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Category:INTERVENTION PETITIONS
MONTHYEARML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20081L4831991-06-21021 June 1991 Petitioner Amend & Suppl to Petitions to Intervene.* Petitions to Intervene & Requests for Hearings & File Joint Suppl to Petitions to Intervene,Including List of Contentions Amended.W/Certificate of Svc ML20082B4441991-06-21021 June 1991 Petitioner Amend & Suppl to Petitions to Intervene.* Amends Petition to Intervene & Requests for Hearings.Files Joint Suppl to Petitions to Intervene.W/Certificate of Svc ML20073A4921991-04-0808 April 1991 Scientists & Engineers for Secure Energy,Inc Amend to Request for Hearing & Petition to Intervene.* Petitioner Renews Request for Remedies Noted in Original Petition ML20073A4241991-04-0808 April 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* Petitioner Renews Request for Remedies Noted in Original Petition ML20066H1961991-02-14014 February 1991 Petitioners Joint Response to Lilco Motion to Dismiss as Moot Petitioners Request for Stay of LBP-91-01.* Urges Board to Deny Lilco Motion to Dismiss & Grant Petitioners Motion to for Stay.W/Certificate of Svc ML20066H0311991-02-11011 February 1991 Joint Supplemental Comments on Proposed NSHC Determination.* Urges Staff Not to Issue Final NSHC Determination. W/Certificate of Svc ML20066H2851991-02-11011 February 1991 Petitioners Joint Notice of Intent to Petition for Review & Request for Stay.* Petitioners Urge Commission to Stay Issuance of License for 15 Working Days After Fr Publication.W/Certificate of Svc ML20066G9331991-02-0707 February 1991 Lilco Opposition to Petitioners Appeal from LBP-91-1.* Petition Should Be Denied Due to Listed Reasons. W/Certificate of Svc ML20067C6971991-02-0606 February 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* W/Certificate of Svc ML20067C9421991-02-0606 February 1991 Scientist & Engineers for Secure Energy,Inc Amend to Request for Hearing & Petition to Intervene.* Amends Petition to Intervene by Providing Encl Affidavits ML20066G9001991-02-0505 February 1991 Lilco Motion to Dismiss as Moot Petitioners Request for Stay of LBP-91-1.* W/Certificate of Svc ML20067C3021991-02-0404 February 1991 Scientists & Engineers for Secure Energy,Inc Amend to Request for Hearing & Petition to Intervene.* ML20067C7781991-02-0404 February 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* Petition to Intervene in Proceeding Re Emergency Preparedness Amend ML20067C8231991-02-0404 February 1991 Scientists & Engineers for Secure Energy,Inc. Amend to Request for Hearing & Petition to Intervene.* Petitioner Renews Request in Original Petition,Contending That Injuries Will Be Remedied by Decision Granting Relief Sought ML20067C8351991-02-0404 February 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* Requests That Action Be Set Down for Hearing After Prehearing Conference & Appropriate Discovery ML20062H5951990-11-21021 November 1990 Reply of Mm Cuomo,Governor of State of Ny,As Friend of Commission in Opposition to Joint Petition for Reconsideration & to Comments of DOE & Ceq.* Certificate of Svc Encl ML20062C2861990-10-24024 October 1990 NRC Staff Response to Shoreman-Wading River Central School District & Scientists & Engineers for Secure Energy,Inc Petitions to Intervene & Requests for Hearing on Proposed possession-only License Amend.* W/Certificate of Svc ML20028H3021990-10-12012 October 1990 Comments of Long Island Power Authority in Response to Commission 901003 Order.* Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy, Inc Petitions Should Be Denied.W/Certificate of Svc ML20028H2981990-10-12012 October 1990 Lilco Opposition to Intervention Petitions & Request for Hearing on 900105 Request to Remove Operating Authority for Shoreham.* W/Certificate of Svc ML20062C0921990-05-21021 May 1990 NRC Staff Response to Petitions to Intervene & Requests for Hearing on Proposed Offsite Emergency Preparedness License Condition Amend,Filed by Scientists & Engineers for Secure Energy,Inc & by Shoreham-Wading....* W/Certificate of Svc ML20062C0861990-05-15015 May 1990 Lilco Opposition to Intervention Petitions & Requests for Hearing on Amend to Emergency Preparedness License Conditions.* W/Certificate of Svc ML20062C0851990-05-10010 May 1990 NRC Staff Response to Petitions to Intervene & Requests for Hearing on Proposed Amend to Licensee Physical Security Plan Filed by Scientists & Engineers for Secure Energy,Inc & by Shoreham-Wading River Central....* W/Certificate of Svc ML20062C0831990-05-0808 May 1990 NRC Staff Response to Petitions to Intervene & Requests for Hearing on Confirmatory Order,Filed by Scientists & Engineers,Inc & by Shoreham-Wading River Central School District.