ML20235T537
| ML20235T537 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/11/1987 |
| From: | Papile J NEW YORK, STATE OF |
| To: | |
| Shared Package | |
| ML20235T449 | List: |
| References | |
| OL-3, NUDOCS 8710130122 | |
| Download: ML20235T537 (7) | |
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k UNITED STATE $ OF AMERICA NUCLEAR RE6ULATORY COMMISSION Before the Atomic Safety and Licensino Board
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In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
""" "I' (Shoreham Nuclear Power Station, Unit 1)
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AFFIDAVIT Of JAMES D. PAPILE
(
James D. Papile, being duly sworn, deposes and says as follows:
1.
I am the Director of the State of New York's Radiological Emergency Preparedness Group (REPG). REPG, under the auspices of the State of New
% i York's Disaster Preparedness Commission, is responsible for emergency planning I
and preparedness for radiological emergencies pertaining to commercial nuclear power plants.
2.
It is my understanding that LILCO's.Second Renewed Motion for Summary Disposition of the Legal Authority Issues (Contentions EP 1-10)
(Motion) notes the existence of a generic State radiological emergency response plan and seeks to infer from this fact that the State is prepared and able to respond adequately to a Shoreham emergency. LILCO's attempted inference is wrong, h[k
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e 3.
It is true that a generic State plan exists. However, detailed site-specific addenda which exist for each plant located in New York State except Shoreham are an integral part of that plan. The site-specific addenda provide the details, procedures, and specific data and information necessary to permit the State to respond as equired to the needs of a particular site, within both the lo mile and 50-m11e planning zones.
The State could not respond adequately to p. Shorehas emergency in the absence of a detailed Shoreham-specific off-site plan appended to the State gencric plan, without the training of State personnel concerning those spe'cifics, and without the evaluation of State personnel during exercises and drills. Since the State plan lacks a Shortham-specific off-site plan, REPG cannot assure that a fully integrated, coordinated and effective State and local response to a Shoreham t.
i emergency could be implemented.
4.
It is my understanding that LILCO's Motion contends that oral authorization to sound the sirens or to take other action can be readily
%s obtained from the State. The bases for LILCO's contention are that the Radiological Emergency Communications System (RECS) lines connect Shoreham and LERO to:
i a) REPG in Albanyl b) the State Police in Albany c) the State EOC in Albany; d) the State Emergency Management Office (SEMO) district office in Poughkeepsie (SEHO is the current name for what LILC0 refers to as the Office of Disaster Preparedness).
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4 a
However, none of these four RECS lines are capable of functioning.
First, there is no RECS line that connects Shoreham and LERO to REPG because REPG's offices have changed locations and the Shoreham RECS line has repained in the same place. This Shoreham RECS line terminates in an office that has no role whatsc.ever in radio'.ogical emergency preparedness and is miles away from REPG's current location.
In addition, the wires for this line are not operational in any event. Second, there is no RECS line that connects Shoreham and LERO to the State Police Consnunications Center in Albany because the State Police's Communications Center has changed locations and the Shoreham RECS line has remained in the same place.
This Shoreham RECS line also terminates in an office that has no role in radiological emergency
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preparedness and the wires are not operational. Third, there is no RECS line that connects Shoreham and LERO to the State E0C in Albany and SEMO district office in Poughkeepsie because the wires are not operational. kan if the wires were operational, these two offices are only staffed during ordinary business hours, thus, LILC0 cannot rely on the Shoreham RECS lines to seek N
oral authorization from the State to sound the sirens or to take any other action.
6.
Additionally, it is my understanding that LILCO maintains that oral authorization to sound the strens or to take o'ther action can be readily obtained by using back-up conenercial telephones if necessary. However, reliance by LILCO upon back up conenercial telephones would be misplaced, unless, among other things, verification and authentication procedures had been adopted. No such verification and authentication procedures exist.
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I 6.
It is my understanding that the LILC0 Motion also argues that certain State employees have become " familiar" with LILCO's Plan as a' result of the litigation in this proceeding. LILC0 suggests that such " familiarity means that l
the State could implement or work with LILC0 to implement LILCO's Man.
It is f
true that certain individual meshrs of REPG have reviewed portions of the LILC0 Plan for purposes of testifying before this Board and the OL-5 Board regarding certain flaws in the Plan and in LILCO's exercise of that Plan. Such review has been limited, however, to the extent necessary to provide truthful and accurate testimony. Most of REPG's members have no knowledge of the LILC0 P1an as it exists today or as it existed at the time of the Shoreham exercise. To my knowledge, no State employee or off tetal is sufficiently familiar with LILCO's Plan to implement all or any portion of it, with or without LILC0 assistance.
