ML20215M214

Affidavit of Rj Watts in Support of Lilco Motion for Protective Order.* Releasing Names of Sources of Lilco Testimony Would Subj Individuals to Harassment & Intimidation.Certificate of Svc Encl

ML20215M214
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/06/1987
From:	Watts R LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20215M194	List: ML20215M191 ML20215M214
References
OL-3, NUDOCS 8705130125
Download: ML20215M214 (5)

Text

'

W/

., uav, .way 6,196 7

\;

ATTACHMENT 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licens!nr Board in the Matter of )

)

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

) (Emergency Planning)

(shoreham Nuclear Power Station, )

Unit 1) )

AFFIDAVIT OF RICHARD J. WATTS IN SUPPORT OF LILCO'S MOTION FOR PROTECTIVE ORDER Richard J. Watts, being duly sworn, deposes and says as follows:

,l 1.

I am presently the President of Richard J. Watts, Inc. My professional qualifications are included in the attachments to LILCO's profiled testimony on recep-tion centers at tab 7. filed March 30,1987. I have personal knowledge of the facts re-cited in this a!!1 davit Decause I have a working relationship with several of the people from the utilities or counties contacted by LILCO's staff in developing its testimony on the monitoring capabilities of other reception centers in New York and because I was personally involved in making some of those contacts.

2.

As president of Richard J. Watts, Inc., I provide radiological consulting in l

the area of health physics, radioactive waste management, and emergency planning to l LILCO for its Shoreham f acility and to other nuclear power plants and countias sur-i rounding these plants in New York State.

3.

In order to maintain my business and to provide such consultation, it is l important to maintain a good working relationship with utility and county personnel in-volved in emergency planning at all nuclear power plants in New York.

G l

l

p.......-..__.. .. .

.)

8

( ,

4. In gathering data about the monitoring capabilities of other reception centers in New York, I contacted several persons with the counties identified in LILCO's profiled testimony on reception centers. These persons hold positions of re-sponsibility with the organizations for which they work, such that there is every reason to be confident that the information they have provided to me is reliable.

5. The information provided to me and reported in LILCO's testimony is available to New York State in the exercise of its day-to-day liason role with the plants in question concerning offsite emergency preparedness, both from local government and utility personnel, and without any need to divulge the names of the persons who i provided this information reported in LILCO's testimony.

6. In my opinion, if the names of the sources are revealed, the potential for intimidation of these individuals would be great since they provided information to me that was ultimately used to refute New York State's claim that other reception centers l

in New York are prepared to monitor 100% of the population. Any contact from the In-tervenors would be intimidating since New York State, a party to this litigation, I

i oversees all offsite emergency planning within the state. The mere knowledge that their names had been turned over to the Intervenors also would cause fear within these individuals that that information may be used against them or their emergency organi-zation at some later date.

7. Identifying any of these individuals by name will greatly hinder and l

possibly destroy the good working relationships I have developed with these different individuals because of the intimidation that may result and the potential fear that re-vealing their names might cause.

l c

l

.m.. . . . . . . . . . , . . . . . . .

. . . . - . 2- e-:. . o.t.e ., , , :e n e- twm . w; a -

\ i The foregoing facts are known by me to be true, of my own knowledge. I am competent to testify to such f acts, and would so testify if I appeared as a witness in a public hearing on this matter.

tc M l I' hk Richard J. W'a'tii-Sutscribed and sworn to before me on thisla day of May,1987.

- Mut .

OD E _

- [Sigpaturd and Title]

LYNN 1 HAUCK Nw Putil.c m the State of New York MONROECOUNTY Cmmisaian Empres Nov. 30.1955'.

l l

l l

I l

l l

l

uLCO, Ndhfi987

'87 HAY 11 P3 :01 0 FFt B af M ;,u CERTIFICATE OF SERVICE hkC 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 FOR ACCEPTANCE OF PROTECTIVE ORDER OR IN THE ALTERNATIVE FOR STAY OF REQUIREMENTS OF APRIL 30,1987

' ORDER AND FOR EXPEDITED REFERRAL OR CERTIFICATION were served this date upon the following by telecopier or by hand as indicated by one asterisk, by Federal Ex-press as indicated by two asterisks, or by first-class mail, postage prepaid.

Morton B. Margulies, Chairman

• Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East-West Towers, Rm. 407 Wuhington, D.C. 20555 4350 East-West Ifwy.

Bethesda, MD 20814 Atomic Safety and Licensing Board Panel Dr. Jerry R. Kline

• U.S. Nuclear Regulatory Cnnmission Atomic Safety and Licensing Washington, D.C. 20555 Board U.S. Nuclear Regulatory Commission Richard G. Bachmann, Esq. **

East-West Towers, Rm. 427 George E. Johnson, Esq.

l U.S. Nuclear Regulatory Commission

! 4350 East-West liwy.

Bethesda, MD 20814 7735 Old Georgetown Road l

(to mailroom)

Mr. Frederick J. Shon

• Bethesda, MD 20814 Atomic Safety and Licensing Board lierbert 11. Brown, Esq.

• U.S. Nuclear Regulatory Commission Lawrence Coe Lanpher, Esq.

l East-West Towers, Rm. 430 Karla J. Letsche, Esq.

4350 East-West Ilwy. Kirkpatrick & Lockhart Bethesda, MD 20814 South Lobby - 9th Floor 1800 M Street, N.W.

Secretary of the Commission Washington, D.C. 20036-5891 Attention Docketing and Service

Section

U.S. Nuclear Regulatory Commission

1717 11 Street, N.W.

j Washington, D.C. 20555

y .

Fabian G. Palomino, Esq. *

' Richard J. Zahnleuter, Esq. Jonathan D. Feinberg, Esq.

Special Counsel to the Governor New York State Department of

. Executive Chamber Public Service, Staff Counsel Room 229 Three Rockefeller Plaza State Capitol Albany, New York 12223 Albany, New York 12224 Ms. Nora Bredes Mrry Gundrum, Esq. Executive Coordinator Assistant Attorney General Shoreham Opponents' Coalition 120 Broadway 195 East Main Street Third Floor, Room 3-116 Smithtown, New York 11787 New York, New York 10271 Gerald C. Crotty, Esq.

Spence W. Perry, Esq. ** Counsel to the Governor William R. Cumming, Esq. Executive Chamber Federal Emergency Management State Capitol Agency Albany, New York 12224 500 C Street, S.W., Room 840 Washington, D.C. 20472 Martin Bradley Ashare, Esq. **

Eugene R. Kelly, Esq.

Mr. Jay Dunkleberger Suffolk County Attorney N;w York State Energy Of flee II. Lee Dennison Building Agency Building 2 Veterans Memorial Highway Empire State Plaza Hauppauge, New York 11787 Albany, New York 12223 Dr. Monroe Schneider Stephen B. Latham, Esq. ** North Shore Committee

. Twomey, Latham & Shea P.O. Box 231 33 West Second Street Wading River, NY 11792 P.O. Box 298 Riverhead, New York 11901 Mr. Philip McIntire Federal Emergency Management Agency 26 Federal Plaza New York, New York 10278 EY.

James N. Christman Stephen W. Miller Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 7,1987

__- _ - _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___.