* Petitions Should Be Denied.W/Certificate of Svc ML20062C0711990-05-0303 May 1990 Lilco Opposition to Intervention Petitions & Requests for Hearing on Confirmatory Order & on Amend to Physical Security Plan.* Petitioners Will Not Suffer Injury in Fact & Petitions Should Be Denied.W/Certificate of Svc ML20062C0631990-04-30030 April 1990 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Application for New License Condition Negating Several Existing License Conditions.W/Certificate of Svc ML20062C0511990-04-30030 April 1990 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Application for New License Condition Negating Several Existing Conditions.W/Certificate of Svc ML20062C0411990-04-20020 April 1990 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Changes to Plant Physical Security Plan. Certificate of Svc Encl ML20062C0261990-04-20020 April 1990 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Application for Amend Changing Plant Physical Security Plan.W/Certificate of Svc ML20062C0121990-04-17017 April 1990 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re NRC 900329 Confirmatory Order Modifying License. W/Certificate of Svc ML20062B9881990-04-17017 April 1990 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Hearing.* Requests Order Vacating Confirmatory Order Pendente Lite & Consolidation of Petition W/Other Intervenors.W/Certificate of Svc ML20196F6891988-11-29029 November 1988 Amended Emergency Planning Contentions Re 880607-09 Shoreham Exercise.* ML20206C2071988-11-0808 November 1988 NRC Staff Response to Intervenors Proffered Contentions Re Emergency Planning Exercise Held on 880607-09.* Certificate of Svc Encl ML20205R5081988-11-0303 November 1988 Lilco Response to 1988 Exercise Contentions.* Intervenors 20 Exercise Contentions Should Not Be Admitted Due to Lack of Basis & Sepcificity.Supporting Documentation & Certificate of Svc Encl ML20205E0931988-10-24024 October 1988 Emergency Planning Contentions Relating to 880607-09 Shoreham Exercise.* Contentions Demonstrate,Exercise Results Again Reveal Fundamental Flaws in Lilco Plan & Exercise. Certificate of Svc Encl ML20151S0561988-08-0909 August 1988 Suffolk County,State of Ny & Town of Southampton Response to Lilco Renewed Opposition to Govts Proposed Contention on Emergency Medical Svcs for Contaminated Injured Individuals & Suggestion of Mootness.* Certificate of Svc Encl ML20151N5481988-07-28028 July 1988 Lilco Renewed Opposition to Intervenor Proposed Contention on Emergency Medical Svcs for Contaminated Injured Individuals & Suggestion of Mootness.* Moves Commission to Dismiss Intervenor Proposed Contention of 870225 ML20154B4811988-05-10010 May 1988 Govts Objections to Lilco First Set of Requests for Admissions Re Contentions 1-2,4-8 & 10 to Suffolk County & Ny State.* Certificate of Svc Encl.Related Correspondence ML20154B5941988-05-0202 May 1988 Govt Response to Lilco 880422 Request for Dismissal of Legal Authority Contentions.* ASLB Should Deny Lilco Request That Legal Authority Contentions Be Dismissed.W/Certificate of Svc ML20149D8021988-02-0505 February 1988 Govt Response to Staff & Lilco Objections to Emergency Planning Contention Re Lilco New Emergency Broadcast Proposal.* Govt Emergency Broadcast Proposal Should Be Admitted in Entirety.W/Certificate of Svc ML20148U5951988-01-27027 January 1988 NRC Staff Response to Proferred Intervenor Contention on Adequacy of Emergency Plan Provisions for Radio Transmission of Emergency Broadcast Sys Messages.* Contention Should Be Denied Due to Lack of Basis.Certificate of Svc Encl ML20147B9821988-01-12012 January 1988 Emergency Planning Contention Re Lilco New Emergency Broadcast Sys Proposal.* Certificate of Svc Encl ML20235R3921987-10-0505 October 1987 Response Supporting Lilco Motion for Summary Disposition of Contention 92.Applicant Entitled to Decision as Matter of Law & 870911 Motion Should Be Granted.Certificate of Svc Encl ML20215L0881987-05-0404 May 1987 Contention Ex 40 -- Calculation of Change in Total Population Dose as Result of Mobilization Delays.* Description & Results of Util Calculations & CA Daverio & Eb Liebermen Affidavits Encl.Certificate of Svc Encl ML20212K4421987-03-0202 March 1987 Emergency Planning Contentions Re 860213 Exercise.