Nor have any State personnel been drilled, trained, or evaluated in exercises regarding the LILC0 Plan, which would be absolutely essential for a successful response to a Shoreham emergency.
7.
I understand that the LILCO Motion states further that the State has seven controlled copies of the LILC0 Man. Four recipients of those copies are attorneys who are using the Plan in connection with the State's litigation efforts. One recipient is the State's equivalent of the NRC's public document room. REPG and other State' agencies that have substantive response roles do not have anything more than scattered remnants of out-of-date transmittals from LILCO. Thus, REPG and key State agencies are not sufficiently familiar with the LILCO Man to imp 1tunt all or any portion of it, with or without LILCO's ass istance.
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~ UNITED STATES OF AMERICA-u's '
h, NUCLEAR REGULATORY COMMISSION' g
Spfore the Atomic Safe $y.Jgnd Licensino Board grP' Y&
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j ~In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket'No. 50-322-OL-3 y
.(Emergency PJ,anning)-
IGhoreham Nuclear Power Station,,
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I, Unit 1)
)
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i CERTIFICATE OF SERVICE 3
I hereby certify that copies of ANSWER OF SUFFOLK COUNTY, STATE OF NEW. YORK, AND TOWN OF SOUTHAMPTON TO LILCO'S MOTION FOR w
SUMMARY
DISPOSITION OF CONTENTION 92 (NO NEW YORK STATE EMERGENCY PLAN) have been' served on the following this 5th day of October,
- 1987 by U.S. maAl, first class.
d Morton B. Margulies, Esq., Chairman Mr'. Frederick J.
Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washingcon, D.C.
20555 Washington, D.C.
20555 Dr. Jerry R. Kline William R. Cumming, Esq.
r Atomic Safety and Licensimg Board Spence W.
Perry, Esq.
t U.S. Nuclear Regulatory Contdission Office of General Counsel N
Washington, D.C.
20555 FederalEmergencyManagementAgencyf 500 C Streeti S.W.,
Room 840 Washington',
D.C.
20472
,l; Fabian G. Palomino, Esq.
W. Taylor R(veley, III, Esq.
Richard J.
Zahleuter, Esq.
Hunton & Wil'11ams Special Counsel to the Governor P.O.
Box '.535 Executive Chamber, Rm. 229 707 East Main Street State Capitol Richmond, Virgl.tia 23212 Albany, New York 12224
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9-Joel Blau,i.Esq...
General Counsel Anthony F.'Earley, Jr., Esq.
Director,: Utility-Intervention N.Y. Consumer. Protection Board'
-Long Island Lighting. Company Suite 1020' 175 East Old Country Road 1_
' Albany, New York 12210 Hicksville,,New York 11801 1
Martin Bradley Ashare, Esq.
Ms. Elisabeth Taibbi', Clerk-e' Suffolk County Attorney Suffolk County Legislature'
,I Bldg. 158 North County Complex Suffolk County Legislaturfy
Veterans Memorial Highway Office Building-Hauppauge, New York 11788 Veterans Memorial Highway,
b
'q' Hauppauge, New York -11788 Stephen B.
Latham, Esq.
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Mr. L.
F. Britt Twomey, Latham & Shea r
Long Island Lighting Company Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901' Wading River, New "ork 11792 Ms. Nora Bredes Docketing and Service Section Executive Director-Office of the Secretary Shoreham Opponents Coalition U.S.. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 I
Mary M. Gundrum, Esq.
Hon. Michael A. LoGrande New York' State Department of Law Suffolk County' Executive 120 Broadway,J3rd Floor H.
Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788.
I MHB Technical Associates Dr. Monroe Schneider 1723. Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792
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Mr. Jay Dunkleburger Richard G. Bachmann, Esq.
J New York State Energy Office U.S. Nuclear Regulatory Comm.'
nj Agency Building 2 Office of General Counsel l
f Empire State Plaza Washington, D.C.
20555
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Albany, New York 12223
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David A.
Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart c
Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 l
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Douglas J.
Hynes, Councilman Town Board of Oyster Bay Town Hall j
Oyster Bay, New York 11771 1
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Michael S. Miller
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KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washingten, D.C.
20036-5891 1
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