological Realth Specialist (2/81-4/83)
Duties:
Reviewed and recommended for approval radioactive materials k
license applications and amendments for medical and acadsmic facilities with Itnited-secpe
- programs, reviewed research j
protocols for investigational New Drug usage for completeness, j
l conducted inspections of limited-scope programs to assure
. compliance with NYSDOH Sanitary Code.
3/80-5/80 New York State Education Department Bureau of Health occupations Education j
Albany, New York 12230
)
Consultant - Designed curriculum guidelines for a nuclear medicine apprenticeship program.
9/77-2/81 Nuclear Medicine Technologist Various Medical Centers in Eew York State.
s
=
i l
D
3 i
PRorESSIONAL AFFILIATIONS: American Association of Physicist in Medicine, Upstate New York l
-Chapter Health Physics Society, Northeastern New York Chapter 4
Capitaland Society of Nuclear Medicine Yachnologists Conference of Radiation Control Program Directors l
l
' 1 J
i i
)
i l
1 6
e
s;<
.g Attachment C Sponsor (s)in place of Mr. Daverlo
Response
2 Crocker and Driekorn (at each place in that question where Mr. Daverio currently appears as a sponsor).
3 Crocker, Driekorn, and Watts 4
Crocker and Driekorn 5
Crocker, Driekorn, and Watts j
l 6
Crocker and Driekorn i
13 Crocker, Driekorn, and Watts
-14 Crocker and Driekorn l
15 Crocker, Driekorn, and Watts 16 Crocker, Driekorn, and Watts 29 Crocker and Driekorn 33 Crocker, Driekorn, and Watts 34 Crocker, Driekorn, and Watts
(
35 Crocker, Driekorn, and Watts l
36 Crocker l
37 Crocker, Daverio, and Watts 61 None (this question will be sponsored solely by Mr. Lieberman) 66 Driekorn 67 Driekorn 68 Driekorn 69 Crocker and Driekorn 70 Crocker and Driekorn l
74 Driekorn and Watts 76 Driekorn
'6-
. g.
ReSDonse '
Sponsor (s)in place of Mr. Daverio 77 Driekorn
'82 Driekorn 85 Driekorn 86 Driekorn 92 Driekorn and Watts 94-Crocker and Driekorn 95
' Driekorn l
96-Driekorn 97-Driekorn and Watts
~
99-Crocker, Driekorn, and Watts '
100 Driekorn and Watts 101 Crocker and Driekorn 102 Driekorn and Watts 103 Crocker 104-Crocker 105 Crocker 106 Crocker 107 Crocker, Driekorn, and Watts 108 Driekorn l
109 Driekorn and Watts 110 Crocker and Driekorn 111' Crocker and Driekorn 112 Crocker 113 Driekorn 114 Driekorn
R
.o 4
Response
Syonsor(s) in place of Mr. Daverio j
115 Crocker and Driekorn 116-Crocker and Driekorn 117 Crocker, Driekorn and Watts 118 Driekorn and Watts 119 Driekorn 121
. Crocker and Driekorn 123 Crocker, Driekorn, and Watts 124 Driekorn and Watts
'125 Crocker and Driekorn
-126 Crocker and Driekorn 127 Crocker
'128 Crocker and Driekorn
'129 Crocker and Driekorn 131 Driekorn 134 Crocker and Driekorn 135 Driekorn and Watts l
136 Crocker and Driekorn i
138 Driekorn 139 Crocker and Driekorn l
140 Crocker and Driekorn 141 Crocker and Driekorn 142 Crocker and Driekorn 143 Driekorn 144 Crocker and Driekorn 147 Crocker l
J
j LILCO, June 11,1987 T;[
'87 JUN 16 P3 :19 CERTIFICATE OF SERVICE CFE 00Ch e :t 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 LILCO'S MOTION TO SUBSTITUTE WITNESSES AND REQUEST FOR EXPEDITED TREATMENT were served this date upon the follow-ing 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 Board U.S. Nuclear Regulatory Commission 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 l
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 i
1717 H Street, N.W.
Executive Chamber Washington, D.C. 20555 Room 229 State Capitol i
Albany, New York 12224
i:
Mary Gundrum, Esq.
Jonathan 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 Chamoer Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq. **
Stephen B. Latham, Esq. **
Eugene R. Kelly, Esq.
Twomey, Latham & Shea Suffolk 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 S w&.k James N. Christman Stephen W. Miller Hunton & Williams 707 East Main Street P.O.. Box 1535 Richmond, Virginia 23212 DATED: June 11,1987
)