* ML20215B1421986-12-0909 December 1986 Revised Emergency Planning Contentions Re 860213 Exercise. Util Lack of Legal Authority & Govt Lack of Participation Discussed ML20214P4121986-11-24024 November 1986 Response to Util Submission of Revised Std Version of Intervenor 860801 Exercise Contentions.Lilco Submission Should Be Modified to Conform to ASLB 861003 Prehearing Conference Order.Certificate of Svc Encl ML20214J6391986-11-24024 November 1986 Response to Util Submission of Revised Std Version of Intervenors Exercise Contentions,Per Board 861113 Order. Submission Seriously Distorts Margulies Board 861003 Rulings & Must Be Rejected.Related Info Encl.W/Certificate of Svc ML20215N6371986-11-0303 November 1986 Response to Intervenor 861103 Pleading Re Objections to 861003 Prehearing Order Concerning Contentions 15,16 & 19 Re Emergency Plan Exercise.Ambiguity Re Unacceptable Contentions Should Be Resolved.Certificate of Svc Encl ML20212M7511986-08-25025 August 1986 Response Opposing Util & NRC 860815 Objections to 860801 Emergency Planning Contentions Re 860213 Exercise.Objections W/O Merit.Contentions Should Be Admitted as Drafted 1992-02-06
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20081L4831991-06-21021 June 1991 Petitioner Amend & Suppl to Petitions to Intervene.* Petitions to Intervene & Requests for Hearings & File Joint Suppl to Petitions to Intervene,Including List of Contentions Amended.W/Certificate of Svc ML20082B4441991-06-21021 June 1991 Petitioner Amend & Suppl to Petitions to Intervene.* Amends Petition to Intervene & Requests for Hearings.Files Joint Suppl to Petitions to Intervene.W/Certificate of Svc ML20073A4921991-04-0808 April 1991 Scientists & Engineers for Secure Energy,Inc Amend to Request for Hearing & Petition to Intervene.* Petitioner Renews Request for Remedies Noted in Original Petition ML20073A4241991-04-0808 April 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* Petitioner Renews Request for Remedies Noted in Original Petition ML20066H1961991-02-14014 February 1991 Petitioners Joint Response to Lilco Motion to Dismiss as Moot Petitioners Request for Stay of LBP-91-01.* Urges Board to Deny Lilco Motion to Dismiss & Grant Petitioners Motion to for Stay.W/Certificate of Svc ML20066H0311991-02-11011 February 1991 Joint Supplemental Comments on Proposed NSHC Determination.* Urges Staff Not to Issue Final NSHC Determination. W/Certificate of Svc ML20066H2851991-02-11011 February 1991 Petitioners Joint Notice of Intent to Petition for Review & Request for Stay.* Petitioners Urge Commission to Stay Issuance of License for 15 Working Days After Fr Publication.W/Certificate of Svc ML20066G9331991-02-0707 February 1991 Lilco Opposition to Petitioners Appeal from LBP-91-1.* Petition Should Be Denied Due to Listed Reasons. W/Certificate of Svc ML20067C6971991-02-0606 February 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* W/Certificate of Svc ML20067C9421991-02-0606 February 1991 Scientist & Engineers for Secure Energy,Inc Amend to Request for Hearing & Petition to Intervene.* Amends Petition to Intervene by Providing Encl Affidavits ML20066G9001991-02-0505 February 1991 Lilco Motion to Dismiss as Moot Petitioners Request for Stay of LBP-91-1.* W/Certificate of Svc ML20067C3021991-02-0404 February 1991 Scientists & Engineers for Secure Energy,Inc Amend to Request for Hearing & Petition to Intervene.* ML20067C7781991-02-0404 February 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* Petition to Intervene in Proceeding Re Emergency Preparedness Amend ML20067C8231991-02-0404 February 1991 Scientists & Engineers for Secure Energy,Inc. Amend to Request for Hearing & Petition to Intervene.* Petitioner Renews Request in Original Petition,Contending That Injuries Will Be Remedied by Decision Granting Relief Sought ML20067C8351991-02-0404 February 1991 Shoreham-Wading River Central School District Amend to Request for Hearing & Petition to Intervene.* Requests That Action Be Set Down for Hearing After Prehearing Conference & Appropriate Discovery ML20062H5951990-11-21021 November 1990 Reply of Mm Cuomo,Governor of State of Ny,As Friend of Commission in Opposition to Joint Petition for Reconsideration & to Comments of DOE & Ceq.* Certificate of Svc Encl ML20062C2861990-10-24024 October 1990 NRC Staff Response to Shoreman-Wading River Central School District & Scientists & Engineers for Secure Energy,Inc Petitions to Intervene & Requests for Hearing on Proposed possession-only License Amend.* W/Certificate of Svc ML20028H3021990-10-12012 October 1990 Comments of Long Island Power Authority in Response to Commission 901003 Order.* Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy, Inc Petitions Should Be Denied.W/Certificate of Svc ML20028H2981990-10-12012 October 1990 Lilco Opposition to Intervention Petitions & Request for Hearing on 900105 Request to Remove Operating Authority for Shoreham.* W/Certificate of Svc ML20062C0921990-05-21021 May 1990 NRC Staff Response to Petitions to Intervene & Requests for Hearing on Proposed Offsite Emergency Preparedness License Condition Amend,Filed by Scientists & Engineers for Secure Energy,Inc & by Shoreham-Wading....* W/Certificate of Svc ML20062C0861990-05-15015 May 1990 Lilco Opposition to Intervention Petitions & Requests for Hearing on Amend to Emergency Preparedness License Conditions.* W/Certificate of Svc ML20062C0851990-05-10010 May 1990 NRC Staff Response to Petitions to Intervene & Requests for Hearing on Proposed Amend to Licensee Physical Security Plan Filed by Scientists & Engineers for Secure Energy,Inc & by Shoreham-Wading River Central....* W/Certificate of Svc ML20062C0831990-05-0808 May 1990 NRC Staff Response to Petitions to Intervene & Requests for Hearing on Confirmatory Order,Filed by Scientists & Engineers,Inc & by Shoreham-Wading River Central School District.* Petitions Should Be Denied.W/Certificate of Svc ML20062C0711990-05-0303 May 1990 Lilco Opposition to Intervention Petitions & Requests for Hearing on Confirmatory Order & on Amend to Physical Security Plan.* Petitioners Will Not Suffer Injury in Fact & Petitions Should Be Denied.W/Certificate of Svc ML20062C0631990-04-30030 April 1990 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Application for New License Condition Negating Several Existing License Conditions.W/Certificate of Svc ML20062C0511990-04-30030 April 1990 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Application for New License Condition Negating Several Existing Conditions.W/Certificate of Svc ML20062C0411990-04-20020 April 1990 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Changes to Plant Physical Security Plan. Certificate of Svc Encl ML20062C0261990-04-20020 April 1990 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re Lilco Application for Amend Changing Plant Physical Security Plan.W/Certificate of Svc ML20062C0121990-04-17017 April 1990 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Hearing.* Requests Hearing Re NRC 900329 Confirmatory Order Modifying License. W/Certificate of Svc ML20062B9881990-04-17017 April 1990 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Hearing.* Requests Order Vacating Confirmatory Order Pendente Lite & Consolidation of Petition W/Other Intervenors.W/Certificate of Svc ML20196F6891988-11-29029 November 1988 Amended Emergency Planning Contentions Re 880607-09 Shoreham Exercise.* ML20206C2071988-11-0808 November 1988 NRC Staff Response to Intervenors Proffered Contentions Re Emergency Planning Exercise Held on 880607-09.* Certificate of Svc Encl ML20205R5081988-11-0303 November 1988 Lilco Response to 1988 Exercise Contentions.* Intervenors 20 Exercise Contentions Should Not Be Admitted Due to Lack of Basis & Sepcificity.Supporting Documentation & Certificate of Svc Encl ML20205E0931988-10-24024 October 1988 Emergency Planning Contentions Relating to 880607-09 Shoreham Exercise.* Contentions Demonstrate,Exercise Results Again Reveal Fundamental Flaws in Lilco Plan & Exercise. Certificate of Svc Encl ML20151S0561988-08-0909 August 1988 Suffolk County,State of Ny & Town of Southampton Response to Lilco Renewed Opposition to Govts Proposed Contention on Emergency Medical Svcs for Contaminated Injured Individuals & Suggestion of Mootness.* Certificate of Svc Encl ML20151N5481988-07-28028 July 1988 Lilco Renewed Opposition to Intervenor Proposed Contention on Emergency Medical Svcs for Contaminated Injured Individuals & Suggestion of Mootness.* Moves Commission to Dismiss Intervenor Proposed Contention of 870225 ML20154B4811988-05-10010 May 1988 Govts Objections to Lilco First Set of Requests for Admissions Re Contentions 1-2,4-8 & 10 to Suffolk County & Ny State.* Certificate of Svc Encl.Related Correspondence ML20154B5941988-05-0202 May 1988 Govt Response to Lilco 880422 Request for Dismissal of Legal Authority Contentions.* ASLB Should Deny Lilco Request That Legal Authority Contentions Be Dismissed.W/Certificate of Svc ML20149D8021988-02-0505 February 1988 Govt Response to Staff & Lilco Objections to Emergency Planning Contention Re Lilco New Emergency Broadcast Proposal.* Govt Emergency Broadcast Proposal Should Be Admitted in Entirety.W/Certificate of Svc ML20148U5951988-01-27027 January 1988 NRC Staff Response to Proferred Intervenor Contention on Adequacy of Emergency Plan Provisions for Radio Transmission of Emergency Broadcast Sys Messages.* Contention Should Be Denied Due to Lack of Basis.Certificate of Svc Encl ML20147B9821988-01-12012 January 1988 Emergency Planning Contention Re Lilco New Emergency Broadcast Sys Proposal.* Certificate of Svc Encl ML20235R3921987-10-0505 October 1987 Response Supporting Lilco Motion for Summary Disposition of Contention 92.Applicant Entitled to Decision as Matter of Law & 870911 Motion Should Be Granted.Certificate of Svc Encl ML20215L0881987-05-0404 May 1987 Contention Ex 40 -- Calculation of Change in Total Population Dose as Result of Mobilization Delays.* Description & Results of Util Calculations & CA Daverio & Eb Liebermen Affidavits Encl.Certificate of Svc Encl ML20212K4421987-03-0202 March 1987 Emergency Planning Contentions Re 860213 Exercise.* ML20215B1421986-12-0909 December 1986 Revised Emergency Planning Contentions Re 860213 Exercise. Util Lack of Legal Authority & Govt Lack of Participation Discussed ML20214P4121986-11-24024 November 1986 Response to Util Submission of Revised Std Version of Intervenor 860801 Exercise Contentions.Lilco Submission Should Be Modified to Conform to ASLB 861003 Prehearing Conference Order.Certificate of Svc Encl ML20214J6391986-11-24024 November 1986 Response to Util Submission of Revised Std Version of Intervenors Exercise Contentions,Per Board 861113 Order. Submission Seriously Distorts Margulies Board 861003 Rulings & Must Be Rejected.Related Info Encl.W/Certificate of Svc ML20215N6371986-11-0303 November 1986 Response to Intervenor 861103 Pleading Re Objections to 861003 Prehearing Order Concerning Contentions 15,16 & 19 Re Emergency Plan Exercise.Ambiguity Re Unacceptable Contentions Should Be Resolved.Certificate of Svc Encl ML20212M7511986-08-25025 August 1986 Response Opposing Util & NRC 860815 Objections to 860801 Emergency Planning Contentions Re 860213 Exercise.Objections W/O Merit.Contentions Should Be Admitted as Drafted 1992-02-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18
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F LILCO, May 4.1987 00L KE TEf' USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 HAY -8 A9 '44 Before the Atomic Safety and Licensing Board f0CkiEt >.' YR k BRANCH In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
CONTENTION EX 40 - CALCULATION OF CHANGE IN TOTAL POPULATION DOSE AS A RESULT OF MOBILIZATION DELAYS Pursuant to the Board's request, Tr. 2017-18 and 2022-28, LILCO has performed calculations to determine the change in total population dose resulting from the delay In the mobilization of Traffic Guides experienced during the February 13 Exercise. A description and the results of these calculations are attached, along with affidavits by
, Charles A. Daverio and Edward B. Lieberman. Basically, the calculations demonstrate that for the delays experienced during the Exercise, there is no significant change in total population dose.
! Respectfully submitted, i
Leb B. Zeug [/ \3 7
Hunton & Williams
- 707 East Main Street
-' P.O. Box 1535 Richmond, Virginia 23212
- DATED
- May 4,1987 s
8705120098 870504 PDR ADOCK 05000322 Q PDR-
c
' Calculation of Effect of Delay in the Mobilization of Traffic Guides on Total Man-Rem Received by EPZ Population Summary A calculation to determine the change in dose received by the EPZ population as a result of the 50-minute delay in the mobilization of certain Traffic Guides during the February 13 Exercise has revealed that the delay had no effect on total population dose.
This result is primarily due 'to two factors. First, the one-way flow treatment along a portion of Rocky Point Road and North Country Road was located on the very edge of or outside the plume, both before and af ter the wind shif t that occurred during the Ex-ercise. Thus, any delay in exiting the area serviced by the one-way. flow would have had almost no effect on total population dose. Second, a sensitivity study using the .
DYNEV model revealed that delays in the implementation of the one-way flow treat-ment for periods up to two hours af ter a recommendation to evacuate would not influ-ence evacuation times since the links downstream of the one-way section control the movement of traffic over that time frame. As a result, total population dose is insensi-tive to the types of mobilization delays experienced by the Traffic Guides during the Exercise.'
Discussion The calculation of total man-rem received by the EPZ population is made by as-
!sessing two factors: 1) population as a function of time, distance and direction from the Shoreham plant, and 2) dose rate from the plume, also as a function of time, dis-
] ' tance and direction from the Shoreham plant. This calculational approach is displayed in chart form in Attachment 1 to OPIP 3.10.2, Total Population Dose. As can be seen i-p from that chart, the dose to the EPZ population is evaluated on a zone-by-zone basis.
For each zone, the average population and dose rate (rem /hr) are multiplied on an i
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. hourly basis to produce dose values. A total man-rem dose for the EPZ is calculated by summing the hourly dose values to determine a total dose for each zone and then by summing those zone doses to produce a total EPZ dose.
In order to achieve a higher level of accuracy for these calculations, the OPIP 3.10.2 method was modified by dividing Zones F and K into five subzones each and by performing calculations at one-half hour intervals instead of one-hour intervals. The five subzones for Zones F and K are shown in Appendix A, Figures 14.1 and 19.1, respectively.
Dose Rate Determination The scenario for the February 13, 1986 Exercise included detailed maps and charts that provide radiation information on whole body and child thyroid dose rates as .
a function of distance and time throughout the duration of the release and over the en-tire field of the plume (Section 6.5 of the Scenario).
In order to use Tables 6.5.2 and 6.5.3 A-F of the Scenario, each zone and subzone was assigned a ristance from the plant and an isopleth. (An isopleth is a line of con-stant radiation concentration within a plume and is based on the dispersion characteris-tics of a release, given meteorology conditions and the point of plume origin.) Each isopleth is identified by a letter designation. For the downwind direction during the Ex-ercise, the following assignments were made:
r-w .
g Zone Distance Isopleths A- 1 mile C B 3 miles G
'C 2 miles I F1 2 miles E F2 4 miles G F3 6 miles I F4 7 miles I
- F5 6 miles outside isopleths G 5 miles G K1 8 miles H K2 7 miles I K3 10 miles I K4 8 miles H K5 8 miles I Q 10 miles I
, The Section 6.5 tables were then used to obtain the dose rates for each zone and subzone at half-hour intervals. - For calculational purposes, time zero was assigned to .
10,:45 with intervals running at each half hour (IA,11:15,11:45,12:15, . . .). The value for each half-hour segment was selected at the midpoint of the time interval. Thus, for the interval of 10:45 to 11:15,- the whole body and child thyroid dose rates for 11:00 were used; similarly, for the 11:15 to 11:45 interval, the values for 11:30 were selected.
Closed window, 4-foot measurements were used as the whole body dose rate.
-Dose rate values that were not included in the Section 6.5 tables were assumed to be at background levels and accordingly, were set at zero. Dose rates of less than one mR/hr were set at one mR/hr.
Population Distribution 4
To determine the population distribution within the EPZ as a function of time,.
Appendix A to the LILCO Transition Plan was used. Appendix E to Appendix A contains the results of computer simulations of evacuation traffic as a function of time and distance from the Shoreham plant. The Appendix E results provide details about evacuating vehicles as they proceed through the 2, 5 and 10-mile boundaries. The 4
- - . . ~ . . - , , _ . . - _ . . , . . _ . - - , , , , - . .
. reported values are cumulative (h, the 10-mile values include vehicles within the 2 and 5-mile areas) and account for traffic as it exits the EPZ in a westerly direction.
For example, if a vehicle begins its evacuation trip 7 miles to the east of the plant, it is-added to the total for the 5-mile zone if its passes within that zone as it travels in a westerly direction out of the EPZ. The data from Appendix A were converted into a percentage of population remaining inside each boundary for use in these calculations.
Case 12 of Appendix A is a simulation of a full 10-mile, controlled evacuation under normal weather conditions. In order to use this case to calculate the population in each zone as a function of time, the zones were assigned to the 2, 5 and 10-mile boundaries as follows:
Zones A-E 2 mile .
F-J 5 mile K-S 10 mile The initial population in each zone was then multiplied by the population percentage remaining within that 2, 5 or 10-mile boundary at given time intervals. As with the dose rate calculation, half-hour intervals were selected, centering on the same times as the dose rato determination.
Total Man-Rem Calculation The dose rate and population data were entered on a LOTUS Spreadsheet. Dose values were calculated as the product of the population times the dose rate divided by
- 2. -It was necessary to divide the result by two since dose rates from Section 6.5 of the Scenario are reported in rem per hour instead of rem per half hour. Zones outside of the plume were not included on the spreadsheet since the dose rates in these areas were zero.
_ .m . - _, _ . - _
7 The summation of the individual zone doses showed that given a controlled evac-uation and the Exercise release, the total thyroid dose was approximately 16,000 man-rem and the whole body dose was approximately 600 man-rem (Attachment 1).
a Calculation of-Dose Resulting from Delay in Implementation of One-Way Flow -
In order to calculate the change in population dose resulting from delays in im- ,
plementing the one-way flow treatment, it was necessary to perform dose calculations for the individual roadway links affected by the delays in the mobilization of Traffic Guides. Two DYNEV sensitivity runs were made for a normal weather, full ten-mile evacuation (Case 12). The first implemented one-way flow at one hour af ter the EBS
~
evacuation recommendation - a " controlled" evacuation; the second assumed imple-e mentation of the one-way flow at one hour and fif ty minutes. By analyzing the detailed .
computer output of the DYNEV model, it was possible to determine the total number of '
vehicles associated with each link as a function of time. This included those vehicles still at home, those awaiting access onto the link and those on the link itself. By as-suming 3 passengers per vehicle (see Appendix A, page III-35) and knowing the dose rate
! in the given area, it was possible to determine the change in dose received by the 4
evacuating population.
The potentially affected roadway links and associated zone, distance and isopleth are as follows:
Link Zone Distance Isopleth
- (2,102)N -- F5 6 miles outside plume
-(2,102)S F3,F4 G miles I (102,1)N F5 7 miles outside plume
-(102,1)S F4 7 miles I (1,35) KS 8 miles I (1,103) K5 8 miles I (103,79) Q 9 miles I 4
- , - - , . _ . - _ _ _ , - - - _ -, - _ , _ .- . - - - . . , ~ . _ - - - , - - --- --.
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, Links (2,102) and (102,1), which include the entire one-way flow treatment, were divided into north and south components. This was done to account for evacuees who would have entered these links from the south and whose evacuation travel would po-tentially have put them within the plume for some period of time, and for those from north of the links who were outside the plume. An analysis of the results obtained from the two sensitivity runs shows that the only significant variation in traffic flow relative to time of implementation of the one-way flow was on link (2,102) (Attachment 3). A dose calculation was done for this link similar to the one for the entire population (At-tachment 2). The results show that had Traffic Guides not been delayed in imple-menting the one-way flow treatment the doses to the persons using link (2,102) would have been 1.67 man-rem whole body and 62.6 man-rem thyroid. The doses resulting from a 50-minute delay were reduced to 1.58 man-rem whole body and 59.5 man-rem thyroid.
As can be seen from Attachment 3, the delay in impleir.entation of the one-way flow did not cause additional back up in the vicinity of link (2,102) during the second hour when the Traffic Guides were not present. A slight reduction in population with-in the area serviced by link (2,102) occurred more than two hours af ter the start of evacuation. This reduction was due to the following factors:
Delay in implementing one way flow on links (2,102) and (102.1) reduced the number of vehicles entering the downstream links (1,103) and (1,35) over the period of the delay (50 minutes).
This reduced inflow permitted traffic on links (1,103) and (1,35) to operate at densities below the Level of Service F for a longer period of time than was the case had the guides been on time.
Since capacity is reduced whenever density is at Level of Service F, the effect of lower density acts to in-crease capacity on links (1,103) and (1,35) relative to the case when the guides are on time.
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4-
- This increase in capacity allows the traffic on these downstream links to flush a little faster during the first two hours following an order to evacuate.
The net effect is to improve slightly the subsequent throughput on the feeder links (2,102) and (102,1).
Had the delay in implementing the one-way flow treatment exceeded I hour and 50 minutes following the order to evacuate, the population in the area serviced by the feeder links would have been serviced at slower flow rates af ter the initial two hours.
These slower flow rates are due to the associated lower capacities of the feeder links (one lane versus two lanes). These slower flow rates would also extend the evacuation time. Additional sensitivity studies conducted with DYNEV confirmed this fact. Spe-cifically, a long term loss of capacity on the feeder links would outweigh any short term benefit of slightly increased capacity on the downstream links. Thus, the longer .
implementation of the one-way flow treatment is delayed past one hour and 50 minutes, the longer the evacuation time.
Thus, in the period from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> af ter the order of evacuation when the plume reached the vicinity of the one-way flow, there were somewhat fewer evacuees remaining in their service areas when the guides are 50 minutes late, than in the case where the guides were on time, and the total dose received was slightly less than in a " controlled evacuation." When implementation of the one-way flow was de-layed by 50 minutes the dose saving was 0.08 man-rem whole body and 3.2 man-rem thyroid. This is obviously an insignificant amount compared to the 600 man-rem whole body and 16,000 man-rem thyroid received by the entire evacuating population.
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Attachment 3 VEHICLES REMAINING IN AREAS SERVICED BV INDICATED LINKS LINK (2,102) LINK (102.1) LINK (1,103) LINK (1,35) LINK (103,79)
ON ON ON ON TIME
- ON TIME DELAVED TIME OELAVED TIME DELAVED TIME DELAYED TIME DELAVED 0.00 2516i 2516 878 878 437 437 0 0 0 0 0:30 2306 2306 790 790 393 393 120 120 60 60 1:00 2188 2188 484 484 240 240 120 120 120 120 1:30 2188 2188 484 484 180 180 120 120 120 120 2:00 2052 2044 324 324 180 180 120 120 120 120 2:30 1680 1700 324 324 180 180 120 120 120 120 3:00 1302 1210 324 324 180 180 120 120 120 120 3:30 696 670 324 324 180 180 120 120 120 120 4:00 212 206 324 324 180 180 120 120 120 120 4:30 198 198 324 324 180 180 120 120 120 120 5:00 0 0 0 0 0 0 0 0 0 0
- Time 0:00 equals 20 minutes after order to evacuate.
On Time Traffic Guides presumed to arrive at time 0:40 Delayed Traffic Guides presumed to arrive at time 1:30.
LILCO, May 1, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
)
(Shoreham Nuclear Power Station, )
Unit 1) )
AFFIDAVIT OF EDWARD B. LIEBERMAN
- 1. My name is Edward B. Lieberman. My professional quali-fications have been admitted into evidence as part of LILCO Exer-cise Exhibit 1, entitled " Professional Qualifications of LILCO Witnesses on Exercise Contentions."
- 2. I have reviewed the attached document entitled, "Calcu-lation of Ef fect of Delay in the Mobiliza tion of Traf fic Guides on Total Man-Rem Received by EPZ Population." The portions of that document which involve the calculation of traffic movement and evacuation times were prepared at my direction and under my supervision. They are true and correct to the best of my knowl-edge and belief.
</rc wm Edward B. Lieberman Subscribed and sworn before me this . MTI day of W/' ,
1987. g My commission expires: 4U4Nd6 /9I9/
/
hm$ No. 52-4742519 yg Ntu:2ry f) G Pub 1ic mf QuellAedin Sunset County Comunission Egime Memh 341 ( /
E LILCO, May 1, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
)
(Shoreham Nuclear Power Station, )
Unit 1) )
AFFIDAVIT OF CHARLES A DAVERIO
- 1. My name is Charles A. Daverio. My professional qualifi-cations have been admitted into evidence as part of LILCO Exer-cise Exhibit 1, entitled " Professional Qualifications of LILCO -
Witnesses on Exercise Contentions."
- 2. I have reviewed the attached document entitled, "Calcu-lation of Ef fect of Delay in the Mobilization of Traf fic Guides on Total Man-Rem Received by EPZ Population." The portions of that document which involve the calculation of total population doses were prepared at my direction and under my supervision.
They are true and correct to the best of my knowledge and belief.
A .
A^ f Charles A. Daverio Subscribed and sworn before me this / day of M ,
1987.
L /
My commission expires:
/
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- . LILCO, May 4i1987' 4
00LMEiff USNHC CERTIFICATE OF SERVICE
'87 ftAY -8 A9:44 LONG ISLAND LIGHTING COMPANY In the Matter of [0CbNNNf f
!iR A NCH (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-5 I hereby certify that copies of CONTENTION EX 40 - CALCULATION OF CHANGE IN TOTAL POPULATION DOSE AS A RESULT OF MOBILIZATION DELAYS were served this date upon the following by Federal Express as indicated by one aster-isk (*), or by first-class mail, postage prepaid.
John H. Frye, !!!, Chairman .* Atomic Safety and Licensing i Atomic Safety and Licensing Board Panel Board .
U.S. Nuclear Regulatory Commission
, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers 4350 East-West Hwy. Oreste Russ Pirfo, Esq.* .
Bethesda, MD 20814 Edwin J. Reis, Esq.
U.S. Nuclear Regulatory Commission Dr. Oscar H. Paris
- Atomic Safety and Licensing (to mallroom)
Board Bethesda, MD 20814
- U.S. Nuclear Regulatory Commission
., East-West Towers Herbert H. Brown, Esq.
- 4350 East-West Hwy. Lawrence Coe Lanpher, Esq.
Bethesda, MD 20814 Karla J. Letsche, Esq.
Kirkpatrick & Lockhart
, Mr. Frederick J. Shon
- South Lobby - 9th Floor 4
Atomic Safety and Licensing. 1800 M Street, N.W.
Board Washington, D.C. 20036-5891 i U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 Fabian G. Palomino. Esq.
- 4350 East-West Hwy. . Richard J. Zahnleuter, Esq.
Bethesda, MD 20814 Special Counsel to the Governor Executive Chamber Secretary of the Commission Room 229 Attention Docketing and Service State Capitol I
Section Albany, New York 12224
- U.S. Nuclear Regulatory Commission 1717 H Street, N.W. Mary Gundrum, Esq.
Washington, D.C. 20555 Assistant Attorney General 120 Broadway Atomic Safety and Licensing Third Floor, Room 3-116 Appeal Board Panel New York, New York 10271 4 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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- m. . . , . _ _ _ _ _ . _ , . _ _ , _ _ , . . . _ _ . _ _ _ , _ _ _ _ _ _ _ _ . . , _ . _ _ . . _ , _ . _ - - . _ , . . _ . _ , _ _ . ,
f ,
i 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. 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 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockefeller Plaza -
Albany, New York 12223
/
Ie6B. Zep 6 Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 4,1987
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